Cruz, Rubio Celebrate One Year Anniversary Of Net Neutrality Rules -- By Trying To Kill Them

from the hurting-consumers-for-the-good-of-consumers-everywhere dept

It has already been a year since the FCC voted to reclassify ISPs as common carriers under the telecom act. And despite the countless calories spent by the telecom industry and its various mouthpieces claiming Title II and net neutrality would demolish all Internet investment and innovation as we know it, you may have noticed that things by and large did not implode. In fact, while the FCC has been snoozing on things like zero rating and usage caps, the mere threat of rules helped the Internet by putting an end to the interconnection shenanigans causing Netflix performance degradation.

But because some apparently believe that opposing a concept with broad bipartisan support is a brilliant political strategy, eight Senators -- including Presidential hopefuls Marco Rubio and Ted Cruz -- decided to mark the one year anniversary with a new bill that aims to dismantle the rules and Title II. In a statement posted to the Rubio campaign website, Rubio outlines how the Restoring Internet Freedom Act (pdf) is all about (insert casual, nonsensical use of words like innovation and diversity here):

"The Internet has always been one of the best models of the free market,” said Rubio. “There are low barriers to entry, back and forth communication between consumers and providers, and a rapid evolution of ideas. “Through burdensome regulations and tight control like the net neutrality rule, the government only hinders accessibility and the diversity of content,” added Rubio. “Consumers should be driving the market, and we can help by encouraging innovation, incentivizing investment, and promoting the competitive environment this industry needs."

While certain Internet businesses may enjoy a free market, with net neutrality specifically we're talking about the telecom industry, which simply isn't free. The telecom market is a protectionist cabal in which a handful of companies, soaked with generations of unaccountable subsidies, enjoy limited competition thanks to their immense political power. The kind of power Comcast is currently abusing with usage caps and zero rating to hurt alternative video services. The kind of power that convinces Presidential hopefuls to proudly declare they're fighting one of the most meaningful and broadly-supported consumer protection efforts in a generation -- because of an undying love of consumers.

It's also hard to argue that the net neutrality rules are "burdensome" when the FCC really hasn't even bothered to enforce them yet, and there's absolutely no objective example of said burden. Comcast imposing usage caps on uncompetitive markets, then exempting its own streaming services from them is about as clear of a violation of net neutrality that you're going to get. But because the FCC's "burdensome" regulations pussy-footed around the threat of caps and zero rating, we're actually left with the rules that don't go quite far enough.

And yes, for about the millionth time you wouldn't need net neutrality rules if we had effective competition in the broadband space. But when push comes to shove, the same people lambasting net neutrality aren't keen on supporting this policy, since it means standing up to the most powerful lobbying operations (AT&T, Verizon, Comcast) the country has to offer. As a result we get politicians that gut consumer protections, do absolutely nothing about the abysmal state of broadband competition, then proudly pat themselves on the back for being such wonderful pals to the American consumer.

Filed Under: competition, fcc, innovation, internet freedom act, marco rubio, net neutrality, ted cruz, title ii
Companies: at&t, comcast, verizon

One Year Later, ISP Claims That Title II Would Demolish Broadband Investment Found To Be Total, Indisputable Bullshit

from the nostradamus-you-ain't dept

In late 2014, the Obama Administration and the FCC shocked everybody by announcing that the government would be uncharacteristically ignoring telecom lobbyists and reclassifying broadband service under Title II -- ensuring it had adequate legal foundation for tougher net neutrality rules. As you might expect, the cable and phone companies immediately set to work with a blistering public relations barrage, with think tankers, editorials, industry consultants and thousands of industry mouthpieces all making one common refrain: Title II would utterly decimate broadband sector investment and crush innovation.

Ignore that the wireless industry had been classified under Title II for the majority of explosive growth years. Ignore as well that companies like Verizon had been classifying its FiOS fiber under Title II for mammoth tax breaks with no ill effect. No, according to companies like AT&T in 2014, Title II was absolutely certain to effectively usher in a telecom investment ice age that would leave the country reeling:

"Reclassification would mire the industry in years of uncertainty and litigation, and it would abruptly stall the virtuous circle of investment and innovation that has propelled the United States to the forefront of the broadband revolution."

