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RFC 6057 - Comcast's Protocol-Agnostic Congestion Management Sys

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Internet Engineering Task Force (IETF)                        C. Bastian
Request for Comments: 6057                                    T. Klieber
Category: Informational                                     J. Livingood
ISSN: 2070-1721                                                 J. Mills
                                                               R. Woundy
                                                           December 2010

        Comcast's Protocol-Agnostic Congestion Management System


   This document describes the congestion management system of Comcast
   Cable, a large cable broadband Internet Service Provider (ISP) in the
   U.S.  Comcast completed deployment of this congestion management
   system on December 31, 2008.

Status of This Memo

   This document is not an Internet Standards Track specification; it is
   published for informational purposes.

   This document is a product of the Internet Engineering Task Force
   (IETF).  It represents the consensus of the IETF community.  It has
   received public review and has been approved for publication by the
   Internet Engineering Steering Group (IESG).  Not all documents
   approved by the IESG are a candidate for any level of Internet
   Standard; see Section 2 of RFC 5741.

   Information about the current status of this document, any errata,
   and how to provide feedback on it may be obtained at

Copyright Notice

   Copyright (c) 2010 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents
   (http://trustee.ietf.org/license-info) in effect on the date of
   publication of this document.  Please review these documents
   carefully, as they describe your rights and restrictions with respect
   to this document.  Code Components extracted from this document must
   include Simplified BSD License text as described in Section 4.e of
   the Trust Legal Provisions and are provided without warranty as
   described in the Simplified BSD License.

Table of Contents

   1. Introduction ....................................................2
   2. Applicability to Other Types of Networks ........................3
   3. Key Terminology .................................................3
   4. Historical Overview .............................................7
   5. Summary .........................................................8
   6. Relationship between Managing Congestion and Adding Capacity ....9
   7. Implementation and Configuration ...............................10
      7.1. Thresholds for Determining When a CMTS Port Is in a Near
           Congestion State ..........................................14
      7.2. Thresholds for Determining When a User Is in an
           Extended High Consumption State and for Release from
           That Classification .......................................15
      7.3. Effect of BE Quality of Service on Users'
           Broadband Experience ......................................19
      7.4. Equipment/Software Used and Location ......................21
   8. Conclusion .....................................................23
   9. Exceptional Network Utilization Considerations .................23
   10. Limitations of This Congestion Management System ..............24
   11. Low Extra Delay Background Transport and Other Possibilities ..24
   12. Security Considerations .......................................24
   13. Acknowledgements ..............................................25
   14. Informative References ........................................26

1.  Introduction

   Comcast Cable is a large broadband Internet Service Provider (ISP),
   based in the U.S., serving the majority of its customers via cable
   modem technology.  During the late part of 2008, and completing on
   December 31, 2008, Comcast deployed a new congestion management
   system across its entire network.  This new system was developed in
   response to dissatisfaction in the Internet community as well as
   complaints to the U.S. Federal Communications Commission (FCC)
   regarding Comcast's old system, which targeted specific peer-to-peer
   (P2P) applications.  This new congestion management system is
   protocol-agnostic, meaning that it does not examine or impact
   specific user applications or network protocols, which is perceived
   as a more fair system for managing network resources at limited times
   when congestion may occur.

   It is important for readers to note that congestion can occur in any
   IP network, and, when it does, packets can be delayed or dropped.  As
   Bob Briscoe has pointed out on an IETF mailing list, some amount of
   packet loss can be normal and/or tolerable, noting "But a single TCP
   flow with a round trip time (RTT) of 80 ms can attain 50 Mbps with a
   loss fraction of 0.0013% (1 in ~74,000 packets) so there's no need to
   try to achieve loss figures much lower than this.  And indeed, if

   flows aren't bottlenecked elsewhere, TCP will drive the system until
   it gets such loss levels.  If, instead, a customer is downloading
   five separate 10 Mbps TCP flows still with an 80-ms RTT, TCP will
   drive losses up to 1 in ~3,000, or 0.03%, and any lower loss rates
   won't be able to improve performance".  As a result, applications and
   protocols have been designed to deal with the reality that congestion
   can occur in any IP network, the mechanics of which we explain in
   detail later in this document.

   The purpose of this document is to describe how this example of a
   large-scale congestion management system functions.  This is
   partially in response to questions from other ISPs as well as
   solution developers, who are interested in learning from and/or
   deploying similar systems in other networks.  In addition, it is
   hoped that such a document may help inform new work in the IETF, in
   the hope that better systems and protocols may be possible in the
   future.  Lastly, the authors wish to transparently and openly
   document this system, so that there could be no doubt about how the
   system functioned.

2.  Applicability to Other Types of Networks

   Several document reviewers and other IETF participants have pointed
   out that, though we refer to functional elements that are specific to
   a Data Over Cable Service Interface Specification (DOCSIS)-based
   network implementation, this type of congestion management system
   could be generally applied to nearly any type of network.  Thus, it
   is important for readers to take note of this and take into
   consideration that this sort of protocol-agnostic congestion
   management system could certainly fit in a wide variety of network
   types and implementations.

3.  Key Terminology

   This section defines the key terms used in this document.  Some terms
   below refer to elements of the Comcast network.  As a result, it may
   be helpful to refer to Figure 1 (see Section 7) when reviewing some
   of these terms.

3.1.  Cable Modem

   A device located at the customer premise used to access the Comcast
   High Speed Internet (HSI) network.  In some cases, the cable modem is
   owned by the customer, and in other cases it is owned by the cable
   operator.  This device has an interface (i.e., someplace to plug in a
   cable) for connecting the coaxial cable provided by the cable company
   to the modem, as well as one or more interfaces for connecting the
   modem to a customer's PC or home gateway device (e.g., home gateway,

   router, firewall, access point, etc.).  In some cases, the cable
   modem function, i.e., the ability to access the Internet, is
   integrated into a home gateway device or Embedded Multimedia Terminal
   Adapter (eMTA).  Once connected, the cable modem links the customer
   to the HSI network and ultimately the broader Internet.

3.2.  Cable Modem Termination System (CMTS)

   A piece of hardware located in a cable operator's local network
   (generally in a "headend", Section 3.10) that acts as the gateway to
   the Internet for cable modems in a particular geographic area.  A
   simple way to think of the CMTS is as a router with interfaces on one
   side leading to the Internet and interfaces on the other connecting
   to Optical Nodes and then customers, in a so-called "last mile"

3.3.  Cable Modem Termination System (CMTS) Port

   Also referred to simply as a "port".  A port is a physical interface
   on a device used to connect cables in order to connect with other
   devices for transferring information/data.  An example of a physical
   port is a CMTS port.  A CMTS has both upstream and downstream network
   interfaces to serve the local access network, which are referred to
   as upstream or downstream ports.  A port generally serves a
   neighborhood of hundreds of homes.  Over time, CMTS ports tend to
   serve fewer and fewer homes, as the network is segmented for capacity
   growth purposes.  Prior to DOCSIS version 3, a single CMTS physical
   port was used for either transmitting or receiving data downstream or
   upstream to a given neighborhood.  With DOCSIS version 3, and the
   channel bonding feature, multiple CMTS physical ports can be combined
   to create a virtual port.  A CMTS is also briefly defined in
   Section 2.6 of [RFC3083].

