-- Barbara van Schewick, Stanford Law School; and
-- Tim Wu, Columbia Law School.
They've all "spent many years devoted to research on the architecture of the Internet and its related policies (and) published widely on" Net Neutrality.
On November 2, they emailed Chairman Genachowski to "flag what (they) believe are two (serious) ambiguities in the Notice that (they) hope can be addressed early to provide a clearer foundation for comments:"
For nearly a century, this has been a central concept in telecommunications law and policy. Nothing should be done to subvert it, so a clear definition is essential. So far, it's "surprisingly narrow."
"Reasonable Network Management"
It's a significant ambiguity because what's not reasonable is "key to the entire rule."