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.

Data speeds are still low in India. I had a data connection of 10MBPS at home in Sweden back in 2004 and India is just getting to that stage and was paying internet bills much lower than India then/now. It was 100 Kroners, equivalent to Rs 600. When internet service providers have stifled any improvement in data rates for a decade, they have milked this cash cow and should provide the benefits to the society. Instead they are trying to further stifle the user independence by lobbying for regulatory framework for OTT. The key players would be the companies which have mobile/landline market plus ISP. New ventures like Hathway, ACT are a threat to companies like Airtel, Vodafone, Idea etc as these companies were the first to provide higher data rates and up the competition. To ensure its level-playing field for entrepreneurs and start-ups this regulatory frameworks should banned. This framework will ensure the rich will stay rich and lobby for their existence and any  entrepreneur/start-up will be blocked from entering.

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.

Govt. has the right to extract taxes from OTT players, and they can be considered as:

1. Telecom companies in case of Skype,  Whatsapp etc
2. Media companies in case of Youtube, Daily Motions etc

OTTs can manage to pay such taxes through their advertisement revenue. We need not control them through ISPs, as the intentions of ISPs are prohibitive than encouraging the usage.

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.

It’s all a part of change and ISPs and TSPs should learn to live with and adapt to it.

1. With the advent of internet postal services have declined. Did postal department crib about it?
2. With the advent of mobile phones, radios have pretty much gone extinct. Did radio manufacturers demanded regulations?
3. With the advent of teleconferencing, air travels reduced. Did aviation industry crib about it?
4. Also, with the advent of telephone/SMS postcards vanished. Did postal department crib about it?

So ISPs and TSPs are just crying like kids here, crying of foul. But they should learn to adapt, and instead concentrate of quality of service and business expansion. When there are more registrations happening for dataplans, they are definitely making money. They should let go of theirs stronghold on voice and sms services. Instead concentrate on better infrastructure to handle data demands now. Encourage people to use more of voice and video services and thus make money. It's quite clear that TSPs like Airtel have vested interest here and any regulations that are forced will be a biased decission. Instead of crying foul, why can't TSPs come up with OTT services to compete fair and square?

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.

OTT players could pay taxes to the Govt. Need not pay TSPs and ISPs. This will have a negative impact on creative ideas on internet. TSPs will become dictators of the internet world.

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 114 virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.

Imbalance is because OTTs are not paying taxes to the Govt of India. If that happens everything will be set right. Those who don’t agree to pay taxes to the local Govt. can be blocked.

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.

Every OTT should register in the country as TSP or Media provider and should abide to the same laws as rest of the TSPs and Television industry

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 to question 6 should apply here as well.

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.

In section 4.6, the decisions FCC is planning to take are better for a nation which claims "All are equal". Please don’t bring reservation policy to internet world.

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.

TSPs and ISPs are not providing unlimited data in actual sense. Decent speed is provided for a limited data usage and beyond that the speed is pathetic. In light of this, TSPs and ISPs have no rights to request further regulation. Internet access should not the throttled further.

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.

Section 4.7, where FCC describes it beautifully.

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?

As per my response to question 6, TSPs are already throttling the speed beyond a data usage, so within that limit why further ways to manage traffic. I find it unnecessary. If any such actions are staged, it has to be very transparent to ensure there is no foulplay.

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.

We don’t get internet for free.  Part of our bill should already been going towards system upgrades. This is a funny question!

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.

The way OTT make money out of advertisements. TSPs should be allowed to make money out of e-commerce websites, where user is not charged for the data usage for such websites. TSPs should not block any website which doesn’t subscribe to such options. They should not slow-down data rates for such non-subscribed e-commerce websites. End user is anyway paying for the data usage. That will ensure if there is a good quality e-commerce company exists as non-subscriber to TSP, company doesn’t get affected by dictatorial attitude of TSP and end user gets the freedom of choice between subscribing e-commerce company and the non-subscribing ecommerce company.

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.

Internet content should not be blocked due to vested interest. Freedom to surf should prevail. Customer should pay to surf complete web and not just contained content.

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.

Let them pay taxes to the Indian Govt. Simple.

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

No regulations please. Get taxes from OTT instead. That’s sufficient.

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.

Anything…

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

TSPs enjoyed unregulated environment for more than a decade. Why worry about OTTs for a dacade?

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

No regulations please. Get taxes from them instead. That’s sufficient.

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

No