Question 1: Is it too early to establish a regulatory framework for OTT services, since internet penetration is still evolving, access speeds are generally low and there is limited coverage of high-speed broadband in the country? Or, should some beginning be made now with a regulatory framework that could be adapted to changes in the future? Please comment with justifications.
Ans: It is too early, in my opinion. Focus as of now should be on improving the quality of services where we are far behind the world.

Question 2: Should the OTT players offering communication services (voice, messaging and video call services) through applications (resident either in the country or outside) be brought under the licensing regime? Please comment with justifications.
Ans: No. These are apps leveraging on the varied uses of data. There is already enough regulation to monitor data usage. More would just make the market inflexible and regressive.

Question 3: Is the growth of OTT impacting the traditional revenue stream of TSPs? If so, is the increase in data revenues of the TSPs sufficient to compensate for this impact? Please comment with reasons.
Ans: Yes, they are probably being impacted. But I think the inflated prices for data more than compensates for this impact.

Question 4: Should the OTT players pay for use of the TSPs network over and above data charges paid by consumers? If yes, what pricing options can be adopted? Could such options include prices based on bandwidth consumption? Can prices be used as a means product/service differentiation? Please comment with justifications.
Ans: I believe the high charges paid by customers for network and data which are, at best, a couple decades behind the rest of the world, should suffice for the telecom operators.

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.
Ans: I do not agree that imbalances exist. It amounts to saying that we should have to pay over and above what we pay to get the data in order to be able to use it. I think that's unfair.

Question 6: How should the security concerns be addressed with regard to OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such OTT players? And, how can compliance with these conditions be ensured if the applications of such OTT players reside outside the country? Please comment with justifications.
Ans: The OTT players should have to cooperate with the regulations of their operating address (where they have a user base) and not just their legal address (where the company is setup).

Question 7: How should the OTT players offering app services ensure security, safety and privacy of the consumer? How should they ensure protection of consumer interest? Please comment with justifications.
Ans: Please refer answer to 6. National and International Regulators should ensure this by enforcing compliance to regulations.

Question 8: In what manner can the proposals for a regulatory framework for OTTs in India draw from those of ETNO, referred to in para 4.23 or the best practices summarised in para 4.29? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.
Ans: A legal expert can comment best on this.

Question 9: What are your views on net-neutrality in the Indian context? How should the various principles discussed in para 5.47 be dealt with? Please comment with justifications.
Ans: Differentiation of service on the basis of provider should strictly be discouraged. The principles of net neutrality should be implemented in letter and spirit to ensure the net remains an even playing field and an attractive option for both new players and consumers.

Question 10: What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? What should or can be permitted? Please comment with justifications.
Ans: Only form that should be practised is that the customer gets what he pays for. Obviously a higher paying customer would get a faster data service.

Question 11: Should the TSPs be mandated to publish various traffic management techniques used for different OTT applications? Is this a sufficient condition to ensure transparency and a fair regulatory regime?
Ans: This differential treatment should not happen.

Question 12: How should a conducive and balanced environment be created such that TSPs are able to invest in network infrastructure and CAPs are able to innovate and grow? Who should bear the network upgradation costs? Please comment with justifications
Ans: TSPs should start listening to customers and understand the huge gap in their QoS in India vis-à-vis the World. Addressing this gap will naturally get them more customers and revenue.
Also, tailoring their services to customer needs rather than arbitrary launches should help them improve revenue and minimise losses.

Question 13: Should TSPs be allowed to implement non-price based discrimination of services? If so, under what circumstances are such practices acceptable? What restrictions, if any, need to be placed so that such measures are not abused? What measures should be adopted to ensure transparency to consumers? Please comment with justifications.
Ans: TSPs should not be allowed to do this.

Question 14: Is there a justification for allowing differential pricing for data access and OTT communication services? If so, what changes need to be brought about in the present tariff and regulatory framework for telecommunication services in the country? Please comment with justifications.
Ans: No. Refer earlier answers.

Question 15: Should OTT communication service players be treated as Bulk User of Telecom Services (BuTS)? How should the framework be structured to prevent any discrimination and protect stakeholder interest? Please comment with justification.
Ans: Technically, I think so. My personal opinion is that they can be charged a fixed amount based on their user base and data consumption. A telecom legal expert can advise on the framework.

Question 16: What framework should be adopted to encourage India-specific OTT apps? Please comment with justifications.
Ans: In this global age, only differentiator should be performance to ensure customers get the best value for money services.

Question 17: If the OTT communication service players are to be licensed, should they be categorised as ASP or CSP? If so, what should be the framework? Please comment with justifications.
Ans: Ask a legal expert.

Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.
Ans: If OTT services will need to pay TSPs, they might have to charge customers. In which case, yes, a regulatory mechanism should be in place. Though, self-regulation should happen through market forces in a free market.

Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.
Ans: Can't comment without adequate knowledge.

Question 20: Are there any other issues that have a bearing on the subject discussed?
Ans: No. I don't think so.