Authored by Yochai Benkler. Market evidence suggests that unlicensed wireless strategies are becoming the primary approach for implementing wireless communications technology. Actual market deployments of wireless technologies suggests that unlicensed follows the innovation model of the Internet, applied to wireless communications. Licensed-spectrum, by contrast, replicates the telephone system model. […] The most immediate implication is that any authorization for the FCC to conduct incentive auctions, and any plans to permit civilian use of federal spectrum, should include substantial discretion for the agency to provide adequate room for unlicensed strategies to develop new generations of innovation.