IGF 2021 - Day 2 - WS #77 Antitrust regulation of Internet platforms in global outlook

The following are the outputs of the captioning taken during an IGF virtual 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.

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>> We all live in a digital world.  We all need it to be open and safe.  We all want to trust.

>> And to be trusted.

>> We all despise control.

>> And desire freedom.

>> We are all united.

>> MODERATOR: Well, thank you Yik Chan Chin.  Would you like to kick us off as the remote Moderator and then I will jump in?  Okay.  There you go.

>> YIK CHAN CHIN: Hi, everybody.  And dear participants, no matter you're online or onsite.  Welcome to this workshop of the antitrust regulation of internet governance in global outlook.  This workshop organized by the (?) be and the IGF.  So I'm Yik Chin from Beijing University and the steering member (?).  So with my other three colleagues, Alison -- Alison here?  Not yet.  Alison and Courtney, Courtney is on site and also Ana is there, is online.  So, three of us will moderate this workshop.

So, this workshop is to explore the way competition policy authority in EU, China, U.S.A. and the South Africa, how do they react to the (?) of the internet platform and whether they are --

(Audio difficulty)

(No audio).

>> YIK CHAN CHIN: For minutes for the region they covered about antitrust in -- of the internet platform.  So, then after that, we have a second part, so, basically, second part each speaker will have a particular question to share with you.  And then the third part will be open the floor to the audience for Q&A questions.  So, in the end we will ask each speaker to wrap up with one minute, one sentence to conclude their remarks.

Okay.  So, this is -- so this is a brief introduction of the workshop.  So, without any delay, I would like to introduce the first -- the five speakers.  So online five distinguished speakers today.  So, the first one we have Ms. (?), yeah, can you wave your hands.  Yeah.  Yeah.  Senior partner from China.  And Jet Deng is the chair of China's competition and antitrust practice.  He is a very experienced lawyer, especially in antitrust -- data privacy protection and data dispute resolution.

The second speaker is Dr. Qing He.  From China.  Dr. He is a system professor in competition law and the internet law and has a Ph.D. in economic law.  Published extensively in antitrust (?) platform.

Our third speaker is Mr. James Hodge.  An honor to have James, too, because he is the chief economist and acting adaptive commissioner at the self-advocates competition commissions.  James, could you please wave.  Say hello to everybody.  Thank you very much, James.

Also Mr. Hodge is also the commission's chair of the online platform market inquiry.  I think many of you already know that in May 2021 the commission initiated online intermediation (?) inquiry in self-advocate.  The inquiry finished two runs of written submission and one online public hearing in November this year.  So, the antitrust stake is high in South African.  So, we are looking forward to James' theory.

The last speaker is Mrs. Albana Karapanco.  Hi.  And she is the advisor to the Minister of the Finance and the Economy of Albania, and also senior associate of the Nico surveys at the PWC Albania and the (?).  So, she's assistant professor and also a lead panelist.

So Albana, (?) degree in the international and the trade (?) from the University of New York.  She run under the University of Greenwich in London.  So, we know that you has the most of the ones the court practice and also most of the ones that legislative element.  So we are looking forward to Albana Karapanco sharing with the insight of EU framework.

So, last but not least, we have Professor Milton Mueller.  We know him well.  He is a professor at the Georgia Institute of Technology, School of Public Policy.  And he is a specialist in the political economy of information and communication, also the cofounder and director of the Internet Governance Project, and also a founding member of the (?). 

So, because the antitrust of digital platform in the U.S. is also highly debated in the east at the moment, so it's a host internet platform such as Facebook and Twitter.  So therefore, professor moon input very significant.

Without any delay I pass the floor to our first speaker, Jet Deng.  Thank you.  You have four minutes.  Thank you.

>> JET DENG: Thank you.  Good morning, good afternoon, good evening.  (?)

>> We ask you to please use headphones or move your Mike closer so we can hear you better.  Thank you.

>> JET DENG: Okay.  Is this better?

>> MODERATOR: Yes, thank you.

>> JET DENG: Okay.  So, I will give you a picture of the antitrust litigation of the platforms in China.  And, actually, this is not quite hot topic in Chinese community.  But the start was quite different, even 14 months ago.  And China is use the antidevelop rule in 2008.  That was significant.  But from 2008 and here 2020 --

>> MODERATOR: I'm so sorry to interrupt but we cannot hear you well, which means that the captioner is also unable to correctly caption the speaker.  So we are going to ask you to -- Yik, I would suggest we go to the other speaker and suggest the professor get a better audio situation.  Maybe use headphones to make sure we are capturing this for the IGF.

>> YIK CHAN CHIN: Use a headphone.  We invite the second speaker to talk or speak first so you can get some time to do that.  Please, go ahead, Qing He.

>> QING HE: Good morning, good afternoon and good evening, everybody.  It's my honor to make this speech here.  And I will make it as quick as I can.  Okay.  Let me share the screen.

Okay.  There will be couple of key words during the speech, like the platform monopoly to choice 1, means urgent in Chinese and the leverage theory essential facilities.  And the main issues will be included in this page.  Please look at (?) site.  The first issue we have to talk about is about the framework analysis, for analysis when we have to decide whether the platform is illegal or not.  The first issue is to define the relevant market.  And the second issue is to determine the market power.  And for the first two issues, actually, we have detailed regulation in China.

For example, we issued guidelines on relevant market definition and entering rules on the prohibition about abuse of dominance and antitrust guidelines platform economy.

And the for the last one, we have to decide whether the platform monopoly has the competitive effect on the digital markets.  It means that we have to compare the advantages in providing efficiencies with the disadvantages in restricting competition.  During this process we have to decide whether there is objective justifications when the platform, you know, conduct abuse.  And it is the most important issue.  And for this one, in legislation, actually, in China we were already regulated in the interim rules, just as I mentioned above.

In practice, actually, there will be cups of justifications for the varieties of conducts, for example, for the exclusive dealing, the incentives for manufacturer training and the information will be considered.  And for (?) the product design improvements will be considered and the refusals to do, to prevent theft of intellectual project will be considered as well.

So, it means that, actually, it is difficult for the people to file the complaints about the platform monopoly.

And look at this page.  We can see in the decision, the final decision on Alibaba, there is lax in justification.  For example, the Alibaba coerced the operators within the platform to comply with to choice 1 policy, choose 1 from 2, I mean.  But whether it is the same as the illegality of the platform monopoly, we should talk about it further and why there are a number of compliant operators who, actually, do it as the Alibaba required.  So we can see, actually, there is leverage, power behind it.  And the leverage, power, it is also regulated in the interim rules and the guidelines in China.  It is the marquee power of the operator in the associated market.

