Subject: VIEWS ON NET NEUTRALITY
From: Chaitanya Doshi
Date: 08-Apr-15 10:37 PM
To: advqos@trai.gov.in
CC: netneutralityindia@gmail.com

TRAI,

This email is a response with regards to the views requested on the issue of Net Neutrality by TRAI by the internet users.

Response to the 20 questions asked by TRAI:

Ans1: It is too early for regulatory frameworks for OTT services, as the internet penetration in India is still limited & the speeds that are offered are very slow, besides the Telephone Service Providers have to consistently provide good internet speeds which is rare to find even in Metro cities.

Ans 2: No the OTT players offering communication service, should not be brought under the licensing regime as many of these OTT players have been providing services since many years, it would wrong to bring them under the licensing regime since they are trying to compete with other similar players by offering different services & sustaining in this tough market.

Ans 3: No I don't think the growth of OTT is impacting the revenue stream of the TSPs, as the charges for using internet are already quite high & the prices have been hiked by TSPs.    

Ans 4: No the OTT players must not be charged over & above the data charges paid by the customers as most of the OTT players provide their services without any charges or minimal charges.

Ans 5: I don't agree that there exists any imbalance in the regulatory environment in the operation of the OTT players, may be at a later date.

Ans 6: The OTT players need to have a server in India or make the records available to the security agencies so that the security concerns can be taken care of. For this purpose the TRAI or the Govt. of India must come up with laws which take care of the security concerns with regards to the OTT players.

Ans 7: The OTT players must mention in the terms & conditions as to what are the steps that they are taking regularly for maintaining the safety, security & privacy of the consumer. They must update the consumers as well with regards to the steps taken to ensure safety of the consumers.

Ans 8: I am not aware of the regulatory frameworks of ETNO, so can't say much.

Ans 9: Net Neutrality must be maintained the way it is currently, TSP must not be allowed to dictate what the consumer can use, once the consumer pays for the internet it's his choice how he intends to use his internet after already charging the consumers for the internet.

Ans 10: No form of discrimination or traffic management practices must be allowed as long as the it is within the legal parameters.

Ans 11: Yes TSP must publish the traffic management techniques used by them as they may be discriminating against a particular OTT as compared to some other OTT as they may have an understanding with one of them.

Ans 12: TSP are profit making companies & not working on cost basis, they always cover the costs of the services provided by them from the consumers, hence they must bear the cost of investment in the network infrastructure.

Ans 13: No TSP must not be allowed to to implement Non - price based discrimination of services, as there will always an opportunity for the TSP to manipulate or abuse the rules to become beneficial to them.

Ans 14:  No there is no justification for the differential pricing for data access & OTT communication services, who are the TSP to tell us how we must use our data pack once we pay for it, unless something illegal is being done using the internet.

Ans 15: No OTT communication service players must not be treated as Bulk users of Telecom Services, because it is the consumer who is using the OTT communication service, it is the choice of the consumer.

Ans 16: There must be no such framework, if the India specific OTT apps are capable to compete with the other OTT apps from around the world why should there be any discrimination. It must be the choice of the consumer which OTT app he wants to use.

Ans 17: I am not aware of whats stands for 'A' in ASP & what does 'C' stand in CSP.

Ans 18: No there is no need to regulate subscription charges for OTT communication services as some OTT players charge the consumers, it is for the consumers to choose which OTT service to avail.

Ans 19: Government needs to draft laws which take care of any security concerns & consumers not being cheated by the OTT players, also the safety & privacy of the consumers must be taken care of in the law.

Ans 20: I don't think there is anything else that needs discussion on this issue, as all relevant questions have been covered here.                                      

 
      Regards

  
Chaitanya M. Doshi