IGF 2022 Day 3 DCNN Internet Openness Formula: Interoperability + Device + Net

The following are the outputs of the captioning taken during an IGF intervention. Although it is largely accurate, in some cases it may be incomplete or inaccurate due to inaudible passages or transcription errors. It is posted as an aid, but should not be treated as an authoritative record.



>> LUCA BELLI: All right. As we already have five minutes of delay, I think almost everyone is here. I see Sabelo also managed to join. Excellent. We are only missing ‑‑ I'm hearing a bizarre echo. I hope we can now check the sound. Yes, perfect now. I'm not hearing my voice twice anymore. Excellent. I see everyone is here. We're only missing KS Park. I'm sure he'll be able to join in the next couple of minutes.

So good morning to everyone. And let me welcome all the participants, speakers, everyone both online and on‑site. We still have a very peculiar hybrid format which is actually really hybrid for the first time. Because I'm seeing that there is quite a number, a good number, of participants on‑site. We have also a good number of participants online.

My name is Luca Belli, Professor here at FGV Law School in Rio de Janeiro. Also the pleasure and honor to be the coordinator of this Dynamic Coalition on net neutrality, funded ten years ago by a group of supporters of Internet openness. We have some of them with us also today. I would like to really welcome with great pleasure and great friendship the very stellar panelists we have today. We'll start with Commissioner Lina Maria Duque del Vecchio who's Commissioner of the Colombian Communications Regulation Commission, CRC. Unfortunately, we will not be able to have Carlota Reyners Fontana from the European Commission because she had another commitment that she could not come. But we are very happy to have Ms. Maarit Palovirta, Senior Director of Regulatory Affairs of ETNO. We also have our good friend, Thomas Lohninger, Director of Epicenter Works. We'll be joined hopefully in a few minutes by Kyun Sin Park, Professor and Director of Open Net Korea. We've been joined by Angela Daly, University of Dundee and FGV Law School. Last but not least, Sabelo Mhlambi, founder of Bhala, an African startup but also a researcher at the Berkman Klein Center at Harvard.

Today, we'll speak about a lot of many different issues all related, of course, to Internet openness. As you might have understood from the very title of this session dedicated to the Internet Openness interoperability + Device + Net Neutrality, we strived to organize a section that may be as multifaceted as possible.

So as many of the people have been following our work for over the past decade know, this Dynamic Coalition of the IGF is a multistakeholder group that has been discussing net neutrality and Internet openness for ten years, literally. We've been promoting net neutrality as a fundamental principle to preserve Internet openness. We also acknowledge that Internet openness is not synonym of net neutrality. Net neutrality is a fundamental component of Internet openness. But the Internet openness, indeed, is much more complex and requires also thinking about interoperability. Thinking about device neutrality. And we will explore the three different dimensions today with our panelists to understand how the role that Internet openness play in promoting not only human rights and the full enjoyment of fundamental rights, of Internet users, but also competition, equality of opportunity, and innovation. Safeguarding the very same peer‑to‑peer nature of the Internet which is what has made the Internet so rich and so useful over the past decades.

We will start by exploring net neutrality issues in different geographical areas. Although we acknowledge, as was mentioned, that Internet openness is much more complex than only focusing on net neutrality. Net neutrality debates have been occupying policies here. In various geographical areas, we have seen that there has been very recent attention and strong, I would say, also attention in the European level about the proposal to introduce a fair‑share model based on the model that has been strongly debated over the past years. And we will hear more about this from Maarit and from Thomas.

We have also seen the very same discussion played out in South Korea over the past couple years. You'll hear about this from KS.

Also we have seen there's been very recent developments in terms of startups conducted by the regulator and also jurisprudence at the Colombian level. Also Latin America is a region where net neutrality and Internet openness keep on being uppermost in the agenda of policymakers and various stakeholders.

Without further ado, I would also only like to mention that my colleague at the FGV Law School ‑‑ oh, she just joined. Smitri Parsheera. I'll co‑moderate this session with my colleague, Professor Smitri Parsheera that was in another session that started with a little bit of delay. Fortunately, she just managed to join now.

Before we start with the keynote remarks of Commissioner Lina Maria Duque del Vecchio, I would only like to ask to the technical assistants to please mute by default all online participants and do not allow them to share things unless the technical assistants permit it. Because we have had last year several example of Zoom bombing. I would really like not to see again in this session, at the IGF in general, because it is very easy to prevent this with default Zoom options. Not allowing speakers to ‑‑ or participants ‑‑ to speak or share unless they are allowed.

If you want, you can make me co‑host so I can do it myself. But, please, just let's try to adopt this very basic cybersecurity measure so that the entire session will evolve smoothly and in the best way possible.

So without further ado, first, I would like to first welcome my colleague, Smitri, that has just joined. Then I'll give the floor to Commissioner Lina Maria Duque del Vecchio for her keynote remarks on the situation of net neutrality and Internet openness in Colombia. Please, Lina Maria, the floor is yours. It's a great pleasure to have you with us today.

>> LINA MARIA DUQUE DEL VECCHIO: Thank you so much, Luca, for your introduction and for allowing us to participate here. It's a pleasure being here, Luca. Good morning, everyone.

As you already said, my name is Lina Maria Duque. It's a great pleasure to be here and share with you the results of this study that we just held about net neutrality in Colombia.

This study, we already ‑‑ we finished it just last year, 2021. And I hope you're seeing my presentation. I'm sorry that I have to share it in this size because I don't have the chance to make it a presentation.

Okay. So the study that we developed has a starting point. In 2011, Colombia accomplished the legal framework to define the rules about net neutrality in Colombia. And how we identify the definition in our legal system.

This framework established it couldn't be blocking, interference, discrimination, or restriction of the rights of the users to access to content and applications on the Internet. Obviously, as long as those applications and content are legal.

It also defines that providers cannot be doing any kind of arbitrary actions discriminating content or applications based exclusively on the origin or ownership of those applications. Based on these provisions, the CRC has the goal to establish the regulatory conditions related to network neutrality and build it based on a few principles that are really, really important. Freedom of choice. Nondiscrimination. Transparency. And a duty of information.

In 2020 because of the network pressures generated during the isolation during the pandemic, it was established that the providers and Internet access providers may implement some kind of traffic management measures that always have to be applying principles of no discrimination. This is like the framework, the legal framework, they we have in the regulatory framework that we have. In the study, we also made an approach of the international situation regarding regulatory definitions and about this net neutrality.

