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Open Internet Disclosure Statement

The Federal Communications Commission (“FCC”) requires that we provide you with the following information regarding MCTV’s mass market retail broadband Internet access services, including information regarding any network management practices that MCTV employs, the performance characteristics of our services, and the commercial terms of our service offerings. The disclosure is intended to provide current and prospective subscribers (“end users”) and providers of “edge” products (i.e., providers of content, applications, service and devices accessed over or connected to MCTV’s broadband Internet access service) with sufficient information to make informed choices regarding the use of such services.

The information provided below applies solely to the portion of our network that provides mass market retail broadband Internet access service. Other portions of our network may be used to provide other services, such as cable or phone service, each of which are subject to their own terms and conditions of service. In addition, MCTV may enter into arrangements to provide Internet service to third party establishments (including coffee shops, bookstores, hotels, libraries, etc.) who then may offer such service to their customers, guests, or others. Nothing herein is intended to address the network management practices, performance characteristics, or commercial terms that may be adopted by such third party premises operators in connection with their provision of Internet service to others.

The information provided herein may be revised from time to time as MCTV deems appropriate and should be read in conjunction with MCTV’s Subscriber Handbook available at www.MCTVOhio.com/legal-notices.

Network Practices:

Congestion Management

MCTV currently offers four levels of Residential and three levels of Commercial Broadband Access. These levels are:

  • 2.5 Megabits per second (Mbps) downstream by 384 kbps upstream
  • 10 Mbps downstream by 1 Mbps upstream
  • 20 Mbps downstream by 1.5 Mbps upstream
  • 50 Mbps downstream by 3 Mbps upstream (residential customers only)

MCTV does not adjust or manage an individual end user’s use of their capacity, but the actual use by an end user can affect the user experience. Downstream refers to the information coming to you from the network and upstream refers to the information going from you to the network. End user experience can be negatively impacted when the end user attempts to run too many tasks simultaneously or by running individual tasks that utilize 100% of the end user’s upstream capacity. For example, uploading large files to cloud-based back up servers may occupy 100% of the end user’s upstream capacity. This could preclude the end user from running other network-related tasks while the file is uploading.

The MCTV network, as a whole, is shared among its users and has a set capacity for downstream and upstream communication. While MCTV will not manage an individual end user’s capacity, MCTV may take action to manage the capacity of the entire network or part of the network if an end user’s actions unreasonably impact the ability of others to use the network. For example, MCTV may employ reasonable network management practices to protect against security or denial of service attacks that can negatively affect our network and may cause service degradation. End users can minimize the possibility of these problems by maintaining an up-to-date anti-virus program on their computer and following common sense practices like avoiding unsolicited attachments from unknown parties.

MCTV wants all end users and edge providers to be able to use the network for all legal purposes at all times. Toward this end, MCTV employs reasonable network management practices to ensure that no single application uses more than 35% of total network capacity. This practice is employed to avoid a single application from overwhelming the network and rendering some end users unable to use the application of their choice or reach the edge provider of their choice. If/when a single application exceeds 35% of total network capacity MCTV monitors that application and may restrict the bandwidth, so as not to overwhelm the network.

Usage Limits

MCTV reserves the right to manage network usage to ensure that the activities of a small number of customers do not degrade, inhibit or interfere with the use of our network. The goal is to ensure that all users have reasonable access to the network at all times. MCTV does not currently enforce specific limitations on the amount of Internet data utilized by its customers through data caps or usage-based billing.

Application Specific Behavior

MCTV does not discriminate against or prevent users of its broadband Internet access service from accessing lawful content or services; running lawful applications and services of their choice; or connecting their choice of legal devices, so long as such applications, services and/or devices do not harm the network or the provision of broadband Internet access service, facilitate theft of service, or harm users of the service. Moreover, MCTV does not impair or degrade specific content, applications, services or non-harmful devices so as to render them effectively unusable, subject to any reasonable network management practices described herein.

MCTV reserves the right to employ reasonable network management practices to prevent specific harmful or illegal activity, such as the dissemination of viruses or other malicious code or the transfer of child pornography or other unlawful content.

Device Attachment Rules

As a courtesy to our customers, MCTV provides customers with a free modem for use with the MCTV network. Customers may utilize this modem or choose to purchase an approved model from a retailer. MCTV requires customers to use modems to connect to its network that are compatible with MCTV’s equipment and services and do not pose the risk of harm to the network. The modem must be a tested and certified 3.0 compliant modem. Information regarding compliant modems may be found at www.MCTVOhio.com/modem-compatability. As technology changes, MCTV reserves the right to update their list of approved models and require the customer to replace a previously-approved modem model that is no longer compatible.

