Subject: Issue for Consultation – Answers
From: Dron Rathore
Date: 09-Apr-15 1:35 PM
To: advqos@trai.gov.in

Q1: : 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.

– I think the topic hasn't been understood completely by TRAI. OTT shouldn't be there. Regardless of booming economy, its not justified in views of General Public as its not at all in favour of the Public. With economy like India, how can one can expect from people to pay for what should comes within the Internet they have paid for. Internet Traffic are merry Bits, that transfer over wire, Telcom industries has to upgrade their Infra now or someday, saying that as a reason is not justified. You are asking a population of 3 Billion to pay for something that they shouldn't be paying just for the sake of 4 organisations who are not able to cope up with their bad Infra? Internet is a small kid in womb in India currently don't kill it! Even the developed country aren't ruling in favour of such acts, recently US Court also put aside the plea of NetFlix and others and brought a major reform where ownership of internet and how it should be charged was left in the favour of General Public.

Q2: 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.

– No! This will cause another kick start of TRAI's not in favour of Innovation and Talent! It is more like I have to pay because I am utilising an innovation to make people's life Better! When did this start happening? Please don't kill innovative brains, and ease of connectivity of humanity!

Q3: s 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.

– TSPs can come up with innovation and innovative ideas that can help people. Like implementing various system level algorithms that boost their backends, improve their Infra to provide much faster network, this way they can boost their revenue by charging for what they are providing.

Q4: 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.

– The Network was there even when OTT wasn't. With Time TSPs improved Bandwidth, which encouraged people to innovate and they build OTT services, with improved infra the running cost for TSPs was lowered so they started providing low rate Internet. So, is this the fault of OTT or OTT user to use the services? Its just internet bits. TSPs can again improve the infra, cut down their running costs, keep innovating!

Q5: 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.

– No, I don't. With our booming economy we require Internet, India is a hub of IT and with PMs plan to connect each individual to Internet this will be a two sided step, where one side we ask people to come online and on other charge the OTT for those who have came online!

Q6: 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.

– Yes this is a valid question and point to be addressed, we can circulate Notices to all the OTT providers to cooperate with the Govt. in case we require Info or Intel on something and as of the history, all OTT have cooperated with our Govt., just the new ones need to be notified about the same. They should keep tracks and logs of IP access, in case of P2P communication, they need to keep track of both the peers logs so that it becomes easier to get the intel. But as the world is moving fast anyone case use proxy to access internet and dodge such concepts, the TCP and UDP communication layers were made this way. We can take measures but can't be 100% sure for this.

Q7: 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.

– They all need to work over the Secure Server Layer(https), the storage of sensitive data should be hashed using public key which resides with the owner(user) itself(password). For Privacy and Data security, OTT should be open about their Infra and should maintain public records regarding this and should be open for governmental Audits.


Q10: 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.

– All stands true, openess, and transparency should be promoted and it should be sole User choice to use a TSP and its service or not.

Q11: 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?

– No, for a country like India, with booming economy there is no requirement of it at current state. This will only cause chaos in general public.

Q12: 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.

– Govt. should collaborate with them, and help the country boom! 


Rest I don't see any point in answering them, there is already an outrage, FCC has already banned differential pricing in US, so quoting it as a problem is a pure negligence and forced implementation technique by your organisation. I would really love if you can again go through everything and clean this mess for forever, and make it illegal for companies to price differential amounts.



Thanks & Best Regards
Dron Rathore