This is how we identified a wide range of positions. As Luca already said, we have different kind of approximations of this situation and legislation has a wide range of really, really extreme situations. We have cases like Australia, Japan, and New Zealand, in where the obligations are only confined to duty of transparency by the service providers regarding the traffic management practices and how they apply to the networks. But they don't have any specific legislation in this regard.

On the other hand, we have places like the European Union where we find the prohibition of Zero Rating offers and the guidance that they're addressed to the monitoring authorities to regulate rules and equal nondiscriminatory treatment in Internet traffic services.

And we also find this case of South Korea that was already mentioned that is really interesting in which we have to be focused on the following. If it's going to be or not a charge or an obligation, enumeration of the networks by the content generators.

With this in mind and what was happening around the world, we analyzed Colombia's situation. And how we were working and how we were dealing with this Internet net neutrality situation. As I already mentioned, our regulation has been established in principles free of choice. Nondiscrimination. Transparency. And information.

The law establishes that the Internet Service Provider can offer plans according to the market and the user needs according also with their consumption profiles.

So under this context, the CRC and taking into account the situation of the market, the study could identify that we have almost 39 offers. 22 packages that are use of application. The most common applications like Facebook, WhatsApp, Instagram, Snapchat and so on. Other kind of access to service of these pre‑paid plans. We have 136 plans identified with 76 packages included. In an additional capacity on a limited use for the users and the consumers.

It's especially important for us to highlight that this diversity of offers between different operations can let us understood how the market was working and how the different operations give offers to the market depending on the opportunity, the pertinence, and the users' position. So the users are making some kind of pressures. Making the operators who have more and bigger offers.

Especially regarding the zero-rating practices. In Colombia, we have those kinds of practices. We can say they have become quite common among the different operators in Colombia. Since the users are requesting them.

In the next slide, I would like to tell you this study also has a consultation. We could not only see how the market was behaving around papers, but we needed to consultate different kind of stakeholders such as users, application providers, Internet service providers, academia, among other parties. They have the chance to participate and express their comments on the regulation that is already established in Colombia. And how they feel around this. And if they can really use and be part of the decisions of having access to Internet.

From the results we obtained from these consultation, we can observe the relation that's focused on principles that have been mentioned address technological and market changes and the development has been around the technological market. That's why we didn't find any kind of need to have any regulation change. But obviously, we have to keep this ‑‑ we have to monitor the situation of this market all the time.

In the next slide, I can show you how month to month it's been changing the use of different applications between the users. This is important because we could identify that the market has the ability to change. And we find multiple offers of plans as a response of the use of the ‑‑ of the needs of the users and the market movements. We have all the time inclusion and exclusion of applications with what the providers offer. Users are telling all the time to the operators what they want to use and why they want to use it.

This graph is showing how month to month this foundation works in the last two years. We find we have applications that have been maintained over the time. There are others that have been changing. Going in, going out. Depending on the popularity that they have between the users. Among the users.

In the next slide, we show you as well how the evolution of consumption of Internet application in Colombia has been working. The net neutrality study I'm talking about, we also quote an additional analysis that we made about consumption of habits in Colombia. That includes the behavior of people that has smartphones between 2019 and 2021. What we found, we found that the users use mobile services and applications and changed from 74% to 78%. The consumption of OTT audiovisual services went from 32% to 36%. And the application messaging services went from 77% to 78%. So this is a variation because of the use the consumers have been making of these applications.

And with this evidence in mind, the preferences of reputations, we could find that the offers we have in our market are changing because of the users' needs. So the CRC has this kind of ‑‑ we have this ‑‑ you can have a local ‑‑ I don't think we have it in English, but we can do something about it. And we have also another situation that we ask for it. Because it's not only that we have the law and we have the regulation. We also went to the enforcements in Colombia to find out if we have any investigations about this matter. And they told us, officially told us, that they don't really have any kind of interest about this matter. This gives us additional evidence about how is the legal framework and the regulatory framework working. That's why we didn't find any kind of evidence to change the regulatory framework in this moment in Colombia.

We finally, as I've already said, this is a study that we made. Analysis identified the rules that we have in Colombia that allows zero rating offers has given more alternatives to users of different kinds of income levels. This is a topic that's been in a permanent discussion from the perspective of innovation and market trends. We are always seeking to promote access to the Internet and content by the Colombian market consumers.

We also wanted to tell you that actually in this moment, currently, we have a legal debate in our constitutional court about the zero rating. We don't have any kind of conclusions right now about the trial that we are having here. But we really think that it's important that policymakers have in mind that it's crucial to maintain a balance between extreme decisions. Protecting the users, of course. They have to have the right of freedom of choice. But not necessarily going to (?) This situation maybe could make to be losing any kind of benefits from these users.

We believe the bullet point is one in the middle when free market has the possibility of defining how the offers can be given to the users and can be sortable for different market segments. This has to make some kind of development of the market. Always focusing on the users and this freedom of choice of the users.

This is our ‑‑ I hope you can read it. If you have questions, obviously, we can be there for you. Thank you so much for your time and for the opportunity.

>> SMITRI PARSHEERA: Sorry. Thank you so much, Commissioner, for giving us the overview of the experience in Colombia. It's really interesting to see how the study is so evidence‑based and based on so much data and information. We also note that you said that the zero-rating topic still remains open unlike in a lot of other jurisdictions where countries have taken a stronger stance or more lenient stance on it already. With that, let me invite Thomas Lohninger, Director of Epicenter Works, to give his comments on both anything that has been said so far by Commissioner Lina as well as perspectives from Europe or anything else he'd like to add. Over to you, Thomas.

>> THOMAS LOHNINGER: Thank you. Thank you very much. And it's a great honor to speak here again at the IGF.

Where to start. The title of this event and the issue that concerns us is the fragmentation of the Internet. I think we currently see two trends that lead to this fragmentation. The one is very close to home for me, the debate about network fees the telecom industry in Europe wants to establish. And that's, as Luca has mentioned, for those in the debate long enough, this all sounds very familiar. Because we exactly discussed this idea ten years ago at ITU level and we were rejected. Now there's discussion that we need this money for network investment which I think is a flawed argument. Because we don't lack money in Europe for investing in networks. It's basically a power grab from the telecom industry. Because what this proposal would mean in practice is that most companies that rely on cloud hosting would see the prices rise that will, of course, also affect public broadcasters, private media, SMEs. Everybody who relies on the cloud to provide an online service would be affected by this. Everyday consumers will see their subscription prices for Netflix and other subscriptions to rise. Because everything that is data intensive will become more expensive. And it's important to pause here and just come up with the reality of how the Internet looks like today. Yeah. That traffic is increasing exponentially and has done so for decades. That was never a problem. The equipment gets more efficient. So we'll see that with the same costs of network equipment, you can actually transmit more and more data particularly in the area of fiber networks.

