Who Posted Your Fake FCC Comment?

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How did you make this?

This database of confirmed fake comments posted to the Federal Communications Commission's Electronic Comment Filing System (ECFS) combines the following sources:

  1. Raw comment submission data in JSON format for ECFS Proceeding "17-108 - Restoring Internet Freedom" available for download from the FCC's website (formerly available at 1 2 3, but now available here).
  2. The New York Attorney General office's May 6, 2021 report Fake Comments: How U.S. Companies & Partisans Hack Democracy to Undermine Your Voice [PDF].

  3. Comma-separated value (CSV) files submitted to the FCC's Box.com widget from April 27, 2017 to August 30, 2017.

  4. Master lists of every CSV file name submitted via Box.com from April 27, 2017 to August 30, 2017, including the corresponding time each CSV file was submitted, and submitter email address used to submit that file.
  5. Server logs for Data.gov's Application Programming Interface (API) "POST" requests (every request to submit raw data for an individual comment using Data.gov's API) sent to the ECFS from April 26, 2017 to August 30, 2017 in CSV format .

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

What do you mean by "Bulk Uploaders" or "CSV files"?

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:

  1. Uploading a CSV file pre-filed with commenters names and contact info through a widget hosted by third-party cloud storage/file transfer company, Box.
  2. Using the Data.gov API to send formatted comment data directly to the ECFS database

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.

How the Box.com and Data.gov data was matched with submitted comments to identify the submitters

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.

Matching the Remaining Comments with the Bulk submissions via Box.com

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 combined the bulk posters' information was easily matched with the existing posted FCC comments in their ECFS (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.

Matching the Remaining Comments with the API key server logs from Data.gov

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:

  • 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 was found. 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 the API key registered to "@protectinternetfreedom.com", 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 via a Freedom of Information Act request showed that CQ Roll Call submitted comments using the language starting with "The unprecedented regulatory power...", confirming CQ 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.

    So what's your proof that these are the posters?

    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 campaign was later verifed by Buzzfeed

    Data.gov API keys with cqrollcall.com email addresses had originating IP addresses that matched 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 a political operative named 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 Fluent in the name. 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 with activty in the server logs that strongly correlate with other comments submitted through Box.com using Eilon's personal email address. Eilon's personal email address was independently-verified to be his.

    Although Ethan Eilon was named in off-record notes given to select reporters by the New York Attorney General's office, this was independently confirmed by the author of this website before the publication of this website.

    With all that said, this website, it's underlying database, and the resulting matches are presented *as-is* with no claim to 100% accuracy.