WS #335 Global Perspectives on Network Fees and Net Neutrality

Summary

This panel discussion at the Internet Governance Forum focused on global perspectives regarding network fees (also called “fair share” mechanisms) and their relationship to net neutrality principles. The debate centers on whether content providers and large technology companies should pay additional fees to telecommunications operators for data delivery, beyond existing interconnection arrangements.

Professor Kyung Sin Park from Korea University presented compelling evidence from South Korea’s experience with network fees implemented in 2016, demonstrating how even partial sender-pay rules led to dramatically increased transit costs, reduced competition, and the departure of services like Twitch from the Korean market. His data showed Korean internet costs became 8-10 times higher than other developed countries, stifling innovation and forcing content providers to relocate operations abroad.

Konstantinos Komaitis from the Atlantic Council emphasized that this debate has persisted for over 15 years without evidence of market failure, particularly noting that European regulators (BEREC) found the internet interconnection ecosystem functions well. He warned that network fees represent a backdoor attempt to undermine net neutrality and could lead to traffic prioritization based on commercial agreements rather than user choice.

Colombian regulator Claudia Ximena Bustamante shared insights from Latin America’s approach, describing ongoing consultations to understand traffic patterns and ecosystem dynamics before implementing any regulatory changes. She noted that traffic growth in Colombia appeared normal rather than exponential, partly due to increased local content delivery networks and compression technologies.

Tatiana Tropinem from the Internet Society argued that network fee proposals are “solutions in search of a problem,” emphasizing that internet users already pay for data access while content providers invest heavily in infrastructure like content delivery networks. Thomas Volmer from Netflix highlighted how collaborative engineering between content providers and ISPs has successfully managed traffic growth through technical solutions rather than regulatory intervention.

The discussion revealed a clear divide between telecommunications operators seeking additional revenue streams and other stakeholders who view network fees as potentially fragmenting the internet’s open architecture and undermining the fundamental principles that enabled its global success.

Keypoints

## Major Discussion Points:

– **Network Fees vs. Net Neutrality**: The core debate centers on whether content providers (like Netflix, Google) should pay additional fees to telecom operators for network usage, with panelists arguing this would undermine net neutrality principles that ensure equal treatment of all internet traffic.

– **Evidence from South Korea’s Implementation**: Professor K.S. Park presented detailed data showing how South Korea’s partial sender-pay rule led to dramatically increased transit prices (8-10 times higher than other countries), caused services like Twitch to exit the market, and resulted in Korean content being served from outside the country to avoid costs.

– **Lack of Market Failure Evidence**: Multiple speakers emphasized that consultations in Europe, Brazil, and other regions have found no evidence of market failure justifying network fees, with BEREC concluding that internet interconnection is a “well-functioning market” where costs have actually decreased despite traffic increases.

– **Alternative Infrastructure Investment Solutions**: Panelists discussed various ways to address connectivity needs without network fees, including reducing spectrum licensing fees, adjusting tax obligations, promoting competition, targeted subsidies for underserved areas, and recognizing that content providers already invest heavily in infrastructure like CDNs and subsea cables.

– **Regulatory Separation and Governance Models**: The discussion touched on how network fees proposals challenge the traditional separation between internet infrastructure regulation and application layer governance, potentially centralizing control and moving away from multi-stakeholder internet governance models.

## Overall Purpose:

The panel aimed to provide global perspectives on network fees (also called “fair share” proposals) and their relationship to net neutrality, examining evidence from different regions and discussing policy alternatives for addressing connectivity and infrastructure investment needs.

## Overall Tone:

The discussion maintained a strongly critical tone toward network fees throughout, with all panelists opposing such proposals. The tone became somewhat tense when telecom industry representatives in the audience challenged the panel’s composition and arguments, with one noting the lack of telecom operator representation on the panel and another calling the discussion one-sided rather than a true dialogue. The moderator acknowledged this criticism but the panelists maintained their positions, creating a somewhat defensive atmosphere by the end.

Speakers

**Speakers from the provided list:**

– **Fabro Steibel** – Panel moderator/facilitator

– **Kyung Sin Park (K.S. Park)** – Professor of law at Korea University Law School, Director of Openet (digital rights organization)

– **Konstantinos Komaitis** – Resident senior fellow with the Democracy and Tech Initiative at the Atlantic Council

– **Claudia Ximena Bustamante** – Executive Director and Commissioner of the Communications Regulatory Commission (CRC) of Colombia

– **Tatiana Tropinem** – Representative from Internet Society

– **Thomas Volmer** – Head of Global Content Delivery Policy at Netflix

– **Rian Duarte** – Representative from the Brazilian Association of Internet Service Providers

– **Louvo Gray** – Representative from the South African Internet Governance Forum, runs an internet service provider in South Africa

– **Frode Kieling** – Representative from Telco (200 million customers in Asia and Nordic)

– **Pablo Barrionovo** – Representative from Telefonica

**Additional speakers:**

None identified – all speakers mentioned in the transcript were included in the provided speakers names list.

