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. We can start working on drafting a framework for the same but it should also take user convenience in account and should make the operator offer services at reasonable rate. As currently internet penetration is increasing and has lot more potential operators shall co-operate and abide to the same, later while on peak may be difficult to get them on same side.

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, I my opinion we live in open and highly connected world. Adding to licencing requirements for application providers and operators shall create digital barriers between India and rest of world and also drastically affect doing business in India

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. No knowledge for the same. Cannot comment

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. No, once the charges for service has been taken from client then TSP should not charge extra to OTT. Incase if they do then charges at the users end must be cut down as revenue from OTT shall compensate for the losses.

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.Dont know

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. I my opinion it is extremly important to know what kind of user data is being collected stored and with whom these data is being shared. Users data and privacy must be maintained but at the same time IT audits must be conducted of the apps from various OTT to make sure no data that can breach national as well as individual security is shared or sent over.

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. Incase of various OTT the application and underlying code base is propertroy. They shall not share and openly get their application audited with their source code available to the auditing authority, yet a through audit and verification must be carried out by Gov agencies like CDAC and others to make sure the privacy and data policies as mentioned by the OTT are followed.

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. Cant say.

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. Internet must remain neutral and consumers should be charged for using once service over the other in any manner. If TSP face losses owing to a specific OTT they must sort the issue within them without having to worry the 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.

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. Yes
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. Very breif topic cannot be answered in such a questioner.
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. Yes.
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, net nuetrality must be maintained and users should be charged discriminatly for using services.

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. Yes may be.
Question 16: What framework should be adopted to encourage India-specific OTT apps? Please comment with justifications.
Ans. Cant say
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. Getting in licencing mandates for OTT may result in infavourbale business enviornment in India must think of alternaive options
Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.
Ans. Yes

Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.
Ans. Cant say
Question 20: Are there any other issues that have a bearing on the subject discussed?
Ans. Uncontrolled pricing and no regulatory framework in place by govt to bare operator from overcharging is a big issue.

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Sanket V Garg,
+91-9970738647

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