Bots and Form Letters Make It Nearly Impossible to Find Real FCC Net Neutrality Comments

The Federal Communications Commissions’ public comment period on its plans to repeal net neutrality protections was bombarded with bots, memes, and input from people who don’t actually exist. The situation’s gotten so bad that FCC Commissioner Jessica Rosenworcel, as well as several members of Congress, including one Republican, have called for the FCC to postpone its December 14 net neutrality vote so that an investigation can take place.

The FCC seems unlikely to comply. According to an FCC spokesman, the FCC is zeroing in on legal arguments within those comments, effectively disregarding any outpouring of support for net neutrality from regular Joes. “The purpose of a rulemaking proceeding is to not to see who can dump the most form letters into a docket. Rather, it is to gather facts and legal arguments so that the Commission can reach a well-supported decision,” Brian Hart, the FCC’s head of media relations, tells WIRED. Now, the Commission is barreling ahead toward Chairman Ajit Pai’s plan to essentially allow internet service providers to speed up or slow down internet traffic however they please.

So, with the FCC declining to investigate its own comments, we decided to undertake an analysis of our own.

Yes, researchers have already sliced and diced the data. But parsing 23 million comments can quickly bend toward abstraction. How many of those commenters are real? How many are bots? How many were real, but using identical form letters drafted by advocacy groups?

For a better handle on just how broken the FCC comment system is, we went granular, analyzing all of the submissions that fell under a single name. We wanted a name that was common enough to produce a decent number of hits (so, you know, not Issie Lapowsky), but singular enough that we could actually mine them in a few days (tough luck, James Smith). We settled on Nicholas Thompson, WIRED’s editor in chief, and excluded any Nicks, or Nicholas Thompsons who also supplied a middle initial.

That left us with 39 results between May 11 and December 8 of this year. Using a combination of Facebook, public records tools like Spokeo and Nexis, and the good old fashioned telephone, we attempted to make contact with each of them. It’s far from a perfect or scientific sample, but it does help illuminate what the chaos in the FCC’s comments look like up close. Here’s what we found:

The Bots

Let’s start with the outright fakes, since they’re in some ways the easiest to sniff out. To find the bot Nicholas Thompsons in our sample, we enlisted the help of FiscalNote, a company that processes public comments on behalf of corporations to help them make sense of the policy landscape. Researchers at FiscalNote previously identified nearly one million comments as bot submissions, all of them opposing net neutrality. Each one followed the same paragraph pattern, stringing together 35 synonymous words and phrases in a particular order to form similar, but not identical, comments.

FiscalNote’s vice president of research Vlad Eidelman found six comments that fit that pattern among the 39 Nicholas Thompsons, all submitted over the course of eight days in May. They included strange grammatical formations, like in the example below:

Dear Chairman Pai, I am concerned about internet regulations. I suggest the commission to repeal Tom Wheeler’s decision to control the Internet. Internet users, rather than so-called experts, should be empowered to enjoy whichever applications we want. Tom Wheeler’s decision to control the Internet is a exploitation of the open Internet. It ended a pro-consumer policy that functioned very, very successfully for a long time with bipartisan support.

Four of the bots were attached to fake home addresses, according to public records searches. The one below was associated with an email address that’s available for purchase on

Chairman Pai: In the matter of the FCC’s so-called Open Internet order. I want to recommend you to overturn The previous administration’s decision to take over broadband. Internet users, not Washington, should be free to purchase the applications we choose. The previous administration’s decision to take over broadband is a perversion of net neutrality. It ended a market-based policy that worked very, very successfully for a long time with broad bipartisan support.

Some bot-generated comments, though, used real names and addresses. Using the email address connected to one of these bot comments, we were able to track down one real Nicholas Thompson whose name and old address in Los Angeles were being used without his knowledge.

Thompson, who now lives in Portland, says he had submitted a pro-net neutrality comment to the FCC earlier this year. When we reached him by phone, he was angry to know that his authentic comment had been effectively cancelled out by a fake comment using his information. “That’s pretty messed up. It’s pretty sneaky on whoever decided to do that,” Thompson says. “I feel, for lack of a better term, just robbed of my voice.”

Confirmed Bots: 6

The Form Letters

Form letters are comments that advocacy groups draft for their members to submit en masse. According to Pew Research, only 6 percent of the roughly 23 million comments submitted to the FCC were actually unique. The rest were a combination of form letters and bots. The most popular form, submitted 2.8 million times, was a pro-net neutrality comment drafted by the advocacy group Battle for the Net. Eight Nicholas Thompsons submitted comments associated with Battle for the Net, each one linked to an authentic street address, though we couldn’t confirm their identities directly.

