Comments of Nick Merrill and Tejas N. Narechania, Business Practices of Cloud Computing Providers, No. FTC-2023-0028

13 Pages Posted: 13 Jun 2023

See all articles by Nick Merrill

Nick Merrill

University of California, Berkeley - Center for Long-Term Cybersecurity

Tejas N. Narechania

University of California, Berkeley, School of Law

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

Suggested Citation

Merrill, Nick and Narechania, Tejas N., Comments of Nick Merrill and Tejas N. Narechania, Business Practices of Cloud Computing Providers, No. FTC-2023-0028 (June 1, 2023). Available at SSRN: https://ssrn.com/abstract=4466429 or http://dx.doi.org/10.2139/ssrn.4466429

Nick Merrill

University of California, Berkeley - Center for Long-Term Cybersecurity ( email )

310 Barrows Hall
Berkeley, CA 94720
United States

Tejas N. Narechania (Contact Author)

University of California, Berkeley, School of Law ( email )

Berkeley, CA 94720-7200
United States

HOME PAGE: http://www.tejasnarechania.net

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