Comcast had its own similar predictions in 2014:

"The sheer uncertainty surrounding such a regulatory environment would produce ‘a profoundly negative impact on capital investment.’ By itself, reduced investment would inhibit job creation, hinder the deployment of broadband infrastructure, and undermine the ‘virtuous circle’ of innovation that the open Internet rules are designed to advance."

But as the last year rolled on, people who could be bothered to actually read industry CAPEX numbers found that investment -- much of it in Google Fiber markets -- was as healthy as ever, if not better. Comcast announced plans to deploy two gigabit service to eighteen million homes, more recently unveiling plans for a major gigabit cable initiative in 2016. Time Warner Cable, Comcast and AT&T all spent much of the year crowing about notable speed upgrades and improvements, from expanded gigabit fiber pushes to housing developments, to notable DOCSIS 3.1 cable and set top box upgrades.

Closing on one year after the FCC voted to enact Title II, Kate Cox at the Consumerist did an amazing job digging through the absolute mountain of misleading claims made by AT&T, Time Warner Cable, Comcast, Verizon and Charter, and comparing them to the companies' recent earnings statements and CAPEX numbers. In nearly every case, claims of the investment apocalypse were found to be utter and undeniable bullshit, with the companies repeatedly indicating that Title II didn't impact company plans in the slightest:

"By and large, the half-dozen companies representing the overwhelming majority of cable Internet and wireless broadband customers in the country, are continuing to invest. But is that just puffed-up chest-thumping to cheer up investors? Those most directly impacted by broadband investment don’t seem terribly concerned. In January, Multichannel News reported that the suppliers who make the stuff that the telecoms spend their money on aren’t losing sleep about a decrease in investment.

Shocking, right? It's almost as if think tankers, lobbyists, and other hired sockpuppets were just spouting nonsense to scare the government away from meaningful net neutrality protections. And when it became clear the data wasn't going to support their predictions, industry think tankers (and Verizon lawyers turned FCC Commissioners) concocted misleading studies claiming sector CAPEX was dropping, and are still making the same claims even now. But as we previously noted in great detail, those studies used farmed statistics and cherry picked CAPEX windows to artfully paint a picture easily disproven by spending just five minutes with any major telecom earnings report.

Of course, the fact that these companies have been proven to be lying through their teeth won't stop them from continuing their lawsuit against the FCC. If said lawsuit doesn't demolish the rules, it's entirely possible the elections will, since any Presidential victor could gut the existing FCC staff and the rules in one, fell swoop. Should that happen, the neutrality debate in the States will reset to zero, giving telecom industry disinformation artists ample opportunity to once again highlight how the broadband industry's greatest innovation isn't in broadband, but in bullshit.

Filed Under: broadband, fcc, investment, net neutrality, title ii
Companies: at&t, comcast, verizon

India Bans Zero Rating As The U.S. Pays The Price For Embracing It

from the unlevel-playing-field dept

As expected, the Telecom Regulatory Authority of India (TRAI) has passed new net neutrality rules (pdf) that specifically ban the practice of zero rating. The rules are relatively clear in that they prevent either content companies or ISPs from striking deals that exempt select content from usage caps. The ruling acknowledges that such models create an unlevel playing field for smaller companies who may not be able to pay to play:

"...differential tariffs result in classification of subscribers based on the content they want to access (those who want to access non-participating content will be charged at a higher rate than those who want to access participating content). This may potentially go against the principle of non-discriminatory tariff. Secondly, differential tariffs arguably disadvantage small content providers who may not be able to participate in such schemes. This may thus, create entry barriers and non-level playing field for these players stifling innovation. In addition, TSPs may start promoting their own websites/apps/service platforms by giving lower rates for accessing them.

The ruling effectively bans Facebook's "Free Basics" program, despite an immense amount of often misleading lobbying and marketing by the social networking company. Net neutrality advocates in India had argued that Free Basics -- which exempts Facebook "curated" content from wireless usage caps -- gave too much walled-garden power to the company, allowing it to corner India's ad and content markets for years to come. Facebook, in contrast, argued it was being entirely altruistic, solely worried about India's poor farmers.

In a statement on TRAI's decision, Facebook reiterated that it was only trying to help:

"Our goal with Free Basics is to bring more people online with an open, non-exclusive and free platform. While disappointed with the outcome, we will continue our efforts to eliminate barriers and give the unconnected an easier path to the internet and the opportunities it brings."

