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: Internet in India is still in it's infancy stage. Just because a lot of people, especially youngsters, use the Internet, more for social networking than anything else, does not mean that we listen to these telcos and cater to their greed to fill their coffers and not think about the overall impact it will have on businesses. A regulartory framework for OTT will kill business in India and we will go back to the stone-age, or witness a mass migration, people leaving India for other more friendly places.

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. Separate licensing for OTT services would be a major overhead.

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: Of course. Do you know how much money do they make from 2G/3G services? There is absolutely no justification in charging more nd separately for these services.

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 of product/service differentiation? Please comment with justifications.

Ans: No extra charges shouldbe levied over and above the data charges. The teclos already mint money and there is absolutely no justification for these additional charges.

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: What imbalance? The OTT players are providing means of communication to the public. Yes, there can be some regulations in terms of misuse, pornography, terrorism etc. But not at the cost of charging extra to citizens.

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 layers reside outside the country? Please comment with justifications.

Ans: Well, the government could put in place a mandate that if required, on an as needed basis, it can demand for logs, data records etc. to investigate special cases, like acts of terrorism, misconduct, money laundering etc. Irrespective of where the OTT player resides.

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: By ensuring their apps are not vulnerable to hacks / leaks, by having appropriate SLAs in place and also monitoring their services regularly to ensure there is no breach.

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: As long as citizens are not charged extra and are not harassed unduly, it should be fine.

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: OTTs should be made accountable for deficiency in services provided by their applications. Similarly, TSPs too should be made accountable for deficiency in services by targetting specific OTT(s) and favoring other(s) for mutual benefits.

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: Not sure.

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: Not mandatory, but if demanded by the government, they should provide all the relevant data.

Question 12: How should the 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: The cost of upgrades is always passed on to the consumer in some form of the other. Yes, marginal increase in charges to consumers is acceptable, but only to a certain limit. It cannot be adhoc and outrageous.

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: From a transparency perspective, TSPs should be able to provide information to consumers (through proper channels) so that it can be verified that there is no misuse. I am totally against any "discrimination", priced or non-priced.

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. We already pay for Internet connectivity, so why pay extra for applications? As mnetioned earlier, marginal increase in charges to consumers is acceptable, but only to a certain limit. It cannot be adhoc and outrageous. I understand that the telcos are in it to make money, but that does not mean they have a right to enforce things on everyone in the country to meet their own dirty needs.

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, they could be treated as BuTS. As for the framework, not sure.

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

Ans: Make sure apps support major regional languiages, do not have content that is sensitive and can hurt people's sentiments.

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: CSPs

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

Ans: No harm in it. Will at least give some control to the government to keep a check on the OTT players. But don't go overboard with it.

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

Ans:  Not sure.

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

Ans: Please do not give undue advantage to the telcos. They will jump on any opportunity to misuse their "powers".

ISPs can slow down some sites on while giving faster speeds to the companies that pay them more.

Why does this matter?

Say its a “big sale day” of Amazon and Flipkart and you are customer of ISP ‘BIGTELCO’.

BIGTELCO can strike a deal with Flipkart for better speed on their network. Due to this you won’t be able to purchase on Amazon even if something is cheaper.

Governments will no more need draconian laws to curb free speech. It can just ask the operators to make critical sites costly to access and also clamp down their speeds. Telcos that already have vested interests from the governments will happily oblige.