And about another issue, it is the essential facility -- it is the essential facilities doctrine, whether it can be used to decide whether it is illegal or not and actually in practice in the Alibaba decision, it is also used, although it is not so specific that the platform can constitute the essential facility or not.  But, actually, it has been mentioned.  And also in guidelines it's also mentioned that what kind of factors we should be considered and should decide whether the platform can be considered to be illegal.  I think that's all about my speech.  Thank you very much.

>> YIK CHAN CHIN: Okay.  Thank you very much.  So, then can you stop the sharing, please.

>> QING HE: Oh, sure.

>> YIK CHAN CHIN: Okay.  Thank you.  Next speaker we want to invite Milton.  Professor Milton Mueller.  Hello, Professor.

>> MILTON MUELLER: Can you hear me?

>> YIK CHAN CHIN: Yeah.

>> MILTON MUELLER: I think what I can bring to this discussion is a relevance to the U.S. situation.

>> MODERATOR: Before you go on, could we please stop sharing the screen of the slide show from the previous presenter?  Thank you so much.

>> QING HE: Sure.

>> MODERATOR: Please go ahead, Milton.

>> MILTON MUELLER: Okay.  So, the United States has over 100 years of experience with antitrust, and in particular we have experience with the problem of network externalities, which is, some of may have heard of as network effects or the idea if your network has more people on it, it's more valuable and that creates a feedback loop, which means that you end up with self-reinforcing of dominance.

So, I think one thing we need to understand about platforms and about antitrust in communication and information industries generally is that compatibility relationships and network effects are extremely important and powerful and society has a very unstable view of this.  So, let's talk about AT&T and the AT&T monopoly.  So, we had incredibly robust competition in the telephone market for 25 years, from 1895 to 1920.  And there was a robust definition about, oh, my gosh, AT&T is taking over.  We need to stop the monopoly, the anti-trust authorities intervened.

But at the same time there were people saying, no, we are tired of this fragmented telephone universe because we have these competing systems that don't interconnect with each other, so we want there to be a monopoly and we want to have a regulated monopoly.  And ultimately that model won.  So in 1920 we passed a law that said the telephone system shall be a monopoly.

And then 50 years later we accuse a telephone system of being a monopoly under the antitrust laws and we eventually broke up AT&T.  However, we did create an interconnection regime that allowed the competing companies to interconnect.

Go forward quite a few years and talk about the Microsoft case.  We had a very critical antitrust case against Microsoft between 1995 and 2005.  It really took 15 years to play itself out.  But most of it happened between '96 and 2000.  And again the issue was compatibility relationships and the network stern externality.  So Microsoft was winning and taking over the market not so much because of its aggressive tactics, although that did play a role, but fundamentally it was compatibility.  People wanted their operating system to be compatible with other people using personal computers, so they became more and more, everybody came more and more sucked into the Microsoft operating system and applications environment.

What ultimately broke that monopoly was not so much antitrust activity, but the rise of middleware in the form of Java that made browsers possible and you could run applications independently of the Microsoft operating system.

So, I think we have the same issue with today.  We have these gigantic platforms and they are major economies of scale and major networks of externality that make them so big.  But we have to decide whether we want to sacrifice compatibility and integration across these platforms for the sake of competition or whether people actually want this kind of compatibility.  I will leave it there.

>> YIK CHAN CHIN: Thank you very much, Milton.  And I think James probably can come back to your question, because in South Africa they are proposing these inquiries right now.  But before that, let's go back to Jet Deng.  Hi, Jet Deng, can you speak now?

>> JET DENG: Yes.  Sorry for the bad audio right now.  I hope this one is better.

>> YIK CHAN CHIN: Much better.  Please go ahead.

>> JET DENG: Okay.  You know, right now the antitrust regulation of the platforms, actually, in China is quite hot topic.  But at the start it was quite different, actually.  If we go back to 14 months ago.  You know, in China we introduced the anti-Murphy law in the year of 2008.  That was 13 years ago.  But for the first -- I would say for the first (?) years there was no one single case intermorph any antitrust enforcement there in the internet industry.

Then we, all of us, we are really surprised to see in the past one year there was actually quite a significant enforcement, like the Alibaba case, in which the Chinese Antitrust Authority imposed 3 billion U.S. dollar fine.  And also the (?) case, the delivery in the platform (?) in which the authority imposed 0.5 billion fund.

So, that is something we will see quite different for the past between the last one year and the preceding half years.  So here we observed this on some kind of a draft from the Chinese top leadership.  So, as a local practitioners here in Chinese antitrust community.  So, obviously, this signals some kind significant that those -- a (?) land of the Chinese consumer policy regarding the antitrust regulation of the platforms.

And also from the technical side we will see, actually, there's no big difference if we compare those penalty decisions of the Chinese cases and those decisions made by the authorities can pass.

So, I just want to share with all of you this kind of consumer policy trend here.  And I hope to go further in detail, intermorph the antitrust regulation of the platforms maybe later for those cases.  Thanks.

>> YIK CHAN CHIN: Okay.  Thank you, Jet Deng.  We will have a second part for discussions so we can ask you further there.

The next comes to Mr. James Hodge.  He is the Deputy Commissioner at the competition authority in South Africa and also the chair of the inquiry, the platform inquiry.  So, James, can you respond here?  Can you hear me?

>> JAMES HODGE: Yes, I can.  Very happy to just give a brief introduction.  And then we can come to specific questions later.

>> YIK CHAN CHIN: Yeah.

>> JAMES HODGE: I think like was outlined by Mr. Deng, it's a journey for many of the competition authorities, the online markets.  It's something that has, sort of, crept up on us over time.  But moving from position of, sort of, passiveness to active enforcement does require quite a shift and I think the first shift is just educating and understanding what are the business models and consumer behavior that separates online world from the traditional markets in order to then understand what might be new theories of harm or different theories of harm or even just determining market power.

So, the fact that consumers may navigate to one site, the fact that dual search may be the dominant platform directing people, all have an impact on assessment of the market, market power, as well as the types of theories of harm.  So, after, sort of, online intermediation, it's more around not necessarily consumer exploitation because it's free because exploitation of sellers and it's a buyer power type relationship.

Same in advertising models.  It may not be, let's say, exploitation of consumers on the price but exploitation of consumers on their privacy and their data.  It is quite a mindset shift.

I think the second thing for South Africa is also to think about strategically for ourselves.  We are a small developing country at the tip of African continent.  And we are not directly, necessarily, overseeing a Google and the Facebook such as the U.S. or Europe might have that.  So, we also have to think about it strategically, where do we position ourselves?

