The Un#ballogetic World of Wireless Ads

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I belong to that rare breed of human that enjoys commercials.  As a social scientist with an interest in the impact of advertisement on consumer behavior, I often find myself, possibly to the chagrin of my wife (though she has not complained), assessing commercials out loud.  Are they informative?  Are they persuasive or attempt simply to elicit attention to the good in the ad?  Might they unintentionally lead to brand confusion?  Most importantly, are they funny?

Thus, having also spent some time among wireless regulators, I cannot help but comment on the recent spate of wireless attack ads perpetuated by three of the U.S. nationwide mobile wireless providers.  The initial culprit this time around was Verizon Wireless, which determined that balls were a good method to represent relative mobile wireless performance among the nationwide competitors.  Shortly thereafter, Sprint aired a commercial using bigger balls while T-Mobile brought in Steve Harvey to demand that Verizon #Ballagize.

There are myriad takeaways that can be had from these commercials.  First, at least on the face of it, the nationwide mobile wireless providers appear to be fiercely competitive with one another.  It would be interesting to look at advertising to sales ratios for this industry relative to that of other industries in the U.S., though at the time of writing of this blog, I did not have access to such data (Ad Age appears to be a convenient source).  Moreover, the content of the commercials suggests that although price continues to be an important factor (Sprint did not veer away from its “half-off” theme in its ball commercial), quality competition that allows competitors to differentiate their product (and in doing so, justify higher prices) remains paramount.

Unfortunately, as a consumer, it is difficult for me to properly assess what these commercials say about wireless quality.  There are a number of points at play here.

  1. The relative comparisons are vague: When Sprint says that it delivers faster download speeds than the other nationwide providers, what does that mean?  When I zoom into the aforementioned Sprint commercial at the 10 second mark, the bottom of the screen shows, “Claim based on Sprint’s analysis of average LTE download speeds using Nielsen NMP data (Oct. thru Dec. 2015).  NMP data captures real consumer usage and performance for downloads of all file sizes greater than 150kb.  Actual speeds may vary by location and device capability.”  As a consumer who spends most of his time in East Lansing, MI, I am not particularly well informed by a nationwide average.  Moreover, I know nothing about the statistical validity of the data (though here I am willing to give Nielsen the benefit of the doubt).  Moreover, I would be interested to know when Sprint states that it delivers faster download speeds, how much faster they are (in absolute terms) relative to the next fastest competitor.
  2. The small print is too small: Verizon took flak from its competitors for using outdated data in its commercial.  This is a valid claim.  Verizon’s small print (13 second mark in its commercial) states that RootMetrics data is based on the 1st half of 2015.  But unless I am actually analyzing these commercials as I am here, and viewing them side by side, it is difficult for me to make the comparison.
  3. The mobile wireless providers constantly question one another’s credibility, and this is likely to make me less willing to believe that they are indeed credible. Ricky Gervais explains this much better than I do: Ricky Gervais on speed, coverage, and network comparisons.

Alas, how is a consumer supposed to assess wireless providers?  An obvious source is Consumer Reports, but my sense, without paying for a subscription, is that these largely depend on expert reviews and not necessarily data analysis (someone correct me if I am wrong).  Another if one is not in the habit of paying for information about rival firms is the FCC.  The FCC’s Wireless Telecommunications Bureau publishes an “Annual Report and Analysis of Competitive Market Conditions with Respect to Mobile Wireless.”  The most recent, Eighteenth Report, contains a lengthy section on industry metrics with a focus on coverage (see Section III) as well as a section on service quality (see Section VI.C).  The latter section focuses on nationwide average speed according to FCC Speed Test data as well as on data from private sources Ookla, RootMetrics (yes, the one mentioned in those commercials), and CalSPEED (for California only).  If you are interested, be sure to check out the Appendix, which has a wealth of additional data.  For those who don’t want to read through a massive pdf file, there is also a set of Quick Facts containing some of the aforementioned data.

However, what I think is lacking is speed data at a granular level.  When analyzing transactions or assessing competition, the FCC does so at a level that is far more granular than the state, and rightly so, as consumers do not generally make purchasing decision across an entire state, needless to say, the nation as a whole.  This is because service where consumers are likely to be present for the majority of their time is a major concern when deciding on wireless quality.  In a previous blog post I mentioned that the FCC releases granular fixed broadband data, but unfortunately, as far as I am aware, this is still not the case for wireless, particularly with regard to individual carrier speed data.

