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.

Answer - Internet is an open infrastructure nothing should break the ethos of a free net. Any regulation that breaks the net nutrality should never be adopted.

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.

Answer - At NO cost should there be any discrimination on any service offered over the internet. All content should be treated equally, no discrimination should be made. If we regulate content then we will not be able to use the internet to freely share content or offer value added services on top of basic offerings.

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.

Answer - TSPs have chosen to offer OTT services for commercial reasons and not otherwise. Any business is going to go through an evolution and there are bound to be times when going can get rough, but that does not mean that you break the fundamental principles just to circumvent your inability to evolve in changing market conditions. Let the market drive innvoation and kill those who want to just sit on their fat bases and not innovate.

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.

Anwer - OTT players have no reason to pay the TSPs. If the TSPs cannot operate violating the net neutrality then they should just wind up and make way for newer companies which can creatively operate and offer reasonably priced net access.

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.

Answer - OTT players are operating in a world which has real people on the other side, how are they different from brick and mortar companies, why add additional regulations for their businesses while they are already governed by the same business regulations non OTT companies are governed by. Moreover, we are moving into an era where everything is connected and are approaching a point where everyone wants to have online presence. So adding regulations for OTT players is discriminatory to begin with and adds impediments for others to get online. If we truly aspire to have digitally connected country/world then we cannot discriminate players on the net. 

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.

Answer - Whose security concerns are we talking about here. I am all for security of my data and privacy, I do not want that to be intruded by anyone including the regulatory bodies or government. Let us not forget that the regulatory bodies and government are tools to ensure that every citizen lives in a secure place. It does not mean that they can run a surveillence state. If I as a citizen think that the service I am using whether within the country or outside is not safe for my data I will not use it - PERIOD. We do not need so called regulators evesdropping to verify security. If we are talking about national security and online platforms are used against a nation then it is a different debate and that should not become the reason for impeding millions of genuine users' freedom. Let us not build a regulation with the aim of keeping check on a small fringe who are involved in nefarious activities. Let us not forget that they will go else where to continue their activities if they find internet is not conducive so by regulating you do not solve the problem but just shift the problem elsewhere.

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.

Answer - All OTT service providers should be ahead on the security curve to beat those who are posing security threats over the internet. In this front the government should establish a strong research and development on the security front to be ahead of the bad guys in identifying and building security parameters that needs to be adopted by businesses while offering services on the internet. Unfortunately, India does not have any security standards which should be mandatory for offering services within India. Instead of wasting time and money on breaking net neutrality the government and regulatory bodies should focus their energies on developing strong indigineous security parameters and guidelines to be implemented and adopted within the country.

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.

Answer - There should be no regulatory frameworks to control the OTT services.

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.

Answer - We are a democratical and free country and net neurtality should be considered as a fundamental right until it can be constitutionally endorsed. So any kind of differential pricing offered to access to services over the internet would mean discriminatory and in violation of neutrality and equality.

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.

Answer - At no point the TSPs can implement any kind of traffic metering and should allow the use of internet free without discrimination of content or service. If TSPs think they cannot operate profittably then they should look else where to do their business.

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?

Answer - There should be no kind of traffic management implemented by TSPs. If they do and do not publish it then it should be considered as a violation and penal action should be taken against such companies.

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

Answer - TSPs started the business of offering data connectivity only because it was profittable, today with changing market conditions if the circumstances change then one cannot go backwards by restricting innovation and creativity. On the contrary the TSPs should adapt to the changing circumstances and tune their prices to remain profittable and competitive. Bottom line they are in the market place, it is the place that will decide who makes what and not the businesses themselves. 

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.

Answer - This is not applicable if the fundamental ethos is to maintain Net Neutrality.

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.

Answer - NO there is no justification and the only mantra that one should be guided is Net neutrality.

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.

Answer - No discrimination of OTT players they are all offering services over the internet and net is free and equal. This whole idea of compartmentalizing the players is regressive and will take us backward. On the contrary all players OTT, TSPs should be constantly focusing in innovating to improve their quality of service through research and upgradation to new technologies.

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

Answer - India specific OTT apps should have no discrimination in any way and they all need to adhere to security levels established by India. TSPs should not come in the way of access to any specific service and offer their service without any discrimination.

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.

Answer - Not applicable in the context of Net neutrality.

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

Answer - No discriminatory charges for OTT services. Mantra is Net Neutrality.

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

Answer - Not applicable in the context of Net neutrality.

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

Answer - What we need is a neutral internet and freedom to speech. Government should strive to uphold these fundamental priciples.