Certainly we found on global mergers there's far more of an ability to participate, even as a smaller country, and maybe one more representative of our region and our continent.  So, although initially we were not notified of the Facebook WhatsApp merger, because there was no revenue generated in South Africa, we did force Google to notify their Fitbit merger and became part of a global group of jurisdictions looking at the merger.

And I think that is important to point out, because I think both the authorities and even the companies are starting to realize that there needs to be a better level of coordination at a global level.  To come up with different regulations or different even remedies in a merger context for a firm that is global by its very nature can create quite a lot of complexities.  So, that is one way we can, I think, move along with others and add our voice to that overall assessment.

I think with the conduct cases, again, seeing what has been happening in other jurisdictions does provide you with insights into what may be going wrong in your own jurisdiction.  So because some of the same companies appear across the globe, if Google is being investigated for something in the U.S., chances are that conduct may be having a negative effect in the South Africa economy, too.  There may be differences because certainly we have home grown platforms that dominate or lead in certain areas other than social media and search.  But even there, the business models get copied.  So, even if it's what is happening to booking.com in Europe, we might suggest that the same sort of conduct and effects might be present in South Africa even if it's not booking.com that is the leading firm.  So I think there's an important part of strategic focus of authority.  And obviously the U.S. and Europe have focused on your bigger platforms.  I think for a country like South Africa we have also got to focus on our homegrown platforms and conduct amongst them.  Because what has often happened in the smaller developing countries is that local platforms emerge mimicking the business model of the global ones, and only later may the global platforms arrive.  So, there are subtle differences, I think, in strategic approach that we take.

Maybe last thing to say is the importance of cooperation, not just globally, which I have mentioned, but nationally.  You need to be cooperating with the information regulatory on privacy issues.  Because competition authority may want more data sharing to promote competition.  But that may be the antithesis to what the information regulator is trying to achieve.

And, obviously, across other cities of government, which may be involved in the regulation of the industry dealing with the online economy has required far greater levels of cooperation than we previously had.  I will stop there, Yik, and take questions later.

>> YIK CHAN CHIN: Yeah, thank you, James.  It's very important issue James just mentioned about the cooperation and the global scale of the antitrust.

In that sense, actually, invited our last speaker, Albana Karapanco, she is the advisor to the Minister of Economy in Albania.  Albanian is candidate countries for the EU.  She will share both EU situation and also Albania's situation.  Thank you.

>> ALBANA KARAPANCO: Thank you very much.  I just terminated my term as a legal advisor to the Minister of Finance in Economy because we had a change of the government, and I'm currently -- I work in PWC, actually, as a lawyer in Albania.  But that has been quite insightful experience.  It's a pleasure to be here.

While based on all the speakers that I have been hearing so far, so the situations everywhere in the world is very, very similar.  So everyone is pushing towards this new antitrust regulation.  And I think and we have noticed that European Union has taken quite a tough approach, which has resulted in very lengthy court procedures generally towards the big tech.

While there is a realization that what is the basis of competition law in treating and the function of the European Union, Article 101 and 102 and also the regulation is not enough to respond to the current platform economy, actually.

So, basically, since -- well, Europe, European Union compared to others has counts around 10,000 platforms.  Most of these are startups and they account only for 2.7% of the global total value.  And in order to be included in the global top 10, the minimum company value has to now rise into 5.5 billion Euros.  There are only 12 European companies in the global top 100.

This new ecosystem has required for new regulation.  And the EU regulation on platform to businesses relations and force in July 2019.  It is the first -- it is considered to be the first ever set of rules creating the fair, transparency and predictable business environment for smaller businesses and traders on online platform.  Nevertheless, given the pandemic and all this increase of the use of platforms, the European Commission considering also the several case laws has decided to propose since last year an additional set of rules for the digital space that consists of two complimentary acts, the digital service acts and the digital market acts.  This was published last year, actually, December 2020 and the new rules are expected to create both a safer and more open digital space for all the users, and also to protect their fundamental rights, but at the same time to lead to fair and more open digital markets for everyone by fostering innovation, growth and competitiveness.  The scaling up of smaller platforms, small, medium size enterprises and startups.  It is supposed to be supported by facilitating access to customers across the whole single market.

These two acts, actually, are also being criticized, strategically speaking they are expected to have much higher impact and much more important, the general data protection.  They compliment one another, but then the results are to be seen in taking here from the word of the previous speaker.  There is also a need to consider all the international scenario and see what is -- how can -- how can all this regulations somehow be coherent with one another, right?  Because all the continents and all the countries are working toward regulating them.  But then some cooperation would be needed on a global scale.

It was just a few weeks ago, actually, when the general court of rule dismisses Google actions against the decision of the commission finding that Google abused its dominant position by competing with comparative shopping services.  And the court decision recognizes that the anticompetitive nature of the practice at issue.  Also they found harmful effects on the competition.  So, basically, what we see is a tough position of European Union towards the giant techs.

One of the concerns that is raising in the mind of experts in the field, actually, is whether these two acts, one the entering force digital service package of the European Union, can they have some -- can they work to the disadvantage of the EU, considering that, actually, most of the big techs, they are homegrown outside European Union.  And there are very few startups.  There are few startups compared to others.  And just based on the latest data that I read, just one (?) is here in European Union.

We will move to Albania.  But then I will leave it to questions.  We are quite lagging behind in that regard.  The Albania is negotiating chapters so the legislation is being approximated.  Our consumer protection are quite old laws.  E-commerce is also an outlaw in Albania.  So I think it will be the next decade that will show how we are going to cope with everything that is happening.

The last errors that showed, the last errors that index showed, actually, that consumers in Albania, they don't use online platforms so much, which is somehow not true, actually, due to informal economy.  But that's very typical and specific to the economy of the country.

Okay.  I will leave it here for the moment.

>> YIK CHAN CHIN: Thank you, Albana.  Now we just have a few questions from the panelists that you answer before we move to the Q&A sections.  And so, first I would like to ask the two Chinese speakers.  So, there's one particular question is about do you think the Chinese approach is different from the U.S. approach?  What is the major difference?  Can any of you give some ideas.

(Non-English language).

>> YIK CHAN CHIN: Hello?  Can you hear me?

>> QING HE: Yes.

>> YIK CHAN CHIN: Please go ahead.

>> QING HE: I think I can share some of the ideas.  Actually, I think there are couple of differences between the Chinese approach and the U.S. approach.  For example, as for the regulation of the abusive conduct, in legislation both sides have this kind of regulation on the abusive conduct.  But in legislation, for example, in the U.S., they actually focus on illegally maintain the dominant position that a platform have already got.  But in China we will focus on the abusive conduct itself.  Which actually we can use the leverage theory.  Because in the U.S., actually, the leverage theory is not supported in most of the cases.  Like the well-known Microsoft case.  The leverage theory is not supported in that case.

