Hearings on Competition and Consumer Protection in 21st Century: Consumer Privacy, February 12-13, 2019 #FTC-2018-0098-D-0051

Submission Number:
Sam Adams
New York
Initiative Name:
Hearings on Competition and Consumer Protection in 21st Century: Consumer Privacy, February 12-13, 2019
This comment and attached document filing relate to Alphabets monopoly Wi-Fi and Advertising network in New York City called LinkNYC. The attached document, The Stop LinkNYC Wi-Fi and Advertising Network Primer, addresses various issues related to Alphabet and the City of New Yorks public-private monopoly business to provide broadband Wi-Fi service and digital advertising in New York City. These issues include monopolistic and anti-competitive practices, the invasion of privacy of consumers (users) and non-consumers (non-users) of the Wi-Fi service, civil rights and constitutional concerns and violations, and potential corruption issues raised by how the monopoly franchise was awarded to Alphabet. Some of the specific issues addressed in the attached document are: 1) The threat the LinkNYC public-private Wi-Fi monopoly poses to the viability of the competitive marketplace for Internet and broadband services provided by wireless, wireline, and Web services companies. 2) The massive financial benefit to Alphabet and the City of New York that could be gained by the LinkNYC network siphoning customers away from existing wireless, wireline, and Web services due to its a) monopoly status and b) ability to provide broadband Internet Wi-Fi service below the equilibrium price set by the competitive market. 3) The threat of reduced tax revenues from existing fee-for-service wireless and wireline broadband providers due to loss of business to the free Wi-Fi service offered by the monopoly partnership. 4) The privacy of both users and non-users of the LinkNYC Electronic Billboard Wi-Fi units with respect to its wireless access point functionality capturing mobile device MAC Addresses, which can be used to locate and track people throughout New York City down to the block or building, 24/7/365. 5) The privacy and tracking of people through the recognition, recording, and analysis of faces/images/conversations captured by LinkNYCs video, audio, and audio sensing capabilities. 6) The privacy of individuals in their domiciles due to LinkNYC video cameras directed towards their windows. 7) The threat to peoples civil rights under the 1st, 4th, 5th, 9th, and 14th Amendments to the Federal Constitution. 8) The privacy of users and non-users with respect to their personal relationships and personal activities. 9) The legal violations of the Franchise Agreement, by both Alphabet and the City of New York, through the integration of video, audio, and photographic recording and sensing capabilities into the LinkNYC Wi-Fi units, as well as the inclusion of a Web browser. 10) The discriminatory and possibly illegal geographic deployment strategy of the Wi-Fi units, where one borough Manhattan receives over 50% of the required structures. 11) The ethics and legality of how the LinkNYC franchise was awarded. 12) The potential ethical and legal violations of public and private sector personnel who were involved in creating, approving, and awarding the LinkNYC franchise to Alphabet.