The FCC Speed Test App provides the FCC with such data.  The Android version which I have on my phone provides nifty statistics about download and upload speed as well as latency and packet loss, with the option to parse the data according to mobile or WiFi.  My monthly mobile only data for the past month showed a download speed above 30 Mbps.  Go Verizon!  My Wifi average was more than double that.  Go SpartenNet!  Yet, my observation does not allow me to compare data across providers in East Lansing and my current contract happens to expire in a couple of weeks.  The problem is that in a place like East Lansing and particularly so in more rural areas of the United States, not enough people have downloaded the FCC Speed Test App and I doubt that the FCC would be willing to report firm level data at a level deemed not to have statistical validity.

For all I know, the entire East Lansing sample consists of my twice or so daily automatic tests that if aggregated to a quarter of a year make up less than 200 observations for Verizon Wireless.  Whether this is sufficient for a statistically significant sample depends on the dispersion in speed observations for a non-parametric measure such as a median speed and also on the assumed distribution for mean speeds.  I encourage people to try this app out.  The more people who download it, the more likely that the FCC will have sufficient data to be comfortable enough to report it at a level that will make it reliable as a decision making tool.  Perhaps then, the FCC will also redesign the app to also report competitor speeds for the relevant geographic area.

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Testing the Limits of Net Neutrality Rules

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In the past few weeks we’ve seen both a wireless and wireline carrier launch new “zero rating” video streaming services that test the boundaries of the FCC’s net neutrality policy: T-Mobile’s Binge On and Comcast’s Stream TV.

According to published reports, FCC chairman Tom Wheeler has praised Binge On as “highly innovative” and “highly competitive,” while also noting that the Commission will continue to monitor the service under its “general conduct” rule. According to Ars Technica, an FCC spokesperson declined comment on Comcast’s Stream TV, which does not count against the company’s data caps.

The FCC’s reported response to the two services is not too surprising. While they share some similarities, they are also different in key respects. Among the differences that come initially to mind are:

In a blog post, Public Knowledge senior staff attorney John Bergmayer argues that Stream TV is subject to and violates the FCC’s Open Internet order as well as the consent decree Comcast agreed to as part of its NBC Universal acquisition. I’d recommend reading the post in full for anyone wanting a preview of legal arguments to be made in more formal channels by Public Knowledge and others likely to challenge Stream TV before the FCC and the courts.

According to Bergmayer:

Comcast maintains that “Stream TV is a cable streaming service delivered over Comcast’s cable system, not over the Internet.” But Stream TV is being delivered to Comcast broadband customers over their broadband connections, and is accessible on Internet-connected devices (that is, not just through a cable box). From a user’s perspective, it is identical to any other Internet service. Comcast’s argument is that if it offers its service only to Comcast customers and locates the servers that provide Stream TV on its own property, connected to its own network, that this exempts it from the Open Internet rules. This is an absurd position that would permit Comcast to discriminate in favor of any of its own services, and flies in the face of the Open Internet rules…

[I]t does not appear that Stream TV is an IP service like facilities-based VoIP. It is not available standalone; you need a broadband Internet access connection to access it. It is thus readily distinguishable from services like facilities-based VoIP. If Comcast offered Stream TV separately from broadband there would be a better case that it was more like traditional cable TV or a specialized service–but it does not.

Bergmayer also reviews some relevant language from Comcast’s NBC Universal consent decree, including:

“Comcast shall not offer a Specialized Service that is substantially or entirely comprised of Defendants’ affiliated content,” and…”[if] Comcast offers any Specialized Service that makes content from one or more third parties available … [it] shall allow any other comparable Person to be included in a similar Specialized Service on a nondiscriminatory basis.”

In an article in Multichannel News, Jeff Baumgartner previews what may be a core element of Comcast’s legal argument defending Stream TV:

“Stream TV is an in-home IP-cable service delivered over Comcast’s cable network, not over the public Internet,” Comcast said in a statement issued Thursday, the same day it launched Stream TV to its second market – Chicago. “IP-cable is not an ‘over-the-top’ streaming video service. Stream enables customers to enjoy their cable TV service on mobile devices in the home delivered over the managed cable network, without the need for additional equipment, like a traditional set-top-box.”