And for some other traditional theories, like the essential facilities, both of countries are conservative in the application of essential facilities doctrine to the digital market.  But, like, I have already mentioned in the PPT, China has already tried to specifies it in the legislation about on what kind of factors we have to consider to decide whether the platform can constitute the essential facilities or not.

But in the U.S. it is, sort of, more conservative about this issue.  And on the other hand, both of China and U.S. have not yet comes up with some kind of black list or white list or gray list.  But let me -- let's say the EU, the issue, it's sort of, kind of, filter for the careful scrutiny to decide whether the dominant platform is -- deserves more concerns, actually.  But I think we can do more.

So, we have to make more --

>> YIK CHAN CHIN: Okay.  We will ask -- so time is up.

>> QING HE: Okay.

>> YIK CHAN CHIN: We will ask from a response from Milton and Albana regarding that.  And maybe James can also comment on that.

>> MODERATOR: Let's give Milton a chance to jump in here on the difference between U.S. and China.

>> MILTON MUELLER: I think Qing said very pertinent things about the substance doctrine behind antitrust.  But I think to me the biggest difference is procedural.  In other words, in the U.S. the companies are tried under a law, and they take it to an independent judiciary that then decides whether they have violated the law.  And I get the impression in China that the executive agencies decide that you have violated the antimonopoly law.  That's it.  You're done.  And that's why they move so swiftly and in the U.S. these cases drag on for 5 or 10 years.

>> YIK CHAN CHIN: Maybe Albana can comment on the difference between the EU -- I'm sorry, the U.S. and China.  What is (?) you as well.  Sorry, sorry, Albana.

>> ALBANA KARAPANCO: Qing, you can continue.  I was reading one of the questions, actually, which is quite, I would say maybe it's a rhetorical question.  If would the EU be to (?) EU home ground alternatives as big as Google, Facebook and Amazon.

I think everyone, if we refer to all the continents and countries and stakeholders, everyone is trying to level the playing field and also is a question, I believe, that most of everything else is certainly a question of power.  I mean, we can never escape that, right?  EU itself is more paternalistic than other system.  Europe is characterized by civil system, which tends to become -- have paternalistic and very rigid in ex-antiregulation, actually.  So I wouldn't have any definite answer to that, because I believe that the question itself could be quite rhetorical.  But I believe that it is also a controlling strategy for all the countries, history of you over the last years, well, shows us that you is being quite rigid in terms of all this big techs.  So, that was it for my part.  Thank you.

>> YIK CHAN CHIN: Thank you.

>> JET DENG: I can give some supplementals from my angle.  Obviously, actually, if you look into the regulation and also if you look into those cases, actually, U.S. there is no significant difference among the Chinese and law and the U.S. antitrust law and also the e-competition law.

I agree that the main difference is with the procedures.  But if we go further, I will say the main difference is with the attitude.  So, why in the first 12 years there's no one think of case in China regarding the recreation of preference.  But all of those case just emerged within just one year.  I think that the attitude of the Chinese top leadership is a key point in this regard.  It is just like in the U.S., you know, the Trump Administration, the Biden Administration and the previous, the Bush Administration, they adopt a quite different attitude in this regard.

>> YIK CHAN CHIN: Thank you, thank you.  (?) you want to respond to Professor Mueller's question, whether, okay, only about procedure?

>> QING HE: Actually, I also learned a lot from the other speakers.  Yes.  Actually, you know, the monopoly law is just issued like 10 years ago.  So, we still have a lot of experience to learn from the other countries.  But we also have many practices in a lot of cases which is focused on the digital market.  So, we also learned a lot from the practice, like we issued the platform guidelines.  So, that's what we are making our efforts about this issue.  Yes, that's all.

>> YIK CHAN CHIN: Thank you.  Okay.  So, I think the next we want to also move to James.  I think, James, in your commission's require and the initiative, actually, you incorporate the concept of public interest component, which is different from most of the competition authority.

So, how does this public interest angle impact on your approach to regulating online platform?  I think Chinese antitrust law, do they -- I do not remember they have a public interest component.  Go ahead.  James, please.

>> JAMES HODGE: Yeah.  I'm very happy.  I think that the (?) is interesting.  I think there are procedural issues but it's also how the law is constructed.  Our law incorporates the public interest which has a broader development angle and also a, sort of, specific focus on participation of small business and in the South Africa apartheid context, individuals who were discriminated against, not given opportunity under apartheid.

Where our interest and focus can lie that may differ.  So, just to give an example, with small business we do have provisions around fairness in the bargaining relationship with powerful buyers.  We do have a lower standard in terms of things like price discrimination, in terms of just how we may frame those cases, under substantial competition but more impeding their participation.  And, of course, in the online world what it has meant is we have also added a focus of South African business participation in the global economy.  So in our online platform inquiry at the moment, part of that is also to understand whether we are just going to be dominated by global platforms or is the scope for local platforms to merge and compete.  Different business models may be different focused.  But is there something inherent in some of these markets that may end up being the South African platforms are pushed out of these spaces.  Specifically the public interest has that element.

Just on the procedures and tools, I mean, guidelines were mentioned, whether you go to court or not.  And every country will have different procedures.  So, for us, we could run an abusive dominance procedure and if you're looking at the major platforms, dominance is easy to establish.  But a market inquiry looks at any factor that may hinder competition.  So it doesn't have to be about a dominant firm.  It can be about a market practice.  And that gives you a lot more flexibility in order to look at things.  You can't under typical abusive dominance.  So you can look at, for instance, just whether certain types of consumer behavior or how consumers' choices is shaped may shape competition on the platform or between platforms.

So, I think any authority looks at the tools they have got, the law they have got and makes strategic choices around what is effective in what situation.

>> MODERATOR: Thank you, James.  Let's go to Milton now for your response to that.  And then I just wanted to invite the audience, who is in the room and also online.  We are going to go to Q&A after we hear from Milton.  So, there's a microphone set up here if you want to come up here.  But, Milton, your response here?

>> MILTON MUELLER: I don't have a lot to say in response.  I think Mr. Jet, sort of, confirmed my perception that really in China there was a change in attitude of the top leadership and suddenly there was a decision, we are going to go after big tech and cut them down to size.  And it wasn't litigated or legally driven in a way that it is in the U.S. and you may like that or you may not like that.  You know, if you just want to get big tech, the Chinese way is much more efficient.  If you want to have more of a rule of law, you're giving them the right to defend themselves and hire expensive lawyers and go through these legal criteria.  So, that's the difference, I think.

