There’s a small but influential number of tech reporters and scholars who seem to delight in making the US sound like a broadband and technology backwater. A new Mercatus working paper by Roslyn Layton, a PhD fellow at a research center at Aalborg University, and Michael Horney a researcher at the Free State Foundation, counter that narrative and highlight data from several studies that show the US is at or near the top in important broadband categories.

For example, per Pew and ITU data, the vast majority of Americans use the Internet and the US is second in the world in data consumption per capita, trailing only South Korea. Pew reveals that for those who are not online the leading reasons are lack of usability and the Internet’s perceived lack of benefits. High cost, notably, is not the primary reason for infrequent use.

I’ve noted before some of the methodological problems in studies claiming the US has unusually high broadband prices. In what I consider their biggest contribution to the literature, Layton and Horney highlight another broadband cost frequently omitted in international comparisons: the mandatory media license fees many nations impose on broadband and television subscribers.

These fees can add as much as $44 to the monthly cost of broadband. When these fees are included in comparisons, American prices are frequently an even better value. In two-thirds of European countries and half of Asian countries, households pay a media license fee on top of the subscription fees to use devices such as connected computers and TVs. …When calculating the real cost of international broadband prices, one needs to take into account media license fees, taxation, and subsidies. …[T]hese inputs can materially affect the cost of broadband, especially in countries where broadband is subject to value-added taxes as high as 27 percent, not to mention media license fees of hundreds of dollars per year.

US broadband providers, the authors point out, have priced broadband relatively efficiently for heterogenous uses–there are low-cost, low-bandwidth connections available as well as more expensive, higher-quality connections for intensive users.

Further, the US is well-positioned for future broadband use. Unlike many wealthy countries, Americans typically have access, at least, to broadband from telephone companies (like AT&T DSL or UVerse) as well as from a local cable provider. Competition between ISPs has meant steady investment in network upgrades, despite the 2008 global recession. The story is very different in much of Europe, where broadband investment, as a percentage of the global total, has fallen noticeably in recent years. US wireless broadband is also a bright spot: 97% of Americans can subscribe to 4G LTE while only 26% in the EU have access (which partially explains, by the way, why Europeans often pay less for mobile subscriptions–they’re using an inferior product).

There’s a lot to praise in the study and it’s necessary reading for anyone looking to understand how US broadband policy compares to other nations’. The fashionable arguments that the US is at risk of falling behind technologically were never convincing–the US is THE place to be if you’re a tech company or startup, for one–but Layton and Horney show the vulnerability of that narrative with data and rigor.

There seems to be increasing chatter among net neutrality activists lately on the subject of reclassifying ISPs as Title II services, subject to common carriage regulation. Although the intent in pushing reclassification is to make the Internet more open and free, in reality such a move could backfire badly. Activists don’t seem to have considered the effect of reclassification on international Internet politics, where it would likely give enemies of Internet openness everything they have always wanted.

At the WCIT in 2012, one of the major issues up for debate was whether the revised International Telecommunication Regulations (ITRs) would apply to Operating Agencies (OAs) or to Recognized Operating Agencies (ROAs). OA is a very broad term that covers private network operators, leased line networks, and even ham radio operators. Since “OA” would have included IP service providers, the US and other more liberal countries were very much opposed to the application of the ITRs to OAs. ROAs, on the other hand, are OAs that operate “public correspondence or broadcasting service.” That first term, “public correspondence,” is a term of art that means basically common carriage. The US government was OK with the use of ROA in the treaty because it would have essentially cabined the regulations to international telephone service, leaving the Internet free from UN interference. What actually happened was that there was a failed compromise in which ITU Member States created a new term, Authorized Operating Agency, that was arguably somewhere in the middle—the definition included the word “public” but not “public correspondence”—and the US and other countries refused to sign the treaty out of concern that it was still too broad.

If the US reclassified ISPs as Title II services, that would arguably make them ROAs for purposes at the ITU (arguably because it depends on how you read the definition of ROA and Article 6 of the ITU Constitution). This potentially opens ISPs up to regulation under the ITRs. This might not be so bad if the US were the only country in the world—after all, the US did not sign the 2012 ITRs, and it does not use the ITU’s accounting rate provisions to govern international telecom payments.

