At the outset, we find the abstract category of “general-purpose computing device”
unnecessary and legally confusing. Any computing ecosystem that includes an app store of
appropriate scale supporting 3rd party applications for user download should fall within the
rules, regardless of how the end device is characterized. We would not support carve-outs
for any device category that uses app stores. Developers, much less lawmakers, cannot
always interpret what kind of device might be used with their app, and should not be
required to parse the law to determine their rights and obligations. To call a mobile device
“general purpose” belies the fact that its primary function is regulated under the FCC’s
rules – a burden no other general-purpose computer must bear.
