[natch]

"Let me be clear: we need a bright-line, per se rule against discrimination, access fees, and paid prioritization on both mobile and fixed."

It would be hard to be less clear than this. When you have a comma-separated list of things you want a rule against, you need to either repeat the word "against" or risk having people at the FCC, who may just be dumb enough to make the mistake, think that you mean you want a rule against only the first thing you mention.

A naive reading of this (again, this is the FCC) would be that you mean we DO need access fees and paid prioritization, which I guess is the opposite of what you mean.

[jdoliner]

I think it's pretty unlikely that the FCC is going to try to follow this letter exactly only to make a semantic slipup like the one you describe. I don't know why you think the people at the FCC are dumb. They do seem to be an organization with several conflicts of interest, but I think they're capable of figuring this sentence out.