# Global Perspectives on Network Fees and Net Neutrality: Internet Governance Forum Panel Discussion

## Executive Summary

This Internet Governance Forum panel discussion examined the global debate surrounding network fees (also termed “fair share” mechanisms) and their relationship to net neutrality principles. The session featured five main panelists representing diverse perspectives, with additional input from telecommunications industry representatives during the Q&A session. Moderated by Fabro Steibel, who referenced a campaign listing “10 reasons” why network fees are problematic for the internet, the discussion revealed significant disagreement between telecommunications operators seeking additional revenue streams and other stakeholders who view network fees as fundamentally flawed policies.

The debate was anchored by evidence from South Korea’s experience with network fees implementation since 2016, which demonstrated negative consequences including increased costs and service departures. This real-world case study provided crucial context for evaluating arguments about network fees’ potential impacts.

## Key Participants and Perspectives

### Academic Analysis

**Professor Kyung Sin Park** from Korea University Law School provided detailed evidence from South Korea’s unique experience implementing partial sender-pay rules. Park presented data showing transit costs 8-10 times higher than other developed countries, services like Twitch exiting the Korean market, and Korean content being served from abroad to avoid domestic fees. Park framed network fees as fundamentally undermining democratic participation by “taxing people for speaking online.”

### Civil Society and Technical Community

**Konstantinos Komaitis** from the Atlantic Council emphasized that this debate has persisted since 2012 without evidence of market failure. He referenced European regulators (BEREC) finding the internet interconnection ecosystem well-functioning, with a recent report showing decreasing data costs. Komaitis characterized network fees as “lazy policy” and warned that dispute resolution mechanisms could serve as a “backdoor to network fees.”

**Tatiana Tropinem** from the Internet Society argued that network fees are “solutions in search of a problem,” noting that users already pay for data access while content providers invest heavily in infrastructure. She emphasized that traffic is requested by users who pay for access, not created unilaterally by online services.

### Regulatory Perspective

**Claudia Ximena Bustamante**, Executive Director of Colombia’s Communications Regulatory Commission, described ongoing consultations to understand traffic patterns before implementing regulatory changes. She reported traffic growth of 1.7 times over two years, which she characterized as normal rather than exponential, partly due to local content delivery networks and compression technologies. Bustamante mentioned a recent Constitutional Court decision against ISP-chosen differentiated service plans that may require regulatory framework updates.

### Content Provider Perspective

**Thomas Volmer** from Netflix highlighted collaborative engineering between content providers and ISPs, noting Netflix’s infrastructure investments including content delivery networks with global server locations. He explained how “cold potato routing” brings content close to users, reducing rather than increasing network burden. Volmer referenced BEREC findings that interconnection markets function well and warned that network fees would create tolls limiting user choice.

### Industry Challenges

During the Q&A session, telecommunications industry representatives challenged the panel’s composition and arguments. **Frode Kieling**, representing a telecommunications company, argued that fundamental internet principles assumed equal traffic sharing, which no longer exists with 70-80% of traffic from content delivery networks. He contended that telco revenues are declining while content provider revenues increase.

**Pablo Barrionovo** from Telefónica criticized the panel’s lack of telecommunications operator representation, arguing for more balanced multi-stakeholder dialogue. He maintained that sustainability problems exist in the current model.

**Rian Duarte** from the Brazilian Association of Internet Service Providers noted that over 20,000 small ISPs in Brazil oppose network fees, revealing divisions within the telecommunications sector.

## Evidence and Case Studies

### South Korea’s Experience

Professor Park’s analysis of South Korea’s implementation revealed several concerning outcomes:

– Transit prices 8-10 times higher than other developed countries

– Major services like Twitch exiting the Korean market

– Korean content providers serving content from outside Korea to avoid fees

– Korean esports teams moving abroad due to latency issues

– Reduced innovation and competition

### Regional Findings

**European Analysis**: BEREC studies found no evidence of market failure in internet interconnection, with recent reports showing decreasing data costs despite traffic increases.

**Brazilian Consultations**: Two separate consultations revealed large telcos supporting network fees while other stakeholders opposed them, with law proposals prohibiting the practice under consideration.

**Colombian Investigation**: Ongoing consultation examining traffic patterns and ecosystem dynamics, with Bustamante advocating evidence-based policy making.

## Technical and Economic Arguments

### Infrastructure Investment

The discussion revealed disagreement about internet infrastructure investment. Content providers like Netflix invest significantly in content delivery networks, challenging narratives that only telecommunications operators invest in internet infrastructure. Multiple speakers noted that various players including CDNs, cloud providers, and edge nodes contribute to internet infrastructure.

### Traffic Management

Several speakers explained how modern internet architecture handles traffic growth efficiently. Local CDNs and compression advances have made traffic growth manageable, while CDN architecture legitimately changes traffic patterns for technical reasons rather than creating unfair advantages.

### Economic Sustainability

Telecommunications representatives raised concerns about revenue sustainability, with declining telco revenues alongside growing content provider revenues. Other speakers argued this reflects normal market evolution rather than market failure requiring regulatory intervention.

