This database of confirmed fake comments posted to the Federal Communications Commission's Electronic Comment Filing System (ECFS) combines the following sources:
The last three data sources were obtained from Freedom of Information Act (FOIA) requests and lawsuits made by Jason Prechtel with the FCC and General Services Adminsitration (GSA).
The aformentioned bulk comment submissions and submitter identifying information (email addresses, IP addresses) were cross-referenced with the descriptions of the comment submitters from the NYAG report, which only directly names comment gathering groups fined by the NYAG.
***This database does not reflect any other entity that submitted comments in bulk to the FCC for the "Restoring Internet Freedom" docket using the Box.com, Data.gov, or otherwise***
Normally, if you want to comment on any one of the FCC's ongoing proposed regulations, you can go to their website and submit an individual comment.
The public commenting process for the 2017 Restoring Internet Freedom rule allowed individuals or groups to post comments in bulk in two separate ways:
These two methods were how the vast majority of comments in response to Restoring Internet Freedom were filed - and how the mass identity fraud was executed in the millions of comments.
To build this database, the ~22 million comment dataset from the "Restoring Internet Freedom" docket (as of August 30, 2017) was filtered out in a series of steps.
First, the dataset filtered out the most common pro-Net Neutrality comment language, as the comment campaigns using stolen identities as identified by the NYAG were all anti-Net Neutrality.
The reduced comment dataset was then matched with the commenter information found in the bulk comment CSV files submitted to Box.com using email addresses associated with Shane Cory and Ethan Eilon.
Each line of each CSV file consisted of a single comment. These lines were extracted and matched with the CSV filename that it came from to associate each comment with the email address of its submitter. Because the CSV files contained the names, addresses, and comments extracted for the posted FCC comments, this data with the bulk poster information was easily matched with the existing posted FCC comment database.
In certain cases, names from the CSV files that contained multiple non-letter characters have been removed to improve searachability, even if the comment the exists in the FCC's ECFS with under a name with garbled characters.
The original plan was to then match the remainder of the FCC comment dataset with the Data.gov API POST request logs. These logs contained the times the POST requests were made, (partial) API keys used to make the submissions, (partial) email addresses used to register the API keys with Data.gov, IP addresses of the computers using the API keys to send comment submission and the IP addresses of the computers used to register those API keys.
Through trial an error, a varying 0.5 to 2 second delay between the Data.gov API POST logs and the "date_submission" data paramter in the FCC comment data. Because of this variability, the comments and posters could not be formulaically synced up with 100% certainty, like with the Box.com CSV originating comments could be.
Instead, an attempt was made to use the "merge_asof" function of a Python programming language library called Pandas to roughly match the closest timestamps between the two datasets. Although this is an imperfect method, the vast majority of POST timestamps from API keys linked to CQ ROll Call and Protect Internet Freedom (Ethan Eilon) correlated with most of the remaining anti-Net Neutrality comments.
Because the timestamps in each FCC comment's listed "date_submission" paramter do not exactly match with the data submission record timestamps in the Data.gov server logs, and because the comment data and Data.gov server logs often show multiple submissions within the same fraction of a second, comments with the highest correlation of matches with Data.gov API keys registered to CQ Roll Call and Ethan Eilon (or an associate) were concluded to be the source of comment text that appeared in the Ethan Eilon Box.com submissions, but did not match with any submitted commenter information originating the Box.com CSV submissions.
In the case of protectinternetfreedom, the highest correlating comments matched bulk submitted anti-Net Neutrality comment language uploaded through Box.com by an email address associated with Ethan Eilon and specific campaign language originating from Box.com CSV files with "TPA" or "FOI" in the filename. These, in turn, correspond with the advocacy groups Taxpayers Protection Alliance and Free Our Internet.
In the case of CQ Roll Call, comment text from the Ethan Eilon Box.com-submitted CSV files with "CFIF" in the filename strongly correlated with CQ Roll Call API times.
Additionally, email records obtained from the FCC in 2019 via a Freedom of Information Act request showed that CQ Roll Call submitted comments using the language starting with "The unprecedented regulatory power of the Obama Administration...", confirming CQ Roll Call originated this comment campaign and that the comments they submitted were submitted in all capital letters - another indicator of the origin of these particular comments.
Given that 100% exact matches between the Data.gov server logs and posted FCC comments may not be possible, comments that were matched to API keys are shown with an asterisk. However, based on the data, it is extremely unlikely these respective comments were submitted by any other entity.
Vertical Strategies, MediaBridge, and CQ Roll Call were all named by NYAG to select reporters in an off-record discussion (notes of which have been leaked and discussed by other outlets).
A MediaBridge email address belonging to MediaBridge head Shane Cory was used to submit 2 million CSV files. The fraudulent MediaBridge comment cmapaign was later verifed in an expose by Buzzfeed.
Data.gov API keys with cqrollcall.com email addresses had originating IP addresses that matched API submissions from other email addresses. Emails from CQ Roll Call to the FCC also show at least one comment campaign.
A personal email address belonging to Vertical Strategies president Ethan Eilon was used to submit the majority of Box.com CSV bulk comment files. Most of these were labelled with acronyms of the front organizations ("TPA", "FOI, "CFIF"), and at least a couple have the word "Fluent" - the name of the company who sourced many of the fake comments - in the filenames. Eilon was also a board member of an anti-Net Neutrality advocacy group called Protect Internet Freedom. A protectinternetfreedom.com email address is linked to a Data.gov API key who's activty in the server logs show strongly correlate with several comment campaigns submitted through Box.com using Eilon's personal email address.
Although Ethan Eilon was named in off-record notes given to select reporters by the office of the New York Attorney General's office, this was independently confirmed by the author of this website before the publication of this website.
With that said, the searchable database presented on this website is presented as-is without claims to 100% accuracy.