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Re: CDT Comments on OPES
OPES will increase the integrity of content delivery over what is
It is of only academic interest to contrast
a pure end-to-end world against a world with OPES. As another
purely academic exercise, contrast a pure voice switching
model against the Internet. The Internet offers many opportunities
for traffic monitoring, substitution, and malicious intervention that
the phone system did and does not. Whether or not the benefits
outweighed the risks was not evident a priori; in the case of OPES,
you cannot make such an evaluation simply by pointing out risks
that are already there without OPES and claiming that OPES somehow
makes them worse.
>>> John Morris <jmorris@xxxxxxx> 08/09/01 02:56PM >>>
FYI, below are comments circulated a few days ago to the IESG, providing a
public policy perspective on some of the issues raised by the OPES working
group proposal. Many of the issues discussed have been discussed on this
list and/or the IETF list; some are addressed in the current charter draft,
while others are not. Whether or not the IETF working group is
established, I am hopeful that these comments can make a constructive
contribution to the discussion of the proposed OPES tools. John Morris
John B. Morris, Jr.
Director, Internet Standards, Technology
& Policy Project
Center for Democracy and Technology
1634 I Street NW, Suite 1100
Washington, DC 20006
(202) 637-0968 fax
We write to outline serious policy concerns raised by the proposal that the
IETF/IESG create a working group on "Open Pluggable Edge Services" (OPES).
As outlined below, OPES would further diminish the "end to end" principles
that have been so important to the development of the Internet. OPES would
reduce both the integrity, and the perception of integrity, of
communications over the Internet, and would significantly increase
uncertainly about what might have been done to content as it moved through
the network. OPES would also increase the risk that ISPs can exercise
bottleneck control over users' access to the Internet, and could favor
certain content and application providers over others.
On the threshold question of whether the IETF should sponsor and sanction
the proposed OPES working group, we believe that the risks of OPES outweigh
the benefits of IETF review and control. In the event that the IESG
approves the creation of the OPES working group, we suggest below a set of
requirements for OPES that would mitigate policy concerns.
The Center for Democracy and Technology first became aware of the OPES
proposals through the work of its newly created Internet Standards,
Technology & Policy Project [see http://www.cdt.org/standards/]. (The
comments below are submitted on behalf of CDT, and not the Project
participants.) CDT is a nonprofit public interest group that promotes civil
liberties and democratic values online. CDT has over the years been very
involved in protecting free speech, privacy, and openness on the Internet,
and these comments reflect those public policy goals.
3.0 Concerns Raised by OPES
3.1 Content Manipulation, Free Expression, and Privacy
OPES would significantly increase the risk of unauthorized interference
with or manipulation of communications as they traverse the Internet. OPES
would diminish end to end network design principles and facilitate
third-party alteration of, or action based on, communications without the
notice or consent of end point parties. As such it creates major concerns
for free expression and privacy online.
The one party consent model defined in the proposed charter poses a threat
to the model of trust built into the end to end model, as well as allowing
third parties to interfere with the free flow of information that has
become a hallmark of Internet communication. For example, OPES could
facilitate third-party or state-sponsored censorship of Internet content
without the knowledge or consent of end users; OPES could also facilitate
third-party manipulation of content for commercial purposes (such as
advertising) without the consent of the end parties. OPES could also
facilitate surveillance systems like Carnivore, risking individual privacy
and discouraging unpopular expression on the web. Those who wish to
publish content with complete integrity may be forced to use end-to-end
encryption of communications, raising barriers to entry in the cost of
publishing and decreasing potential benefits of caching.
Undeniably, as proposed, OPES would require the consent of either the
sender or receiver. Also undeniably, the IETF process would likely ensure
that this and other security and privacy concerns would be honored in a
proper implementation of OPES.
At bottom, however, OPES is not a protocol for communications between
computers or networks, but rather is a self-contained facility to
manipulate content. The core functions of OPES (rule-based review of
content, diversion of selected content, and execution of proxylets or other
content manipulations) can be implemented entirely within one server (or
linked servers). There is no fundamental need that certain protections and
guidelines be followed to, for example, ensure interoperability among
networks. It appears unlikely that meaningful security and validation
requirements could be made to be so integral to OPES that such requirements
could not be easily overridden within an individual implementation of OPES.