And it's also interesting to hear from the South Africa authority how much more flexible they have.  This would not fly with most of the antitrust economists in the U.S.  They would want a much more, you have to be a monopoly and you have to abuse or do something illegally with that market power, rather than just some kind of practice that people think is unfair.  Because we are very concerned about competitors just using the antitrust laws to protect themselves rather than actually protecting the market process.

>> YIK CHAN CHIN: That's a difference which is public interest component incorporated by the South Africa competition commission.

Now we are open to the floor.  So, if you want to open your mic.

>> MODERATOR: We have one person here if you can take the mic and we will also go back to the discussions.  We want to make sure we keep this engaging and interactive.  Please introduce yourself.

>> AUDIENCE: It's Katharina from Georgia, the country.  From the perspective of the small representing the regulator, Georgian regulator.  And when the panel representatives are talking about the big tech platforms antitrust behavior or possible abuse of dominance, et cetera, all of this is considered on a regional level on the (?) level as itch heard today and on different panel.

But the effect of this behavior for even small countries like Georgia is it's also crucial, right, whenever it might be damaging for our Georgia customers, Georgian alternative platforms.  And my question is, where do you see this cooperation, for example, for the antitrust bodies in smaller countries or who are not the home country for Facebook or Google, et cetera, but they see the breach is even, for example, how they self-regulate the content, for example, how Facebook self-regulates their content.  This is something beyond Georgian legislation but this is the challenge, for example, for countries, for our consumers and for our stakeholders.

So, where do you see this cooperation?  Thank you.

>> MODERATOR: Thank you.  Milton, you wanted to respond to that?  And then we will go to the online panelists.  Okay.  I think that's a good point, Milton suggests we get some additional questions.  And Alison, why don't you go ahead and throw in your question.  That way we can go to the panelists and make sure that we have time to respond to several.  And we will have one more in the room after Alison.

>> ALISON GILLWALD: Sure.  Thanks very much, Courtney.  Mine was a follow-up question for James, but I think it does relate to the others.  And part of it has been answered by the response to the public and just question.  Although I think the real nub there is how you balance the public interest issues which are, obviously, not easier.

James, you were speaking about what you could do within the legislation and you were distinguishing between an anticompetitive, abusive behavior as opposed to a market review.  And I was wondering from a, kind of, technical point of view, what the challenges are in dealing with these digital markets, with these global markets, global players around, kind of, defining your market in order for -- so I know for the market review perhaps you don't have those problems which you would have with an anticompetitive behavior case.

But, you know, it does raise the question of -- it firstly raises this question of, you know, maybe somebody is dominant, your local player is dominant in your market but maybe that's the only way we can be able to compete at a global level so it does raise that public interest question, which I don't think is easily answered.  I would like if you could go back and, sort of, say how you have to weigh those issues without, obviously, indicating your findings on this inquiry, which is still open.

But then practically, how do you actually define these markets in order to review them?  And particularly then, you know, in terms of the identification of any practice or abuse that you want to remedy, how do you, actually, remedy some of the things?  Because they may be in your jurisdiction in some form or other or they may not, actually, legally exist within your jurisdiction.  But then how do you do -- you know, enforce the remedies?  And you have spoken about the need for global collaboration in order to do some of these things.

But you're not going to get the United States instituting an antitrust thing against Facebook or whatever just because it's been found by the South African case that the WhatsApp Facebook is anticompetitive or something like that.  I wanted to know if you could give us the technical granularity and challenges compared to competing with the all analog markets.

>> YIK CHAN CHIN: We will take the other question.  And then the panelists will -- (?) so Andrew, can you please unmute and then you can ask a question.  Please go ahead.  You have to unmute your -- I cannot hear you.

>> ANDREW CAMPLING: Is that better?

>> YIK CHAN CHIN: Yeah.

>> ANDREW CAMPLING: I put it in the chat and I will read it out loud and this might be a particular relevance to James on the panelists.  And that's the area of standards development specifically so it's in standards.  Most of the, sort of, standards bodies that I'm familiar with are dominated by the tech sector and have little or no input or oversight from any other stakeholders at all.  And arguably some of the recent standards developments appear to favor centralization of infrastructure and strengthen the market dominance of the established major players.

So, with that in mind, should internet standards face greater scrutiny from antitrust regulators?  And no offense intended, James, but do those regulators have the necessary knowledge and skills to do this in that sort of environment of standards development?  Thank you.

>> MODERATOR: James, we are going to give you a couple of minutes to get your thoughts together because you've got detailed questions.  Take one last question from the room and then go back to all the panelists.  So, we will go to James first, since you have had a couple of pointed questions.  Please, all the panelists get ready after this other question.

>> AUDIENCE: My question stems from some of the other comments that were made before about the Euro project.  I have been involved in the regulatory attempts.  I agree they come from a change of attitude even in Europe.  Europe has not been regulating for a long time or (?) regulation from the end of the '90s.  And all of a sudden some things happened that prompted European leaders to come forward with some pretty heavy regulation that is currently being discussed.

But if you have a look at this, this is not really just about market power and economy, as it was suggested with other comments.  They have (?) prompted this regulation stuff like the U.S. cloud or there are stuff like the ban from social media.  If you remember (?) commented very negatively.  These are the kind of things that prompted action.

My perception is that, yes, it's a matter of antitrust regulation, of course it's a matter of economy and so on.  But it's also a matter of using antitrust regulation to address stuff which is not really just about market power but more about fundamental rights and the fact like also the person from Georgia was commenting that many countries including Europe feel they have no power, no authority over the policies of this big tech companies.

Do you feel that maybe the antitrust regulation which is the only common base across market economies across the world is UAE as a proxy for the lack of common regulation and common ways of action on other issues connected to freedom of speech, content control, these kind of things?

>> MODERATOR: Thank you very much.  There's a common theme throughout several questions.  James, I think we should go to you first to respond to the specific questions raised.

>> JAMES HODGE: Very happy to.  And Andrew doesn't insult me.  So don't worry about that.  I think as I indicated before, learning is part of this process.  And that's maybe come to Alison's questions.  You know, probably five years ago we led through a merger of two big e-commerce platforms because the view was to strain by retail, the brick and mortar retail, one of them is making a loss.  And I think those are the lessons you have over time.  So there has to be a massive investment in your teams and your understanding of the business models.

I mean, we even considered bringing in business people to, kind of, educate us around business models and how things work, because quite easily you can be hoodwinked into thinking that, for instance, you know, we recently had one of the first probably prohibited platform mergers in South Africa.  And, again, you know, we were presented with facts that there's lots of entrants.  But we know in this sort of market, deep pockets and the ability to respond is probably what separates out true constraints from just wannabes.