3.4.  Channel Bonding

   A technique for combining multiple downstream and/or upstream
   channels to increase customers' download and/or upload speeds,
   respectively.  Multiple channels from the Hybrid Fiber Coax (HFC)
   network (Section 3.11) can be bonded into a single virtual port
   (called a bonded group), which acts as a large single channel or port
   to provide increased speeds for customers.  Channel bonding is a
   feature of Data Over Cable Service Interface Specification (DOCSIS)
   version 3, as described in [DOCSIS_MULPI].

3.5.  Coaxial Cable (Coax)

   A type of cable used by a cable operator to connect customer premise
   equipment (CPE) -- such as TVs, cable modems (including eMTAs), and
   Set Top Boxes -- to the HFC network.  This cable may be used within
   the home as well as in segments of the "last mile" network running to
   a home or customer premise location.  There are many grades of
   coaxial cable that are used for different purposes.  Different types
   of coaxial cable are used for different purposes on the network.

3.6.  Comcast High Speed Internet (HSI)

   A service/product offered by Comcast for delivering Internet service
   over a broadband connection.

3.7.  Customer Premise Equipment (CPE)

   Any device that resides at the customer's residence, connected to the
   Comcast network, whether controlled by Comcast or not.

3.8.  Data Over Cable Service Interface Specification (DOCSIS)

   A reference standard developed by CableLabs that specifies how
   components on cable networks need to be built to enable HSI service
   over an HFC network, as noted in [DOCSIS_CM2CPE], [DOCSIS_PHY],
   [DOCSIS_MULPI], [DOCSIS_SEC], and [DOCSIS_OSSI].  These standards
   define the specifications for the cable modem and the CMTS such that
   any DOCSIS-certified cable modem will work on any DOCSIS-certified
   CMTS, independent of the selected vendor.  The interoperability of
   cable modems and CMTSs allows customers to purchase a DOCSIS-
   certified modem from a retail outlet and use it on their cable-
   networked home.  All DOCSIS-related standards are available to the
   public at the CableLabs website, at http://www.cablelabs.com.

3.9.  Downstream

   Description of the direction in which a signal travels, in this case
   from the network to a user.  Downstream traffic occurs when users are
   downloading something from the Internet, such as watching a web-based
   video, reading web pages, or downloading software updates.

3.10.  Headend

   A cable facility responsible for receiving TV signals for
   distribution over the HFC network to the end customers.  This
   facility typically also houses one or more CMTSs.  This is sometimes
   also called a "hub".

3.11.  Hybrid Fiber Coax (HFC)

   A network architecture used primarily by cable companies, comprised
   of fiber-optic and coaxial cables that currently deliver Voice,
   Video, and Internet services to customers, as defined in Section 1.2

3.12.  Internet Protocol Detail Record (IPDR)

   Standardized technology for monitoring and/or recording subscribers'
   upstream and downstream Internet usage data based on their cable
   modem.  The data is collected from the CMTS and sent to a server for
   further processing.  Additional information is available at
   http://www.ipdr.org, as well as [IPDR_Standard] and [DOCSIS_IPDR].

3.13.  Optical Node

   A component of the HFC network generally located in customers' local
   neighborhoods that is used to convert the optical signals sent over
   fiber-optic cables to electrical signals that can be sent over
   coaxial cable to customers' cable modems, or vice versa.  A fiber-
   optic cable connects the Optical Node, through distribution hubs, to
   the CMTS, and coaxial cable connects the Optical Node to customers'
   cable modems.

3.14.  Provisioned Bandwidth

   The peak speed associated with a tier of service purchased by a
   customer.  For example, a customer with a 105 Mbps downstream and
   10 Mbps upstream speed tier would be said to be provisioned with
   105 Mbps of downstream bandwidth and 10 Mbps of upstream bandwidth.
   This is often referred to as 105/10 service in industry parlance.

   The Provisioned Bandwidth is the speed that a customer's modem is
   configured (and the network is engineered) to deliver on a regular
   basis (which is not the same as a "Committed Information Rate" or a
   guaranteed rate).  Internet speeds are generally a best effort
   service that are dependent on a number of variables, many of which
   are outside the control of an Internet Service Provider (ISP).  In
   general, speeds do not typically exceed a customer's provisioned
   speed.  Comcast, however, invented a technology called "PowerBoost"
   [PowerBoost_Specification] that, for example, enables users to
   experience brief boosts above their provisioned speeds while they
   transfer large files over the Internet, by utilizing excess capacity
   that may be available in the network at that time.

3.15.  Quality of Service (QoS)

   A set of techniques to manage network resources to ensure a level of
   performance to specific data flows, as described in [RFC1633] and
   [RFC2475].  One method for providing QoS to a network is by
   differentiating the type of traffic by class or flow and assigning
   priorities to each type.  When the network becomes congested, the
   data packets that are marked as having higher priority will have
   higher likelihood of being serviced.

3.16.  Upstream

   Description of the direction in which a signal travels, in this case
   from the user to the network.  Upstream traffic occurs when users are
   uploading something to the network, such as sending email, sending
   files to another computer, or uploading photos to a digital photo

4.  Historical Overview

   Comcast began the engineering project to develop a new congestion
   management system in March 2008, the same month that Comcast hosted
   the 71st meeting of the IETF in Philadelphia, PA, USA.  On May 28,
   2008, Comcast participated in an IETF Peer-to-Peer Infrastructure
   Workshop [RFC5594], hosted by the Massachusetts Institute of
   Technology (MIT) in Cambridge, MA, USA.

   In order to participate in this workshop, interested attendees were
   asked to submit a paper to a technical review team, which Comcast did
   on May 9, 2008, in [COMCAST_P2PI_PAPER].  Comcast subsequently
   attended and participated in this valuable workshop.  During the
   workshop, Comcast outlined the high-level design for a new congestion
   management system [COMCAST_P2PI_PRES] and solicited comments and
   other feedback from attendees and other members of the Internet
   community (presentations were also posted to the IETF's P2Pi mailing
   list).  The congestion management system outlined in that May 2008
   workshop was later tested in trial markets and is in essence what was
   then deployed by Comcast later in 2008.