But what happens when other countries start copying the US, imposing common carriage requirements, and classifying their ISPs as ROAs? Then the story gets much worse. Countries that are signatories to the 2012 ITRs would have ITU mandates on security and spam imposed on their networks, which is to say that the UN would start essentially regulating content on the Internet. This is what Russia, Saudia Arabia, and China have always wanted. Furthermore (and perhaps more frighteningly), classification as ROAs would allow foreign ISPs to forgo commercial peering arrangements in favor of the ITU’s accounting rate system. This is what a number of African governments have always wanted. Ethiopia, for example, considered a bill (I’m not 100 percent sure it ever passed) that would send its own citizens to jail for 15 years for using VOIP, because this decreases Ethiopian international telecom revenues. Having the option of using the ITU accounting rate system would make it easier to extract revenues from international Internet use.

Whatever you think of, e.g., Comcast and Cogent’s peering dispute, applying ITU regulation to ISPs would be significantly worse in terms of keeping the Internet open. By reclassifying US ISPs as common carriers, we would open the door to exactly that. The US government has never objected to ITU regulation of ROAs, so if we ever create a norm under which ISPs are arguably ROAs, we would be essentially undoing all of the progress that we made at the WCIT in standing up for a distinction between old-school telecom and the Internet. I imagine that some net neutrality advocates will find this unfair—after all, their goal is openness, not ITU control over IP service. But this is the reality of international politics: the US would have a very hard time at the ITU arguing that regulating for neutrality and common carriage is OK, but regulating for security, content, and payment is not.

If the goal is to keep the Internet open, we must look somewhere besides Title II.

Day 1 of the Internet Governance Forum is in the books, and everyone is talking about what will happen on Day 2. Brazil recently announced that it will host a meeting on Internet governance in April. Tomorrow, ICANN is hosting a meeting at 1pm to explain how the April meeting will work.

Everyone that I’ve talked to in the hallways has brought up the meeting in April. No one is quite sure what to expect.

On one hand, Brazil has been part of the coalition that is pushing to do more Internet governance at the ITU. On the other hand, ICANN seems to be a willing participant in Brazil’s scheme. The recent “Montevideo Statement,” issued by various Internet organizations, called for globalizing the IANA function, which means at a minimum removing the US’s special role of maintaining the domain name system’s root zone file.

ICANN wants independence from the US government, and Brazil wants ICANN to be independent from the US government (and possibly dependent on the ITU), so this makes them allies for now.

Bizarrely, NSA surveillance continues to be cited as a reason for Brazil’s actions, although of course the IANA function has nothing to do with surveillance. The IANA issue is mostly about status. Other governments seem to feel slighted by the US’s control of the root zone file.

In any case, tomorrow we may know slightly more about ICANN and Brazil’s schemes.

The New York Times reports:

The Russians, who with only minimal success, had for years sought to make these companies provide law enforcement access to data within Russia, reacted angrily. Mr. Gattarov formed an ad hoc committee in response to Mr. Snowden’s leaks.

Ostensibly with the goal of safeguarding Russian citizens’ private lives and letters from spying, the committee revived a long-simmering Russian initiative to transfer control of Internet technical standards and domain name assignments from two nongovernmental groups that control them today to an arm of the United Nations, the International Telecommunications [sic] Union.

It’s not immediately clear to me how moving Internet standards and DNS from IETF and ICANN to the ITU is supposed to stop the NSA from spying on Russians, so the smart read is that this is retaliation pure and simple.

Brazil’s foreign minister, Antonio Patriota, for example, a week ago endorsed the Russian proposal to transfer some control over Internet technical standards to the United Nations telecommunications agency.

While these are not major changes in policy positions, the NSA’s surveillance programs seem to be galvanizing those who want the ITU to take an active role in Internet governance. It’s time for the USA to practice what it preaches on Internet freedom.

Next week, I’ll be in Geneva for the 2013 World Telecommunication/ICT Policy Forum, better known by the acronym WTPF-13. This is the first major ITU conference since the WCIT in December, and the first real test of whether what some are calling the “post-WCIT era” really exists, and if so, what it means. For those just now tuning in, the WCIT was a treaty conference in Dubai in which some ITU member states pushed hard to make elements of the Internet subject to intergovernmental agreement, resulting in the refusal of 55 countries to sign the treaty. I published a retrospective account of my experience at the WCIT at Ars Technica.

