Hi Sir,

Please see the answers for 20 question regarding regulatory frame work for OTTS.

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.

Answer: Internet should not regulated for OTT. Let the users decide how they should use internet. Regulation of
Internet/OTT services is against the progress of technology. Let the benefits of technology reach each and every Indian.

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.

Answer: Why Internet/OTT players should be brought under license regime? Communication is the power of people. Any developed society will have better communication system. It is a parameter of development. Regulating them is retrograde.

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.

answer: Let telecom operators charge for their expense without affecting net neutrality. Or is the problem that OTT services may make more profit? Telecom operators can charge for whatever expense they make plus the profit.

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.

Answer: As a user I pay for connectivity. How I use Internet is none of the telecom companies business. Let them provide the gateway to Internet, rest users will take care. What site to access, what application to be used.. let the user decide on that. Telecoms regulating that is infringement upon basic rights.

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.

Answer: Why should the service of telecom firms be compared with that of OTT? Let teleom companies provide the connectivity. There ends its role. It is similar to asking mobile manufacturers not to provide 'clock' or 'calculator' in their mobile phones.

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.

Answer: Currently whatever can be tracked or controlled over Internet can be done for OTTs as well. There is no new concern in this regard. All the logs metadata can be tracked.

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

Answer: Consumer protection is not done by regulating OTTs. Privacy laws can be enacted covering the online space as well to achieve this.

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.

Answer: There should not be any regulatory framework for OTTs in India.

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.

Answer: Any act affecting net neutrality will affect Indian progress as well. Regulatory frame work will lead to information monopoly in Internet. The equal opportunity for every one to be heard hat exists now in Internet will be lost. This will definitely affect the startups.

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: The users pay for bandwidth and connectivity to Internet. There should be no control beyond that.

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?

Answeer: There should be no traffic management of OTTs.

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.

Answer: Let the users pay for what they are using. But that payment mechanism should not be based on what they do in Internet.

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.

Answer: Why telecos should bother about discrimination of services? Let telecos provide connectivity and forget rest of the things.

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: There shoudl not be 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.

Answer: Do not regulate OTTs

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

Answer: Do not regulate OTTs

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.

Answer: Do not regulate OTTs

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

Answer: Do not regulate OTTs

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

Answer: Do not regulate OTTs

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

No

Regards

Haynes