The Cooperative Association for Internet Data Analysis (CAIDA) would like to take this opportunity to comment on the quality of the data underlying evaluation of the proposed MCI-Worldcom merger. CAIDA is a collaborative undertaking by industry and government to promote greater cooperation in the engineering and maintenance of a robust, scalable global Internet infrastructure. CAIDA provides a neutral framework for competitors to work together to address current and future operational and engineering requirements of the commercial Internet. CAIDA's current focus is on developing and deploying traffic measurement and analysis tools to support engineering level decision-making and related collaborations.

The views presented below concern the inadequacies of the data upon which the Federal Communications Commission (FCC) is basing its Internet-related decisions and the industry-wide failure to acquire and analyze basic traffic statistics in support of business, operational, and regulatory decisions affecting the Internet. We [CAIDA] are not qualified to reflect on the economic merits or business implications of the proposed merger, and question the ability of any party, including the FCC, to make thoughtful decisions in this matter given the poor quality of the data and analyses associated with the commercial Internet.

The lack of reliable traffic information is ubiquitous in the Internet sector. The absence of detailed engineering-level data directly affects the quality of Internet service providers' operational and capacity decisions, the ability of government to make well-reasoned regulatory and economic decisions, and the ability of Internet hardware and software vendors to develop adequate specifications for future products. The current MCI-Worldcom discussions provide an important opportunity for the FCC, as well as the Internet service providers and suppliers, to take steps to ensure that future decisions will be based on a detailed understanding of the facts and trends underpinning this strategic industry.