Network Management Policy

1. Purpose

Headfirst Communications LLC (“HFC,” “we,” “our,” or “us”) operates broadband Internet access services for residential and business customers. This Network Management Policy describes the practices HFC uses to operate, maintain, secure, and protect its network while providing reliable Internet access to customers.

2. General Network Philosophy

HFC’s goal is to provide open access to the Internet without unreasonable discrimination between lawful applications, services, devices, or content.

HFC does not intentionally block lawful Internet traffic except when necessary to:

• Protect network integrity;
• Mitigate security threats;
• Comply with legal requirements; or
• Prevent abuse of shared network resources.

3. Congestion Management

HFC monitors utilization across network infrastructure to ensure reliable operation. Under normal operating conditions, HFC does not throttle or prioritize specific lawful applications or protocols.

If network congestion occurs, HFC may implement reasonable network management measures, including:

• Temporary traffic shaping;
• Rate limiting of specific subscribers causing network impairment; or
• Prioritization of network control traffic necessary for service operation.

Such measures will be applied only as necessary to maintain network stability and service availability.

4. Network Performance

Actual customer performance may vary based on factors including:

• Customer equipment;
• Wi-Fi performance;
• Local network conditions;
• Internet destination performance;
• Upstream provider performance; and
• Peak usage periods.

Advertised speeds represent the maximum service speed purchased and are not guaranteed at all times unless specifically stated in a written service agreement.

5. Application and Protocol Neutrality

HFC does not intentionally block, throttle, or degrade lawful Internet applications based solely on:

• Content;
• Application type;
• Protocol;
• Service provider; or
• Device manufacturer.

6. Security Measures

To protect customers and the network, HFC may:

• Filter malicious traffic;
• Block known malware command-and-control systems;
• Mitigate denial-of-service attacks;
• Restrict spoofed network traffic;
• Prevent unauthorized access attempts; and
• Filter traffic that threatens network integrity.

7. Abuse Prevention

HFC may investigate or restrict traffic associated with:

• Distributed denial-of-service attacks;
• Spam operations;
• Malware distribution;
• Network scanning;
• Unauthorized access attempts; or
• Activities prohibited by HFC’s Acceptable Use Policy.

8. Email Services

HFC does not currently provide hosted email services. To reduce abuse and spam originating from customer networks, HFC may restrict outbound SMTP traffic on TCP port 25.

Alternative mail submission ports such as TCP 465 and TCP 587 are generally unaffected.

9. DNS Services

HFC may provide recursive DNS resolver services for customer convenience. Customers may use HFC-provided DNS servers, third-party public DNS providers, or their own DNS infrastructure where permitted by their service plan.

10. DDoS Mitigation

HFC reserves the right to implement mitigation measures when customer traffic threatens network stability. Mitigation techniques may include traffic filtering, rate limiting, blackholing, upstream mitigation services, and temporary service restrictions.

11. Customer Equipment

Customers are responsible for the operation and security of customer-owned equipment connected to the HFC network.

HFC may disconnect or restrict equipment that:

• Causes harmful interference;
• Generates malicious traffic;
• Impairs network operations; or
• Violates applicable laws, regulations, or HFC policies.

12. Service Prioritization

At this time, HFC does not sell paid traffic prioritization services. HFC does not prioritize Internet traffic based on payments received from content providers, application providers, or websites.

13. Changes to Network Management Practices

Network management practices may evolve as technology, security requirements, regulatory requirements, and customer demand change. Material changes will be reflected in updates to this policy.