   Following an August 2008 FCC document [FCC_Memo_Opinion] regarding
   how Comcast managed congestion on its High-Speed Internet ("HSI")
   network, Comcast disclosed to the FCC [FCC_Net_Mgmt_Response] and the
   public additional technical details of the congestion management
   system that it intended to and did implement by the end of 2008
   [FCC_Congest_Mgmt_Ltr], including the thresholds involved in this new

   system.  While the description of how this system is deployed in the
   Comcast network is necessarily specific to the various technologies
   and designs specific to that network, a similar system could be
   deployed on virtually any large-scale ISP network or other IP

5.  Summary

   Comcast's HSI network has elements that are shared across many
   subscribers.  This means that Comcast's HSI customers share upstream
   and downstream bandwidth with their neighbors.  Although the
   available bandwidth is substantial, so, too, is the demand.  Thus,
   when a relatively small number of customers in a neighborhood place
   disproportionate demands on network resources, this can cause
   congestion that degrades their neighbors' Internet experience.  The
   goal of Comcast's new congestion management system is to enable all
   users of our network resources to access a "fair share" of that
   bandwidth, in the interest of ensuring a high-quality online
   experience for all of Comcast's HSI customers.

   Importantly, the new approach is protocol-agnostic; that is, it does
   not manage congestion by focusing on the use of the specific
   protocols that place a disproportionate burden on network resources,
   or any other protocols.  Rather, the new approach focuses on managing
   the traffic of those individuals who are using the most bandwidth at
   times when network congestion threatens to degrade subscribers'
   broadband experience and who are contributing disproportionately to
   such congestion at those points in time.

   Specific details about these practices, including relevant threshold
   information, the type of equipment used, and other particulars, are
   discussed at some length later in this document.  At the outset,
   however, we present a very high-level, simplified overview of how
   these practices work.  Despite all the detail provided further below,
   the fundamentals of this approach can be summarized succinctly:

   1. Software installed in the Comcast network continuously examines
      aggregate traffic usage data for individual segments of Comcast's
      HSI network.  If overall upstream or downstream usage on a
      particular segment of Comcast's HSI network reaches a
      pre-determined level, the software moves on to step two.

   2. At step two, the software examines bandwidth usage data for
      subscribers in the affected network segment to determine which
      subscribers are using a disproportionate share of the bandwidth.

      If the software determines that a particular subscriber or
      subscribers have been the source of high volumes of network
      traffic during a recent period of minutes, traffic originating
      from that subscriber or those subscribers temporarily will be
      assigned a lower priority status.

   3. During the time that a subscriber's traffic is assigned the lower
      priority status, their packets will not be delayed or dropped so
      long as the network segment is not actually congested.  If,
      however, the network segment becomes congested, their packets
      could be intermittently delayed or dropped.

   4. The subscriber's traffic returns to normal priority status once
      his or her bandwidth usage drops below a set threshold over a
      particular time interval.

   Comcast undertook considerable effort, over the course of many
   months, to formulate our plans for this congestion management
   approach, adjusting them, and subjecting them to real-world trials.
   Market trials were conducted in Chambersburg, PA; Warrenton, VA; Lake
   City, FL; East Orange, FL; and Colorado Springs, CO, between June and
   September 2008.  This enabled us to validate the utility of the
   general approach and collect substantial trial data to test multiple
   variations and alternative formulations.

6.  Relationship between Managing Congestion and Adding Capacity

   Many people have questioned whether congestion should ever exist at
   all, if an ISP was adding sufficient capacity.  There is certainly a
   relationship between capacity and congestion.  But there are two
   types of congestion that generally present themselves in a network.

   The first general type of congestion is regularly occurring and is
   the result of gradually increasing traffic levels up to a point where
   typical usage peaks cause congestion on a regular basis.  Comcast,
   like many ISPs, has a set capacity management process by which
   capacity additions are automatically triggered based on certain usage
   trends; this process is geared towards bringing additional capacity
   to the network prior to the onset of regularly occurring congestion.
   As such, capacity is added when needed and before it presents
   noticeable effects.  This process is in place since capacity
   additions are not instantaneous and in many cases require significant
   physical work.

   The second general type of congestion is unpredictable congestion,
   which can occur for a wide range of reasons.  One example may be due
   to current events, where users may be all rushing to access specific
   content at the exact same time, and where the systems serving that

   content may not be able to keep up with demand.  Another example may
   be due to a localized disaster, where some network paths have been
   destroyed or otherwise impaired, and where many users are attempting
   to communicate with one another at traffic levels significantly above

   Thus, in both cases, even with continuous upgrades and constant
   investment in additional capacity, the fact remains that network
   capacity is not unlimited.  A congestion management system, absent
   superior protocol-based solutions that do not currently exist, can
   therefore help manage the effects of congestion on users, improving
   their Internet experience.

7.  Implementation and Configuration

   It is important to note that the implementation details below and the
   overall design of the system are matched to traffic patterns that
   exist on the Internet today and that the authors believe will exist
   in the near future.  While the authors desired to make the system
   highly adaptable and a good long-term network investment, significant
   changes in such traffic patterns may necessitate a change in the
   configuration of the system or, in extreme cases, a different type of
   system altogether.

   To understand exactly how these new congestion management practices
   work, it is helpful to have a general understanding of how Comcast's
   HSI network is designed.  Comcast's HSI network is what is commonly
   referred to as a hybrid fiber-coax network, with coaxial cable
   connecting each subscriber's cable modem to an Optical Node, and
   fiber-optic cables connecting the Optical Node, through distribution
   hubs, to the Cable Modem Termination System (CMTS), which is also
   known as a "data node".  The CMTSs are then connected to higher-level
   routers, which in turn are connected to Comcast's Internet backbone
   facilities.  Today, Comcast has over 3,200 CMTSs deployed throughout
   our network, serving over 15 million HSI subscribers.

   Each CMTS has multiple "ports" that handle traffic coming into and
   leaving the CMTS.  In particular, each cable modem deployed on the
   Comcast HSI network is connected to the CMTS through the ports on the
   CMTS.  These ports can be either "downstream" ports or "upstream"
   ports, depending on whether they send information to cable modems
   (downstream) or receive information from cable modems (upstream)
   attached to the port.  (Note that the term "port" as used here
   generally contemplates single channels on a CMTS, but these
   statements will apply to virtual channels, also known as "bonded

   groups", in a DOCSIS 3.0 environment.)  Even without channel bonding,
   multiple channels are usually configured to come out of each physical
   port.  Said another way, there is generally a mapping of multiple
   channels to each physical port.

   Currently, on average, approximately 275 cable modems share the same
   downstream port, and about 100 cable modems share the same upstream
   port; however, this is constantly changing (both numbers generally
   become smaller over time, based on current DOCSIS technology).  Both
   types of ports can experience congestion that could degrade the
   broadband experience of our subscribers and, unlike with the previous
   congestion management practices, both upstream and downstream traffic
   are subject to management in this new congestion management system.