And the most intensive services are video streaming applications but make up only 2% of the revenue that's generated with the Internet. The majority of the revenue comes from search engines and e‑commerce. And they only make up a minor fraction of the bandwidth that we transmit. It doesn't take much for a Google search field to appear in your browser. But yet, this idea which brands itself as being fair tries to redistribute money. I think a digital tax would be far more suited for the much‑needed equilibrium. To quote Tim Wu, “if we give up net neutrality to afford a better Internet, it's like selling a picture to afford a better frame.”

If we allow ISPs to exercise termination monopoly, we'll end up in this. Because that's the business model that we know from the telephony era.

I think we'll continue the discussion. I also would like to address other issues raised around zero rating. As the esteemed Commissioner has spoken previously. I was invited to give expert testimony in the case in front of the Constitutional Court of Colombia that the Commissioner has mentioned. Article 56 of the Colombian Net Neutrality Law. Telcos are allowed to discriminate if they believe they're fulfilling a market demand. We only know this weird provision to exempt the nondiscrimination rule based on market demand from one other country. That's South Korea. I hope Professor Park can elaborate more on that.

I would really like to take a moment particularly at IGF here in Africa and raise the question to also the auditorium here. What zero rating is really doing. Particularly in the Global South. The answer that we have gotten from our colleagues in India in their struggle to enshrine net neutrality protections in law, they see it as a form of digital colonialism. Instead of giving people access to the full Internet, it's a telecom company deciding which individual applications people are allowed to access. Often, payments from, for example, Facebook, in order to have their applications zero rated. Telecom operators are a vital piece of infrastructure in an information society. We need to hold telecom operators to human rights standards.

And more particularly because the Commissioner said users request zero rating. Of course, they request it. If the price for data volume in Colombia is low. We have seen this over and over again throughout the world that when zero rating is outlawed, the prices stay the same. Magically, the data volume doubles or triples. We've seen this in India. We've seen it in Korea. We've seen it in Slovenia, Netherlands, Austria, Germany. We believe zero rating creates an incentive for artificial scarcity. You can only exempt an application from data caps if the data caps are low enough to still give the application a priority lane to the user.

And I believe that any form of application‑specific traffic management in zero rating, any form of discrimination in that regard, is contrary to the freedom of choice of users. This becomes really self‑evident if we look at the aforementioned study and the study we have done in 2019 about zero‑rate situation in Europe before zero rating was outlawed in the continent. And there we saw that Facebook is always the main beneficiary of these things. That's the case in Colombia. And that's also the case in Europe where among the top‑ten zero rated applications, four were from Meta Incorporated.

And lastly, I want to say I'm really sad that Ms. Reyners is not here with us today. The European Commission opened up a very important debate. They have so par left us in the dark. There's no clear process. None of this is in the work programme of the EU. We have no consultation. And more and more actors, including seven EU Member States, have to fear that the European Commission gets more captured from the telecom industry. And this very important question. And there would be more to say, but I think I'll leave it at that.

>> LUCA BELLI: Thank you very much, Thomas, for this rather enlightening and critical perspective. It's very good to have both sides of the debate here. And we'll have a brief space for a question and answer after the next presentation. Then also at the end, of course, an open debate to deepen this.

Of course, a point that really struck my attention was, indeed, the consumer demand. I think those in the net neutrality debates for years, it always looks like a chicken and egg situation. Like, consumers want this kind of offering because they really want them or because they're the only offering available. And there is no ‑‑ the market is not offering an alternative. We have seen it actually when regulation is implemented or adopted. This situation might be different. I mean, India is a very telling example. But there are many others, Europe and Portugal has decided to take a very vocal stance on zero rating only one week ago.

Now, without entering too much into the details of the discussion because we have Q&A precisely for this. I'd like now to give the floor to Maarit who works for ETNO and has been one of the main proponents, if not the main of this proposal that was mentioned by Thomas. So we have the great pleasure to have Maarit with us to discuss what would be the merits and why this kind of proposal has been introduced. Please, Maarit, the floor is yours.

>> MAARIT PALOVIRTA: Thank you very much, Luca. Thank you for inviting ETNO to this discussion. Thank you also for being a relentless advocate for all of us. An ambassador for the open Internet. I know this is not the first session you're organizing at the context of the IGF, or, indeed, the European IGF, on the topic.

So very interesting views from the previous speakers. Especially also very good to hear from the Colombian Commissioner. I didn't know, myself, I'm not so familiar with the situation in Latin America. So it was very interesting to hear from that point of view as well.

Before making comments on this fair contribution issue, I'd like to just make a few remarks on the Internet and the open Internet issue as such. Because, of course, we have a long history on this in Europe. I think that although it is maybe not the first topic on the table in terms of new policy initiatives in the EU, it is still something that's constantly there.

ETNO, we're a firm believer in the open Internet and do defend this vision both at the technical and policy level. Technical level is also very important today because if we look at the global Internet infrastructure is, of course, based on open Internet standards. We know very well that in the recent past, there have been some challenges to try and change the standards, the global Internet standards, that allow us to have interoperable Internet.

We've been very vocal on this calling to keep the open global Internet intact. That will also, of course, benefit us operators, SMEs, and all of us to keep the Internet interoperable and accessible for all of us.

Also on the policy side, I think it's very important to mention that there are the Open Internet Regulation, of course, which is a very key bloc. We at ETNO have been certainly always very much advocating for openness to the extent possible. We note in some countries, of course, we have legal obligations as telecom operators especially when there's online criminality and such occasions.

So I think we look at the European open Internet regulation, that's been in place for many years. From our point of view, the regulation is very stable. There haven't been many issues in terms of implementation or interpretation. Of course, in the beginning of the regulation, there were always a few test cases, if you like, but actually, if you look back in the history in the last years, the regulation has been rather stable.

Now, there have been a few external factors maybe to highlight here. And they already came up as well. That had, perhaps, challenged, you could say, the regulation. And one is the pandemic that Lina Maria, the Commissioner, already mentioned. In Europe, the pattern changed quite dramatically. Operators had to react. We were very much reassured by our regulators that this was well within the scope of the regulation.

