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This report presents the results of an engineering evaluation of some of the issues raised by the Federal Communications Commission’s “Open Internet” Notice of Proposed Rulemaking. The Report suggests a strategy entailing a conservative process for evolving from the limitations of current locked and closed wireless device and application environments to a more open future as envisioned by the “any device” and “any application” portions of the Commission’s draft Open Internet rules. This Report proposes:

• An Any Device environment made possible through third-party or FCC certification.
• An Any Application environment subject, where necessary, to application-neutral traffic management that is fully transparent and disclosed to customers.