There's a lot of technical stuff where we need to get involved and we can't just move on the issue of internet standards.  We would have to educate ourselves before moving.

Part of the problem you have raised, Alison, is remedies.  And to be quite frank, I think there's a lot of, sort of, people out there that believe that apart from paying fines, that a lot of the remedies that have been imposed, quite frankly, do not work.  And Google shopping, there's a lot of research that suggests it hasn't worked.  It hasn't, in fact, promoted comparative shopping sites.  And firms find a way to work around.  We saw career recently introduce a law to try and bring down the price of commissions or the level of commissions amongst app stores.  But the law there required the app stores to offer alternative payment means.  And all Google did was come and say, well, I'll charge you 11% because you're going to spend three or 4% dealing with the payments operator.  So, the overall fees are still the same.  So, there's a lot of work around and this is primarily one of the problems with regulation, that it can be ineffective in such a dynamic space.

And that maybe brings me to the first question, which was around cooperation.  I mean, South Africa as a small nation has had to stand up and assert our jurisdiction.  But the problem that every competition authority faces is you only have jurisdiction over economic activity in your country.  And even that for some of the global platforms will be questioned, if they have a presence in your country.  So, it is an issue where we need more global cooperation, because as I mentioned earlier, global cooperation means that you can collectively have more, I think, influence over large platform.  They are substantially larger.  I think, you know, I think one of our former entrepreneurs who now heads up Tesla SpaceX recently had his own net worth exceed the South African GDP.  That is the kind of difference in bargaining power that exists.  Unless it is global cooperation, I think the small nations will be left behind in the process.

And the point of that cooperation is more to ensure that rules that may be thrashed out on a bigger global stage between the U.S. and EU also filter down to the other countries as well.  So, that is going to be, I think, critical in order to protect your smaller country consumers.

>> YIK CHAN CHIN: I think whether others also want to comment on those issues of global collaboration and as, of course, the last question about whether the competition can act as a policy to tackle the global issues, maybe Albana can respond and also James, can you respond as well.  And also Milton.  Please go ahead.

>> ALBANA KARAPANCO: Thank you very much.  I'm thankful to the gentleman who posed the comment and I saw the question.  Well, I totally agree with your approach.  It is a proxy as well to respect all the EU existing legislations, that is not only related to the antitrust regulation.  So, in that regard, we agree this comes very clearly also in all the documents that address these two in X expected entering force.

As to the lady talk about Georgia, I fully understand you because I think Albania stays in a very similar position, actually, to Georgia.  Maybe even a bit in a transitory phase if we take into consideration the change of the legislation and regulatory environment and enforcement issues that have been persistent through all the last decades.  Thank you.

>> YIK CHAN CHIN: And also Jet, do you want to respond to the cooperation how China cooperate with other global partners in terms of antitrust or whether there's a global theme.

>> JET DENG: Sure, sure.  I have the chance to participate in the Chinese antitrust law legislation.  So, back to 14 years ago.  So, at that time, actually, China, we introduce the competition law, many based on the models of the U.S. and the EU.  And in those enforcement, I understand that the Chinese also the actuary has a number of communications with both the U.S. and the EU compacts but the Chinese is also quite cautious on those cooperation of those space cases.  And right now China is in the process of realizing the anti-Murphy law and the way (?) actually (?) from the U.S. antitrust law and the EU competition law.  And from my perspective, I observe there's some communication interactions between the Chinese authority and can pass in certain investigations.  And I think it is more important for U.S. and UN China to establish some kind of mechanism so in which the authority that can build up some regular communications and the cooperations.

So, up to now we only have the bricks mechanism in which, you know, China, Russia (?) Africa, India, they have some regular communications.  So for -- in the long term, it will be quite important to -- for those major jurisdictions to build up some kind of international enforcement cooperation mechanism.

>> YIK CHAN CHIN: Thank you.  Milton, do you want to respond from an American perspective?

>> MILTON MUELLER: Those are very complex set of questions, particularly the one about small country jurisdictions.  And I'm not sure how to respond to that without hymning and hawing.  I do want to respond to (?) comment.  I think it's dangerous and unadvisable to use antitrust as a proxy for something else, right?  In fact, this is one of the abuses of antitrust law that's well known in history, is that, basically, people who are losing a competition get the government to intervene on their behalf and then particularly in a dynamically changing technological market, you find out that the interventions you make either have no effect, like Mr. Hodges pointed out or you find out the whole market structure changes five years down the road and particularly if you're in a litigious system like the U.S., your conclusion is pretty much irrelevant or even distorting and making things worse down the road.

So, an example of this is the AT&T breakup.  Not that I didn't support that.  It was good to break that up and create competition.  But the whole system was premised on the idea that there is a long distance market, right, and we are going to have this elaborate structure of making equal access between the local exchange and the long distance market.  And then 10 years after this settlement there is no long distance market because cell phone collapses the entire country into the local exchange market.  So, the whole premise of that system was, basically, wiped out in the space of a few years.  And you could say similar things about the Microsoft settlement.

So, you have to be careful.  I mean, you may feel threatened by and not like these big firms.  But you have to ask, why are they big?  And one of the reasons is, what are the basic economic factors driving, you know, these markets?  And if they are advertising driven, then the more eyeballs you have, the more valuable you are.  If there are network externalities then having everybody on the same network generates huge benefits for the users.  And you have to think about what you're doing when you try to break that up.  So, all of these big interventions tend to founder on the notion of finding a good remedy.  You know, what is the actual remedy that will make things better?  And if that remedy is not really a question of, sort of, the abusive monopoly power, then don't use antitrust law.  Come up with legislation, which is what the Europeans are doing.  We will see how it works.  I don't have a good enough grasp to know how I think it will work.  But if indeed you want new rules for these markets, then formulate new rules.  But don't say, you know, we are going to redefine the nature of antimonopoly law because we don't like you.  You've got to have a rule of law.  You've got to have stable expectations for economic progress.

>> YIK CHAN CHIN: I think this is very interesting questions because I think in both James' speech and also Albana's, the EU antitrust law, there's a component about public interest; is that right?  So, I think James also mentioned that when South Africa commission considered public interests, one of the components about how to protect the local enterprise; is that right?  But Milton's point that said this should not be the component to be considered.  So, what is your response, James?  From my understanding of Milton's point.

>> JAMES HODGE: Look, I think, to be frank, globally there is a greater focus on exactly what you may consider this, sort of, softer competition issues around privacy, around inequality, around access to platforms.  So, I think the world has definitely shifted more towards the direction of the South African competition law in the last five years, and even, I think, the U.S. has shifted under the new administration and with the success of the, sort of, group who have now taken over the Federal Trade Commission and DOJ.  I think there is a role for that.  It's how you balance it.  And our position has always been rather have it in the law.  It used to be there's, sort of, political discretion around strategic issues that existed, even, I think, today in UK law.  Our approach is put it in the law that forces the proper wearing up.  And the South Africa has a court system, much like the U.S., although we have a specialist court, not a low court that can hear these matters.