Second one was this Russian war on Ukraine. And the fact that there are now some sanctions in place that include website blocking which are, of course, based on regulation in Europe. While this is not something operators like to do, but again, there was a legislative package behind. So that we were, let's say, convinced by our policymakers and regulators that this was within the scope of the Open Internet Regulation.

We have a good audience from other parts of the world on how other parts of the world actually think about net neutrality. I think Europe alongside Colombia, one of the few places in the world where you have a very solid regulatory framing around the open Internet issue. It's a shame we don't have a U.S. speaker here. The U.S. used to have an open Internet policy, or legal resolution, let's say, until 2015 but have since repealed it. It would be interesting to see as well what have been the impacts, if any, in the U.S. in that regard.

Those were my introduction remarks on the open Internet in general. Now that we have included the fair contribution in this open Internet discussion today, I'd like to make a few remarks. I'm very happy, Luca, you already mentioned that this ‑‑ what you call fair share and we like to call the fair and proportionate contribution principle, is different. So we are not looking at the principles. We're very much looking at a very targeted approach, a market‑driven approach that would help us, the operators, ensure that we have good connectivity available for all end user.

And we also have to ‑‑ I have to say upfront that we don't actually believe this issue of fair contribution and the net neutrality regulation of the open Internet, as you say, Luca, there's a little bit of a different. The net neutrality regulation, we don't think these two are interdependent in the case of Europe or mutually exclusive. We very much believe both of these can exist in parallel.

Also, it would be good to highlight when we talk about the fair contribution as ETNO, we are, of course, thinking about the European digital ecosystem. We're not talking about the global ecosystem. Not claiming this is something the whole world should be doing. It's just in the European context where we see certain dynamics and also a very specific regulatory framework on the telecommunications sector, that we believe that this would be a good solution going forward.

And, indeed, as was already said, so we have been one of the advocates for this principle. And maybe just a few words to explain what exactly do we mean by it. So the European Commission actually, now we have ‑‑ these have been recently approved. We have now two policy documents from the European Commission that are quite clearly outlining that all market ‑‑ I'm looking at my notes because I'm trying to quote it literally. So all market actors benefiting from the digital transformation should assume their social responsibilities and make a fair and proportionate contribution to the public goods, services and infrastructures for the benefit of all Europeans. And this is in two documents. One document is about digital goals in Europe. Another one is about digital rights and principles.

What is important to note as well that the document on the European rights and principles not only recognizes this principle of fair and proportionate contribution, but also in parallel endorses the open Internet principle. So these principles are seen as complementing each other and very much co‑existing rather than somehow going against each other

So from our side, of course, the discussion then, if we look at the ETNO viewpoint purely, so what we are seeing is ‑‑ and Thomas I think already mentioned ‑‑ is this ever‑increasing Internet data volumes. And also the fact that the data generators, the data generators are more and more concentrated. So we are seeing that there is more and more, let's say, market power being concentrated to certain data generators. That leads to certain types of dynamics in the digital ecosystem in Europe. And some of those dynamics have to do very much with the business model and the commercial practices. Commercial negotiations between the two parties. So let's say let's call them the big Internet companies. On one hand. The European Telecommunications Sector on the other hand. What we see is clearly an imbalance in bargaining power between our two, let's say, camps, if you like.

And, of course, because we have the open Internet regulation in place, so we are not talking about pricing content, et cetera. But we are stepping back one step, you know, outside of the, let's say, in the value chain and this is especially can be seen in the IP interconnection market.

Then on the other hand, we also are receiving there seems to be a very clear asymmetry in terms of the application of extensive regulation obligations on the network operators but also then, of course, the fact that the global Internet giants are not subject to such a serious regulatory regime as our sector has been for many, many years.

So there are various, let's say, market imbalances that we are seeing. This combined with the data volumes, it is making the European digital ecosystem unbalanced. And also financially, frankly, unsustainable. And also here, I might add, that we have very ambitious political goals in terms of connectivity in Europe and other digital toggles, too. The European Union aims to have 5G and fiber connectivity 100% covered within the European Union. So there's, let's say, limited time to make this happen.

From our point of view, we're not talking here about Internet fragmentation or changes to the Internet infrastructure as such. The technical infrastructure. It is really about the business models that are running on top of that infrastructure in the digital ecosystem. And I think that's, hence, you know, we are seeing that this is rather a European business discussion that needs to be looked at that has a very specific European history. We're not actually then linking this directly into the open Internet model as such.

So maybe I'll just stop there and let others also make their first comments. Thank you.

>> SMITRI PARSHEERA: Thank you so much, Maarit. I think what we're going to do now is allow for a round of questions and comments from the audience online or in the room.

Just before that, I wanted to jump in because you mentioned a few times that you're obviously giving the ETNO perspective but saying how this is rooted in the European context. But there is clearly like with in policy debates, you know, contagion that flows into other parts of the world. I can say this from the Indian perspective, where I come from, we're already seeing where speakers before we have mentioned there's a strong net neutrality regime, a strong stance on zero rating that's been taken. In light of this discussion around fair share and contribution, we've seen telecom industry in India which historically has been advocating. Talking about regulation in other ways has also now started talking about government, the fair use. I think start of a discussion in Europe, for example.

In the case of net neutrality, this will certainly have repercussions beyond Europe. But it would be interesting to hear from others in the room on questions or comments around that. Let me open it. Are there any questions from the audience so far?

>> Anything in the room yet? We don't have the chat in front of us.


>> LUCA BELLI: Yeah, we aren't able to see properly the room. So Maarit or Thomas, if you see there is anyone willing to provide comments or ask a question, please tell us. Because you have the mic in front of us. Otherwise, we can keep with some comments, taking questions from the online in the chat. Or provide comments. Is there anyone in the room that wants to provide comments or questions? I don't see anyone. So, actually, we can ‑‑ I can take advantage to provide a quick comment.

>> We have one question.

>> LUCA BELLI: Oh, yeah. Sorry. Sorry. Please go ahead.

>> We have one question.

>> It's more a comment than a question. My name is Lars. I chair the IETF. The Internet Engineering Task Force. I think it's reasonable if geographies like the EU are concerned how they can encourage services to stay local. We at the same time need to be careful that we don't chorus the underlying global infrastructure into a shape that isn't optimal for serving the entire planet. There's the services then there's the infrastructure. And we sort of need to pay attention to when we try establish legitimate goal at the service level that we don't sort of make the Internet less efficient as an accident. Thank you.