   Based upon the design of the network and traffic patterns observed,
   the most likely place for congestion to occur is on these CMTS ports.
   As a result, the congestion management system measures the traffic
   conditions of CMTS ports, and applies any policy actions to traffic
   on those ports (rather than some other, more distant segment of the

   To implement Comcast's new protocol-agnostic congestion management
   practices, Comcast purchased new hardware and software that were
   deployed near the Regional Network Routers ("RNRs") that are further
   upstream in Comcast's network.  This new hardware consists of
   Internet Protocol Detail Record ("IPDR") servers, Congestion
   Management servers, and PacketCable Multimedia ("PCMM") servers.
   Further details about each of these pieces of equipment can be found
   below, in Section 7.4.  It is important to note here, however, that
   even though the physical location of these servers is at the RNR, the
   servers communicate with -- and manage individually -- multiple ports
   on multiple CMTSs to effectuate the practices described in this
   document.  That is to say, bandwidth usage on one CMTS port will have
   no effect on whether the congestion management practices described
   herein are applied to a subscriber on a different CMTS port.

   Figure 1 provides a simplified graphical depiction of the network
   architecture just described:

   Figure 1: Simplified Network Diagram Showing High-Level Comcast

   Network and Servers Relevant to Congestion Management

                             /                         \
                            | Comcast Internet Backbone |
                             \                      -----
   +------------+             --------------------/       \
   | Congestion |                                /         \
   | Management |<+++GigE++++             +---->|  Internet |
   |   Server   |           +             |     |  Backbone |
   +------------+           +             |      \ Router  /
                            +           Fiber     \       /
   +------------+           +             |         -----
   |    QoS     |           +             |
   |   Server   |<+++GigE++++             \/
   |            |           +           -----
   +------------+           +         /       \
                            +        /         \
   +------------+           +       |  Regional |
   | Statistics |           +++++++>|  Network  |
   | Collection |<+++GigE++++       |   Router  |
   |   Server   |                    \         /
   +------------+     +---Fiber------>\       /<------Fiber----+
                      |                 -----                  |
                      \/                                       \/
                    -----                                     -----
                  /       \                                 /       \
                 /  Local  \                               /  Local  \
                |   Market  |                             |   Market  |
                 \  Router /                               \  Router /
       +--------->\       /<------------+                   \       /
       |            -----               |                    ------
       |             /\                 |                       /\
     Fiber           |                 Fiber                    |
       |           Fiber                |                      Fiber
       |             |                  |                       |
       \/            \/                 \/                      \/
    /------\      /------\           /------\                /------\
   |  CMTS  |    |  CMTS  |         |  CMTS  |              |  CMTS  |
    \------/      \------/           \------/                \------/
       /\            /\                 /\                      /\
       |             |                  |                       |
      Fiber         Fiber              Fiber                   Fiber
       |             |                  |                       |
       \/            \/                 \/                      \/

   +---------+   +---------+       +---------+             +---------+
   | Optical |   | Optical |       | Optical |             | Optical |
   |  Node   |   |  Node   |       |  Node   |             |  Node   |
   +---------+   +---------+       +---------+             +---------+
       /\          /\   /\                /\                /\     /\
       ||          ||   ||______          ||           _____||     ||
      Coax        Coax  |__Coax|         Coax         |Coax__|    Coax
       ||          ||         ||          ||          ||           ||
       \/          \/         \/          \/          \/           \/
   +=======+   +=======+   +=======+   +=======+   +=======+   +=======+
   = Cable =   = Cable =   = Cable =   = Cable =   = Cable =   = Cable =
   = Modem =   = Modem =   = Modem =   = Modem =   = Modem =   = Modem =
   +=======+   +=======+   +=======+   +=======+   +=======+   +=======+

   + Note: This diagram is a simplification of the actual network +
   +     and servers, which in actuality includes significant     +
   +  redundancy and other details too complex to represent here. +

                                 Figure 1

   Each Comcast HSI subscriber's cable modem has a "bootfile", which is
   essentially a configuration file that contains certain pieces of
   information about the subscriber's service to ensure that the service
   functions properly.  (Note: No personal information is included in
   the bootfile; it only includes information about the service that the
   subscriber has purchased.)  For example, the bootfile contains
   information about the maximum speed (what we refer to in this
   document as the "provisioned bandwidth") that a particular modem can
   achieve based on the tier (personal/residential, commercial, etc.)
   the customer has purchased.  Bootfiles are generally reset from time
   to time to account for changes in the network and other updates, and
   this is usually done through a command sent from the network and
   without the subscriber noticing.  In preparation for the transition
   to this new congestion management system, Comcast sent new bootfiles
   to our HSI customers' cable modems that created two Quality of
   Service (QoS) levels for Internet traffic going to and from the cable
   modem: (1) "Priority Best Effort" ("PBE") traffic; and (2) "Best
   Effort" ("BE") traffic.  As with previous changes to cable modem
   bootfiles, the replacement of the old bootfile with the new bootfile
   requires no active participation by Comcast customers.

   Thereafter, all traffic going to or coming from cable modems on the
   Comcast HSI network is designated as either PBE or BE.  PBE is the
   default status for all Internet traffic coming from or going to a
   particular cable modem.  Traffic is designated BE for a particular
   cable modem only when both of two conditions are met:

   o  First, the usage level of a particular upstream or downstream port
      of a CMTS, as measured over a particular period of time, must be
      nearing the point where congestion could degrade users'
      experience.  We refer to this as the "Near Congestion State" and,
      based on the technical trials we have conducted (further validated
      in our full deployment), we have established a threshold,
      described in more detail below, for when a particular CMTS port
      enters that state.

   o  Second, a particular subscriber must be making an extended, high
      contribution to the bandwidth usage on the particular port,
      relative to the service tier they purchased, as measured over a
      particular period of time.  We refer to this as the "Extended High
      Consumption State" and, based on the technical trials we have
      conducted (further validated in our full deployment), we have
      established a threshold, described in more detail below, for when
      a particular user enters that state.

   When, and only when, both conditions are met, a user's upstream or
   downstream traffic (depending on which type of port is in the Near
   Congestion State) is designated as BE.  Then, to the extent that
   actual congestion occurs, any delay resulting from the congestion
   will affect BE traffic before it affects PBE traffic.