As it stands, companies that violate the rules need to pay 50,000 rupees per day ($740), up to a maximum of 5 million rupees (an inconsequential sum to carriers and Facebook alike). The rules will be in place for two years and could be open for review at that time. As such, Facebook could still lobby to have the restriction on zero rating weakened, or could modify its Free Basics program so that it better adheres to the rules. Or, better yet, as Mozilla had suggested if Facebook really wants to help it could take all of the marketing, PR, lobbying, and design money being spent on Free Basics, and actually spend it on improving India's lagging telecom infrastructure.

India now joins The Netherlands, Japan, Chile and Slovenia in passing net neutrality rules that clearly prohibit zero rating. Contrast that to the rules here in the States, which don't specifically forbid the practice, instead ambiguously stating that services will only be examined on a "case by case" basis. But the mere act of opening the door to the precedent of zero rating already has already resulted in companies like Comcast and Verizon abusing it, both of them now exempting their own services from usage caps, while still penalizing competing services like Netflix.

Filed Under: free basics, india, net neutrality, trai, zero rating
Companies: facebook

Verizon Gives Net Neutrality A Giant Middle Finger, Exempts Own Video Service From Wireless Usage Caps

from the ill-communication dept

In 2010, Verizon successfully sued to demolish the FCC's original net neutrality rules. In 2015, Verizon joined the rest of the industry in helping launch a barrage of lawsuits to try kill and kill a more legally-sound and updated version of those same rules. While that case continues through the courts, Verizon has made it clear that 2016 will be the year the telco raises a giant middle finger to the FCC and net neutrality supporters alike.

The company sent an e-mail to Verizon Wireless customers this week informing them that using the carrier's Millennial-focused Go90 streaming video service will no longer count against the company's mobile broadband usage caps. As in, Verizon has decided to give its own streaming video service an incredibly unfair advantage over any rival services. According to an updated customer agreement website, the change in policy only occurred this week after the company updated the company's app to version 1.4:

"Beginning on or about February 4, 2016, if you are a Verizon Wireless post-paid customer and you download the current version of go90 (release 1.4), you can watch any video on go90 without incurring Verizon Wireless data usage charges so long as you are connected to LTE. Other activity that does not involve watching videos, such as downloading go90 from an app store, browsing or searching for shows, posting comments, sharing clips and viewing settings will incur data usage charges."

Verizon's decision to zero rate its own streaming video services comes on the heels of the company's launch of something it's calling "Free Bee sponsored data." Under that program, companies can pay Verizon to have specific content (like a single video) or entire websites or apps cap-exempted. Between Free Bee and this week's announcement, Verizon's apparently decided to show the public just how little of a shit it gives about net neutrality advocate concerns.

Of course Verizon's simply following on the heels of related zero rating efforts by AT&T, Comcast, and T-Mobile. AT&T's been testing a sponsored data program for a few years now. T-Mobile's Binge On service exempts streaming video services from the company's usage caps, throttling all services to 1.5 Mbps by default. Comcast's also gotten in on the game, exempting its own streaming video service from the company's slowly-expanding usage caps.

We've noted for some time how the practice of zero rating is an absolutely horrible precedent, given that by giving some deeper-pocketed services a leg up, you're automatically putting smaller companies, startups, non-profits, and educational services at a distinct disadvantage. While T-Mobile may have opened the door with a program that skirts the edges of good taste, Comcast and Verizon have walked right through the door, and are downright laughing in the face of net neutrality by exempting their own services from caps.

And again, so far the FCC has done little more than nod dumbly as companies make a mockery of the idea of an open, level Internet. While the FCC says it has fired off some "informal," low-level inquiries asking carriers for more detail, the agency has given absolutely no serious indication that it intends to thwart the practice of zero rating any time soon. The irony of course is that as Verizon's tries to shed its reputation as a stodgy old phone company by desperately wooing Millennials, it's making it abundantly clear the company just can't seem to shed Ma Bell era behavior.