>> LUCA BELLI: Yes, indeed. That's a very good point. Actually, I think we all agree that it's a noble goal to try to on the one hand have market players that have a very large size to contribute to the infrastructure, the development of information, the funding of information, and also at the same time try to keep local and distributed if we want the architecture of the Internet as much as we want.

We don't have to also forget that the majority, on the one hand, Midwest of the services, especially large platforms, do not only rely on traditional telecoms operators' infrastructure to provide their service. They also create enormous content delivery networks and they invest enormously in infrastructure. It may be a little bit an overstatement when we hear in some discussion that service provider are free riders. Because on the one hand, they invest enormously in this kind of local infrastructure. Enhance the quality of service for the users. Then on the other hand, it's also true that if large platforms add a lot of users, the users are already paying a fair share for using Internet access. So if you have a lot of users of a given technical operator using, let's say, Facebook or YouTube, they will be already contributing with the infrastructure costs that the traffic generate on the one hand by paying their monthly fee to operators.

And on the other hand, also, by having these services investing in networks and what has also been called the flattening of the Internet. So creating of the infrastructure. So it's also a little bit bizarre, if you want, to reconcile this what was mentioned by Commissioner del Vecchio about users driving this demand.

On the other hand, what was mentioned about the fair share and being a large platform that drive this traffic. It is very bizarre to have both these perspectives at the same time. Also remember that, yes, on the case of the user driving demand, again, in the case of zero rating, it's not really obvious that users are driving demand. Maybe it's the only thing that they are offered. I can give you ‑‑ I can provide example, Brazil. According to recent statistics, 99% of users use primarily social networking and instant messaging apps in their ‑‑ to connect the Internet. Again, I'm not sure that that is because ‑‑ that is their demand. It is maybe more because zero rating schemes are used by 80% of population, which is poor. So if you are ‑‑ I mean, let's not have a European mind for the moment, but let's think about most developing countries. Developing countries, the majority of the population is poor. So if you have to pay ‑‑ if you have zero rating where services are supposedly for free but you'd like to pay with your personal data, the population will choose them not really because they demand them but it's the only option perceived as free. Subsidized by large social media corporation.

And, again, no one here in this discussion I think is trying to be the advocate of very large platforms that have created a lot of distortions and concentrations and have for many reasons have a negative impact on the architecture of the Internet.

But perhaps a better way of having them contributing to social costs and negative externalities they might generate would be to tax them properly rather than asking a fair share contribution for something that other users already banking.

I'm introducing some provocation here in the debate so we can maybe have reactions from speakers. And also checking if KS Park is already connected or not. I'm not seeing him in the chat. I may ask you, again, Maarit and Thomas, to check if KS is in the room. I'm not sure if he will participate remotely or on‑site.

>> MAARIT PALOVIRTA: I'm not sure he identified himself. I don't know if I would recognize him. We don't have any hands up here.

>> THOMAS LOHNINGER: He's not in the room, sadly.

>> LUCA BELLI: We've lost KS. If we have replied from the original panelists, Commissioner del Vecchio had other commitments. She just left. If Thomas or Maarit want to comment, we can. Otherwise, we can pass it to the second session.

>> THOMAS LOHNINGER: To tie a few things up we just heard, I think one important thing, zero rating doesn't work like you take a pen and circle a few apps on your smartphone and they're magically excluded from your data cap. It actually requires commercial agreements between the provider of the app and the telecom operator. Every telecom operator that wants to zero rate them. And they also include technical identification criteria. So you actually as a telecom operator have to not only just transport the packages but have to open every package up. Look which application is inside. Depending on what you see, you count them differently. They either count against your data cap or not. They either still go through the pipe or they're dropped because you're out of data volume. You need to do something called packet inspection to do zero rating. That means there's a privacy cost for these types of programmes. And there's also a cost on the side of the provider of these applications. Most services can only afford between one and three of the zero‑rating relationships. Doing more is unattainable because they need to have 20, 30, 50, thousands of zero‑rating deals that are ongoing if you really want to be zero rated all across the world.

There's only one company that does this effort. And that's Meta. Facebook. And so we also have to see that the zero‑rating offers inherently tinker with the way in which the Internet was meant to work. We have so far no interoperability standard here also because, of course, it's not technical classes that are zero rated. It's famous and commercially strong brands of apps that get zero rated. There is a marketing underlying value why telcos are doing this in the first place.

And those two issues we're discussing today are interlinked. In Europe until last year, we had zero rating in all but two EU countries. So almost everywhere you had zero rating. That meant that exactly the type of platforms that the telecoms now say they are evil and they're cluttering up the pipes, they're sending too much data. Until last year, this data was free. This data was sponsored. Users were incentivized to use YouTube and WhatsApp. And so it's a little bit difficult to now turn around and demand money for something that until last year you were giving away for free.

And I also agree that this is not just something that can be looked at isolated in the EU. This will have global repercussions. Telecom industry doesn't want to be a pipe. They want to sell us more than just access to the Internet. They want to sell us individual services or get money from those services. And net neutrality prevents them from doing that. And whenever they see the other ways to no longer be are not possible, then they turn around and go the interconnected route. We'll see this debate replicated. I hope we can prevent it in Europe. But no matter if you succeed or fail, I fear that this debate will proliferate to other regions as well.

>> MAARIT PALOVIRTA: Can I go first? I'll make a few comments, Luca, on you say, provocations. One is you mentioned about the investment in CDNs by the big tech, et cetera. That is, of course, true. The amount of investment is not in the same category as, of course, the amount of investment that telecom operators put into the networks that we are building in network. But, yes, there is some investment going into CDNs and caches by the big tech.

Now, then you might still ask that are these ‑‑ whose benefit are these CDNs and caches working for? Who is the ultimate beneficiary? Because, yes, they are bringing the data closer to the user. But if you then look at the interconnection market in Europe, which traditionally has been defined by being transit, you now see various reports are saying that, in fact, CDNs are now becoming a substitute for transit. We had a recent report raising CDN as one of three ways to interconnect IP traffic.

You might say the big tech giants are closing in in the communication interconnectivity value chain and we should be looking at when we're talking about, for example, IP pairing, the conversation we have in Europe is no longer relevant. Actually, the whole market has changed so much that we should be looking at these things in a very different way. I think that's okay, yes, there's some value. It has at the same time changed dynamics in the market and our regulation and regulatory framework is no longer actually following.