The WTPF will be different than the WCIT in several important ways:

• It’s not a treaty conference. The output of the meeting is instead a report and several opinions. Draft text of these have been negotiated over three preparatory meetings of an “Informal Experts Group” (IEG). The WTPF will finalize the text, which is non-binding, but is likely to be selectively quoted at future treaty conferences in order to pursue the agenda of each member state.
• Sector members can participate. The ITU is an intergovernmental organization, and member states are its primary constituency. However, the ITU also allows for “sector members,” which are mostly corporations that are involved in international telecommunications. Sector members will have microphones and be able to address the chair during the WTPF, something they could not do during the WCIT. It has not yet been made conclusively clear to me whether sector members will be able to formally vote, if a formal vote is held. (Secretary-General Hamadoun Touré said there would be no voting at the WCIT, but both informal and formal votes were held.)
• The Internet is explicitly on the table. The Secretariat promised that Internet governance would not be considered at the WCIT, but it ultimately was, which is one reason that the conference failed to produce a treaty that all countries could feel comfortable signing. But the official theme of the WTPF is “international Internet-related public policy matters,” so there is widespread agreement that the Internet is a suitable topic of discussion at the WTPF, even if there is little agreement on conclusions.
• Anybody can download and read the official WTPF documents. Before and during the WCIT, working drafts and member state contributions were kept secret. Jerry Brito and I started WCITLeaks in order to give the general public access to these documents. For whatever reason—whether exposure of the lack of transparency in the WCIT process embarrassed the ITU Secretariat, or they were planning to make the WTPF more open anyway—all WTPF documents are available for your perusal, several in all six official ITU languages. Either way, I’m happy to applaud the decision to make the documents available.
• The WTPF is only three days long. The WCIT was almost two weeks. This imposes significant limitations on the amount of deliberation that can occur. There is also a WTPF every 4 years, whereas a WCIT happens only on an as-demanded basis.

Since the conference is going to be short, I expect that most of the debate will focus on the six draft opinions that have been attached to the Secretary-General’s report. The report itself is probably too long to receive substantial revision in only three days. Consequently, the opinions are likely to be where the action is. The draft opinions are:

1. Promoting Internet Exchange Points (IXPs) as a long term solution to advance connectivity
2. Fostering an enabling environment for the greater growth and development of broadband connectivity
3. Supporting Capacity Building for the deployment of IPv6
4. In Support of IPv6 Adoption and transition from IPv4
5. Supporting Multi-stakeholderism in Internet Governance
6. On supporting operationalizing the Enhanced Cooperation Process

Opinions 1 and 2 will be consider in Working Group 1, 3 and 4 will be considered in Working Group 2, and 5 and 6 will be considered in Working Group 3.

The United States has expressed qualified support for the current draft text of all six opinions in its contribution to the WTPF:

The United States is prepared to endorse the consensus achieved by the IEG and adopt the six non-binding opinions as presented in the annex to the Secretary General’s report. We take this approach based on our desire for a successful forum, despite some concerns with respect to the opinions on multi-stakeholderism and enhanced cooperation. But we recognize, as we hope all participants do, that to attempt to renegotiate the text or introduce new topics or opinions during this meeting would cause significant difficulties and upset the consensus already achieved.

Nevertheless, other countries have proposed substantial changes to the draft IEG text. Perhaps the most controversial opinion is number 5 on multi-stakeholderism. Multi-stakeholderism is a tricky element of international Internet politics. Most participants have agreed at one point or another that the “multi-stakeholder” institutions that currently govern the Internet are an important part of the Internet’s success. However, this has led the more authoritarian countries to insist that governments are stakeholders too, and it has led those who support greater ITU involvement in international Internet policy to insist that the ITU is a multi-stakeholder organization.

For example, in a speech two weeks ago in Brussels, Secretary-General Touré said:

This opinion reiterates what I have been saying for some time—that the ITU has been multi-stakeholder from its inception, and that it was the success of the multi-stakeholder approach within ITU that inspired the multi-stakeholder principles agreed at the ITU-led World Summit on the Information Society, WSIS.