The FCC does address the idea in rules released in December 2014, which explain that “an entity that delivers cable services via IP is a cable operator to the extent it delivers those services as managed video services over its own facilities and within its footprint…IP-based service provided by a cable operator over its facilities and within its footprint must be regulated as a cable service not only because it is compelled by the statutory definitions; it is also good policy, as it ensures that cable operators will continue to be subject to the pro-competitive, consumer-focused regulations that apply to cable even if they provide their services via IP.”

In his blog post Bergmayer cites language from the Commission’s Open Internet order related to the provision of “Non-Broadband Internet Access Service Data Services.” In my view, a key sentence in that section of the order is “The Commission expressly reserves the authority to take action if a service is, in fact, providing the functional equivalent of broadband Internet access service or is being used to evade the open Internet rules.” On the face of it, I’m inclined to agree with Bergmayer that this appears to be the case with Comcast’s Stream TV, when coupled with its data cap policies and the reality of Comcast’s multifaceted market power in both distribution and content.

And, more generally, I think Bergmayer is correct that “Comcast’s program raises a host of issues under the Open Internet rules, the consent decree, and—most importantly—general principles of competition.”

The fact that Comcast is testing the bounds of the Commission’s new rules is not surprising, given its focus on maximizing shareholder value within a set of interrelated and dynamic markets in which it enjoys substantial market power, but faces significant challenges to its traditional revenue streams and growth prospects. In fact, I view it as helpful that Comcast is moving fairly quickly in this direction, since it is likely to force the FCC and the Courts to revisit yet again the question of how to craft communication policy that serves the public interest in the Internet age.

And, with the Commission having classified broadband access as a Title II service, my hope is that any court review of FCC action responding to Stream TV or similar services will consider substantive policy arguments (e.g., related to competition and the public interest) rather than simply ruling that the Commission cannot impose net neutrality rules absent a Title II classification of broadband access (which seemed to be the central message of the most recent DC Circuit Court ruling).

We are clearly moving into a world where the central element of our once heavily (and often clumsily) siloed communication infrastructure and policy (and arguably our economy and society as a whole) is IP connectivity. Though some believe the FCC has outlived its usefulness in that world, my own preference—at least for now—is that the Commission retain sufficient tools and authority to continue serving as the specialized regulatory agency responsible for setting ground rules that help ensure that the public interest is well served during and after this historic and vitally important transition from yesterday’s communication technology and industry structure to tomorrow’s.

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Unlicensed Spectrum: A Look at Google’s Project Nova

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Though Google has not revealed much in the way of details, the Internet search giant is expected to launch a WiFi/MVNO wireless service sometime in the near future. Based on limited comments from company executives and reports in the Wall Street Journal (see here and here; subscription may be required) and elsewhere, it seems that the service will:

Speaking at the Mobile World Congress held March 2-5 in Barcelona Spain, Sundar Pichai, Google senior VP of products, appeared to downplay the scope and disruptive impact of the MVNO service, known internally as Project Nova.

As reported by TechCunch, Pichai said “We don’t intend to be a network operator at scale. We are actually working with carriers.” And according to Wired, Pichai also pointed out that “[c]arriers in the US are what powers most of our Android phones [and]…[t]hat model works really well for us.”

Google may, in fact, have limited ambitions for Project Nova. But I suspect the cautious nature of Pichai’s comments reflects a desire to avoid prematurely upsetting the industry’s dominant carriers—whose customers purchase huge numbers of Android devices—more than it does a lack of Google-scale ambition for Project Nova. And the fact that Google won’t be operating its own network and will be “working with carrier partners” doesn’t mean Nova doesn’t have potential to seriously disrupt the mobile industry’s status quo.

I expect Google to approach Nova the way it approaches most new product introductions: start small in “beta” mode, then adapt to market developments. Sometimes this leads to products being killed, revised or merged with others (see a partial list here), while at other times it leads to aggressive expansion, as was the case with the Android operating system.