When you were talking about the users paying more than once, et cetera. There the telecom operator point of view, the only reason we're in business because we have end user customers. We want to make sure they're still our customers next month. So we're trying to provide the best service possible and best quality possible to provide them the content that, indeed, they want to see and have. I don't think there's any secrets about that.

However, if you look at other markets, for example, I don't know, e‑commerce, postal service. So if you're ordering a packet from an e‑commerce platform, you're paying both for the packet or whatever product you're buying and then you also pay for the postal service. In this business model, sometimes it may be the consumer who pays for the postal service. In other cases, it is the e‑commerce platform who is also paying for the postal service. So this is not something unheard of. Actually, it's rather common. Also can be, you know, we can look at things like newspapers and other things. Right? So this is a very common business model. But for historical reasons, this hasn't been the business model for telecommunication operators.

So, yeah, maybe those are just one of the reflections. Maybe one more points on the users paying. So you made the point, Luca, that it's the user asking for the content. Well, indeed. That is the way. But what we also are observing is that the big giants on the platforms, they're also now using technologies in a way that they are, let's say, making it very easy and facilitating and pushing some content to a certain level. When we're talking about video, for example, YouTube. They are, let's say, compelling the user to use as much content as possible. So they're trying to maximize, in fact, the time that the end user would use on that platform. And this is because, of course, they get more money from advertisers if they can show that some person is spending two hours instead of one. And this is, you may argue, that is the users' choice in a way. Yes. There are also very kind of, well, different business practices that are being used to try and maximize the users' attention there. And we do not think that this is necessarily transparent to the user. But also not necessarily fair when you consider the total and the whole ecosystem. Thank you.

Now I pass it on to Lars who had another comment in the room, Luca.

>> Thank you. I could say a lot about what you just said. I think we're out of time. I want to go back to what you said about the zero‑rating infrastructure. So there's a push from vendors of telco equipment and interest from operators to put in infrastructure that administer basically resource scarcity, capacity scarcity. Right? That's money that's being taken away from building out capacity which they need to do, anyway. In some way, zero rating can be subsidizing the hyperscalers, the entrenched parties. Not making more capacity available for new players to enter the market or smaller businesses to have the ability to reach the customer. So it's a very dangerous sort of slippery slope. It sounds very attractive, but there's a lot of downsides to it.

>> SMITRI PARSHEERA: Thank you. Thank you so everyone in the room. With that, we're going to transition to the second phase of our panel discussion. Before that, there was one comment in the chat from Sabelo. I think that speaks to the Indian example that Thomas was giving earlier. I'll quickly address that. He talks about how when zero rating was removed, the data costs stayed the same and actually increases. I wouldn't say it's causation. It's just correlation. What happened, around 2018, there was a ban on zero rating and there was the entry of a new telecommunications player in the Indian markets which completely transformed the way the market works. Dynamics, competition of prices, were dropped. These two things happened in parallel. Which supports the thing it doesn't mean it's all gloom and doom and success and progress. I wouldn't say it was as a result of the zero‑rating regulation. It was a parallel development that took place.

But with that, now let me invite Angela Daly, who is a professor at the University of Dundee, to come in and give us her intervention piece. Angela, over to you.

>> ANGELA DALY: Hi, everyone. Just give me a second.


>> ANGELA DALY: Hi, everyone, I hope you can hear me and see me okay. Thank you very much for inviting me to speak. Yes, sorry, I can't be there in person for what sounds like some really good discussions.

So I'm going to talk following from some of the previous interventions, particularly in the European perspective. I'm going to talk hopefully very briefly about the situation in the United Kingdom. As you probably are aware, over the last couple years, I want to point to developments around net neutrality which are currently going on there, which are similar to what's being proposed in the European Union. Very similar dynamics in the debates. But because the UK is now kind of out of EU law or jurisdiction of EU law broadly speaking, there are local divergences.

So basically, from the UK perspective, also from the academic perspective, net neutrality had been a topic which generate add lot of discussion and debate up to the 2015 Net Neutrality Regulation. The UK was still a member of the European Union at that time and so current UK law reflects the EU's Open Internet Regulation for Net Neutrality and has not been changed since the UK left the European Union. There was a lot of debate around net neutrality in the UK and other parts of the European Union. In more recent year, there's been less attention and particularly less academic research about how those ‑‑ how the regulation has been implemented. What actually happened. Academic attention has shifted to other issues. Particularly when it comes to telecoms and the Internet, it's shifted much more toward what is now in the EU, the Digital Markets Act and in the UK is the Digital Markets Unit. So issues around the rule of telcos, in particular the rule of net neutrality, has it worked or not worked, has been a rather neglected topic at least among academics.

About two years ago, myself and some collaborators at a university based in Scotland, in the UK, we decided to revisit the issue of net neutrality. And just for full disclosure, we wrote a report which was funded by British telecom, VT, but doesn't reflect the views of British telecom. Reflects our own views. I think it's important to discuss this was a funded research and briefly released the report over a year ago. I generally found that net neutrality has been generally enforced and reasonably well followed by telcos and others in the UK as in other parts ‑‑ also, sorry, in other parts of the European Union. Issues that remain kind of difficult and not necessarily that well resolved. As I'm sure you can probably discuss from the preceding discussions on zero rating and also the role of Content Delivery Networks, CDNs.

What has happened since we released the report ‑‑ and I'll share a link to it in the chat ‑‑ is the UK Telecommunications Authority has released some of its current thinking about net neutrality in parallel to developments going on in the UK around the Digital Markets Unit which is a similar kind of intervention to the Digital Markets Act in the European Union. And but is not yet legislated. So it possibly early next year will be like new legislation around the Digital Markets Unit in the UK and aimed at large online intermediaries.

But in the interim, they have released a new kind of consultation, on its new thinking around how to implement the current net neutrality rules. So it's proposed some revisions to its guidance on how net neutrality rules should apply in the UK. This is still within the framework of the current legislation which as I mentioned still reflects the EU's open Internet regulation. Essentially, what Ofcom is proposing is various clarifications around the kinds of packages and specialized services that Internet service providers can offer as it claims is? The current rules including things like what traffic management measures can be used to deal with congestion and what zero rating packages are appropriate or not.

I think one of the previous speakers said that zero rating ‑‑ maybe I am mischaracterizing this ‑‑ but zero rating is kind of prohibited in the EU. Think it's a little bit ‑‑ maybe I misheard this. It's not at least the case in, sorry, the UK where some forms of zero rating have been allowed as long as they don't impact too negatively on competition. The UK is taking a very competition, or supposedly very competition‑driven approach to the issue of net neutrality and zero rating. Not so much kind of I would say a consumer‑oriented or rights‑oriented approach.