Now, Opinion 5 does  not say that the ITU is a multi-stakeholder organization (read it yourself), and the ITU is certainly not and has never been a multi-stakeholder institution, unless “multi-stakeholder” is defined as simply having multiple stakeholders. Among those who originally advocated multi-stakeholderism, the term connotes a certain bottom-up, voluntary, inclusive, and even informal process, which is incompatible with intergovernmentalism. This…loose talk…by the Secretary-General appears to be intended to position the ITU to take a more active role in Internet governance. Some member states share Dr. Touré’s apparent agenda. For example, Brazil’s proposed replacement for Opinion 5 explicitly says, “ITU is a multistakeholder organization.”

Russia’s proposed edits to Opinion 5 focus much less on the ITU itself and more on the role of government. For instance, it invites member states:

to exercise their rights on Internet Governance to control distribution, appropriation and development of Internet numbering, naming, addressing and identification resources and support the operation and development of the basic information and communication infrastructure, include the Internet, at the national level.

In other words, Russia wants to supplant existing Internet governance structures with national laws.

Aside from Opinion 5, the other major issue I am keeping my eye on is Working Group 2 on IP addresses and the IPv6 transition. Late last week, there was an unexpected shuffling of Working Group chairs. The chairwoman of WG3 was removed, the chairman of WG2 was moved to WG3, and Musab Abdullah from Bahrain was announced as the new chairman of WG2.

Those of us who were at the WCIT remember Mr. Abdullah as a forceful advocate for measures, like calling party identification and government-managed naming and numbering resources, that would have enabled greater government control of telecommunication services. And Bahrain is one of the most repressive regimes with respect to the Internet in the world. Reporters Without Borders considers Bahrain one of only five “state enemies of the Internet” in 2013.

So why did this shakeup of Working Group chairs happen, and why is one of the world’s top censors now chairing the Working Group on IP addressing? Could there be a strong push in favor of an expansive role for governments in assigning IP addresses, one that would allow governments to more easily link IP addresses to individuals in order to support censorship? We’ll find out next Wednesday morning when WG2 convenes.

For updates during the WTPF, follow me on Twitter. As always, any views expressed in this post or in future posts and tweets are my own, and should not be attributed to any government or delegation.

People of the same trade seldom meet together, even for merriment and diversion, but the conversation ends in a conspiracy against the public. — Adam Smith, The Wealth of Nations

As we approach the World Telecommunication/ICT Policy Forum, the debate over whether intergovernmental organizations like the International Telecommunication Union should have a role to play in Internet governance continues. One argument in favor of intergovernmentalism, advanced, for instance, by former ITU Counsellor Richard Hill (now operating his own ITU lobbying organization, delightfully named APIG), goes as follows:

• Everybody already agrees that governments are sovereign within their own territories.
• Other than a few “separatists,” everyone agrees that national laws apply to use of the Internet within national borders.
• It may be advantageous to “harmonize” national laws concerning the Internet.
• Harmonization of national laws happens through intergovernmental organizations, such as the ITU.
• Therefore, intergovernmental organizations such as the ITU should have a role in Internet governance.

My purpose in this post is to unpack the third premise. Who exactly benefits (and who is harmed) when national governments harmonize their national laws concerning the Internet?

One way to begin to answer this question is to see which governments think they would benefit from a greater intergovernmental role. One rough metric might be International Telecommunication Regulations (Dubai, 2012) signatories. In the map below, signatories are shown in black.

If it’s not clear from the map, there is a strong correlation between authoritarianism and support for the ITRs. Ninety-one percent of those countries ranked as Full Democracies in the Democracy Index opposed the ITRs, while 91 percent of those countries listed as “Authoritarian” supported them.

What national laws do these authoritarian regimes believe need harmonization? I am not privy to any government’s internal deliberations, but as The Economist reports, many of these countries are engaged in “monitoring, filtering, censoring and criminalising free speech online.” It seems to me that the most reasonable hypothesis is that countries like Algeria, Saudi Arabia, Bahrain, China, United Arab Emirates, Russian Federation, Iraq, and Sudan would benefit from a “national Internet segment” because it would normalize the idea of such monitoring and censorship.

In other words, authoritarian regimes favor intergovernmental “harmonization” of national Internet laws because it would enable them to get away with more authoritarianism. China already basically operates a “national Internet segment;” traffic into and out of China is filtered by the government. It is going to be a problem for the Chinese government when its subjects become wealthier, more empowered, and ultimately able to point to Internet policy outside of China and politely ask why part of the Chinese Internet is missing. If other countries were to adopt national Internet segments, the Chinese government would be able to avoid this uncomfortable conversation.