Filed Under: exempt, fcc, go90, net neutrality, streaming video, zero rating
Companies: verizon

India Set To Ban Zero Rating As Facebook's Misleading Lobbying Falls Flat

from the phony-altruism dept

Apparently the millions Facebook has been spending on advertisements, lobbying, marketing and spamming the Indian government will be for naught. The Telecom Regulatory Authority of India (TRAI) appears poised to ban the practice of zero rating as part of its new net neutrality rules, effectively killing Facebook's controversial Free Basics zero rating program once and for all in the country. According to the Times of India, TRAI is expected to deliver the death blow to Facebook's world-domination ambitions within a week:

"Trai will issue an order to this effect within a week, top sources told TOI. The order is also expected to bar free or subsidised data packages that offer access to only a select services, such as Facebook, Twitter or WhatsApp messenger. "These are discriminatory and are against the concept of digital democracy. We will not allow them," a source said. The regulator's stand will clear the confusion over net neutrality. There were apprehensions over the manner in which free Internet was being offered, after the introduction of some zero-rated platforms with preferential treatment to a few websites for a fee."

India would join Japan, The Netherlands, Chile and Slovenia in banning zero rating entirely, based on the idea that cap exemption gives some companies a leg up, and unfairly distorts the inherently level Internet playing field.

That's something the FCC refused to do here in the States, and as a result we're witnessing telecom carriers rushing toward who can be the most "innovative" in the zero rating space. AT&T and Verizon are now formally charging companies for premium, cap-exempt status, T-Mobile is throttling every shred of video that touches its network to 1.5 Mbps (and lying about it), and Comcast is now exempting its own streaming video service from usage caps, much to the chagrin of smaller streaming competitors. So far, the FCC's response has been to nod dumbly.

In India, Facebook (lead by former FCC boss and neutrality waffler Kevin Martin), has been engaged in a blistering media and lobbying campaign to convince India that a curated walled garden run by Facebook was a great way to help the nation's poor farmers. Indian activists and critics like Mozilla disagreed, arguing that the company was simply hiding its lust to control emerging ad markets under the banner of altruism, and if Facebook really wanted to help India's poor, it should focus on improving the country's actual Internet infrastructure.

Facebook's initial response was to call critics of the company's program extremists who were hurting the poor (despite many of the critics being local Indian activists who've dedicated a lifetime to that task). When that didn't work, Facebook changed the name of the program, and filled local newspapers with full-page editorials by CEO Mark Zuckerberg declaring the company's sole interest was poor farmers, not cornering developing ad markets. When people didn't buy that, Facebook tried tricking its users (including those in the U.S. and UK) into spamming the Indian government.

It appears to be that last effort that may have pushed TRAI over the edge (you can read TRAI politely trying to ask Facebook (pdf) to prove the 11 million bogus supporters of Free Basics actually exist). Assuming TRAI follows through on reports, Facebook's now forced to do what many critics wanted all along: actually put all of the money spent on lobbying and marketing Free Basics -- into actually helping shore up India's lagging telecom infrastructure.

Filed Under: broadband, india, internet basics, net neutrality, trai, zero rating
Companies: facebook

New Report To FCC Details How Binge On Violates Net Neutrality

from the and-john-legere-will-respond-with-curses dept

Stanford Law professor Barbara van Schewick, one of the leading scholars on net neutrality, has filed a report with the FCC detailing how T-Mobile's Binge On clearly violates net neutrality. As we've been highlighting, Binge On has numerous problems when it comes to net neutrality, and appears to clearly violate some of the FCC's rules. There's also the fact that T-Mobile flat out lied about it and claimed that it was "optimization" when it's really throttling.

The 51-page report by van Schewick details the problems with Binge On in great detail, noting that it falls afoul of the FCC's transparency rules, that it unfairly picks winners and losers and that it harms competition. The core argument:

Binge On undermines the core vision of net neutrality: Internet service providers (ISPs) that connect us to the Internet should not act as gatekeepers that pick winners and losers online by favoring some applications over others. By exempting Binge On video from using customers’ data plans, T-Mobile is favoring video from the providers it adds to Binge On over other video.

T-Mobile says that it does not intend to become a gatekeeper on the Internet: It says Binge On is open to all legal video streaming providers at no cost, as long as they can meet some “simple technical requirements.” The idea is that any discriminatory effects of Binge On disappear as more providers join the program. However, the technical requirements published on T-Mobile’s website are substantial. They categorically exclude providers that use the User Datagram Protocol (UDP), making it impossible for innovative providers such as YouTube to join. They discriminate against providers that use encryption, a practice that is becoming the industry standard. While some providers can join easily, a significant number will need to work with T-Mobile to determine whether their service can be part of Binge On. Many will have to invest time and resources to adapt their service to T-Mobile’s systems. The smaller the provider, the longer it will likely take for T-Mobile to get to it.