One thing, though, to note, which I think maybe is a feature of the UK but it would be interesting to hear from others about what is happening in their countries and jurisdictions is the use of zero rating in a kind of public interest way. So during the COVID‑19 lockdowns in the UK like many other places there was a correspondingly large use of data and Internet services and so on. In fact, some public health ‑‑ the UK has a public health system. The National Health Service. A universal public health care system. So some information that was available in the National Health Service was actually not zero rated so you could access that without using any data allowance. And there was also ‑‑ there were also discussions about whether certain education materials would be zero rated. Particularly to people from low‑income backgrounds who had children at home who were remote schooling. In the end, that didn't happen. These discussions, the health information did happen. I believe, although I'm not entirely sure about this, it was based on the goodwill of telcos that they would not charge data. I don't know if there was a formal contract or agreement between the government and the health service and the telcos. That is kind of an interesting feature. As we discussed at the time our report was launched last year, we're not entirely sure that zero rating, that content in a kind of public interest way entirely complies with net neutrality rules. I don't think net neutrality rules especially around zero rating were really conceptualized as being something that would facilitate genuine public interest access to certain forms of information. But it seems that that did happen sort of. In the UK. And at least was no negative enforcement action was taken against any of the telcos that did that.

Ofcom is also proposing in its clarification of the guidance is to facilitate certain kinds of prioritization and zero-rating access from a public interest perspective, for instance, to emergency services which I think is a kind of interesting intervention. I've not seen it so much happen elsewhere. Yes, we had the debates around Meta and zero rating particularly in emerging economies and how I guess ostensibly there's arguments this is in the public interest where there's actually not ‑‑ where it may not be. But I think in the UK case, we have some examples of zero rating of genuinely public interest content. And it's a bit unclear to me whether this is compatible with current net neutrality rules or not.

At the moment, Ofcom is consulting on these proposals. As I mentioned already in the new year, there will be likely more going on about the Digital Markets Unit about the kind of relationship between online and intermediaries and other areas including telcos. It remains to be seen how net neutrality may or may not fit into that. But it will be interesting in my view, anyway, to watch the UK and see how this proceeds next year. And also to what extent there is convergence or divergence between the UK and the European Union. The UK is not within the European Union anymore, it does have a trade agreement with the European Union in which, from memory, there are net neutrality provisions. If the UK did depart kind of substantially from what is going on in the European Union, could there be a trade issue about that? So one to watch. I'm interested to hear if anything that I've been saying about net neutrality, zero rating in the public interest, is turning up elsewhere. Thanks.

>> LUCA BELLI: Thank you very much, Angela. These were excellent comments. And before I give the floor to Sabelo, I just wanted to react quickly to this. Because there is actually ‑‑ this is a very good example of how actually zero rating could be something also used for the public interest. There are countries like Jamaica ‑‑ there are very few countries, but there are countries that are zero rating public online services since many years. I think Jamaica was the first one since 2017. Public services ‑‑ online portals for public services are accessible without consumption of data allowance. And this is a very good example how this could be interesting to use in practice.

Again, let's remember that this ‑‑ we have spoken a lot about Europe. These practices are extremely widespread in the Global South where people do not have the money to pay for Internet access.

So what is zero rated is frequently what is the Internet experience for many people? That is a very strong dimension of Internet fragmentation, if you want, zero rating can produce negative externality. The fact the Internet becomes only a couple of platforms that are zero rated.

And the interesting ‑‑ think what is interesting ‑‑ we did actually a study with this coalition in 2018 mapping what kind of services were rated at the time. In 2018, the most interesting finding I think was that in 100 countries that we analyzed, in 98 out of 100, platforms that are part of what's now called the Meta were zero rated. There's one player that is actually subsidizing access to its own platforms around the world globally. And at the time, there were only one country that was subsidizing access to public services. So imagine, for instance, if you have to pay taxes online which happens in most countries nowadays, you have to pay for Internet access. If you want to ‑‑ you have online education during a pandemic, you have to pay for it. Whereas, if you want to watch selfies and or disinformation on social network, that is subsidized. And it's allowed. It's a very also important social distortion which we have in mind. And, again, we should also have in mind to try to mitigate these kind of distortions which will not create other distortions. It would be much better to regulate properly taxation, regulate properly information. Also to understand that all these things are interconnected. Maybe the greatest distortion we have at this moment is we still are focusing in a kind of regulation that is in silos. Data protection regulation completely separated from telecom regulation. Completely regulated from content regulation. We should start to look at this from an interconnected perspective. Because that is the kind of holistic perspective. It will allow us actually to have a sustainable governance and regulation.

Sorry if I'm speaking too much. I think it's time to introduce our ‑‑ I still don't see KS. Neither online nor on‑site. I think it's time to introduce our last speaker, of course, not least, Sabelo. The founder of Bhala. He has a very interesting perspective, actually, of the other components of Internet that we have somehow neglected so far. Interoperability and device neutrality. Also because he has some very personal history to recount about how the distortion that the lack of interoperability or device neutrality can produce. So, please, Sabelo, it's a great pleasure to have you with us today. The floor is yours.

>> SABELO MHLAMBI: Thank you, Luca. Thank you to all the previous panelists. This is very insightful. Very happy to be joining you all.

I just would like to ‑‑ net neutrality and device neutrality. The Sub‑Saharan African perspective. Zero rating? The African content, Sub‑Saharan Africa, is shaped by two realities. The first one that Africa has the largest share of the world's least developed countries. It also has the highest costs of data. You have people with the least amount of spend paying most amount. Sometimes African pay three times the cost of data that they'd normally pay for in the United States. Zero rating is seen a little bit differently. We can compare that to what happened in India. When Meta and Facebook went into the region and met some resistance.

So they took those lessons and they repackaged themselves and apply the same policy. They were successful. Very successful, actually. So one thing that was quite surprising was that even the NGOs, they were quite supportive of zero rating by Meta. And Twitter and these platforms. Because they saw them as sort of a democratic means to promote open debate on issues of social importance. As a way to prevent government censorship. Especially during Internet shutdowns or when there's issues of great public interest.

And so the NGOs really took a different approach than NGOs in other parts of the world by really quite embracing zero rating.