Here’s one of them:

The FCC’s Open Internet Rules (net neutrality rules) are extremely important to me. I urge you to protect them.\n\nI don’t want ISPs to have the power to block websites, slow them down, give some sites an advantage over others, or split the Internet into “fast lanes” for companies that pay and “slow lanes” for the rest.

Three other Nicholas Thompsons submitted comments connected to the group Taxpayers Protection Alliance, which Pew says was responsible for spreading some of the most widely used anti-net neutrality messages. All three of those comments tracked to real addresses associated with Thompson families. Here’s one example:

Obama’s Federal Communications Commission (FCC) forced regulations on the internet that put the government, and unaccountable bureaucrats, in control. These rules have cost taxpayers, slowed down broadband infrastructure investment, and hindered competition and choice for Americans. The time to remove the regulatory stranglehold on the internet is NOW. I urge the taxpayer-funded FCC to undo the terrible regulatory burdens that ex-FCC Chairman Tom Wheeler imposed on the internet. After 20 years, and trillions of dollars in infrastructure investment, there is no reason for the government to come in and ruin what has been a thriving tool that has changed the way we all live. Chairman Pai’s proposal to repeal Title II regulations will ensure the continued growth of a dynamic, open internet for all American consumers and taxpayers.

Confirmed Form Letters: 11

The Real Nick Thompsons

In the end, we were able to directly contact three, actual sentient beings named Nicholas Thompson who either picked up their phones or answered our Facebook messages and confirmed their identities. All three supported net neutrality. One of them had submitted the Battle for the Net form letter mentioned above.

The other two submitted unique comments:

I am writing to express my strong opposition to the repeal of net neutrality. It is an assault on the right of all Americans to an open and equitable internet. The internet has not only become essential for cultural, artistic, social and educational purposes, but has largely replaced other methods of doing essential tasks such as registering with government agencies, paying bills, renewing licenses, etc. In some of these cases the older methods have even been phased out completely, leaving the internet as the ONLY option. It is therefore a public utility that all have an equal right to and it is shameful and abhorrent that there is any attempt at all to repeal net neutrality. Thank you for your consideration.


I oppose the repealing or potential loosening of net neutrality rules in all forms, and wish for the full extent of it as known to the public to be preserved. Please do not take any actions that directly lead to that.

For those keeping score at home, that’s less than 8 percent that we were able to positively confirm over the course of several days. That’s with a pool of 39 comments. Now multiply that task by more than 600,000, and you’ll see what the FCC is up against.

Confirmed Nicholas Thompsons: 3

The Unknowns

It remains unclear who, or what, was behind the remaining comments—nearly half overall. Among the comments that opposed net neutrality, several seemed likely to be fake. One comment, below, was submitted identically by three Nicholas Thompsons, including two who provided home addresses that don’t exist. According to Pew, that same comment was submitted nearly 1.3 million times overall, suggesting many of them may have been fake.

Before leaving office, the Obama Administration rammed through a massive scheme that gave the federal government broad regulatory control over the internet. That misguided policy decision is threatening innovation and hurting broadband investment in one of the largest and most important sectors of the U.S. economy. I support the Federal Communications CommissionÍs decision to roll back Title II and allow for free market principles to guide our digital economy.

Two more anti-net neutrality comments submitted by Nicholas Thompsons, used real addresses linked to Thompson families, but the text of the comment was identical to one that was also flagged by a Redditor named Shaun Seckman. Seckman says his name and old address were also used without his permission to send the same message, which read:

Obama’s Net Neutrality order was the corrupt result of a corrupt process controlled by Silicon Valley special interests. It gives some of the biggest companies in the world a free ride at the expense of consumers and should be immediately repealed!

“This post was absolutely not made by me,” Seckman wrote. “I am in favor of Net Neutrality and would not have made such comments.” Given that the message matches the ones supposedly sent by two Nicholas Thompsons, it seems they may be fake, as well.

The rest are a mystery. Some appear to be form letters whose origins are unclear, because the text doesn’t appear elsewhere online. Others used real home addresses, but people finder sites like Spokeo and Nexis didn’t turn up any Thompsons living there. Those sites, of course, are riddled with inaccuracies of their own. Several other comments were likely fake, because they were submitted using home addresses that don’t exist. At least one was likely real, given it was a unique comment, attached to an authentic address belonging to a Nicholas Thompson, whose voicemail recording includes his name. But without talking to each of these remaining Nicholas Thompsons, it’s impossible to know for sure.

The utter messiness of this tiny sample alone demonstrates just how much is unknown about the comments the FCC received, and which it is required by law to consider.

As a workaround, the FCC has decided to ignore the majority of comments submitted by the public in favor of lengthy legal arguments submitted by interest groups and corporations. In doing so, it undermines the only real tool the public has to express their opinions about the rules that govern them. It’s silencing their voices more than a million bots ever could.