   We now explain the foregoing in greater detail in the following

7.1.  Thresholds for Determining When a CMTS Port Is in a Near
      Congestion State

   For a CMTS port to enter the Near Congestion State, traffic flowing
   to or from that CMTS port must exceed a specified level (the "Port
   Utilization Threshold") for a specific period of time (the "Port
   Utilization Duration").  The Port Utilization Threshold on a CMTS
   port is measured as a percentage of the total aggregate upstream or
   downstream bandwidth for the particular port during the relevant
   timeframe.  The Port Utilization Duration on the CMTS is measured in

   Values for each of the thresholds that are used as part of this
   congestion management technique have been tentatively established
   after an extensive process of lab tests, simulations, technical
   trials, vendor evaluations, customer feedback, and a third-party
   consulting analysis.  In the same way that specific anti-spam or
   other network management practices are adjusted to address new issues
   that arise, it is a near certainty that these values will change over
   time, as Comcast gathers more data and performs additional analysis
   resulting from wide-scale use of the new technique.  Moreover, as

   with any large network or software system, software bugs and/or
   unexpected errors may arise, requiring software patches or other
   corrective actions.  As always, Comcast's decisions on these matters
   are driven by the marketplace imperative that we deliver the best
   possible experience to our HSI subscribers.

   Given our experience as described above, we determined that a
   starting point for the upstream Port Utilization Threshold should be
   70 percent and the downstream Port Utilization Threshold should be
   80 percent.  For the Port Utilization Duration, we determined that
   the starting point should be approximately 15 minutes (although some
   technical limitations in some newer CMTSs deployed on Comcast's
   network may make this time period vary slightly).  Thus, over any
   15-minute period, if an average of more than 70 percent of a port's
   upstream bandwidth capacity or more than 80 percent of a port's
   downstream bandwidth capacity is utilized, that port is determined to
   be in a Near Congestion State.

   Based on the trials conducted and operational experience to date, a
   typical CMTS port on our HSI network is in a Near Congestion State
   only for relatively small portions of the day, if at all, though
   there is no way to forecast what will be the busiest time on a
   particular port on a particular day.  Moreover, the trial data and
   operational experience indicate that, even when a particular port is
   in a Near Congestion State, the instances where the network actually
   becomes congested during the Port Utilization Duration are few, and
   managed users whose packets may be intermittently delayed or dropped
   during those congested periods perceive little, if any, effect, as
   discussed below.

7.2.  Thresholds for Determining When a User Is in an Extended High
      Consumption State and for Release from That Classification

   Once a particular CMTS port is in a Near Congestion State, the
   software examines whether any cable modems are consuming bandwidth
   disproportionately.  (Note: Although each cable modem is typically
   assigned to a particular household, the software does not and cannot
   actually identify individual users or the number of users sharing a
   cable modem, or analyze particular users' traffic.)  For purposes of
   this document, we use "cable modem", "user", and "subscriber"
   interchangeably to mean a subscriber account or user account and not
   an individual person.  For a user to enter an Extended High
   Consumption State, he or she must consume greater than a certain
   percentage of his or her provisioned upstream or downstream bandwidth
   (the "User Consumption Threshold") for a specific length of time (the
   "User Consumption Duration").  The User Consumption Threshold is
   measured as a user's consumption of a particular percentage of his or
   her total provisioned upstream or downstream bandwidth.  That

   bandwidth is the maximum speed that a particular modem can achieve
   based on the tier (personal/residential, commercial, etc.) the
   customer has purchased.  For example, if a user buys a service with
   speeds of 50 Mbps downstream and 10 Mbps upstream, then his or her
   provisioned downstream speed is 50 Mbps and provisioned upstream
   speed is 10 Mbps.  It is also important to note that because the User
   Consumption Threshold is a percentage of provisioned bandwidth for a
   particular user account, and not a static value, users of higher-
   speed tiers have correspondingly higher User Consumption Thresholds.
   Lastly, the User Consumption Duration is measured in minutes.

   Following lab tests, simulations, technical trials, customer
   feedback, vendor evaluations, and an independent third-party
   consulting analysis, we have determined that the appropriate starting
   point for the User Consumption Threshold is 70 percent of a
   subscriber's provisioned upstream or downstream bandwidth, and that
   the appropriate starting point for the User Consumption Duration is
   15 minutes (this has been further validated in our full deployment).
   That is, when a subscriber uses an average of 70 percent or more of
   his or her provisioned upstream or downstream bandwidth over a
   particular 15-minute period, that user is then in an Extended High
   Consumption State.  Therefore, this is a consumption-based threshold
   and not a peak-speed-based threshold.  Thus, the Extended High
   Consumption State is not tied to whether a user has bursted once or
   more above this 70% threshold for a brief moment.  Instead, it is
   consumption-based, meaning that a certain bitrate must be exceeded
   over at least the entire User Consumption Duration.

   The User Consumption Thresholds have been set sufficiently high that
   using the HSI connection for Voice over IP (VoIP), gaming, web
   surfing, or most streaming video cannot alone cause subscribers to
   our standard-level HSI service to exceed the User Consumption
   Threshold.  For example, while one of Comcast's common HSI service
   tiers has a provisioned downstream bandwidth of 22 Mbps today,
   streaming video (even some HD video) from Hulu uses less than
   2.5 Mbps, a Vonage or Skype VoIP call uses less than 131 kbps, and
   streaming music uses less than 128 kbps (in this example, 70 percent
   of 22 Mbps is 15.4 Mbps).  As noted above, these values are subject
   to change as necessary in the same way that specific anti-spam or
   other network management practices are adjusted to address new issues
   that arise, or should unexpected software bugs or other problems

   Based on data collected from the trial markets where the new
   congestion management practices were tested (further validated in our
   full deployment), on average less than one-third of one percent of
   subscribers have had their traffic priority status changed to the BE
   state on any given day.  For example, in Colorado Springs, CO, the

   largest test market, on any given day in August 2008, an average of
   22 users out of 6,016 total subscribers in the trial had their
   traffic priority status changed to BE at some point during the day.

   A user's traffic is released from a BE state when the user's
   bandwidth consumption drops below 50 percent of his or her
   provisioned upstream or downstream bandwidth for a period of
   approximately 15 minutes.  These release criteria are intended to
   minimize (and hopefully prevent) user QoS oscillation, i.e., a
   situation in which a particular user could cycle repeatedly between
   BE and PBE.  Thus, without this lower release criteria, we were
   concerned that certain users would oscillate between BE and PBE
   states for an extended period, without clear benefit to the system
   and other users, and would place an unnecessary signaling burden on
   the system.  NetForecast, Inc., an independent consultant retained to
   provide analysis and recommendations regarding Comcast's trials and
   related congestion management work, suggested this approach, which
   has worked well in our trials, lab testing, and subsequent national

   Simply put, there are four steps for determining whether the traffic
   associated with a particular cable modem is designated as PBE or BE:

   1. Determine if the CMTS port is in a Near Congestion State.

   2. If yes, determine whether any users are in an Extended High
      Consumption State.

   3. If yes, change those users' traffic to BE from PBE.  If the answer
      at either step one or step two is no, no action is taken.