But that has resulted in the fair balance.  So, to take one example in merger control, we do look at entrenchments and whether they are harmful because and they are necessary.  And that has never prevented a merger going through and that's the balance that's been maintained.  In an online world we are going to have to navigate this and part of the reason for an inquiry is exactly the way to explore that.

But to take an example, if, you know, what we have been exploring in public hearings is if Google search is the channel or the top of the funnel for most commercial activity, then what happens on the first page of Google matters and can -- does that start to shape and favor those with the deepest pockets, your global who are going for the (?).  Can you have almost a predatory approach of almost a low and no return on investment.  So most of the advertisers look at the return in terms of bookings or whatever that they get.  That you can have trepidation in that context.

Whether there's a remedy of that, that is, I think, where I would agree.  This is complex.  It does change business models.  And it's not easy.  And it may have unintended consequences.  You may remove the top ads on Google and find that the organic is still dominated by the bigger companies that invest in certain end-to-end optimization.  So that is probably the biggest challenge.

I think there are interventions such as the platform to business regulations that the EU brought in around transparency, around that which probably work more effectively.  I think other regulation may be undone by dynamics.  But this is certainly the challenge.  And I think one raised in the, sort of, forward for this session was about different business models.  In food delivery we are seeing local models.  By local entrepreneurs, servicing a need in areas where the big companies have not gone.  But when the big companies come, are they going to be destroyed when your business model is sink massive amounts into consumer marketing promotion, does that change it?  Can we have both there in the market and how?

I think we are at that exploratory stage, I mean, for us as an inquiry and I think globally, and we don't always have the answers and we have stepped with trepidation.  But the reality is there are dominant platforms, there is abuse and that has to be on the radar for treatment.

>> YIK CHAN CHIN: Okay.  Thank you, James.  I think that's a well complicated questions.  And also I think as far as annual in Chinese antitrust law they also took into consideration why the big platform could destroy diversity in the market.  But we have to have other hour to discuss these.

So, I have to pass the mic to the next question.  And Ana, do you want to speak or your question?

>> IOANA STUPARIU: Yes, thank you, Yik Chan Chin, and thank you everyone for insightful discussion.  We have a question from the chat for Milton this time.  And after you answer, Milton, I pass the mic to Courtney, who also has a question, and also to continue with questions from the live audience.

So, Milton, the question for you is, from Jorge Cancio.  He says, what do you think is the agenda on platforms of the Biden Administration and how does it relate to the projected alliance for the future of the internet, which was in the news?

>> MODERATOR: We are going to take more questions:  Do you want to invite anyone from --

>> IOANA STUPARIU: Courtney, we cannot hear you.

>> MODERATOR: Can you hear me now?  Is this working.  Okay.  I want to invite anyone in the live audience to come up to the microphone to ask your question after my question.  So, my question is whether we are thinking about this in the right way and whether the current frameworks, our legal frameworks are adequate to assess the potential antitrust implications of some of these major platforms where it's not in a single -- you know, it's not in a single business, whether it's, actually, about advertising or whether it's about data and whether we can think more creatively about antitrust, for example, putting, you know, data into a public trust.  How could we think outside of the box since we are in a new environment and are the current legal frameworks even adequate to this.  And as we think about trust and earlier this question around, kind of, cooperation and multi-stakeholderism in the standard setting, I would just think, you know, ask the two regulators on the panel about how they are incorporating not just business and not just government perspective, but civil society and, you know, advocacy groups on behalf of not just users, but citizens, the individuals affected by this.  One more question on the floor.  Please introduce yourself.

>> AUDIENCE: I would like to take your consideration, all the panelists, to the super applications.  I think in many countries right now, especially eastern countries, let me call them mobile first countries which people, they get familiar with internet within their mobile cell phones, right?  So, they are more and more using super applications.  There is one app and everything then when they are -- in terms of they log into the app, they will see everything.  And as much as they use the super applications and the super access, they are getting more users, the (?) regulators to select to put their rules inside is less and less because you cannot ban a super application with billions of users, like V chat, go Jake we have seen more and more every day.

My big question is how regulators, how law regulators can regulate the antitrust policies, antitrust regulations inside the regional and even global huge super applications.  Thank you.

>> YIK CHAN CHIN: Any other questions?  So we will collect the question and pose to the panelists.

>> MODERATOR: There is one more question in the room if you want to make it quickly and this may be the last round.

>> IOANA STUPARIU: There are no other questions in the chat at this point.  If there's anyone from those attending virtually wants to address a question, please raise your hand now or write in the chat.  Thank you.

>> MODERATOR: Please go ahead.

>> AUDIENCE: I'm a man and I represent regulatory body for digital maintenance.  One of our main concerns is regarding international platforms.  I am coming from Iran, most of the international platforms have no office and have no authority person there.  But the thing is that they are generating a huge revenue from this issue.  And many, many local platforms have problems because due to many concentration that can reach their voices.

But personally as a person who is coming from legal and technical background, I don't know which panelist is more related.  But how do you consider computation of antitrust?  Because I believe that the future, we are entering into web territory era and I believe that the current and classic antitrust and competition regulation itself cannot ensure, itself cannot ensure.  How do you consider computational antitrust to --

>> MODERATOR: I think we will have a -- go to him first and go to the panelists in the Zoom room to respond to the variety of questions.  Go ahead, Milton.

>> MILTON MUELLER: Should I go?

>> YIK CHAN CHIN: Yeah, please go ahead.

>> MILTON MUELLER: Okay.  The Biden Administration, obviously, has taken at least nominally in terms of posturing they have taken a more aggressive approach to antitrust enforcement.  And there's also a ton of legislation about platforms in the United States.  Most of it pretty simple minded kinds of let's get the platform kinds much things and not very well thought out, frankly.

But they are, in fact, talking about retrospectively making Facebook, I think, divest Instagram, which in terms of remedies is one of the more coherent ones that you might want to think about.  But, again, it wouldn't -- I mean, it would make Facebook smaller and possibly create some competition in that particular market.  But we have seen, in fact, TikTok come along and really eat Facebook's lunch in a certain area of social media.  So, the idea that the market is closed to that kind of innovation is different.