Security

MCTV employs certain practices to ensure the security of our customers and our right to protect our network. These include practices intended to protect MCTV servers against Denial of Service attacks and to prevent harmful elements such as viruses, spam and identity theft. To that end, MCTV blocks a limited number of ports that are commonly used to send spam, perpetrate identity theft or launch attacks on the network.

Port

Reason

tcp/udp 135

Viruses

udp 402

Unsafe Compaq Client

udp 427

Unsafe Service Discovery

tcp/udp 445

Win 2k File Sharing

tcp/udp 548

MacOS File Sharing

udp 1900

Unsafe Universal PnP

tcp 3127

MyDoom Worm

tcp 4444

Blaster Worm

udp 9009

Unsafe LDAP

udp 12345

Common Trojan Port

tcp/udp 27374

Sub7 Trojan

udp 31337

Back Orifice Trojan

udp netbios-ns

Viruses

udp netbios-dgm

Viruses

udp netbios-ss

Viruses

tcp 25(smtp)

Viruses/Spam Relays

icmp echo

Viruses/Hacking Exposure

tcp 80 (www)

Unsafe WWW Port/Viruses

udp 5351

Shadowserver

 

Performance Characteristics

Service Description

MCTV offers their residential and commercial customers a variety of levels of broadband Internet access service tiers with varying targeted speeds and features that may affect the suitability of such service for real-time applications. The features, pricing and other commercial terms of our service offerings are modified from time to time, and not all packages are available in all areas. Each package is priced to reflect the particular speed and features of that package. Full descriptions and pricing information for all currently available packages are available at www.MCTVOhio.com/home-internet-packages and www.MCTVOhio.com/business-internet-packages.

The FCC requires that we disclose information regarding the expected and actual speed and latency of our Internet access service offerings. Latency measures the average time it takes for a data packet to travel from one point on a network to another. It is typically measured by round-trip time utilizing milliseconds. While latency generally does not have a significant impact on day-to-day Internet usage, certain applications may be particularly affected by latency, such as high-definition multiplayer online games.

Our advertised speeds are estimates that MCTV targets to achieve for its customers. MCTV cannot guarantee that a customer will achieve those speeds at all times. The actual speeds achieved by customers may vary based on a number of factors, including but not limited to: (a) the performance and capabilities of customer’s computer; (b) the connection between a customer’s computer and modem, such as the use of wireless routers; (c) variances in network usage; (d) the distance a packet of information must travel from the customer’s computer to its final destination on the Internet; (e) congestion or variable performance at a particular website or destination; or (f) performance characteristics of transmissions over the Internet that are outside of MCTV’s control.

There are a number of available tools online that customers may utilize to measure Internet performance. One of the available tools is operated by Ookla Inc. and is available at mctv.speedtest.net/. Please note that all speed tests have biases and flaws and should be considered a guide rather than a conclusive measurement of performance. Ookla, Inc. reported the following test results for the following service tiers:

 All speeds in Mb/sec

Advertised Service

Latest Test Date

Downstream

Upstream

Latency

2.5/.384

5/31/2016

2.43

0.34

8

10/1

5/31/2016

9.43

1.07

8

20/1.5

5/31/2016

21.02

1.2

9

50/3

5/31/2016

50.25

3.13

8

 

Impact of Specialized Services

The FCC’s “Open Internet” rules distinguish between our mass market retail broadband Internet access and “specialized services” that share capacity with our broadband Internet access services over our last-mile facilities. Examples of these “specialized services” may include MCTV’s home and business phone services which utilize Voice over Internet Protocol (“VoIP”) technology. Use of these services, which are not subject to the same rules as our broadband Internet access services, share bandwidth with our Internet access service and because of the nature of the service may sometimes receive priority on our network. As a result, increased use of these services may affect our broadband Internet access service at certain times. MCTV monitors the impact of these services on our network to minimize their impact on our broadband Internet access service.

Commercial Terms

Pricing

MCTV offers multiple tiers of broadband Internet access service. The current pricing and other terms and conditions of the various tiers, including fees associated with early termination or additional network services is available at www.MCTVOhio.com/home-internet-packages, www.MCTVOhio.com/business-internet-packages or by calling our office.

Privacy Policy

MCTV values the privacy of our customers. The personal information that you provide to MCTV is governed by our Privacy Policy available at http://www.MCTVOhio.com/legal-notices, which is subject to change from time to time.

Redress Options

If you have any questions or concerns regarding your service, please contact our customer service department. Customers may also email us at AskMCTV@MCTVOhio.com.

Written complaints may be sent via U.S. mail to: MCTV, PO Box 1000, Massillon, OH  44648-1000. The FCC has established procedures for addressing informal and formal complaints relating to its “Open Internet” rules. For information concerning these procedures, please refer to the FCC’s website at www.fcc.gov/guides/getting-broadband.