Comments of Nick Merrill and Tejas N. Narechania, Business Practices of Cloud Computing Providers, No. FTC-2023-0028
13 Pages Posted: 13 Jun 2023
Date Written: June 1, 2023
Abstract
The phrase “cloud computing” can refer to any one of a wide range of products and services, from software provisioned as an internet-delivered service, to hosted infrastructural solutions. In this comment, we focus specifically on content delivery networks (or CDNs, for short), one sort of an infrastructure-as-a-service.
CDNs are systemically important to the modern internet. Specifically, CDNs offer, among other things, content caching and cybersecurity services. CDNs thus offer significant improvements over prior, more decentralized models of the internet, in which latency was a bigger problem, and certain cyberattacks were more frequent and disruptive. But extreme concentration in the market for CDN services also poses new and unique risks to the internet. Specifically, such concentration may undermine competition among providers of infrastructural services, the security and resiliency of the internet in other ways, and the web’s openness as a platform for speech, commerce, and innovation.
By raising these issues, we do not discount the important improvements, described above, brought about by CDNs. Rather, we raise these issues for the Commission’s attention so that internet users may continue to enjoy the benefits brought about by CDNs while industry and regulatory authorities address these concerns.
Keywords: cloud computing, CDN, content delivery networks, internet, backbone, core, internet exchange, FTC
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