The wide proliferation of OPES implementations would, it seems, be likely
to lead to the modification of such implementations to facilitate
unauthorized manipulations of content. The incentives for unauthorized
manipulations are clearly present on the Internet, and OPES would make such
improper actions easier to implement. Just very recently we have seen
examples of largely unauthorized manipulation of content for marketing
purposes by third parties. [See, e.g.,
ml]. OPES seems likely to facilitate such schemes.
3.2 Facilitating Gatekeepers
OPES could further promote the creation of bottleneck power in the hands of
Internet Service Providers. Over the past few years, the Internet has seen
broadband ISPs move toward a business model of contracting with "preferred"
content providers and facilitating the fast delivery of that content over
competing, non-preferred content. OPES would significantly increase the
potential of ISPs to enter into preferential or even exclusive contracts
with service providers ("the exclusive language translation services
offered to users of XYZ ISP"). These preferred and exclusive arrangements
can serve to reduce innovation and competition for content and services on
the Internet. Although high bandwidth content is already subject to
potential discrimination in delivery over some ISPs, OPES would likely
increase such potential for discrimination among service providers. This
bottleneck and/or gatekeeper power raises serious public policy concerns.
3.3 Suggested Action
Ultimately, from a public policy perspective, we believe that the risks of
OPES outweigh its undeniable potential benefits. We understand that, in
the absence of an IETF sanctioned implementation of OPES, the same
capabilities are likely to be created elsewhere (through iCAP and other
techniques). It is our perception, however, that IETF sanction would
further promote the acceptance and use of these techniques, and in turn
that would lead to the significant risk of abuse.
4.0 Proposed OPES Policy Requirements
We fully appreciate that there is not a clear and obvious answer to the
question of whether the IETF/IESG should create an OPES working group. If
such a working group is created, we would look forward to making a
constructive contribution to that effort. In such a context, we suggest
that certain requirements be added to the OPES charter. None of these
safeguards would provide protection against non-complying implementations
of OPES, but they would at least define the ground rules for proper
implementations of OPES. The requirements we would suggest are:
4.1 End Point Notice
A metatag indicating that some OPES manipulation has been performed on a
given communication should be available to the end points of an
exchange. Concerned parties should also be notified as to the nature of
the OPES service provided (thereby creating a nontrivial requirement of the
creation of a vocabulary or taxonomy of OPES services, as discussed below).
This full disclosure will be especially important if OPES services are used
routinely and an object is manipulated in several different ways by a
variety of services.
As the OPES proposals currently anticipate and require, no content should
be subject to an OPES manipulation without the clear consent of either the
sender or ultimate recipient of the communication.
4.3 End Point Veto
The consent of one party is not sufficient to protect the speech and
privacy interests of all end point parties subject to OPES services. Both a
sender and the ultimate recipient should be able to veto the use of OPES
manipulation, through the use of (for example in the web context)
metatags. For example, a web user should be able to include a "no OPES"
metatag in an initial http request, and the responding web site should
honor that metatag (even if only by refusing the request as some web sites
now do if cookies are not accepted - an unfortunate result but at least one
that is honest). Similarly, a web publisher should be able to include a
"no OPES" tag that is honored by OPES servers later in the communication.
4.4 Other Goals - Privacy, Negotiation
PRIVACY: Because there is unlikely to be an opportunity for a prior review
(by the end user or the user's P3P agent) of the privacy policies of the
OPES server (or a third party server called out by OPES), such OPES-related
privacy policies should be reflected in the privacy policies of any content
publisher who chooses to use OPES. Thus, publishers who wish to use OPES
should take responsibility for the use or dissemination of information by
an OPES service provider. We believe that addressing this need, or some
of an OPES provider, should both be a part of OPES and should be included
in revisions to the P3P specification.
NEGOTIATION: It would be desirable for all parties to have the ability to
communicate their respective wishes regarding OEPS services to achieve some
mutually satisfactory result. Given that many OPES services may be
performed on a given object, both parties should be able to decide which
must be overridden. For example, a web publisher might demand that the
quality of her images are not downgraded by an OPES compression service,
and a user may consent to a longer download time and bypass that OPES
service for that particular image. The same user might not agree to
disable an OPES virus scan at the request of the content provider.
We recognize that such negotiation capability poses several large design
problems and hence propose it as a goal to be explored rather than a
requirement for moving forward.
We appreciate the opportunity to present our views on the OPES proposals,
and we look forward to further contributing on this issue in appropriate
venues. For questions or further information about this document please
feel free to contact John Morris <jmorris@xxxxxxx> or Alan Davidson
<abd@xxxxxxx> at CDT. ##