## Net Neutrality and Democratic Implications

Multiple speakers emphasized that network fees contradict net neutrality principles by allowing ISPs to prioritize traffic based on payment rather than user choice. Park argued that net neutrality is essential for democratic participation, preventing regression to telephony-style systems that tax online communication.

Volmer compared potential network fee systems to cable TV, where ISPs control content access through special deals, directly contradicting net neutrality principles that users should control their content access.

## Alternative Approaches

Speakers proposed various alternatives to network fees:

– Reducing spectrum licensing fees

– Adjusting tax obligations and coverage requirements

– Providing regulatory flexibility

– Implementing targeted subsidies for underserved areas

– Promoting competition and technical collaboration

The discussion highlighted successful technical collaboration between content providers and ISPs through CDN deployment and traffic engineering without requiring regulatory intervention.

## Areas of Disagreement

### Historical Internet Principles

Significant disagreement emerged about internet traffic exchange foundations. Kieling claimed equal traffic sharing was a founding principle, while Park disputed this characterization. The debate revealed different interpretations of how modern CDN architecture relates to historical internet design.

### Market Failure Evidence

Sharp disagreement existed about whether current conditions justify regulatory intervention. Telecommunications representatives argued that revenue imbalances demonstrate sustainability problems, while others maintained that studies show well-functioning interconnection markets.

### Multi-Stakeholder Representation

Telecommunications representatives criticized the panel composition as one-sided, while the moderator noted that consultations consistently show most stakeholders opposing network fees except large telcos.

## Global Development Concerns

**Louvo Gray** from the South African Internet Governance Forum, who operates an ISP, raised concerns about network fees impacting efforts to connect over one billion unconnected people in Africa. He noted shifts from telco-owned to content provider-owned undersea cables and worried about new barriers for African-owned networks and content creators.

## Regulatory Separation Issues

The discussion touched on concerns about network fees challenging traditional separation between internet infrastructure regulation and application layer governance, potentially centralizing control and moving away from distributed governance models.

## Conclusion

The panel revealed fundamental disagreement between telecommunications operators seeking additional revenue and other stakeholders opposing network fees based on evidence from South Korea and various regional studies. The weight of evidence presented, particularly regarding negative outcomes in South Korea, suggests significant challenges for network fee proposals.

The discussion emphasized the importance of evidence-based policy making, with ongoing consultations in various regions examining these issues. Alternative approaches to addressing infrastructure investment concerns were proposed that would not undermine internet openness or net neutrality principles.

The debate appears likely to continue across multiple jurisdictions, with the fundamental tension between telecommunications revenue concerns and broader stakeholder opposition remaining unresolved. However, the evidence presented suggests that network fees face substantial policy and technical challenges in gaining widespread acceptance while maintaining the internet’s open architecture.

Fabro Steibel: So, hello everyone, welcome to the panel Global Perspectives on Network Fees and Net Neutrality. I really enjoy this panel because we have been talking about this for some years now. So I’ll make a short introduction. We have five speakers. Each one will have a slot of one minute to present himself, 12 minutes to address the topic and then we open for questions and comments from the audience online and on site. So if you’re unaware of network fees are, some will call them fair share, some will call them internet tools, so some will support, some will not support. The idea is that the price, the cost that you use for connectivity can or cannot vary according to the telco decision and the service provider. This has been a topic for consultation in Europe, in Brazil, in South Korea, in US and other places and in some countries they have experienced the network fees impact like South Korea. We did a campaign, we call it the Internet Tool, and we gave 10 reasons why we believe it’s against the past for the Internet. So there you have your issues of consumer rights, you’ll have issues of data costs, and others. It’s of particular interest the report from BEREC that will say that the cost for data has been decreasing the past years, which does not justify the introductions of new fee systems. That said, telcos will support that they need more proportional contribution to the networks, governments will say that they need more investments for connecting the unconnected, and it’s a topic of different size and contradictions. So I’ll give here the floor, one minute for each one to introduce. So K.S. Park. K.S. Park is professor of law at Korea University Law School, and director of Openet. Welcome.

Kyung Sin Park: Yes. I don’t think at IJF, especially at IJF, we should not be afraid of talking about not just the economic significance of net neutrality, or other norms or practices by which we have financed the data delivery around the world to make the Internet possible. I’ll get into that, and I’ll talk about how even a small departure from that golden rule, the golden practice, will cause disasters on the Internet ecosystem as seen in South Korea.

Fabro Steibel: Thank you, K.S. We move now to Konstantinos Komatis, resident fellow. with the Atlantic Council Democracy and Tech Initiative.

Konstantinos Komaitis: Hi. Hello, everyone. Good morning. So glad to see so many of you here. Interested in this topic, as Fabro said, my name is Konstantinos Komaitis. I am a resident senior fellow with the Democracy and Tech Initiative at the Atlantic Council. I have spent pretty much 20 years discussing this issue, so I can’t believe that we’re still discussing this issue, frankly. I was in Dubai when this was a thing in 2012. Then I was part of the conversations in Brussels when the open internet regulation was being discussed in 2015. And then since 2021, I believe, if I remember correctly, we have been discussing it again in Europe, and I have been engaging in those conversations as well, and also in some conversations that are happening in Brazil. So very much looking forward to this.