I don't think there is a strong relationship between the Biden Administration's approach to competition policy and their proposed alliance, which I'm waiting to see what exactly that consists of.  But I think that they might have some kind of idea that the internet should be -- the services on the internet should be competitive, blah, blah, blah.  But I don't think that there's a strong relationship there.  And, again, in the U.S. things are very legally driven.  So, whatever the Biden Administration justice department does about platforms regarding their antitrust or antimonopoly situation is going to have to be grounded in existing antitrust law or they are going to have to get new regulations or new legislation from congress.  And we all know how effective the U.S. congress is at passing comprehensive laws.

I will leave it at that.  I can't address the Iranian guy's question, but I think I have spoken enough.

>> YIK CHAN CHIN: Thank you.

>> MODERATOR: Thank you.

>> YIK CHAN CHIN: Yeah.  That's last two questions and one is about super applications and the other one is about the computation antitrust law.

So, can the panelist that responds to that two questions?  Yeah, James, please, go ahead.

>> JAMES HODGE: I can offer a quick response.  I mean, on the computational, what we and other jurisdictions are doing is at least trying to use technology, I mean, primarily around detection of collusion.  This is where informatics can help in terms of just scraping prices from different areas, government tenders, et cetera, in order to automate that sort of process.  So that's been probably your biggest investment in computational antitrust.  Obviously, moving online in a pandemic has spurred us to move electronically.  That has been another shift forward as well.

In terms of the involvement of civil society, Sydney, that's what's been a cornerstone for us and even in abuse cases we sometimes bring in civil society as friends of the court.  So, if it's a case in respect to an abusive, say, a pharmaceutical company or healthcare or price gouging in a pandemic, these all, I think, are important.  In an inquiry we also have reached out to other regulators, governments, industry organizations, and that is critical as well.

And in terms of building that legal framework, I think to Courtney's question, part of the problem is that many of the issues are cross-cutting as one of the people earlier, sort of, highlighted in the question.  So, that's why you need cooperation.  Just this morning I had a meeting with our advertising standards body to find out if they have any advertising standards for internet companies.  We have heard from the information regulator.  But there are gaps.  And this also makes enforcement quite difficult because many firms may question your jurisdiction.  Are you, in fact, entitled to look at this or must you leave it for someone else.  And then other regulator has got to go through the process.  But they are all so intertwined that probably those jurisdictions with a single consumer protection law mixed with competition law are at a big advantage in this space.

>> YIK CHAN CHIN: Thank you.  Jet, do you want to also respond to the question about super application or the computational antitrust?  Jet, do you want to respond from the Chinese perspective about the super application?  Hello?

>> JET DENG: Yes.  Sure.  In China, actually, we are also face some quite similar problem.  Here, actually, the Chinese internet business or market is separated from the other parts of the world.  Not only because of the language, but also because of those restrictions, those policies.  And then based on the quite big the population.  So, here we have some very big players.  Like for the e-commerce we have Alibaba, the radio, we have the TikTok, sort of, media.  We have the (?).  And here we are also interpreting the issue of how can we promote the diversity, how we can just using the antitrust law to safeguard those interests of the small and medium sized players.

So, one solution might be the, for now we have the policy of looking into those mergers which the big platforms is acquiring small or medium-sized platforms like this.  And for those -- for those (?) cases, we have been more cautious just to pre run the big platforms, they will leverage their sites and their money to restrict those growth of the small or medium-sized, their competitors.

>> YIK CHAN CHIN: Thank you. 

Albana, do you wanted to respond to the question about computational antitrust and the super applications?  (?)

>> ALBANA KARAPANCO: Thank you.  Unfortunately, it's a question I cannot give in my expertise.  I will leave it to the people who work on the field of computational antitrust.  I cannot really give appearance to that.  Sorry.

>> YIK CHAN CHIN: Thank you very much.  Yes, thank you.

Do we -- is any other questions?

>> MODERATOR: Not in the room and I think we have five minutes only.

>> YIK CHAN CHIN: Yeah, yeah.

>> IOANA STUPARIU: No questions in the chat either.

>> YIK CHAN CHIN: Then we will wrap up this section.  I think if possible I would like to thank you all for participating and especially thank you for all these distinguished speakers to give us very insightful and exciting debate on those issues.  And as we can see, this is a very complicated issue and also different component and consideration.  And I think probably the collaboration at a global level may not be reached for in the near future but certainly is something we needed to consider.

So, I want to ask each speaker to wrap up their stand, position, by one sentence.  Should we start with Milton, one sentence, please.

>> MILTON MUELLER: Okay.  Here comes a very long sentence.  First of all, I would lake to thank, Yik Chan, for putting this together.  It's a great idea to have this comparative and you really brought together a very good group of people.

I would say technology markets are dynamic and don't mistake temporary dominance for permanent dominance.  And always be aware of how, you know, markets evolve and how when companies get big, sometimes it's because they are doing things that people want them to do.

>> YIK CHAN CHIN: Okay.  Qing He, can you speak one sentence to wrap up?

>> QING HE: Yes, sure.  I would like to respond to the speakers have already talked about the issue.  Actually, I also wrote for to build up some mechanism to afford regular communication between the U.S. and the China about how to address this issue.  Yes.  Thank you.

>> YIK CHAN CHIN: Thank you.  Thank you.  We can read your article later.  Okay?  Because of (?) publishing in English.  So (?) later.

Jet Deng, one second.

>> JET DENG: The internet platforms is for communication and the basis of the communication is diversity.  And so I hope we can use the competition law to safeguard and promote the diversity.  Thank you.

>> YIK CHAN CHIN: Okay.  Albana, please.

>> ALBANA KARAPANCO: I think that -- well, this is (?) topic at the beginning of its development, I think, and I think the main question is how we stay grounded when the ground itself is shaking.  I'm very thankful to the panel and insightful to all, and I think that we will discover everything with the passage of time how all this problematic will evolve and go both in European but then also in the U.S., which is the main -- the region of my main interest.  Thank you.

>> YIK CHAN CHIN: Thank you.  James.  Last but not least, James, please.

>> JAMES HODGE: Thank you, Yik.  Yes, thank the panel and then the audience as well.  But I would say probably there needs to be a focus on the global cooperation, to deal with global platforms of the size and strength these are, we need to also coordinate and cooperate in order to have an equal bargaining dynamic as well.

>> YIK CHAN CHIN: Thank you all.  I think we are almost finished.  So, again, thank you for participation.  I think we are going to leave the room.  And we will have a report published on the website, the IGF website so you have future download.  If you want to have, are there any questions for the speakers later, you can (?) and we can pass their contact information to you as well.  Thank you everyone.

>> MODERATOR: Thank you for bearing with us through this hybrid session.

>> YIK CHAN CHIN: Thank you.

>> QING HE: Thank you very much.

(Session was concluded at 15:35 UTC)