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multi-year investigation by the New York Attorney General
governmentRelevant to AI governance discussions as a cautionary case study showing how public comment processes—increasingly used for AI regulation—can be gamed by coordinated inauthentic campaigns, undermining democratic input into technology policy.
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Importance: 52/100press releaseprimary source
Summary
The New York Attorney General's multi-year investigation found that ~18 million of 22 million public comments submitted to the FCC during its 2017 net neutrality repeal were fraudulent, including 8.5 million impersonating real people funded by broadband companies and 9.3 million fake pro-net-neutrality comments from a single individual. The investigation exposed large-scale astroturfing campaigns where commercial lead generators fabricated consumer responses rather than collecting genuine public input. Three companies were sanctioned as a result.
Key Points
- •18 of 22 million FCC comments were fake: 8.5M impersonating real people (broadband-funded) and 9.3M fictitious identities (single actor)
- •Broadband industry hired lead generators who promised prizes to lure consumers but ultimately fabricated responses entirely—classic astroturfing
- •Over 500,000 fake letters were also sent to Congress, extending the manipulation beyond the FCC rulemaking process
- •Demonstrates how public comment systems can be systematically corrupted by coordinated inauthentic behavior at scale
- •Raises urgent questions about the integrity of AI/tech policy comment processes, relevant to AI governance rulemaking
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Attorney General James Issues Report Detailing Millions of Fake Comments, Revealing Secret Campaign to Influence FCC’s 2017 Repeal of Net Neutrality Rules
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Attorney General James Issues Report Detailing Millions of Fake Comments, Revealing Secret Campaign to Influence FCC’s 2017 Repeal of Net Neutrality Rules
May 6, 2021
Multi-Year Investigation Into 2017 Net Neutrality Rulemaking Finds 18 Million
Fake Comments Filed with FCC, Half a Million Fake Letters Sent to Congress
Broadband Industry Funded Six Companies That Engaged in
Illegal Activity and Impersonated Millions of Americans
AG James Announces Three Agreements Ending
Fraudulent Practices by Perpetrators of Fake Comments
NEW YORK – New York Attorney General Letitia James today released a report detailing the results of her office’s wide-ranging investigation into fake, public comments submitted to the Federal Communications Commission (FCC) in a 2017 proceeding to repeal net neutrality rules . Net neutrality prohibits broadband providers from blocking, slowing down, or charging companies to prioritize certain content on the internet. Attorney General James’ investigation uncovered widespread fraud, as well as abusive practices used to sway government policy — using masses of comments and messages to create the false impression of popular support. Additionally, Attorney General James today resolved investigations into three companies that contributed to the millions of fake comments submitted in the 2017 net neutrality proceeding.
“Americans voices are being drowned out by masses of fake comments and messages being submitted to the government to sway decision-making,” said Attorney General James . “Instead of actually looking for real responses from the American people, marketing companies are luring vulnerable individuals to their websites with freebies, co-opting their identities, and fabricating responses that giant corporations are then using to influence the polices and laws that govern our lives. But, today, we are taking action to root out this fraud and the impersonation that has been corrupting the process for far too long. From net neutrality rules to laws affecting criminal justice reform, health care, and more, these fake comments have simply been generated to influence too many government policies, which is why we are cracking down on this illegal and deceptive behavior. My office will continue to shine a spotlight on abuses and disinformation and ensure those who break the law are held accountable.”
Through its investigation, the Office of the Attorney General (OAG) found that, in 2017, the nation’s largest broadband companies funded a secret campaign to generate millions of comments to the FCC. Many of these comments provided “cover” for the FCC’s repeal of net neutrality rules. This practice — disguising an o
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