Last week LLFCC published a playful little piece: "Faux Celebrity FCC filings on the rise." Overnight it became the blog's most popular story, logging more hits in less time than anything else on the site. It also generated several interpretations with which I disagree.

The "Faux" article disclosed something that I've noticed over the last year or so. Every now and then some wag files comments with the FCC using the name of a famous person: Donald Trump, Paris Hilton, even Leon Trotsky, Joseph Stalin, George W. Bush, and Jesus Christ. The filings often mangle some auto-comment available on the Web site of a public interest or lobbying group.

They can be pretty funny, too.

"I'm a dead Communist, but I don't want to pay more for my telephone service!" declared "Leon Trotsky" in an FCC comment submitted in March of 2005 regarding a Commission proposal to boost Universal Service Fund rates.

So I compiled all these comments into a story, posted it, and sent it to the mother of all media regulation sites: Techdirt, whose lead writer Mike Masnick generously mentions my blog from time to time.

He ran with the story. "Did Paris Hilton, Donald Trump, Joseph Stalin, Leon Trotsky And Jesus All File Complaints With The FCC?" Masnick's posting asked.

"While it's all rather amusing, it does point out how silly it is for the FCC to take some of these filings seriously," he concluded. "Too many of them are simply generated by lobbying campaigns, rather than real people."

Once the story appeared on Techdirt, it really got around. The next thing I knew, one of the smartest people in telecommunications policy was writing about it: Adam Thierer of the free market oriented Progress and Freedom Foundation.

"The whole process has become a complete joke," Thierer concluded after summarizing my story.

"Some of my research on the FCC's indecency complaint process has illustrated how one group—the Parents Television Council (PTC)—has essentially been able to stuff the complaint ballot box at the FCC by filing endless strings of computer-generated complaints from its website. The PTC then fires off letters to the FCC and Congress that essentially say, 'Look! Millions of Americans out outraged by the content on TV and are clamoring for regulation!' In turn, that nonsense gets included in the congressional record when legislation is introduced, and politicians claim 'the American people have spoken' and are overwhelming in favor of regulation."

" . . . we shouldn't allow the FCC or Congress to lean on the bogus 'public record' to justify expanding government regulation," Thierer concludes.

While I'm glad that Thierer enjoyed my piece, there are several problems with his spin on my blog, I think. The first is just a matter of record: Some of the bogus filings I cited did not call for regulation. They called for deregulation, protesting against the expansion of the Universal Service Fund, anti-piracy rules, and FCC style censorship. It's not accurate to characterize all this stuff as coming from one perspective, because it doesn't.

Second, just because somebody with a wicked sense of humor files a comments doesn't mean that the FCC shouldn't take their perspective seriously. Unlike the individuals who just go with some public interest Web forms' autotext, these folks actually took the time to edit the script and express their own individuality. And maybe they had some good reason to file anonymously. Does that mean their voice doesn't count?

Finally, although in writing a final Order on some issue the FCC should obviously privilege more informed and detailed comments, I'm sure that most of the time real people do submit these auto-comments. The Media Access Project's Harold Feld offers a sensible way to think about these filings. He calls his system the "Alice's Restaurant" rule of brief comments.

"If one commentor says 'my media sucks because of consolidation,' that's an outlier and you ignore it. If two people file, 'my media sucks because of consolidation,' then it's just tree huggin' liberals and you ignore it. But if two million people file such comments, that's data—because we've demonstrated enough people care to at least make a minimal effort to express their feelings."

The Technology Liberation Front reposted Thierer's blog on my blog, and Dan Isset of the Parents' Television Council responded:

"With all due respect, complaints filed with the FCC via the Parents Television Council website are not 'computer generated' any more so than any message sent to Capitol Hill or elsewhere via any similiar online communications service (ie Capwiz or Voter Voice). Indeed such communications are generated by individual Americans - aka the owners of the broadcast airwaves - who have a right to petition the government for a redress of grievances. Surely you're not suggesting that the voices of hundreds of thousands of Americans should be silenced simply because you don't like what they say or the method by which they communicate with their government?"

So the question before us, perhaps, is not about discounting certain forms of communication to the FCC, but about prioritizing them. I think that if the FCC made it easier for individuals to file proceeding comments directly with the Commission, the agency would receive a much higher quality of comment. I've made some suggestions in this area myself.

But what LLFCC wants to make clear here is that I didn't write that "Faux Celebrities" story to discredit the millions of Americans who contact the FCC in one way or another. Truth be told, I posted it just for fun.