Fake Comments: How U.S. Companies & Partisans Hack Democracy to Undermine Your Voice (NY AG Report)

# Fake Comments:

How U.S. Companies & Partisans Hack Democracy to Undermine Your Voice

This report was prepared by the Bureau of Internet and Technology and the Research and Analytics Department, with special thanks to: Assistant Attorney General Noah Stein and Special Enforcement Counsel Jordan Adler, with assistance from Assistant Attorneys General Ezra Sternstein and Hanna Baek, Internet Technology Analyst Joe Graham, and Legal Assistants Richard Borgia and Shirly Huang, all of the Bureau of Internet and Technology, under the supervision of Deputy Bureau Chief Clark Russell and Bureau Chief Kim Berger; Data Scientist Kenneth Morales in the Research and Analytics Department, under the supervision of Deputy Director Megan Thorsfeldt and Director Jonathan Werberg; and Chief Deputy Attorney General Chris D’Angelo. The Office of the New York Attorney General also acknowledges that other law enforcement agencies assisted with the investigation that helped make this report possible.

Executive Summary.. 3

Background. 8

1. Net Neutrality – Purpose and History . 8

2. Public Comments – Purposes and Effects..

3. Comments in the FCC Net Neutrality Proceeding.. 9

4. A Corruption of the Democratic Process. .10


# e OAG’s Findings .

1. The Country’s Biggest Broadband Companies Spent $$ 8.2$ Million to Oppose Net Neutrality, Including Generating 9 Million Comments and Letters in Opposition.... 1

A. The Plan: Manufacture Grassroots Support . 11 B. Broadband Company Money Funded Three Astroturfing Efforts, and Each Resulted in Fraud.. ... 12 C. The Broadband Industry Hid Its Involvement Behind Advocacy Groups to Create the False Impression of Widespread Grassroots Opposition to Net Neutrality .. . 23 D. The Broadband Industry Sent Over Half a Million Letters to Congress. . 25 E. The Broadband Industry’s Campaign Organizers Ignored Red Flags of Fraud and Impersonation. .. 26

2. More than 9.3 Million Additional Fake Comments Using Fictitious Identities Were Submitted to the FCC with Automated Software.. 27

A. A 19-Year-Old College Student Submitted Over 7.7 Million Fake Comments In Support of Net Neutrality Using Fictitious Identities . . 27 B. An Unknown Party Submitted More Than 1.6 Million Comments Using Fictitious Identities . . 28

3. Lead Generators Corrupted Over 100 Other Advocacy Campaigns with 4.6 Million More Fraudulent Comments and Messages That Impersonated Real People . .. 28

A. Fluent .. .28

B. Digital Advertising Firm.. . 29

C. React2Media. . 30

# Recommendations. . 31

Endnotes. ..36

# Executive Summary

On June 19, 2017, the Federal Communications Commission (FCC) received a comment from Kenneth Langsam of Nassau, New York. Mr. Langsam had written to express support for the proposed repeal of regulations that require internet service providers to treat all internet communications equally. Mr. Langsam “urge\[d\]” the agency to eliminate these anti-discrimination protections, often referred to as net neutrality rules.

However, th

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