Fabro Steibel: Thank you, Konstantinos. So we move now online to Claudia Ximena Bustamante. She’s Executive Director, Commissioner of the Communications Regulatory Commission, CRC, of the government of Colombia. Welcome, Claudia.

Claudia Ximena Bustamante: Hello, everyone. Thank you for having me in this space. I’m Claudia Ximena Bustamante, Executive Director and Commissioner of the Communications Regulatory Commission of Colombia. We have been studying this topic since last year and working on net neutrality more than a decade. It would be a pleasure to discuss with all the panelists today.

Fabro Steibel: Thank you, Claudia. So now, we move to Tatiana Tropinem from Internet Society.

Tatiana Tropinem: Thank you very much for having me here, Tatiana Tropinem, Internet Society. In a society we have been engaged with this debate very closely, because various proposals, not only on network fees, I will speak later about how this debate has been shifting, taking different directions and different angles, but how ultimately there is no indication that there is any problem that actually needs to be solved. In fact, all these proposals on network fees are more solutions in search for a problem, and how they ultimately can fragment the Internet, disadvantage consumers and have quite a detrimental impact on Net Neutrality. Thank you.

Fabro Steibel: Thank you, Tatiana. And now we move to Thomas Volmer, Head of Global Content Delivery Policy at Netflix.

Thomas Volmer: Thank you, Fabro. And hi, everyone. It’s great to have such a nice attendance early in the day. Hopefully if we put on a good show, more people will also walk into the room. So thank you all for making it. So I’m Thomas Volmer. I represent Netflix today and the so-called private sector. But you know, it’s been 20 years in this great community of IGF. We’re all part of this multi-stakeholder process. And, you know, from event to event, sometimes we represent different organizations. And so I think I’ll bring that perspective also as a practitioner of IP interconnection. I’ve been doing this for 15 years on the telecom side and then on the hyperscale, on our content side. And yeah, I look forward to a great discussion. I’m a little bit intimidated because I see Professor Park has prepared a slide deck. So yeah, I’ll just talk through the issue.

Fabro Steibel: Park always have good decks. We should all be intimidated. So I think there is a higher issue here. So we have been discussing network fees for a few years. But directly related to that is how do we govern, how do we regulate the Internet? So in the past, we make a distinction between how we serve the Internet and how we use the Internet. two layers of the internet that we keep separate, at least in terms of regulation. In Brazil, for example, the telecom agency is allowed to rule the infrastructures of the internet but not the application layers. In other countries this happens as well, in the EU and others, and this has been questioned. And this is directly related to the idea of network fees, so it’s very good to discuss this, because beyond the idea of network fees per se, there is a discussion here on how we regulate the internet and how many people, how many agencies we have involved in that. So KS, would you like to start?

