Subject:
From: AMiT SiNGH
Date: 10-Apr-15 11:56 PM
To: advqos@trai.gov.in

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.

ANSWER: Any regulatory framework which breaks the principles of Net Neutrality should NEVER be adopted, neither now nor in the future.

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.

ANSWER: NEVER because it will hamper consumer choice, stifle growth of new kinds of products and services, and impede India’s economic progress. For example, if airline companies decide to offer online customer service through voice chat, an already heavily taxed and loss-making industry should not have to take another license.

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.

ANSWER: Radio channels cannot tax television channels for reduction in revenue. Even if OTT players are impacting the traditional revenue streams of TSPs, the TSPs cannot tax OTT services. Market forces should allow TSPs to reach a profitable price-point. TSPs need to invest in the quality and expansion of their existing products. TSPs need to explore outside their traditional revenue streams. India’s economy needs to favour innovative companies’ not outdated incumbents with vested interests.

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.

ANSWER: OTT players should NEVER pay TSPs for anything that can entail the violation of principles of Net Neutrality.