Network Management Policy

Antietam Broadband (“We”, “Our”, “Us”) provides this Network Management Policy (“Policy”) in accordance with Federal Communications Commission (“FCC”) requirements to disclose certain network management practices, performance characteristics, and commercial terms. Additional information about our broadband policies and practices is available at AntietamBroadband.com.

Network Practices

We engage in network management practices that are tailored and appropriate for achieving optimization on our network considering the particular network architecture and technology of our broadband Internet access service. Our goal is to ensure that all our customers experience a safe and secure broadband Internet environment that is fast, reliable, and affordable. We want our customers to experience all the Internet offers, whether it is social networking, streaming videos, listening to music, or communicating through email and videoconferencing.

Our network practices include congestion- and security-protocol-management. Such protocols and practices generally will not impact our customers’ user experience. We manage our network using various tools and industry-standard techniques to ensure fast, secure, and reliable Internet service.

1. Blocking: We do not block or discriminate against lawful Internet content, applications, services, or non-harmful devices. We conduct only reasonable network management.
2. Throttling: We do not throttle, impair, or degrade lawful Internet traffic based on content, application, service, user, or use of a non-harmful device. We engage in only reasonable network management practices.
3. Affiliated Prioritization: We do not favor any Internet traffic over others, including through the use of techniques such as traffic shaping, prioritization, or resource reservation, to benefit an affiliate, and we have no plans to do so.
4. Paid Prioritization: We do not favor or prioritize any Internet traffic over others, and we do not prioritize Internet websites over others in exchange for any consideration to benefit any content, applications, services, or devices.

Network Management Practices

Our network management practices are intended to ensure that we provide our customers with the best possible Internet access. We do not inspect traffic for any other purposes other than to keep track at the network level, where traffic flows ensuring that the network is adequate for the demands of customers. To achieve this goal, we employ network management techniques such as identifying spam and preventing its delivery to customer email accounts, detecting malicious Internet traffic, and preventing the distribution of, or inadvertent access to, malware, phishing, viruses, or other harmful code or content.

1. Congestion Management

Our Internet network is a shared network, consistent with industry standards. This means customers share upstream and downstream bandwidth. The goal of our congestion management practices is to enable better network availability and speeds for all our customers by:

• Adapting and upgrading our network to maintain or improve network performance as demand for our Internet service increases.

• Adapting and upgrading our network to maintain or improve network performance as demand for higher bandwidth applications increases.

• Identifying potential bandwidth abusers.

Because our Internet service network is a shared network, periods of high network demand may result in Internet traffic congestion. Our network monitoring practices are continually conducted, and adjustments are made accordingly to provide our customers with the best possible experience. Congestion tends to occur during periods of peak demand for higher bandwidth applications. Generally, the frequency of congestion tends to increase from 7 pm to 11 pm, especially on Friday and Saturday nights and holidays.

Our network and congestion management practices do not discriminate based on the type of application being used, nor are they based on any particular customer’s aggregate monthly data usage. We examine only current network conditions, not our customers’ online activities. We also check for abnormal traffic flows, network security breaches, malware, loss, and damage to the network. If a breach is detected or high-volume users are brought to light by complaint, we provide notification to the customer via email or phone.

If we take any congestion management actions, the vast majority of our customers’ Internet activities will be unaffected. Some customers may, however, experience more extended download or upload times or slower surf speeds.

2. Application-Specific Behavior

Except as may be provided elsewhere herein, we do not engage in any application-specific network management activities on our network. We do not inhibit or favor applications or classes of applications over our High-Speed Internet/broadband data network. All traffic is treated in a “protocol-agnostic” manner, which means management is not based on applications and is also content neutral. We do not block or rate-control specific protocols or protocol ports, modify protocol fields, or otherwise inhibit or favor certain applications or classes of applications.

3. Device Attachment Rules

While we do not have specific device restrictions, to use our Internet service, a customer must have a gateway device that includes a Network Interface Card (“NIC”). If a customer or potential customer believes they have an unusual configuration, our help desk team will assist the customer in determining if there is an equipment compatibility problem.

For best results, modems, wireless modems, or other proprietary network gateways used on our broadband network should be provided by us. Customers may, however, attach their own devices to their modems, including wired or wireless routers, laptops, desktop computers, video game systems, televisions, or other network-enabled electronics equipment. Customers are responsible for ensuring that their equipment does not harm our network or impair other customers' service. We are not responsible for the functionality or compatibility of any equipment provided by our customers. Customers are responsible for securing their own equipment to prevent third parties from unauthorized access to our broadband network and will be held responsible for the actions of such third parties who gain unauthorized access through unsecured customer equipment. If we discover a customer device is harmful to our network, we have the right to request that the customer remove such device.

For any questions regarding the types of devices allowed or required, customers should contact cx-ab-cs-sales@myactv.net. While there are no formal approval procedures to get a specific device approved for connection to the network all devices must be UL certified and carry the FCC Part 64 certification.

4. Security

We know the importance of securing our network and customers from network threats and annoyances. As normal practice, we do not block protocols, content, or traffic for network management, but we may block or limit traffic such as spam, viruses, malware, or denial-of-service attacks to protect network integrity and the security of our customers.

We use the following practices to ensure end-user security and network security:

• Employ S-Flow –This protocol attaches an identifier for all traffic on the network. S-Flow captures the source and destination of all traffic, allowing us to engineer and troubleshoot the network properly.

• Implement DDOS mitigation software which blocks malicious attacks that intend to disrupt service from the internet to our network.

• Utilize Anti-Spoof software, which is intended to identify and isolate one user’s hardware from impersonating another user’s hardware.

