Dear Mr. Shri A. Robert. J. Ravi, Advisor (TD & QoS),

 

I have gone through the Consultative Paper on Regulatory Framework for Over-the-top (OTT) services.

 

I am a internet user which I access over broadband or on my mobile so I am statkeholder in this process.

 

Frankly I am amused on reading your paper as it seems to have been written not by an unbiased person but some ISP / Mobile company.

 

According to me & all other user’s OTT can be defined as any regular businesses which provide services / products. The only difference is that these businesses provide these services over the internet.

 

Example 1 : Let us take a ABC & XYZ are brick & mortar stores. It sells goods to its customers & people reach the store in their vehicles driving on the road. Say the road is a toll road.The road company does not charge the ABC Provision store money for allowing the ppl to use the road. Nor does the road company charge differential pricing based on whether the vehicle uses the ABC Provision or XYZ Provision.

 

The road company is charging for providing the road to travel. That is its responsibility & it charges the ppl for using the road irrespective of their destinations. It cannot claim that ABC / XYZ are making money from ppl who are travelling on their road so it should get a cut of the profit. Nor can they tie up with say XYZ provision store & say that if you buy from XYZ we shall charge you less or only if you buy from XYZ you can use the fast lane otherwise use the slow lane.

 

Example 2 : Contiuning the same anology in Example 1 suppose a company transports goods which allows the company to rake in huge profits. The road company cannot say that this company is making huge money by transporting goods over our road network so we want them to pay more based on their profits.

 

Similarly ISP / Mobile companies are providing the pathway to access the internet. They can charge based on bandwidth / GB’s downloaded. What we access on the internet cannot be detemined by them nor can they hope to profit from it. If their logic was to be accepted then they can even ask for % from sales of online retailers. That is absurd.

 

In the US also this logic of differential pricing / bandwidth allocation has been rejected by the FCC & principle of what is commonly called as “net-neutrality”  has been upheld. So this consunlatitive paper was never needed in the first place.

 

Kindly do not distort the internet. We stand firmly opposed to any changes that leads to differential pricing / bandwidth allocation by ISP’s / Mobile companies.

 

Regards,

 

Amit Garg

Treasurer & Project Convenor,

AFRT 199, Round Table India