The “cooperation” that is likely to result from intergovernmental Internet policymaking is not the solving of communications problems, which is already accomplished quite ably through international technical organizations such as the Internet Engineering Task Force, but a kind of collusion. If we all agree to respect each other’s right to control information within our respective borders, say the authoritarian regimes, we can tame the more revolutionary aspects of the Internet and solidify our grip on power.

In practice, therefore, intergovernmentalism seems to enable national policies that are not only deplorable from a broadly liberal perspective, but illegal under international law. The Universal Declaration of Human Rights, Article 19 reads:

Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers.

Intergovernmentalism should be opposed, therefore, not merely by “separatists,” those who believe national governments have no business applying national law to the Internet. It should be opposed by anyone who does not wish to advance the agenda of censorship.

Jerry Brito and WCITLeaks co-creator Eli Dourado have a conversation about the recent World Conference on International Telecommunications (WCIT), a UN treaty conference that delved into questions of Internet governance.

In the lead-up to WCIT—which was convened to review the International Telecommunication Regulations (ITRs)—access to preparatory reports and proposed modifications to the ITRs was limited to International Telecommunications Union (ITU) member states and a few other privileged parties. Internet freedom advocates worried that the member states would use WCIT as an opportunity to exert control over the Internet. Frustrated by the lack of transparency, Brito and Dourado created WCITLeaks.org, which publishes leaked ITU documents from anonymous sources.

In December, Dourado traveled to Dubai as a member of the U.S. delegation and got an insider’s view of the politics behind international telecommunications policy. Dourado shares his experiences of the conference, what its failure means for the future of Internet freedom, and why the ITU is not as neutral as it claims.

Download

Related Links

• WCITLeaks, Brito and Dourado
• Final Acts of the World Conference on International Telecommunications, ITU
• Behind closed doors at the UN’s attempted “takeover of the Internet”: Conflicting visions for the future of the Internet collide in Dubai., Ars Technica
• WCIT is about People vs. Their Governments, The Technology Liberation Front

Vinton Cerf, one of the “fathers of the internet,” discusses what he sees as one of the greatest threats to the internet—the encroachment of the United Nations’ International Telecommunications Union (ITU) into the internet realm. ITU member states will meet this December in Dubai to update international telecommunications regulations and consider proposals to regulate the net. Cerf argues that, as the face of telecommunications is changing, the ITU is attempting to justify its continued existence by expanding its mandate to include the internet. Cerf says that the business model of the internet is fundamentally different from that of traditional telecommunications, and as a result, the ITU’s regulatory model will not work. In place of top-down ITU regulation, Cerf suggests that open multi-stakeholder processes and bilateral agreements may be a better solutions to the challenges of governance on the internet.

Download

Related Links

• Keep the Internet Open, by Cerf
• Information about the World Conference on International Telecommunications (WCIT), Internet Society
• WCITLeaks.Org

While preparing my latest Forbes column, “Does the Internet Need a Global Regulator?” I collected some excellent resources. I figured I would just post all the links here since others might find them useful as we work our way up to the big U.N. International Telecommunication Union (ITU) World Conference on International Telecommunications (WCIT) in Dubai this December. Please let me know of other things that I should add to this resource database. I’ve divided the database into “General Resources” and “Opinion Pieces”:

General Resources:

• World Conference on International Telecommunications (WCIT-12) official website
• White House statement on WCIT: “Ensuring an Open Internet,” by Lawrence Strickling, Philip Verveer, and Daniel Weitzner, May 2, 2012.
• Internet Society “What is the WCIT?” F.A.Q.
• Internet Society’s Scoop.It page curating news on WCIT
• Center for Democracy & Technology briefing paper by : “ITU Move to Expand Powers Threatens the Internet,” March 12, 2012.
• David A. Gross & Ethan Lucarelli, “The 2012 World Conference On International Telecommunications: Another Brewing Storm Over Potential UN Regulation Of The Internet,” November 2011.
• Michael Joseph Gross, “World War 3.0,” Vanity Fair, May 2012.
• [BOOK] Milton Mueller – Networks and States: The Global Politics of Internet Governance (2010).
• Internet Governance Project blog.
• [RADIO] National Public Radio: “Who — If Anyone — Should Control The Internet?” January 12, 2012.