• Utilize the industry practice of blacklisting and blocking access from other Internet service provider networks that are spreading malicious software.

• Utilize these protocols and practices to protect and secure our customer data and network for the benefit of all customers. These protocols allow us to comply with federal CALEA and other Law Enforcement requirements.

These tools and practices may change from time to time to keep up with changing network technologies and new and innovative ways our customers use the network.

We continually monitor our network. In the event of a security breach, an alarm would trigger. We will react to the network intrusion and will refer to Law Enforcement Agencies as needed.

Customer conduct that abuses or threatens our network or violates our Acceptable Use Policy, Subscriber Agreement, or other policies will be asked to stop immediately. If a customer fails to respond or cease such conduct, we may suspend or terminate that customer’s service.

Additionally, Users are prohibited from violating or attempting to violate our security, including, without limitation, (a) accessing data not intended for such User or logging into a server or account which such User is not authorized to access, (b) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization, (c) attempting to interfere with, disrupt or disable service to any user, host or network, including, without limitation, via means of overloading, flooding, mail bombing or crashing, (d) forging any packet header or any part of the header information in any E-mail or newsgroup posting, or (e) taking any action in order to obtain services to which such User is not entitled. Violations of system or network security may result in civil or criminal liability. We may investigate occurrences that may involve such violations, and we may involve and cooperate with law enforcement authorities in prosecuting Users who are alleged to be involved in such violations.

Performance Characteristics

1. Service Description

Our Internet service products enable residential and commercial customers to access all lawful content, applications, and services of their choice available on the Internet. We offer Internet service over Digital Subscriber Line (“DSL”), Data Over Cable Service Interface Specification (“Cable”), Fixed Wireless, and Fiber-to-the-Home (“FTTH”). Information about our different service offerings can be found at AntietamBroadband.com.

All of our Internet services can support typical real-time applications, including messaging, voice applications, video chat applications, gaming, and Internet video. If users or developers have questions about real-time applications, please contact us at 301-797-5000.

2. Network Performance

We offer customers a variety of Internet service levels/speeds. Each service level is described with the expected maximum transfer speeds associated with it. We test our network routinely to address any issues concerning network congestion. Our goal is to provide the customer with the speeds they have subscribed to.

The speeds we identify for each Internet access service level/speed are the maximum upload and download speeds that customers could experience. We provide and engineer our network to deliver the speeds to which customers subscribe. However, we do not guarantee that a customer will achieve those speeds, as it is possible to experience slower speeds for a variety of factors. Such factors potentially impacting speed include customer equipment, premises wiring, network equipment, congestion in our network, congestion beyond our network, performance issues with an Internet application, content, or service, and more.

Latency is another measurement of Internet performance. Latency is the time delay in transmitting or receiving packets on a network. Latency is primarily a function of the distance between two points of transmission but also can be affected by the quality of the network or networks used in transmission. Latency is typically measured in milliseconds and generally has no significant impact on typical everyday Internet usage. As latency varies based on any number of factors, most importantly the distance between a customer’s computer and the ultimate Internet destination (as well as the number and variety of networks your packets cross), it is not possible to provide customers with a single figure that will define latency as part of a user experience.

Each customer’s actual speed experienced will be based on the service level/speed subscribed to and the factors described above.

The following tables show our internal testing results.

Residential Speeds

3. Impact of Non-BIAS Data Services

The FCC defines Non-Broadband Internet Access Services (“Non-BIAS”) to include services offered by broadband providers that share capacity with Broadband Internet Access Services (“BIAS”) (previously known as “Specialized Services”) also offered by the provider over the last-mile facilities. At this time, we are not offering any non-BIAS data services.

Commercial Terms

1. Pricing

We offer multiple levels of internet service. Our pricing for our different service offerings and other terms can be found at AntietamBroadband.com or here. Prices do not include applicable federal, state, or local taxes and regulatory fees. Prices and packages are subject to change.

2. Privacy Policies

We value the privacy of our internet service customers. Like most companies, we collect certain information about our customers and use it to provide our services. We collect information when our customers interact with us, when our customers use our internet service, and when our customers visit our website. This information is used to deliver, provide, and repair our services and establish and maintain customer records and billing accounts. We protect the information we have about our customers and require those we share it with to protect it. We do not sell, license, or share information that individually identifies our customers with others without your consent, except as necessary when working with vendors and partners for business purposes and when necessary for them to do work on our behalf. Additional details about our Privacy Policy can be found at www.schurz.com/about/privacy-policy.

3. Redress Options

We strive to provide excellent customer service and resolve any issues promptly. If you have questions, complaints, or requests for additional information, please call 301-797-5000 or email us at cx-ab-cs-sales@myactv.net. We take all such questions and complaints seriously.

Suspension or Termination

Any customer which we determine, in our sole discretion, to have violated any element of this Network Management Policy shall receive a written warning, and may be subject at our discretion to a temporary suspension of service pending such customer’s agreement in writing to refrain from any further violations; provided that we may immediately suspend or terminate such customer’s service without issuing such a warning if we, in our sole discretion deems such action necessary. If we determine that a customer has committed a second violation of any element of this Policy, such customer shall be subject to immediate suspension or termination of service without further notice, and we may take such further action as we determine to be appropriate under the circumstances to eliminate or preclude such violation. We shall not be liable for any damages of any nature suffered by any customer, User, or any third party resulting in whole or in part from our exercise of our rights under this Policy. Additional requirements and/or penalties apply as found in our Acceptable Use Policy at https://myactv.net/legal/aup.php.