Dear Sir/Ma'am
I am writing in regards to the consultation paper on OTTs put up online by TRAI. Below are my answers to your 20 questions.
1. OTTs should not be brought under any regulatory framework at present. the only regulatory law that should eb apssed is a net neutrality law which will prevent any discriminatory practice on part of TSPs to improve the ratings of their own applications over the OTTs
2. The above point is valid also for any OTTs offering communication services (voice, messaging and video call services) through applications
3. TSPs provide us with data and in my opinion any suppsoed impact is duly compensated by the data charges of these TSPs. These charges are already high and any attempt to regulate OTTs will only allow such TSPs to exploit the consumers dependence on the OTTs services.
4. OTTs also should not be allowed to pay any TSPs directly as this will allow TSPs room to favour a higher paying OTT over another OTT in the same sector. Eg. If Meru and Ola paid different prices then the TSP could choose to give the higher paying company more bandwidth affecting consumers ability to access the other OT.
5. I don't think there any imbalances in the regulatory
environment in the operation of OTT players.
6. Indian cyber laws or another EXISTING relevant law should apply to OTTs. Any data that a OTT collects should be confidential.
7. OTTs offering services need to include a confidentiality clause in their Terms of Agreement which states that no data that is collected in performance of the application will be shared with any third party in any form.
8. I think we should take up the following EU practice as mentioned in my next sentences if we are seeking to carry out any regulation. The European Union (EU) approved new rules aimed at
guaranteeing equal access to the internet and cutting cell phone charges.
9. I am supportive of net neutrality. TSPs should not be able to control or limit an OTTs or a consumers' access to the internet.
10. There are NO forms of discrimination that is allowable.
11. Yes TSPs should publish any traffic management techniques they use to manage OTT traffic.
12. TSPs will always charge customers for any upgrading or new service tehey provide. To think that a TSP will provide a service for free or at a loss is naive and unrealistic.
13. No non-price discrimination practices should be allowed.
14. There is NO justification for allowing differential pricing
for data access and OTT communication services
15. No they shouldn't
16. I have no idea
17. no comment.
18. there is no need to regulate subscription charges for
OTT communication services
19. No steps should be taken by the Government for
regulation of non-communication OTT players
20. Nothing
Please consider this my official submission.
best
Marianne