Kyung Sin Park: Yes. That’s me, that’s my contact information in case you want to take it down. So I’m a professor at the school and also directing open net digital rights organization that have been fighting for various golden digital norms, including net neutrality. Now, you all know that the sender pay rule that was proposed by telcos at ITU 2012 was roundly rejected by all stakeholders, and you already know why they were rejected, because there is this canonical relationship between net neutrality and information revolution. Under the net neutrality regime, where traffic is not discriminated for content, device, application, or whether the traffic was paid for, under that regime everyone has a chance to spread his or her message to everyone else without having to worry about the cost of data delivery. You can just put up one video revealing, say, police brutality, and one billion people can watch it. The photo that you see is the statue of democracy fighters who worked around the time of Gwangju Massacre of 1980, which was a really important event in the modern history of Korea. They are risking their lives in printing leaflets, asking people to come out for demonstration, and passing those leaflets out, they’ll have to risk their lives, otherwise risk of being caught by the police and being tortured. And these days, the protest organizers, they don’t have to go through this risk. They can just put on one video, one message, and people will come out. And that’s how you see the massive demonstrations in South Korea these past few decades. So fight for net neutrality is not just to fight to continue information revolution, but also not to regress back to the world of telephony or postage, where the sender, whoever is speaking, has to pay the cost of delivering their messages. The sender payroll exactly undercuts this pro-democratic effect of the internet by taxing people for speaking online. So the internet was built on this idea that we can all crowdsource our connections with one another for free. Because everyone pays for local connection, no one has to pay for the global delivery of data, no matter where you are. And standard payroll undercuts that. So we have had this system where everybody’s paying for local connection, but really don’t have to pay anything for actual delivery of the data. Now network fee proposer, which was revived a few years ago, is something different. It seems to apply only to the cross-border data traffic. It has nationalistic character to it. So what telcos are saying is that they’re spending money to maintain the domestic network. So whoever is sending data into the network, thereby burdening the domestic network, needs to pay the telcos who are maintaining it. But what telcos are forgetting is that the traffic route of any internet communication has the overseas segment and the domestic segment. Who is paying for the overseas segment? Big techs are investing in subsea cables and content delivery networks. Now telcos, they can charge their customers the monthly fees, exactly because the customer exactly because their customers can receive the data from overseas big techs delivered through these subsea cables and CDNs. So, telcos are benefiting from the big techs’ overseas infrastructure as much as the big techs are benefiting from the domestic infra. So, it is this mutual beneficial relationship. So, internet communication has this beneficial relationship and that’s why the early internet framers, the early framers of the internet decided not to charge one another and that decision really made the information revolution possible. Actually, telcos already know this because, you know, telcos, when they receive the traffic through the hierarchical, the normal hierarchy before the big techs began delivering the traffic at their doorstep through subsea cables, they actually paid money to the higher-tier telcos. But now, by receiving traffic directly from the big techs, they are actually saving money. Again, a mutually beneficial relationship. Now, you already know that when there is this mutual benefit, usually peering takes place on a settlement-free basis. Now, net neutrality does not require peering to be settlement-free. Peering can be paid for and net neutrality does allow that, but the problem with the network fee law, the fair sale deal or, you know, network fee law in other countries is that it mandates paid peering. Think about it. If the law And I would like to ask you, what do you think will happen if one party requires one party to pay, and the other party to get paid? What do you think will happen in that relationship? There will be abuse. The party entitled to payment will abuse the relationship to charge as much as possible, and the other side will have to succumb to whatever the demand is. Why? Because they have a legal obligation to make the payment. Now, how do I know this? You don’t need a thought experiment to do this, because the real experiment happened in South Korea in 2016. You will see that even small departure from this mutual beneficence principle causes a huge problem. So in South Korea in 2016, the government instituted a partial sender pay rule. So under this rule, only among the telcos, only among the ISPs, the sender had to pay. What happened? Telcos, you can see the image, you can see the picture above, the telcos hosting popular contents like Facebook cash server or Naver, Korea’s number one platform. By definition, because they were popular to all the users of the internet, they became the net sender of the traffic, and they had to pay other telcos. Which means hosting popular contents became a burden for the telcos, so the competition among the ISPs to host popular contents disappeared. And because the competition disappeared, Korea became the only country that the transit prices, which is really the internet access fees on the supply side or data supply side, did not fall unlike all other countries where the transit prices fell by at least 5 to 10 percent each year. Already in 2017, you can see that Korea’s transit prices is 8.3 times Paris, 6.2 times London, 4 or 5 times New York and L.A. And this trend continues to 2021 when the Korea prices became 8 times London and 10 times Frankfurt. And this, of course, makes the network environment toxic for Korean content providers. Which explains why you don’t see successful startups from Korea after Naver and Kakao. Even public interest apps like COVID-19 contact tracing apps, the operators complained to the media that network fees are restricting their ability to meet the demand. Many Korean content providers ended up leaving Korea to avoid exorbitant access fees and this affects the foreign content providers as well. It has exerted upward pressure on paid peering fees that Korean ISPs charged on foreign content providers. So Twitch, the premium game video platform, pulled out of Korea in 2022 citing, quote-unquote, network fees 10 times more expensive than other countries. 10 times Frankfurt, you see it? And, you know, when this happens, you think that, oh, okay. So, today, Naver has a domestic platform, Naver has a game platform, so they should welcome this, because now one competitor is eliminated. No, Naver also opposes this law, because they know that if this law is accepted, it will consolidate the system where the content providers always have to pay to send traffic. And Cloudflare gave up serving Korea content from Korea, instead they are serving it from Hong Kong or Tokyo, making Korea the market with the most latency among OECD countries. Now, probably there is a nagging argument that, you know, still, we should do something about big techs, because their traffic accounts for like 40% of the entire traffic volume. But the argument is really unfounded and almost childish. I mean, if NVIDIA chips cover 90% of the AI chips market, does NVIDIA have to pay something back to the customers, right? We have to think about the cost, right? Whether the traffic actually increases the cost of network maintenance. Now, okay, well, does traffic really cause congestion? No. I mean, you see, on the left side, if ISP provides 50 Mbps, then it can be distributed to five houses, but if the ISP provides only 30 Mbps, you know, it will cause problems for all the households. Now, what’s going to happen? So, this means that no matter how much each household, no matter how much a single household tries to use data, it cannot use more because the pipeline is already fixed for each household. So, the real responsibility for removing congestion comes from ISP who are laying the regional line, whether it would be 50 Mbps or 30 Mbps, whether it’s enough to supply all the households.

Fabro Steibel: Now, I like that even the dog is upset in the right hand side.

Kyung Sin Park: Yes, okay, I’m almost done. So, this is the graph showing how over the four years of the pandemic, the traffic increased five times, and yet the green bars representing not just network maintenance cost, but also capex, capital cost, has remained the same over the years. So, I’ll stop there, and then I’ll answer any questions you may have.

Fabro Steibel: Thank you, KS, and the discussion is particularly important now. I welcome you to see either in the ISOC report or KS publications the graph on the first days of implementation of the network fees in Korea. You see a spike of internet flowing outside of Korea to come back to Korea. In the current state where we need kind of AI fabrics, we need data centers, we must remember that this kind of data flow is the milk way, is the basis of how we fund data centers. If we make data be processed elsewhere, our data centers will become less cheap to process or own.

