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Comment by mikegreenberg

1 year ago

It seems the definition of IaaS Products could very well extend to ISPs: https://www.federalregister.gov/d/2024-01580/p-46

> This proposed definition adopts the E.O. 13984 definition for “Infrastructure as a Service product”, which is any product or service offered to a consumer, including complimentary or “trial” offerings, that provides processing, storage, networks, or other fundamental computing resources, and with which the consumer is able to deploy and run software that is not predefined, including operating systems and applications.

How would an ISP not be misconstrued as a "managed network"? Deploy/run software could just as easily be running some protocol over the network connection?

Sure, there are very few international ISPs which would be affected by this as physical infrastructure must be local to the user, but I wonder if this would be true always (e.g.: Starlink)

I can't see how an ISP (or VPN for that matter) would qualify for the second half "and with which the consumer is able to deploy and run software that is not predefined, including operating systems and applications."

This would apply to all hosting providers, which is bad enough.

  • Some counterexamples:

    - TCP is a spec delivered by a software implementation program. Maybe you disagree that TCP is being "deployed" as opposed to "used"?

    - What about peer-to-peer hosted webpages? Certainly this is deployed software served over the internet connection?

    The devil is in the details... details which are not specified in the order. It wouldn't be hard to imagine a lawyer arguing the finer details of "deployed" and "software" and falling on a definition which results in a less "open" Internet.

    Also, I think of the meaning of "that is not predefined" is not at all clear. Predefined at what point in time?

    IANAL.

  • Internet connections can be used to SSH into a box to deploy and run software. IANAL, but I could see that catching ISP's and VPN's.