Opinion Pieces:

• Robert McDowell, “The U.N. Threat to Internet Freedom” Wall Street Journal, February 21, 2012.
• ITU Secretary General Dr. Hamadoun Touré, “Securing the Future Benefits of Technology,” The Guardian (U.K.), March 6, 2012. [+ a recent speech on the issue.]
• Andrea Renda, “The U.N., Internet Regulator?” Wall Street Journal Europe, April 25, 2012.
• Gordon Crovitz, “The U.N. Wants to Run the Internet,” Wall Street Journal, May 6, 2012
• Adam Thierer, “Does the Internet Need a Global Regulator?” Forbes, May 6, 2012
• Gregory Francis, “UN Moves on Internet Governance: Latest Dispatch,” CircleID, April 26, 2012.
• Aspen Institute, Toward a Single Global Digital Economy: The First Report of the Aspen Institute IDEA Project, (April 24, 2012).
• Edward J. Black, “UN’s ITU Could Become Next Internet Freedom Threat,” Huffington Post, March 9, 2012.
• Jerry Brito, “The Case Against Letting the U.N. Govern the Internet,” Time TechLand, February 13, 2012.
• Tom Tauke, Verizon, Speech at New Democrat Network Internet Governance Event, April 19, 2012
• former Rep. Rick Boucher “U.N. Efforts Put Internet Freedom at Risk,” Politico, May 3, 2012.

Here’s a sharp editorial from The Economist about Internet governance entitled,  “In Praise of Chaos: Governments’ Attempts to Control the Internet Should be Resisted.” In the wake of the recent Internet Governance Forum meeting, many folks are once again debating the question of who rules the Net? Along with Wayne Crews, I edited a huge collection of essays on that topic back in 2003 and it’s a subject that continues to interest me greatly. As I noted here last week, many of those who desire greater centralization of control over Net governance decisions are using the fear that “fragmentation” will occur without some sort of greater plan for the Net’s future. I believe these fears are greatly overstated and are being used to justify expanded government meddling with online culture and economics.

The new Economist piece nicely brings into focus the key question about who or what we should trust to guide the future of the Internet. It rightly notes that the current state of Net governance is, well, messy. But that’s not such a bad thing when compared to the alternative:

the internet is shambolically governed. It is run by a hotch-potch of organisations with three- to five-letter acronyms. Many of their meetings, both online and offline, are open to the public. Some—like the Internet Governance Forum, which held its annual meeting in Nairobi this week—are just talking shops. Decision-making is slow and often unpredictable.

It is in short a bit chaotic. But sometimes chaos, even one that adherents like to claim somewhat disingenuously is a “multi-stakeholder” approach, is not disastrous: the internet mostly works. And the shambles is a lot better than the alternative—which nearly always in this case means governments bringing the internet under their control.

Quite right, and the editorial continues on to pose the crucial question about today’s situation:

Imagine if the ITU, a classic example of a sluggish international bureaucracy with antiquated diplomatic rituals, or indeed any other inter-governmental organisation, had been put in charge of the nascent global network two decades ago. Would it have produced a world-changing fount of innovation? We think not.

Indeed, it would be hard to imagine top-down design and central planning could have given rise to today’s Internet. While very few global officials propose the wholesale government takeover of the Net today, we should nonetheless be skeptical about calls to have international bureaucracies exert greater authority over the Internet, regardless of the justification. Messy governance beats top-down planning.

Declan McCullagh has done some great reporting this morning on an ITU plan to trace the source of all Internet communications. Meaning: no more anonymous speech online.

The U.S. National Security Agency is also participating in the “IP Traceback” drafting group, named Q6/17, which is meeting next week in Geneva to work on the traceback proposal. Members of Q6/17 have declined to release key documents, and meetings are closed to the public.

Read the whole thing.

It’s particularly interesting to note the role of VeriSign in developing this surveillance capability for the ‘net. McCullagh quotes Tony Rutkowski of VeriSign stepping up to defend the plan. Rutkowski published a summary of the plan in May.

Great reporting by McCullagh. Not a great thing for VeriSign to be doing.