Konstantinos Komaitis: Thank you Fabro. So it’s a very hard task to follow KS because she has been literally doing this for such a long time and he has the data. I’m going to give a little bit of the European perspective here which actually is in some ways the reason we are still having this conversation globally because telcos, European telcos, and a small number of them really started this conversation. I’ll focus on predominantly four points. So one of the key arguments that we have been hearing in Europe is the fact that this idea of network phase is necessary because it is required to finance the increasing demands over infrastructure in Europe. And of course we all know that the internet infrastructure is not just limited to access networks because actually the internet is not really a monolith and it consists of many different players that are invested heavily in order to make sure that this infrastructure expands and is able to meet the demands of users. As I said in the beginning this is really not new. We have been having this conversation for 15 years at least and for 15 years we have been having reports suggesting that actually the internet model of traffic exchange is responsible for producing lower prices, promoting efficiency and innovation, and attracting investment that is necessary to keep up pace with the demand. So over the years of course and because the internet has changed and because the demands of users have also changed we have seen this increasing number of new players entering the infrastructure to facilitate the higher demands of traffic. You have content delivery networks, you have cloud providers, you even have community networks, satellite networks, data center, edge nodes and content caches are just a few of the new infrastructures that have developed to support internet communications. So the reality is that there is really not just one way to finance infrastructure and I think that it would be really naive to believe that. However, you know, telcos are fixated in just one way, direct payouts, give us money and we promise that we are going to address your infrastructure’s needs. The second point that I want to raise is really about what KS was also talking about, this idea of network neutrality and what such a system could do to this very basic yet fundamental principle that exists in the internet. So we all know that the internet is a network of interconnected networks, when data moves from point A to point B it is routed through these networks and now different companies own and manage different parts of the network. So the fact of the matter is that, you know, ISPs are really the gatekeepers to the content users to access and ISPs have a lot of power, if you think about it, at their disposal. They can mess up with traffic, they can degrade your traffic, they can change your quality, they can do a bunch of different things. So the idea of network neutrality is that they are not allowed to do that and we need to make sure that this continues to happen because if we give them any indication that the rules are a little bit flexible they will be able to mess up with the way traffic is delivered and the experience that users end up having. So imagine an environment where telecom operators are able to negotiate deals for infrastructure development. with certain companies within the Internet’s value chain. So logic dictates here that there must be some sort of a trade-off. We cannot expect money just to be handed out to telcos from Google or any other big company. So the possibility is, and that could happen, that a telco may end up prioritizing traffic or allowing content from certain companies. And that is a real issue. The other thing that needs to be pointed out, especially in the context of Europe, is that no one has ever proven that there was ever a market failure. Literally. I mean, there have been studies after studies after studies that actually say it is the contrary. There is no market failure in Europe. So when we have been asking for evidence that, you know, why do we need this change in order to be able and support a market, we have not been getting that evidence. And this now is on top of a global pandemic where we saw a massive increase in traffic. If there was ever a period in time where we could have had market failure, it would be during that one year in Europe when we were all locked up in our houses and the only thing that we were doing was accessing the Internet. So another point. Moving money from one private actor to another is really not a good idea. It’s actually a pretty lazy idea, if you think about it. So the Internet is made up of independent networks and each network joining the Internet is responsible for their own policies, their maintenance and upgrades. Any proposal now that suggests a forced subsidy from one part of the Internet’s value chain to another through undue… The European Commission should really focus more on incentivizing investment in innovation rather than trying to transform the way those networks interconnect. And the last point that I want to make, and I will just wrap up, is that I find it very ironic that in Europe we are talking a lot about competition and the fears of market concentration, and here, you know, we should be asking ourselves how sustainable really is a model where big technology companies will be paying off telcos? And I have been asking that question. I mean, how long do we think this is going to be happening if it goes through? Five years? Ten years? Fifteen years? When is going to be the point before big technology companies say, you know what, I don’t want to pay anymore, I’m just going to start providing my own, you know, become an ISP and start providing my own Internet access? And then you really talk about Internet concentration, market concentration, sorry. Before closing, right now in Europe we are at a place where we sort of phased off discussing network fees, but we are entering a place where we’re discussing dispute resolution mechanisms. So we’re not using the term network fees, but we’re really talking about other ways in order to make sure that this money flows from one private actor to another. And we’re even discussing perhaps reopening again the conversations around the open Internet regulation which has affected the network neutrality conversations. Let me make something very quick. I want to be very clear, a dispute resolution mechanism is a backdoor to network fees, it is exactly the same. The idea is again not new, it has been borrowed from the publishers and we saw it happening in the context of in Australia and in France where some deals have been made between big technology companies and publishers. Unfortunately we don’t have a lot of visibility in how that works simply because those agreements are covered by NDAs so they are not transparent and the only thing we know however is that they don’t cover smaller publishers. These are literally deals between huge publishers and technology companies. So again, we need to rethink what we want to create, if it is literally about innovation and investment and ensuring that infrastructure develops, this is really not the way to do it and happy to discuss further.