   4. If a user's traffic has been designated BE, check user consumption
      at the next interval.  If user consumption has declined below the
      predetermined threshold, reassign the user's traffic as PBE.  If
      not, recheck at the next interval.

   In cases where a CMTS regularly enters a Near Congestion State, and
   where congestion subsequently does occur, but where no users match
   the criteria to be classified in an Extended High Consumption State,
   this may indicate the congestion observed is regularly occurring,
   rather than unpredictable congestion.  As such, this may be an
   additional data point in favor of considering whether and when to add

   Figure 2 graphically depicts how this congestion management process
   works, using an example of a situation where upstream port
   utilization may be reaching a Near Congestion State (the same
   diagram, with different values in the appropriate places, could be
   used to depict the management process for downstream ports, as well):

   Figure 2: Upstream Congestion Management Decision Flowchart

 +------------+       /  \            +---------+            +---------+
 |   Start    |     /      \          |         |           /         /
 | Congestion |    /        \         |         |          /         /
 | Management +-->+ Question +--YES-->| Result  |--THEN-->/ Action  /
 | Process    |    \   #1   /         |   #1    |        /   #1    /
 |            |     \      /          |         |       /         /
 +------------+       \  /            +---------+      +---------+
                       \/                                     |
                       |                                     THEN
                       NO                                     |
                       |                                      \/
                       \/                                     /\
                  +---------+                                /  \
                  |         |                              /      \
                  |         |                             /        \
                  | Result  |<-------------NO------------+ Question +
                  |   #2    |                             \   #2   /
                  |         |                              \      /
                  +---------+                                \  /
                          /\                                 \/
  +---------+            /  \                            +---------+
  |         |          /      \                          |         |
  |         |         /        \        THEN, AT         |         |
  | Result  |<--YES--+ Question + <---NEXT ANALYSIS------+ Result  |
  |   #4    |         \   #3   /         POINT        /\ |   #3    |
  |         |          \      /                       |  |         |
  +---------+            \  /                         |  +---------+
                          \/                          |
                          |                           |


  Question #1: Is the CMTS Upstream Port Utilization at an average
               of OVER 70% for OVER 15 minutes?

    Result #1: CMTS marked in a Near Congestion State, indicating
               congestion *may* occur soon.

    Action #1: Search most recent analysis timeframe (approx. 15 mins.)
               of IPDR usage data.

  Question #2: Are any users consuming an average of OVER 70% of
               provisioned upstream bandwidth for OVER 15 minutes?

    Result #2: No action taken.

    Result #3: Change user's upstream traffic from Priority Best Effort
               (PBE) to Best Effort (BE).

  Question #3: Is the user in Best Effort (BE) consuming an average
               of LESS THAN 50% of provisioned upstream bandwidth
               over a period of 15 minutes?

    Result #4: Change user's upstream traffic back to Priority Best
               Effort (PBE) from Best Effort (BE).

                                 Figure 2

7.3.  Effect of BE Quality of Service on Users' Broadband Experience

   When a CMTS port is in a Near Congestion State and a cable modem
   connected to that port is in an Extended High Consumption State, that
   cable modem's traffic is designated as BE.  Depending upon the level
   of utilization on the CMTS port, this designation may or may not
   result in the user's traffic being delayed or, in extreme cases,
   dropped before PBE traffic is dropped.  This is because of the way
   that the CMTS handles traffic.  Specifically, CMTS ports have what is
   commonly called a "scheduler" that puts all the packets coming from
   or going to cable modems on that particular port in a queue and then
   handles them in turn.  A certain number of packets can be processed
   by the scheduler in any given moment; for each time slot, PBE traffic
   is given priority access to the available capacity, and BE traffic is
   processed on a space-available basis.

   A rough analogy would be to busses that empty and fill up at
   incredibly fast speeds.  As empty busses arrive at the figurative
   "bus stop" -- every two milliseconds in this case -- they fill up
   with as many packets as are waiting for "seats" on the bus, to the

   limits of the bus' capacity.  During non-congested periods, the bus
   will usually have several empty seats, but during congested periods,
   the bus will fill up and packets will have to wait for the next bus.
   It is during the congested periods that BE packets will be affected.
   If there is no congestion, packets from a user in a BE state should
   have little trouble getting on the bus when they arrive at the bus
   stop.  If, on the other hand, there is congestion in a particular
   instance, the bus may become filled by packets in a PBE state before
   any BE packets can get on.  In that situation, the BE packets would
   have to wait for the next bus that is not filled by PBE packets.  In
   reality, this all takes place in two-millisecond increments, so even
   if the packets miss 50 "busses", the delay will only be about one-
   tenth of a second.

   During times of actual network congestion, when packets from BE
   traffic might be intermittently delayed, there is a variety of
   effects that could be experienced by a user whose traffic is delayed,
   depending upon what applications he or she is using.  Typically, a
   user whose traffic is in a BE state during actual congestion may find
   that a webpage loads sluggishly, a peer-to-peer upload takes somewhat
   longer to complete, or a VoIP call sounds choppy.  Of course, the
   same thing could happen to the customers on a port that is congested
   in the absence of any congestion management; the difference here is
   that the effects of any such delays are shifted toward those who have
   been placing the greatest burden on the network, instead of being
   distributed randomly among the users of that port without regard to
   their consumption levels.  As a matter of fact, our studies concluded
   that the experience of the PBE subscribers improves when this
   congestion management system is enabled.  This conclusion is based on
   network measurements, such as latency.

   NetForecast explored the potential risk of a worst-case scenario for
   users whose traffic is in a BE state: the possibility of "bandwidth
   starvation" in the theoretical case where 100 percent of the CMTS
   bandwidth is taken up by PBE traffic for an extended period of time.
   In theory, such a condition could mean that a given user whose
   traffic is designated BE would be unable to effectuate an upload or
   download (as noted above, both are managed separately) for some
   period of time.  However, when these management techniques were
   tested, first in company testbeds and then in our real-world trials
   conducted in the five markets (further validated in our full
   deployment), such a theoretical condition did not occur.  In
   addition, our experience with the system as fully deployed in our
   production network demonstrates that these management practices have
   very modest real-world impacts.  In addition, Comcast did not receive
   a single customer complaint, in any of the trial markets, that could
   be traced to this congestion management system, despite having
   broadly publicized these trials.  In our subsequent national

   deployment into our production network, we still have yet to find a
   specific complaint that can be traced back to the effect of this
   congestion management system.

   Comcast continues to monitor how user traffic is affected by these
   new congestion management techniques and will make the adjustments
   necessary to ensure that all Comcast HSI customers have a high-
   quality Internet experience.

7.4.  Equipment/Software Used and Location

   The above-mentioned functions are carried out using three different
   types of application servers, supplied by three different vendors.
   As mentioned above, these servers are installed near Comcast's
   regional network routers.  The exact locations of these servers are
   not particularly relevant to this document, as this information does
   not change the fact that the servers manage individual CMTS ports.