The result: Binge On allows some providers to join easily and creates lasting barriers for others, especially small players, non-commercial providers, and start-ups. As such, the program harms competition, user choice, free expression, and innovation.

What's perhaps even more interesting is that van Schewick includes in the report alternatives that T-Mobile could have adopted that would have created similar plans that actually benefit consumers without messing up net neutrality:

Binge on in its current form violates net neutrality. However, T-Mobile could offer alternative innovative plans that benefit customers and allow the ISP to compete without violating net neutrality. For example, T-Mobile could offer customers a zero-rated low-bandwidth mode at the same speed as Binge On, but contrary to Binge On, customers would be able to use this mode to watch video or do anything else online. It would be their choice.

Alternatively, T-Mobile could allow customers unlimited access to the entire Internet after customers reach their cap, just at a slower speed – the same speed currently offered through Binge On. After reaching their cap, customers could watch video or do anything else online; again it would be their choice. This option offers customers truly unlimited video, unlike Binge On. Contrary to advertising, Binge On video is limited: Customers can watch video included in the program only until they reach their monthly data cap through other Internet uses that are not zerorated. As such, advertising Binge On as “unlimited” video might violate the FCC’s transparency rule, which requires ISPs to accurately describe their service. In contrast, this alternative option would allow T-Mobile to offer “unlimited video streaming” that stands up to its name and respects net neutrality.

Finally, T-Mobile could increase the monthly data caps on its capped plans to account for the average amount of video that people are watching. Customers could use that additional bandwidth to do anything online, including watching video. Again, it would be their choice. All of these alternative plans are entirely consistent with net neutrality.

Of course, the remaining question is still the really big one: will the FCC actually do anything about Binge On... Van-Schewick-2016-Binge-on-Report-20160129

Filed Under: barbara van schewick, bingeon, fcc, john legere, net neutrality
Companies: t-mobile

Netflix Applauds T-Mobile's Binge On, Forgets It Opposed Zero Rating Just Last Year

from the principles-for-sale dept

Last year, you might recall that Netflix took some heat for striking zero rating deals with Australian ISPs, exempting Netflix content from broadband usage caps. Australia was a relatively unique scenario in that the cost of transit is so high, most big content services had struck similar deals, and Netflix didn't want to put itself at a disadvantage in the newly launched Australian market by stubbornly holding on to neutrality principles. Still, it's worth recalling what Netflix said after a few weeks of criticism:

"Data caps inhibit Internet innovation and are bad for consumers. In Australia, we recently sought to protect our new members from data caps by participating in ISP programs that, while common in Australia, effectively condone discrimination among video services (some capped, some not). We should have avoided that and will avoid it going forward. Fortunately, most fixed-line ISPs are raising or eliminating data caps in line with our belief that ISPs should provide great video for all services in a market and let consumers do the choosing."

And what it specifically said about zero rating content:

"Zero rating isn't great for consumers as it has the potential to distort consumer choice in favor of choices selected by an ISP."

Fast forward to 2016, and Netflix is suddenly throwing its support behind T-Mobile and its controversial Binge On zero rating program. Speaking on the company's earnings call this week, Netflix CEO Reed Hastings praised Binge On, which throttles every shred of video that touches the T-Mobile network to 1.5 Mbps, whether or not consumers or content partners asked it to. According to Hastings, he's thrilled about the program because it has driven more usage to Netflix:

"It’s voluntary to the customer. Every customer of T-Mobile can decide to turn it on or turn it off," Hastings explained on an earnings call today. "They’re not charging any of the providers. It’s an open program. Many of our competitors such as Hulu and HBO are in the program also." Netflix may be more inclined to defend this program because the company benefits from it: Hastings says that Netflix is seeing more viewership from T-Mobile customers — no surprise since it makes "unlimited video consumption possible." Hastings added that he hopes these kinds of programs expand further."