Fabro Steibel: Thank you Konstantinos and that reminds two big gaps in the network fees mechanism. The first one is, if you transfer funds from the private sector to another private sector, you cannot make sure that that funds will be used for connectivity, for connecting the unconnected or innovation. Basically you just transfer from the same sector one place to another, you don’t pass through the government, you don’t even have this and the second one is transparency. If you increase the need to have private contracts, you can have NDAs and you can have less transparency on how these costs are shared and how this is impacting the internet. So Claudia, we go online to you. Welcome.

Claudia Ximena Bustamante: Okay, regarding this discussion, I want to address first the net neutrality as a principle. In Latin America, many countries have adopted that there is no neutrality in their laws. For instance, in Colombia, since 12 years ago, neutrality is applied in Colombia. For that reason, we need to have an open internet without discrimination related to the type of traffic or company, or any sector. I think this helps to foster innovation and to continue the evolution of the ecosystem. When we talk about network fees or fair share, it’s a discussion that is brought to the table mainly by the telecom operators who control the access networks. And they indicate that there are huge investments needed in the years forward. And they need that all parts in the ecosystem contribute to the sustainability. From the regulator perspective, we need first to identify if there is a problem, if there is a market failure. For the reason in Colombia, at the end of the last year, we opened a consultation to all the stakeholders, but not focused on fair share specifically, but in the whole ecosystem to understand better… In Colombia, how is the functioning between access networks, content networks, and all of the agents of the value change of internet for mobile and for fixed telecom networks? In that council, we ask for information about traffic evolution, ARPUs, infrastructure provided by the different actors, the content access providers and the telecom, and we are gathering this information to have a real diagnosis of what’s happening here, because as we heard before, the Europe and the South Korea approaches are very different, and we cannot only bring that experience directly to the Latin region. We need to understand what is happening in Latin America, having in mind that we have multinational companies also working here. In the first analysis that the CRC has taken, we saw growth of the traffic in 1.7 times in the last two years. We think this is a normal growth. There is no exponential growth of the traffic that sometimes was mentioned by some actors, and we think this could be due to main assets. One of them is the distribution that has been made for the content. We have more CDNs and caching installed inside our country, and this helps to have the local or domestic traffic instead of overseas. And the other is the technical advances made in compression. Some content providers have been working on that, and in the LATAM region we have news about agreements between big tech companies and big ISPs in different countries like Mexico, for instance. This will help to lower the need for traffic, for networks, lower the pressure for the network that is handling that traffic. Of course, we understand that there’s a great pressure for investment and for connecting users. We have now a lot of users that have not been reached by any network at the moment. We have a connectivity gap in Colombia and in different regions, and as a strategy and as a public policy, we need to address that. In that aspect, different discussions have been taken. to have more actors, more stakeholders contributing to universal service funds, to have more resources to address this connectivity gap. This is a topic that has been discussed by many public policy government agencies around the region, and it’s a way to have more services, more reach of the services for the users. But at this moment, we don’t think there is a specific solution for this discussion that has been taken mainly in the last two years for Latin region. We know BEREC, like Konstantinos said before, has more years discussing this, and we know we have studied their experiences about the conclusions of the functioning of the IP interconnection and how the peering and the agreements are still working for the European context. We hope to have the results of our analysis related to this open consultation of the Internet ecosystem in Colombia in the next month. And also, we have a new legal aspect to review, because our constitutional court recently took a decision about our net neutrality law, and maybe as a regulator. We need to make a review of the current regulatory framework related to neoneutrality, because the Constitutional Court considers that offers differentiated plans to the users with specific applications or contents chosen by the ISP, not by the user directory. It’s against the neutrality principles. For that reason, we will have to study that decision when it’s fully published in the coming month. Maybe we have in the next year an updated regulatory framework for neoneutrality and for this discussion.

Fabro Steibel: Thank you very much, Claudia. It’s very interesting that the results of the consultations are coming in the next month. Brazil has done a consultation twice. We have evaluated all contributions and split from those supporting network fees and rejecting network fees. Basically, big telcos are one side, the others are in the others, which reinforces an Internet Society report from two years ago that I think was named Telcos versus the World. So, Tatiana, please feel free.

