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ECFS & "Serial Filers"/Process Abusers

Those of us who file comments at FCC from time to time are annoyed a little by the delay in comments filing for review. The confirmation you get when you file comments says:

This confirmation verifies that ECFS has received and accepted your filing. However, your filing will be rejected by ECFS if it contains macros, passwords, redlining, read-only formatting, a virus, or automated links to other documents.Filings are generally processed and made available for online viewing within one business day of receipt.

While this process may check for viruses and macros, it apparently does not check for process abusers.

Take the case of one “Mr. P” who has filed 6,757 comments at FCC since 2006! He has filed 157 comments, generally “STATEMENT FOR THE RECORD “ in Docket 09-157 alone! In the case of this docket it appears that all the comments filed have no relation to the NOI in question. Their presence in the docket file only complicates access for legitimate comment filers and practitioners.

A 2013 filing of 13 documents on one day by Mr. P. - all appear unrelated to the NOI in question

From his Twitter page we understand that he has “an interest in journalism often writes for http://Examiner.com”. Readers outside the DC area may not be familiar with a this website, but the Examiner was a daily free right wing newspaper in Washington from 2005 to mid-2013 that seemed to focus mainly on the evils of Obamacare. It is now a monthly free publication distributed at vending machines downtown that has moderated slightly in its right wing tone. He is also a sometimes blogger although he has not posted anything in almost a year, apparently viewing ECFS now as his publication platform of choice.

In 2012 FCC dismissed several filing of his dealing reassignment by AT&T of a 700 MHz spectrum license “for lack of party-in-interest standing”. However, this does not apply to comments in “informal rule makings”.

In 2012, Multichannel News’ John Eggerton (better known as the Washington bureau chief of Broadcasting & Cable) wrote “FCC Filing: Pangasa’s Sincerest Form of Flattery?”

Serial FCC filer Mr. P., who has flooded the commission with hundreds of comments in numerous dockets was at it again last week, filing a dozen new comments at press time opposing the sale of cable spectrum to Verizon Wireless.The comments included one that struck a little too close to home.”

Eggerton then pointed out that one of the filings was plagiarized without attribution from an article he had written for that publication. Another was lifted from comments by another group without attribution.

When will FCC limit such abusive filings? On March 20, 2014 Mr. P. submitted filings in 15 dockets.

If FCC does not want to limit such filings, perhaps it could modify the ECFS search system to make it easy to exclude results from such serial filings just as it allows on to exclude “brief comments”?

Brief comment exclusion option in ECFS

(Perhaps certain trade associations think your blogger is also an “abusive filer”?
For the record, Marcus Spectrum Solutions LLC has
submitted 50 ECFS filings since 2006.)


Dane Ericksen, a prominent broadcast consultant and former FCC staffer, sent me a message about this post including a 2012 e-mail he had sent to FCC on the same subject that never received a response!

Here it is (ECFS screenshots not included):

From: Dane Ericksen <________@h-e.com>
Date: August 27, 2012 2:13:37 PM PDT
To: Julius Genachowski
Cc: Kris Monteith
Subject: ECFS modification

August 27, 2012

Dear Chairman Genachowski:

I am writing to urge the FCC to take action in response to Electronic Comment Filing System (ECFS) "spam," which occurs when numerous, repetitive, and often extraneous comments are filed in the ECFS. Perhaps the FCC can modify the ECFS to allow a user to ignore comments by a particular filer when conducting a search for comments. Although the ECFS currently allows one to filter out "brief comments," that filter doesn't work when a submission is filed as a regular, or non-brief, comment.

ECFS spam makes it difficult to pick out the comments that are legitimate. For example, there is one individual, a Mr. P., who has already filed over five thousand (5,000!) ECFS comments in 2012 (see the first attached screen capture PDF file). Mr. Pangasa seems to be targeting a number of rulemakings, including my area of immediate interest, ET Docket 10-142 (MSS Flexibility), which is littered with non-pertinent or vaguely pertinent submissions by Mr. P.; see the attached second screen capture PDF file.

The ability to search the ECFS, while excluding filings by up to, say, three named filers (or even just one), would be most helpful to solving the ECFS spam problem. I hope that the FCC will be able to implement this refinement to the ECFS, which has proven to be an otherwise excellent resource.


Dane E. Ericksen, P.E., CSRTE, 8-VSB, CBNT
Co-Chair, Engineers for the Integrity of Broadcast Auxiliary Services Spectrum (EIBASS)
SBE Certification Committee (1987-present)
Secretary, SBE Chapter 40, San Francisco (2000-present)
c/o Hammett & Edison, Inc.
Consulting Engineers
San Francisco, CA
707/996-5200 voice
707/996-5280 fax

cc: Ms. Kris Monteith, Acting CGB Bureau Chief


On 9/25/14 your blogger got an e-mail from the individual identified above as a “serial abuser”. The following is the bulk of the message:

I found an article mentioning my name when I searched for myself in Google (on the front page) talking about comment spam on FCC website. I admit I have submitted too many comments to the FCC in the past. Sometimes when one is really passionate about something it's hard to forget not to get carried away and I spammed the proceedings. I have always found spam repugnant in email, txt, etc and I agree that it is wrong.

I pledge to stop spamming the ECFS section. I would like in return to ask if you can please remove my name from your article about ECFS Serial Abusers. I am trying to clean up my Google ranking and should not be penalized for past mistakes.

I would either like my name removed or for this page not show up in the first page of results for my name. I am sorry if my actions offended anyone. I agree that the ECFS system can and should be improved. I think the FCC should in fact have a disclaimer on the site about spam issues and advise not to file too many comments at one time. I never found any anti spam policy on the site.

In view of his promise to stop abusive filing, we have changed every mention of his name in the post to “Mr. P.” If he reforms and never abuses again the deletion will remain. But, if his abuse returns we will put his full name back in the post.

We hope his message is sincere and he has learned a lesson.

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