   The first application server is an IPDR server, which collects
   relevant cable modem volume usage information from the CMTS, such as
   how many aggregate upstream or downstream bytes a subscriber uses
   over a particular period of time.  IPDR has been adopted as a
   standard by many industry organizations and initiatives, such as
   CableLabs, the Alliance for Telecommunications Industry Solutions
   (ATIS), the International Telecommunication Union (ITU), and the
   Third Generation Partnership Project (3GPP), among others.  The IPDR
   software deployed was developed by Active Broadband Networks, and is
   noted as the Statistics Collection Server in Figure 3.

   The second application server is the Congestion Management server,
   which uses the Simple Network Management Protocol (SNMP) [RFC3410] to
   measure CMTS port utilization and detect when a port is in a Near
   Congestion State.  When this happens, the Congestion Management
   server then queries the relevant IPDR data for a list of cable modems
   meeting the criteria set forth above for being in an Extended High
   Consumption State.  The Congestion Management server software
   deployed was developed by Sandvine.

   If one or more users meet the criteria to be managed, then the
   Congestion Management server notifies a third application server, the
   PCMM application server, as to which users have been in an Extended
   High Consumption State and whose traffic should be treated as BE.
   The PCMM servers are responsible for signaling a given CMTS to set
   the traffic for specific cable modems with a BE QoS, and for tracking
   and managing the state of such CMTS actions.  If no users meet the
   criteria to be managed, no users will have their traffic managed.
   The PCMM software deployed was developed by Camiant, and is noted as
   the QoS Server in Figure 3.

   Figure 3 graphically depicts the high-level management flows among
   the congestion management components on Comcast's network, as
   described above:

   Figure 3: Simplified Diagram Showing High-Level Management Flows
   Relevant to the System

   +---------------+                            +---------------+
   |  Congestion   |     Instruct QoS Server    |      QoS      |
   |  Management   |******to Change QoS for****>|     Server    |
   |    Server     |         a Device           |               |
   +----+---+------+                            +-------+-------+
        /\  /\                                          *
        |   |    Relay Selected                         *
        X   +---Statistics: Bytes---+               QoS Action:
        |       Up/Down by Device   |             Change from PBE
        X                  +-------+-------+     to BE, or from
        |                  |  Statistics   |       BE to PBE
        X                  |  Collection   |            *
    Periodic SNMP          |    Server     |            *
     Requests to           +---------------+            *
   Check CMTS Port                 /\                   *
    Utilization                    |                    *
      Levels                 Statistics Sent            *
        |                 Periodically From CMTS        *
        X                          |                    *
        |              +-----------+-----------+        *
        +-X-X-X-X-X-X->|   CMTS in Headend     |<********
                          H   /\        /\   H
                          H Internet Traffic H
                          H  to/from User    H
                          H   \/        \/   H
                      / | User's  +---------+  |\
                     /  | Home    |  Cable  |  | \
                        |         |  Modem  |  |
   ============         |         +---------+  |
   = Notes:   =         +----------------------+
   =          ========================================================
   = 1 - Statistics Collection Servers use IP Detail Records (IPDR). =
   = 2 - QoS Servers use PacketCable Multimedia (PCMM)               =
   =     to set QoS gates on the CMTS.                               =
   = 3 - This figure is a simplification of the actual network and   =
   =     servers, which included redundancies and other complexities =
   =     not necessary to depict the functional design.              =
                                 Figure 3

8.  Conclusion

   Comcast started design and development of this new protocol-agnostic
   congestion management system in March 2008.  Comcast shared the
   design with the IETF and others in the Internet community, as well as
   with an independent consultant, incorporating feedback we received
   into the final design.  Following lab testing, the system was tested
   in Comcast's production network in trial markets between June and
   September 2008.  Comcast's production network transition to this new
   protocol-agnostic congestion management system began in October 2008
   and was completed on December 31, 2008.

   As described herein, the new approach does not manage congestion by
   focusing on managing the use of specific protocols.  Nor does this
   approach use TCP "reset packets" [RFC3360].  Rather, the system acts
   such that during periods when a CMTS port is in a Near Congestion
   State, the system (1) identifies the subscribers on that port who
   have consumed a disproportionate amount of bandwidth over the
   preceding 15 minutes and (2) lowers the priority status of those
   subscribers' traffic to BE status until those subscribers meet the
   release criteria.  During periods of actual congestion, the system
   handles PBE traffic before BE traffic.  Comcast's trials and
   subsequent national deployment indicate that this new congestion
   management system ensures a quality online experience for all of
   Comcast's HSI customers.

9.  Exceptional Network Utilization Considerations

   This system was developed to cope with somewhat "normal" occurrences
   of congestion that could occur on virtually any IP network.  It
   should also be noted, however, that such a system could also prove
   particularly useful in the case of "exceptional network utilization"
   events that existing network usage models do not or cannot accurately
   predict.  Some network operators refer to these exceptional events as
   "surges" in utilization, similar to sudden surges in demand in
   electrical power grids, with which many people may be familiar.

   For example, in the case of a severe global pandemic, it may be
   expected that large swaths of the population may need to work
   remotely, via their Internet connection.  In such a case, a largely
   unprecedented level of utilization may occur.  In such cases, it may
   be helpful to have a flexible congestion management system that could
   adapt to this situation and help allocate network resources while
   additional capacity is being brought online or while a temporary
   condition persists.

10.  Limitations of This Congestion Management System

   The main limitations of the system include:

   o  The system is not an end-to-end congestion management system, nor
      does it enable one.

   o  The system does not signal the presence of congestion to user
      applications or to all devices on the network path.

   o  The system does not explicitly enable additional user and/or
      application responses to congestion.

   o  The system does not enable distributed denial-of-service (DDoS)
      mitigation or other capabilities.

11.  Low Extra Delay Background Transport and Other Possibilities

   There are several new IETF working group efforts that are focused on
   the question of congestion and its effects, avoiding congestion,
   managing congestion, and communicating congestion information.  This
   includes the Congestion Exposure (CONEX) working group, the
   Application Layer Transport Optimization (ALTO) working group, and
   the Low Extra Delay Background Transport (LEDBAT) working group.
   Should one or more of these working groups be successful in producing
   useful work, it is possible that the design or configuration of the
   system documented here may need to change.  For example, this
   congestion management system does not currently have a way to take
   into account differing classes of data transfer, such as a class of
   data transfer that LEDBAT may specify, which may better yield to
   other traffic than existing transport protocols.  In addition, CONEX
   may specify methods for this or other systems to signal congestion
   state or expected congestion to other parts of the network, and/or to
   hosts on either end of a particular network flow.  Furthermore, it is
   conceivable that the result of current or future IETF work could
   obviate the need for such a congestion management system entirely.

