Over 1.3 million additional pro-net neutrality comments submitted to the Federal Communications Commission (FCC) appear to be coming from non-U.S. filers from foreign countries, according to a new analysis released today by the National Legal and Policy Center (NLPC), a leading government watchdog.

A forensic analysis of comments received between July 3rd and Net Neutrality “Day of Action” on July 12th shows that the FCC was flooded with 1.3 million comments from addresses in France, Russia and Germany. This time the comments came almost exclusively from the email domains Pornhub.com and Hurra.de (Germany). As with NLPC’s previous analysis, thousands of the comments appear to come from fake email addresses and fake physical addresses overseas.

NLPC’s latest analysis of foreign comments flooding the FCC docket matches similar patterns found in our previous analysis and some new patterns as well:

325,076 comments were submitted from Germany

325,528 comments were submitted from one Russian address: (улица Полевая кв. 391 Челябинск, Россия)

102,192 comments were submitted from France

476,937 comments were submitted from the U.S. but entered into the system as “international filer”.

Additionally, more than 1 million of the comments had an email addresses with a Pornhub.com domain extension.

Roughly 19,116 comments followed the same pattern as previous comments submitted into the docket utilizing domain extensions generated by what appears to be an online fake email generator program.

Click here to download a 4-page pdf containing examples of the public comments.

“As we have noted in our previous two analyses, the gaming of the comment submission process continues and in fact appears to have reached epidemic proportions,” said National Legal and Policy Center President Peter Flaherty. “Pro-net neutrality supporters like Fight for the Future reported generating more than 2 million comments into the FCC’s docket during the Day of Action. However, our analysis shows that more than half of the comments generated in the past two weeks appear to be fake, utilizing fake email addresses fake domains such as Pornhub.com, addresses that are clearly foreign, and hundreds of thousands which even use Cyrillic characters.”

“At this point, the deception appears to be so massive that the comment process has been rendered unmanageable and meaningless,” said Flaherty. “More ominously, with hundreds of thousands of comments appearing to come from Russia, we must ask ourselves whether once again, Russian interests are attempting to sow chaos in U.S. official policymaking proceedings.”

In June, Democrat U.S. Rep. Frank Pallone called for a full investigation of a handful of allegedly fake comments submitted by anti-net neutrality supporters, but has yet to call for a similar investigation into what now appear to be millions of fake comments submitted from Russian and other overseas addresses. “We call on Representative Pallone to condemn the gaming of the FCC comment process by the filing of millions of pro-net neutrality comments that are clearly fake,” Flaherty concluded.