While there are parallels between Project Nova and Google Fiber, the company’s investment in local fiber optic networks, there are also important differences that could translate into much faster growth potential for Nova. The key difference is that Project Nova doesn’t require Google to undertake the time-, labor- and dollar-intensive task of building fiber networks city by city and block by block. As a result, while Google Fiber is intended to be a profitable business and is gradually expanding to more cities, Project Nova could allow Google to move very quickly and relatively inexpensively to deploy a nationwide service using other companies’ physical networks.

Having read a mix of pre-launch speculation available online (see excerpts below), I’m inclined to believe that:

  1. Pichai’s comments notwithstanding, Google is aiming high in terms of Project Nova’s strategic value to the company and its impacts on industry dynamics;
  2. Even if the project stumbles initially and/or needs substantial revisions along the way, Google will stick with it for the long haul and, over time, succeed in expanding its role and disrupting the status quo in the wireless communication sector.

Below are excerpts from online commentary that have helped inform this point of view. As always, comments are welcome, especially from those who see things differently.

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“LTE Unlicensed” Deployments Planned for 2016

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In the last post in this series I reviewed several different points of view regarding the pros and cons of cellular carriers using “LTE Unlicensed” (LTE-U) to expand their network capacity. In this post I’ll take a closer look at movement in this direction among U.S. carriers.

[Note: The deployment of LTE in unlicensed bands is referred to by multiple names, including “LTE Advanced in unlicensed spectrum,” “LTE Unlicensed” (LTE-U) and, most recently “Licensed Assisted Access” LTE (LAA). In this post I’ll refer to it as LTE-U, though other names may appear in some excerpts included in the post.]

The two U.S. cellular providers that have so far expressed most enthusiasm for LTE-U are Verizon and T-Mobile.

Reporting from the Mobile World Congress held March 2-5 in Barcelona, Spain, Mike Dano wrote the following in the March 3 FierceWireless online newsletter:

[B]ased on the discussions I’ve had this week, it appears that Verizon…, Vodafone and other carriers last year decided they wanted to make LTE-U a reality–and they decided they didn’t want to wait for the 3GPP to standardize the technology. So they teamed up with some network technology companies to design real-world tests of the technology…

Verizon clearly has high hopes for the tests and the technology–it has said that it plans to commercially deploy it in the 5 GHz and 3.5 GHz bands in 2016. Verizon is not the only carrier that supports LTE-U/LAA. T-Mobile announced this year that it too will deploy what it calls LAA in the 5 GHz band in 2016. T-Mobile CTO Neville Ray said he believes the carrier can get LAA-capable handsets this year.

As Dano notes, “[h]owever, not all carriers are on board.” Specifically, he points to comments from Tom Keathley, senior VP of wireless network architecture and design for AT&T. As one might expect from a carrier that has invested in a network of more than 30,000 WiFi hotspots, AT&T’s concerns include the risk that LTE-U deployments will not share unlicensed spectrum fairly and efficiently with WiFi.

Keathley said that current approaches to LTE-U are vague about how exactly to check for existing users in unlicensed bands, and how long LTE users can occupy unlicensed spectrum.

Dano also cites comments from Eric Parsons, an executive at Ericsson, a leading wireless network equipment vendor, regarding how these spectrum sharing issues might be dealt with in different regions of the world. As Parsons explains, “there are very specific guidelines in Europe and Japan that cover these areas, but countries like the United States don’t have specific guidelines.”

T-Mobile, which has less licensed spectrum to work with than its competitors (see here for T-Mobile CEO John Legere’s perspective on this issue), seems particularly interested in LTE-U. In anticipation of commercial deployments in 2016, it has announced plans for multiple tests of the technology, in cooperation with Alcatel-Lucent and Qualcomm, Ericsson and Nokia.

In a January 5, 2015 blog post T-Mobile chief technology officer Neville R. Ray shed some light on the company’s plans:

Currently, there is approximately 550 MHz of underutilized spectrum in the 5 GHz Unlicensed National Information Infrastructure (UNII) band, which is available for any use within the FCC’s rules for the UNII band. LAA is a new and innovative approach that allows for licensed and unlicensed spectrum to work seamlessly together. And, we’ve already begun work with our various chipset, radio infrastructure and device partners to bring LAA production trials to life this year and bring the technology to our customers in the near-future.

During T-Mobile’s February 19, 2015 yearend earnings call, Ray provided an update on the company’s LTE-U plans:

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