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?
   
   OTT services are THE reason people use internet. Controlling and monitoring internet from a security point of view is very well taken and understandable but making OTT services regulated from ISP’s point of view not acceptable at all.
   
   
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?
   
   most of these services are invented outside India and as I know, none of the country has such license regime. When mature economies are not putting these services under license and are flourishing then no point in licensing these in India.
   
   
3. Is the growth of OTT impacting the traditional revenue stream of telecom service providers (TSPs)? If so, is the increase in data revenues of the TSPs sufficient to compensate for this impact?
   
   Truth is nobody knows , not even Indian government,  how much these TSPs earn because of shoddy business practices and nexus of politicians and businessmen (2G scam). But from the earning and profit statements of these TSPs in newspapers, I understand that TSPs are making huge profits already and there is no limit to their hunger for profits as everyone else.
   Data services are making these companies more rich and TSPs are crying for the simple reason that they are not competent enough to create business on data services whereas other people are. TSP are scared of competition which is going in favor of end user.
   
   
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?
   
   OTT service providers are spending billions of dollars to build their services and most prominent ones giving it for free. TSPs should not charge anything to OTT service providers because TSP exists because of these OTT service providers. Over the years ,during telecom revolution and scams, TSPs found to be involved in wrong business practices and cheating their customer on the pretext of this and that reason. I remember being charged Rs. 30/- for caller tune which I never subscribed and Rs.50/-  for hearing songs which my cell phone was never capable of and I never subscribed it. TSP are still confusing and cheating their customers by making call plans complex to understand.
   The answer to your question :
   Should the OTT players pay for use of the TSPs network over and above data charges paid by consumers :  NO
   
   
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?
   
   Indian government can state security laws to OTT players and force the compliance. From the impact on economy  point of view, mature economies have gained out of free internet rather than losing something.
   
   
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?
   
   Every country has its own security laws and have rights to force OTT players to compliant. If Indian government can force BlackBerry to handover the encryption key then why not ask Skype to give access to call logs and in fact Indian government already have access of these then why this question now ?
   
   
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?
   
   In an open internet and world as a whole the idea is survival of fittest. There are already enough security compliance standards and govt controls on OTT services worldwide so let these standards rollout and let govt take care of security. BlackBerry and Nokia were out of business because of better services based on iPhone and Android. Businesses have to reinvent themselves to be competitive and relevant.
   
   
8. In what manner can the proposals for a regulatory framework for OTTs in India draw from those of European Telecommunications Network Operators (ETNO)? What practices should be proscribed by regulatory fiat?
   
   This question is for those who are familiar with regulatory framework and are expert and you should not ask this question from general public.
   
   
9. What are your views on net-neutrality in the Indian context?
   
   Let the internet work as it is working now. There is no Indian context anymore because Internet is a worldwide phenomenon and Indians are already far far behind in nurturing a conducive environment for young entrepreneurs or give birth to revolutions like Google, Facebook.
   
   Industrialists like Sunil Mittal Bharti cannot think outside the boundary of Airtel but Govt. of India should think about whole country. Net-neutrality can bring revolution for whole country and can bring prosperity for all Indian citizens whereas controlling OTT services will bring wealth to 10-20 people at the most.
   
   
10. What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? What should or can be permitted?
    
    Question is WHY TO CONTROL AT ALL ???
    When whole world is agreeing to let internet flow freely then questions of controlling it only matter in China not India.
    
    
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?
    
    Call drops in metro cities like Delhi, Mumbai, Bangluru etc. is rampant and no TSP talks about it. Who would trust these private companies to publish traffic management practices when these TSP are not following exiting laws. Trusting TSPs would be a foolish mistake.
    
    
12. How should a conducive and balanced environment be created such that TSPs are able to invest in network infrastructure and Content and Application Providers (CAPs) are able to innovate and grow? Who should bear the network upgradation costs?
    
    Why don’t Indian government takes cues from mature economies like US, UK where net-neutrality is already in place. TSPs are already charging to consumers for data and making huge profits. More the network is efficient more is money to be made for these TSPs.
    
    
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?
    
    Let internet work freely. Forget about controlling internet and asking the same question again and again by twisting words.
    
    
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?
    
    No justification for allowing differential pricing for data access.
    
    
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?
    
    no idea what this question is.
    
    
16. What framework should be adopted to encourage India-specific OTT apps?
    
    All OTT apps are equal when we talk about net-neutrality.
    
    
17. If the OTT communication service players are to be licensed, should they be categorised as Application Service Providers (ASP) or Communications Service Providers (CSP)? If so, what should be the framework?
    
    No idea
    
    
18. Is there a need to regulate subscription charges for OTT communication services?
    
    No need to regulated OTT services
    
    
19. What steps should be taken by the Government for regulation of non-communication OTT players?
    
    Let the freedom of Internet prevails.
    
    
20. Are there any other issues that have a bearing on the subject discussed?
    
    Seems like TSP are not competent enough to understand the impact of free Internet on this world as a whole. They are only concerned about the profitability and running away from competition.

Regards,

Vimal Rai

BizGrid Infotech

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