12.  Security Considerations

   It is important that an ISP secure access to the Congestion
   Management servers and the QoS Servers, as well as QoS signaling to
   the CMTSs, so that unauthorized users and/or hosts cannot make
   unauthorized changes to QoS settings in the network.

   It is also important to secure access to the Statistics Collection
   Server since this contains IPDR-based byte transfer data that is
   considered private by end users on an individual basis.  In addition,
   this data is considered ISP-proprietary traffic data on an aggregate

   basis.  Access to the Statistics Collection Server should also be
   secured so that false usage statistics cannot be fed into the system.
   It is important to note that IPDR data contains a count of bytes sent
   and bytes received, by cable modem MAC address, over a given interval
   of time.  This data does not contain things such as the source and/or
   destination Internet address of that data, nor does it contain the
   protocols used, ports used, etc.

13.  Acknowledgements

   The authors wish to acknowledge the hard work of the many people who
   helped to develop and/or review this document, as well as the people
   who helped deploy the system in such a short period of time.

   The authors also wish to acknowledge the following individuals for
   performing a detailed review of this document and/or providing
   comments and feedback that helped to improve and evolve this

   - Kris Bransom

   - Bob Briscoe

   - Lars Eggert

   - Ari Keranen

   - Tero Kivinen

   - Matt Mathis

   - Stanislav Shalunov

14.  Informative References

               Livingood, J. and R. Woundy, "Comcast's IETF P2P
               Infrastructure Workshop Position Paper", FCC
               Filings Comcast Network Management Proceedings, May 2008,

               Livingood, J. and R. Woundy, "Comcast's IETF P2P
               Infrastructure Workshop Presentation on May 28, 2008",
               FCC Filings Comcast Network Management Proceedings,
               May 2008,

               CableLabs, "Data-Over-Cable Service Interface
               Specifications - DOCSIS 3.0 - Cable Modem to Customer
               Premise Equipment Interface Specification", DOCSIS
               3.0 CM-SP-CMCIv3-I01-080320, March 2008,

               Yassini, R., "Data-Over-Cable Service Interface
               Specifications - DOCSIS 2.0 - Operations Support System
               Interface Specification", DOCSIS 2.0 CM-SP-OSSIv2.0-C01-
               081104, November 2008, <http://www.cablelabs.com/

               CableLabs, "Data-Over-Cable Service Interface
               Specifications - DOCSIS 3.0 - MAC and Upper Layer
               Protocols Interface Specification", DOCSIS 3.0 CM-SP-
               MULPIv3.0-I11-091002, October 2009, <http://

               CableLabs, "Data-Over-Cable Service Interface
               Specifications - DOCSIS 3.0 - Operations Support System
               Interface Specification", DOCSIS 3.0 CM-SP-OSSIv3.0-I10-
               091002, October 2009, <http://www.cablelabs.com/

               CableLabs, "Data-Over-Cable Service Interface
               Specifications - DOCSIS 3.0 - Physical Layer
               Specification", DOCSIS 3.0 CM-SP-PHYv3.0-I08-090121,
               January 2009, <http://www.cablelabs.com/cablemodem/

               CableLabs, "Data-Over-Cable Service Interface
               Specifications - DOCSIS 3.0 - Security Specification",
               DOCSIS 3.0 CM-SP-SECv3.0-I11-091002, March 2008, <http://

               Zachem, K., "Letter to the FCC Advising of Successful
               Deployment of Comcast's New Congestion Management
               System", FCC Filings Comcast Network Management
               Proceedings, January 2009,

               Martin, K., Copps, M., Adelstein, J., Tate, D., and R.
               McDowell, "FCC Memorandum and Opinion Regarding
               Reasonable Network Management", File No. EB-08-IH-1518 WC
               Docket No.  07-52, August 2008,

               Zachem, K., "Letter to the FCC Regarding Comcast's
               Network Management Practices", FCC Filings Comcast
               Network Management Proceedings, September 2008, <http://

               Cotton, S., Cockrell, B., Walls, P., and T. Givoly,
               "Network Data Management - Usage (NDM-U) For IP-Based
               Services.  Service Specification - Cable Labs DOCSIS 2.0
               SAMIS", IPDR Service Specifications NDM-U, November 2004,

               Comcast Cable Communications Management LLC, "Comcast
               PowerBoost Specification", Website Comcast.com,
               June 2010, <http://customer.comcast.com/Pages/

   [RFC1633]   Braden, B., Clark, D., and S. Shenker, "Integrated
               Services in the Internet Architecture: an Overview",
               RFC 1633, June 1994.

   [RFC2475]   Blake, S., Black, D., Carlson, M., Davies, E., Wang, Z.,
               and W. Weiss, "An Architecture for Differentiated
               Services", RFC 2475, December 1998.

   [RFC3083]   Woundy, R., "Baseline Privacy Interface Management
               Information Base for DOCSIS Compliant Cable Modems and
               Cable Modem Termination Systems", RFC 3083, March 2001.

   [RFC3360]   Floyd, S., "Inappropriate TCP Resets Considered Harmful",
               BCP 60, RFC 3360, August 2002.

   [RFC3410]   Case, J., Mundy, R., Partain, D., and B. Stewart,
               "Introduction and Applicability Statements for Internet-
               Standard Management Framework", RFC 3410, December 2002.

   [RFC5594]   Peterson, J. and A. Cooper, "Report from the IETF
               Workshop on Peer-to-Peer (P2P) Infrastructure, May 28,
               2008", RFC 5594, July 2009.

Authors' Addresses

   Chris Bastian
   Comcast Cable Communications
   One Comcast Center
   1701 John F. Kennedy Boulevard
   Philadelphia, PA  19103
   EMail: chris_bastian@cable.comcast.com
   URI:   http://www.comcast.com

   Tom Klieber
   Comcast Cable Communications
   1306 Goshen Parkway
   West Chester, PA  19380
   EMail: tom_klieber@cable.comcast.com
   URI:   http://www.comcast.com

   Jason Livingood
   Comcast Cable Communications
   One Comcast Center
   1701 John F. Kennedy Boulevard
   Philadelphia, PA  19103
   EMail: jason_livingood@cable.comcast.com
   URI:   http://www.comcast.com

   Jim Mills
   Comcast Cable Communications
   One Comcast Center
   1800 Bishops Gate Drive
   Mount Laurel, NJ  08054
   EMail: jim_mills@cable.comcast.com
   URI:   http://www.comcast.com

   Richard Woundy
   Comcast Cable Communications
   27 Industrial Avenue
   Chelmsford, MA  01824
   EMail: richard_woundy@cable.comcast.com
   URI:   http://www.comcast.com


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