On September 10, 2012, the FCC filed its brief in the appeal of the Open Internet Rules. The FCC defended the rules, arguing that openness is critical to the success of the Internet and that threats to openness justify the rules. The FCC outlined a long history of regulation, from the rules applied to computer-based networks in the 1980s to the requirement in Section 706(b) that the FCC “encourage the deployment on a reasonable and timely basis of advanced telecommunications capability to all Americans” by promoting competition. It also cited other statutory authority, such as over spectrum licenses, universal service, and to protect competition in video distribution. In addition, the FCC also argued that an open Internet drives investment and economic growth. Finally, the FCC identified the threats to an open Internet, which include providers favoring their services over competing services, providers demanding additional compensation to allow priority access to edge providers, and the risk of a provider downgrading traffic to companies that do not pay for priority access. Verizon and MetroPCS must file reply briefs by October 24, 2012. Verizon Wireless v. FCC, Case No. 11-1355 and consolidated cases (D.C. Cir.).