Hi,

Please find below the 20 questions

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Question 1: Is it too early to establish a regulatory framework for Internet/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.
A1 Yes too early to establish regulatory framework - 3G speeds are slow - price is already terribly high. No regulations now - only once the services/infrastructure improves.

Question 2: Should the Internet/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.
A2 no they should not - they are providing a way for people to connect - licensing them means you are taking away the connection.

Question 3: Is the growth of Internet/OTT impacting the traditional revenue stream of Telecom operators/Telecom operators? If so, is the increase in data revenues of the Telecom Operators sufficient to compensate for this impact? Please comment with reasons.
A3 Yes the telecom operators already make huge margins off prepaid customers.

Question 4: Should the Internet/OTT players pay for use of the Telecom Operators 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 of product/service differentiation? Please comment with justifications.
A4  A minimal charge could be applied - based on the no. of users using the product/ the kind of consumption the product user requires.

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of Internet/OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to Internet/OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.
A5 Yes - by simple regulations not affecting the end consumers like the one answered in A4

Question 6: How should the security concerns be addressed with regard to Internet/OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such Internet/OTT players? And, how can compliance with these conditions be ensured if the applications of such Internet/OTT players reside outside the country? Please comment with justifications.
A6 Compliance should be managed for security concerns - if not possible the internet/OTT player should not be allowere to operate in the country

Question 7: How should the Internet/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
A7 Usual internet security measures- encryption, digital certificates, SSL

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 or the best practices? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.
A8 Those which are applicable to the Indian landscape - in accordance with understanding of the existing infrastructure and services provided and the already high tariffs in place.

Question 9: What are your views on net-neutrality in the Indian context? How should the various principles be dealt with? Please comment with justifications
A9. Net neutrality in India should remain - we are still a growing country - we cannot be bringing in rules/regulations to charge for services at this stage. Telecom companies already have huge margins and make money from existing services - they should not be greedy to get more from OTTs . How are other countries managing?  Imagine a student in rural India having to pay for accessing information online - unfair and unjust. Please do not let the telecos win

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.
A10 There should be no discrimination or traffic management practice - else only those OTTs will get a good speed who pay a higher price

Question 11: Should the Telecom Operators 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?

A11 Yes - to ensure transparency they should be mandated to publish this information. Publishing along with regulation would make it more fair - the chance to evaluate feedback from customers.

Question 12: How should the conducive and balanced environment be created such that Telecom Operators 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.

A12 if you compare 3G network in India v/s other countries - the speed and connective is terrible. It is the telecom operators responsibility to ensure they first have the infrastrcture in place to provide good service -  then the charges they levy are acceptable. The initial investment should be by the telecom operators - and prices can be increased accordingly for the customer spread.

Question 13: Should Telecom Operators 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.

A13 No discrimination of services based on price or otherwise.

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.

A14 No justification for differential pricing for data access and OTT communication 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.

A15 Yes - it is an option. I do not have enough knowledge to comment on this.

Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications.

A16 Increase awareness of such apps - any framework should not involve any discrimination towards non-Indian OTT apps

Question 17: If the App based/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.

A17 CSP. The OTT players responsibility for usage of their products.

Question 18: Is there a need to regulate subscription charges for App based/OTT communication services? Please comment with justifications.

A18 Yes - they should not be allowed to take undue advantage of their products being popular

Question 19: What steps should be taken by the Government for regulation of non-communication App based/OTT players? Please comment with justifications.

A19 There should be regulations- they should not be allowed to take undue advantage of their products being popular

Question 20: Are there any other issues that have a bearing on the subject discussed?

A20 Net Neutrality is important for a country like India - please do not give into the Telecom operators demands.

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Thanks & Regards,

Meghna