FTC's solicitation for public comments: Make your voice heard

The Federal Trade Commission (FTC) wields considerable influence over technology. Now, they are soliciting public comments on the business practices of so-called "cloud computing" providers. In a recent announcement, the FTC said that its staff are seeking to better understand the impact of [the growing reliance on cloud computing], the broader competitive dynamics in cloud computing, its implications for artificial intelligence, and potential security risks in the use of [the] cloud."

Since it isn't every day that the FTC solicits public comments on subjects in which the free software community is so well-versed, let's take this opportunity to submit comments that support digital sovereignty. The hope is to persuade policy makers to make software freedom and privacy a central part of any future considerations made in the areas of storage, computation, and services. Such comments will be made part of the public record, so any participation promises to have a lasting impact.

Take Action

Write about it! Help influence decision makers and docket commentors by writing on the subject. As for your text, we have prepared the following points for consideration:

• When considering rules and regulations in technology that stand to protect people's fundamental civil liberties, it is important to start from the question, "does this decision improve digital sovereignty or diminish it?"
• In the case of computing, (e.g. word processing, spreadsheet, and graphic design programs), the typical options diminish digital sovereignty because the computations are being run on another computer under someone else's control, inaccessible to the end user, who therefore does not have the essential freedoms to share, modify, and study the computations (i.e. the program). The only real solution to this is to offer free "as in freedom" replacements of those programs, so that end users may maintain control over their computing.
• In the case of storage, today's typical options diminish digital sovereignty because many storage providers only provide unencrypted options for storage. It is imperative that individuals and businesses who choose third-party storage always have the choice to encrypt their storage, and the encryption keys must be entirely within the control of the end user, not the third-party provider.
• In the case of services (such as email, teleconferencing, and videoconferencing), while the source code that runs services need not necessarily be made public, end users deserve to be able to access such services via a free software client. In such cases, it is imperative that service providers implement a design of interoperability, so that end users may use the service with any choice of client.
• Free software allows end users to inspect the software for possible security flaws, while proprietary software does not. Therefore free software is the only realistic option for an end user to achieve verifiable security.

Such responses address the questions being asked by the FTC in the Market power and business practices affecting competition section of their instructions, while maintaining focus on our free software advocacy efforts.

Feel free to use any of these suggestions, adapting them to your own style of writing. The only thing we ask is that you keep the free software message strong throughout. If you would like to run any ideas by us before submitting, we are delighted to receive your drafts at campaigns@fsf.org.

A note about the FTC docket website

Unfortunately, the FTC's website requires nonfree JavaScript (reCAPTCHA, specifically) to comment on a document, and the FTC has declined repeated requests for instructions for how to submit comments by paper form. If you're not in the habit of avoiding nonfree JavaScript for the sake of your freedom, which we recommend, you can also leave comments on the FTC's website. While you're there, let webmaster@ftc.gov know about the injustice of proprietary JavaScript and encourage them to respect the freedom of their users.

If you would like to join us in reaching out to the FTC to request comments be accepted in ways that do not require running nonfree JavaScript, please consider contacting their office by mail and/or phone:

Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Telephone: (202) 326-2222

The deadline to submit is June 21, which is just enough time to publish something meaningful on the topic in support of free software.