The zero rating also includes Internet infrastructure such as hot spots. Public hot spots provided by Google. Recently, we've seen Internet backbones by Meta and Google being built under the ocean all the way to the African continent. Google just connected their last backbone to South Africa two to three months ago. And, again, this is not met with resistance, issues of privacy, access, or competition. They are really not quite discussed.

Something else that's quite interesting, too, is that the zero rating is also pushed by ‑‑ it's so popular that the telecoms also offer zero rating for people who can pay for it. So if the company wants to have their product, their app, their website zero rated, you now have this commercialized process. So you can then go and pay to have your service made accessible to other users.

But, of course, this only benefits those who are able ‑‑ the companies that are well funded. Often western or eastern companies that can go in there and pay the high cost of the Internet. In order to make their services and data quite profitable.

Something that makes it much worse as well or compounds it is in the content, mobile is first. So mobile phones are the primary way of accessing any type of connectivity. Any type of data or Internet. So now we see telecoms becoming more than telecoms. Now they're becoming banks. They're becoming ways to shop. Ways to pay for your bills. Ways to spend money. They also employ the same tactics where they give the advantages to themselves. It becomes harder for the private industry to then try to create competing services as well.

So this is one aspect with the telecoms. I like to also look at the app platforms such as Google Play that are prevalent within the continent. What Google does is quite interesting from a developer perspective. I'll give a quick example for my company. We made an African language keyboard that users could access if they want to communicate in their own languages using artificial intelligence. Offering things such as spell correction, next‑word prediction. And the rest.

What is interesting is that when you have a large big tech company that controls the platform for other apps, they tend to have certain advantages that they give to themselves. If you install any other keyboard on the Google Play store, you get this big warning saying, oh, be careful. This app can take your credit card information. Your privacy. Theoretically, that is all true. However, if you install Google's app, there's no such warning. Right? Even though they can do the same. Even though we know that they do the same. That we know there's some privacy issues, data harvesting by these companies. You don't see the same policies, the same warnings, placed on their apps. But they're placed on other competitors.

So in the minds of consumers, this creates this illusion that, whoa, is this service or app by my fellow developer within the same country, is it reliable, safe, and so forth?

Then going from the app store platforms, now even with device neutrality, half of the cell phones made or sold in African continent each year, they come from a single Chinese company. They come prepackaged with the apps that the same manufacturing designs. So you have social media duplicates of YouTube, TikTok, Instagram, WhatsApp. They're prepackaged. It's hard to offer alternative competing apps because they control half of the mobile smartphone ecosystem. Then they decide what gets on those apps.

If you have a high cost of downloading apps ‑‑ there was a study done in South Africa that demonstrated most people ever install just five apps on their phones. Nothing more. Due to the devices having lower storage, lower memory. When you have a manufacturing pre‑installing apps or have some apps that are zero rated or free, and people having such a short limited amount of apps that are possible that they can install, it then, you know, it sort of breaks the promise of the Internet being this open infrastructure marketplace with a low barrier to entry. The barrier essentially becomes quite, quite, quite high due to the limitations. And, unfortunately, this is something that is not quite addressed well.

We're seeing now that phone manufacturers in the African continent, they assemble the parts to make the cell phone. Often, they want to use the most popular operating system for mobile phones which is the Android system. Then to use the same Android system, Google requires you to install a basic set of apps that they make. So this could be like Google Chrome, Google Search and so forth. And so if you ‑‑ the Google keyboard. If you don't install these apps, as a phone manufacturer, you can't use the operating system which now keeps you away from your users who are used to using the Google operating system. So this also gives an advantage to, you know, these large tech companies.

In addition to that, in many cases, they'll offer paid incentives. They say if you install our search engine, we'll pay you ‑‑ I forget the exact number. It's, like, maybe 8 cents per search or something like that. Now the companies are now getting paid by Google to install those apps. Now if you have a competing service, you now have to offer the same deal. Okay. We'll pay you for every device that uses our app and so forth.

The main issue there is that the greatest damage to this is that it lowers the ability for the local ecosystem to merge to create localized solutions that are designed by local developers, designed by local companies, to serve the local markets. Then it allows foreign companies to then come in and shape entire ecosystem. I think it was Thomas earlier who spoke about digital colonization. This is another instance of that. Where now the local ‑‑ now you're not able to create your own local infrastructure. You have to depend on the finished goods being sold back to you. So the data is being extracted but giving back the finished goods and keeping sort of, like, the continent as the fastest‑growing digital marketplace is the is entirely dominated.

Zero rating affects quite a lot but there isn't much, a lot of policy or resistance that we can see at this particular moment compared to the conversations which we're seeing in Europe. What happened in India. We just heard earlier from similar efforts in Colombia to sort of assess zero rating. But, you know, it's not quite as pronounced and strong unless you're in Sub‑Saharan Africa. This is something I hope the entire sort of community can take into account when we're thinking about the scope of these tech companies and the influence across the world.

>> LUCA BELLI: Thank you very much, Sabelo, for this really excellent remarks. That really let us understand the complexity of the issue.

Unfortunately, I thought that our deadline, the end of our session was at 45. Actually, I just noticed it was at 35. So we're already three minutes above our deadline. So I would like to use this remaining two minutes that I'm sure the IGF technical team will give us to see if there's any final remarks from our panelists that should be extremely quick. Do we have any final remarks? Either from people on‑site, panelists on‑site or online? Otherwise, we can start to wrap up.

It looks like we don't have any final remarks.

>> MAARIT PALOVIRTA: Quick word of thank you from the venue. No substantial remarks. A really good discussion, I thought. Nice to hear views from around the world on this important topic.

>> LUCA BELLI: Thank you.

>> THOMAS LOHNINGER: Thanks. Here from the room, we had great participation. Sadly, there's another session starting here physically quite soon. There's a little bit of time pressure. But I think it is obvious that we need to continue the discussion. And thanks, everybody, who participated.

>> LUCA BELLI: Thank you very much to everyone for the very fantastic presentations. And very lively and excellent discussion about a lot of very different dimensions of Internet openness from a lot of very diverse perspective around the world. I think it's something that is very evident is we really start to have to analyze the complexity of the issue from a multilayer and multidimensional perspective. And do not only focus on either the access and network layer are net neutrality or the platform and up layers, content layers. We have to start to interconnect the full stack and try also to understand how this, not only how these layers are interconnected and impact on one another, but also how regulation should be thought in a way that considers the positive or negative externalities of any player on the other layers as well.

Thank you very much for the excellent discussion. And we will see you at the next session of this coalition next year. I wish you an excellent IGF 2022. Chiao-chiao.