But as the EFF has pointed out, the fact that users can opt out is irrelevant. T-Mobile's been throttling every shred of video that touches its network to 1.5 Mbps (streamed or direct downloaded) by default, and then lying about it. Critics like YouTube and the EFF have, quite correctly, pointed out that such a program should be opt-in, for both consumers and content partners. The other problem is simply one of precedent; let T-Mobile dick about with how content gets treated, and that opens the door to every carrier modifying traffic to their own benefit.

By refusing to ban zero rating outright, the FCC has opened the door to a flood of similar ideas that are even worse and, cumulatively and aggressively, are eroding the idea of an open Internet. Worse, it's happening to the thunderous applause of some consumers, who think they're being given a gift when an ISP imposes utterly arbitrary usage caps, then graciously allows select content to bypass said caps. Make no mistake though; the act of fucking about with traffic in this fashion is an assault on net neutrality. That many people don't understand this yet (or are eager to ignore the fact when it benefits them) doesn't magically make it less true.

A few years ago, Netflix's Hastings went on a Facebook rant about how Comcast was unfairly letting its own streaming services bypass the company's usage caps. But now that Netflix is seeing benefits from zero rating, it's apparently willing to throw its principles in the toilet. Netflix may want to be careful where it treads. As some companies have discovered, zero rating isn't your friend -- and the special treatment that benefits you today may come back to bite you tomorrow.

Filed Under: binge on, bingeon, net neutrality, streaming video, throttling, zero rating
Companies: netflix, t-mobile

Here's Verizon's Shiny New Assault On Net Neutrality

from the not-with-a-bang-but-with-a-whimper dept

Verizon has joined the chorus of companies testing the FCC's willingness to enforce its own net neutrality rules. The telco just unveiled something it's calling FreeBee sponsored data, which effectively lets content companies pay to have their content exempt from wireless user usage caps. Much like AT&T's controversial sponsored data service, the service makes a mockery of net neutrality in that it lets companies pay to give their content a leg up in the marketplace, putting other competitors at a distinct disadvantage.

According to a Verizon press release, companies can either pay Verizon to have their entire app or website exempted from usage caps (paying Verizon for each byte consumed), or pay Verizon a lump sum to have specific content exempted from usage caps (a video, a single audio file, or an app download). This is, according to Verizon, a wonderful way to add "value and utility" to the overall consumer experience:

"With 1 in 3 Americans now watching videos on their smartphone, and another 100 million on tablets, the business case for mobile is clear," said Colson Hillier, vice president, Consumer Products at Verizon. "In today's digital economy, FreeBee Data is a departure from the one size fits all approach to marketing. The opportunity to add value and utility to consumers' everyday experiences will fundamentally transform how brands and businesses connect with their customers."

Right, well, no.

While these zero rating efforts are pitched to oblivious consumers as akin to "free shipping" or "1-800 numbers for data," they've been rightly lambasted by critics as a mammoth distortion of the traditionally-level Internet playing field. Whereas deep-pocketed companies can gain marketing advantage by throwing money at Verizon for cap-exempt status, smaller competitors, startups and non-profits won't enjoy the same luxury. Not only does sponsored data give wealthier, bigger companies an unfair advantage, it gives companies like Verizon (with a generation of documented anti-competitive behavior under its belt) far too much power.

Unlike numerous other countries (Norway, Chile, Netherlands, Japan, Slovenia), the FCC chose to specifically avoid banning zero rating, instead stating it would act on a "case by case basis" to determine what's anti-competitive, and what's just creative marketing and pricing. That has opened the door to companies being allowed to brutally violate net neutrality, provided they're just marginally clever about it.

Comcast, for example, is now exempting its own streaming service from its usage caps, claiming that it doesn't violate net neutrality because it's "delivered over Comcast's managed IP infrastructure" and not the actual Internet. T-Mobile's now throttling every video service that touches its network by default (and lying about it), but claims this is ok because users can opt out. AT&T and Verizon, meanwhile, are simply letting giant companies pay if they want to gain an utterly unfair competitive advantage over smaller, more shallow-pocketed competitors.

And so far the FCC's response to these practices has ranged from praising them to weak-kneed promises that the agency is conducting notably informal inquiries. And while it's entirely possible the FCC wants to see if its neutrality rules withstand ISP lawsuits before leaning on them too heavily, it's also entirely possible the regulator is simply too timid to actually enforce the rules the public demanded it pass.

Filed Under: data caps, fcc, freebee, net neutrality, sponsored data, zero rating
Companies: verizon