Tatiana Tropinem: Thank you very, very much. I just want to start with a very brief reflection that these debates are developing and there are some shifts. As Konstantinos said, there is not one way to finance the infrastructure development, and there are certainly various and very creative ways on how big telcos push this idea. Konstantinos Komaitis, Claudia Ximena Bustamante, Paula Bernardi, Thomas Volmer, Claudia Ximena We are witnessing various debates and discussions about regulating platforms through quality standards, which again is a backdoor to network fees. And what does it show? To us, it shows that it is not about these initial concerns about the lack of infrastructure investments. So far, we don’t see any indication that there is a problem that needs to be solved with the network fees or fair share. As I said at the beginning, in fact, it’s like a solution, various solutions have been proposed in search for a problem. It is my understanding, of course, we will look forward to see the outcomes of the consultation in Colombia, but various debates in Latin America found no marked failure. The consultations in the European Union also failed to provide any evidence of a problem that needs any regulatory interventions like that. And even more, the European body of regulators for electronic communication, BEREC, already mentioned here, has concluded that Internet’s interconnection ecosystem is a well-functioning market. It has very good dynamics with very balanced bargaining powers. And BEREC also said that the introduction of these cost-sharing mechanisms would, in fact, have very negative consequences on the Internet ecosystems. So, it’s basically all about the telecom operators generating revenue. And to us, the reference to content providers being traffic generators is the flawed premise that BEREC has already debunked, at least in the EU. So following these developments and following these narratives in the EU, in Latin America and also in South Korea, basically lets us witness how the big telecom operators are trying to break the net neutrality frameworks. And they are even saying it openly, that hello, hey, this is the time to review the net neutrality. And as I said already, the premise that content providers or platforms are traffic generators, that they generate the traffic, is fundamentally flawed. The traffic is not created by the online services. It is requested by internet users. It is this traffic that those very users already pay for in the internet subscription and just as online service pays for their own internet access to send it. So to put it simple, there is no service free riding on the internet because data access and fees have already been paid. There have already been factors at the cost. And in addition to telecom operators, for example, content generators have their own investments. I’m pretty sure Netflix could tell us how much they invest in this content creation. It’s also millions. So from our perspective, any solutions that would introduce network fees would first of all disadvantage the smaller players by creating much higher entry barriers. They will risk fragmenting the internet by conditioning this connectivity on prior contracting with the user’s network. And ultimately, these costs are going to be passed on the end users, which contradicts that very principle of. And this is the kind of fairness that these proposals seem to be motivated by. But more importantly to us, to our mission, these solutions can fragment the open and globally connected Internet because the current global connectivity is based on voluntary inter-networking agreements that allow network operators to optimize their connectivity to meet their customer needs. And this is basically a cornerstone for the Internet to be an efficient network, resilient network that is able to host new applications, deploy these innovative services. And this happens without prior contracting with everyone in the system. And these arrangements foster innovation, they foster development. So how these network fees solutions will break the Internet? Simply speaking, and I’m really saying it simply, they can turn the idea of the Internet into a telephone system. The same regulation. And again, talking about the development of this debate, as Fabio mentioned already, in Brazil there is a proposal to revoke the norm that clearly separates telecom services from value-added services as the Internet. And this distinction allowed Brazilian Internet to grow as a decentralized competitive ecosystem. We recently published an open letter for Brazilian lawmakers and regulators highlighting the threat that this proposal of separation creates. Centralizing Internet control, weakening market diversity, disrupting current governance model which is based on public interest and multi-stakeholder input. So to sum up, if we stop treating the Internet as technology-neutral, general-purpose network, we will just lose it. And we will rebuild it. We already witnessed the evidence, like for example when KC spoke about South Korea, and anecdotally also, but importantly for users and services, when you look at Korean markets, you see that teams playing big esports in Korea do not play from South Korea anymore. They move to other countries to avoid playing because of disadvantage in network latencies that are basically unbearable for their activity. And I know that for some regions it might be irrelevant, but in South Korea it’s a very big issue. And as I said before, the consultations in Latin America and the EU didn’t find any market failures to justify such interventions in the traffic. And just to wrap up, if we continue these debates that connect the issue of investment to telecom infrastructure, to this flawed premise of traffic generators, we will always get nowhere, we will get stuck at best, and at worst we’ll have fragmented internet. Exactly because the initial premise in this discussion is absolutely flawed. And in this context, any solution, if we think that okay, maybe the investment in the infrastructure is a problem, but any solution that connects network infrastructure investment to traffic generator is not a proper solution, because it does not solve the root of the problem. Thank you.

Fabro Steibel: Thank you, Tatiana. And I think I can bring another topic to the table, which is freedom of expression. There is a big policy framework that we need a huge sheriff in the internet, that the open and safe internet needs limits to be enforced, and then we need sheriffs. And network fees are not content neutral. They might imply on what is distributed and how. So let’s say I have Netflix, a documentary in favor of free internet. I am a believer of myself and I have a documentary against myself. If I can make a distinction on how both of them, each of them, reach the audience, there is a direct impact on freedom of expression amongst others. So, Thomas, moving to you.

Thomas Volmer: Yeah, I don’t know if the documentary is for or against you, Fabro, so I haven’t seen it yet, so maybe it will come soon. No, thanks. A lot has been said already, of course, so I’ll try not to repeat what many of you have said. Maybe just to start looking at the evidence, good policy is always grounded on evidence. The discussion, of course, has been rebooted in the past two years, but it’s not been years, it’s been decades. We have decades of perspective on Internet traffic growth. And in the past, what, let’s say 25 years, since the Internet has gone really commercial and mainstream, traffic has probably grown 500 or 1,000 times. Is this out of control? Is the Internet breaking? No, it’s thriving, it’s doing great, because that growth is absolutely sustainable. And the reason for that is that it’s managed really well in a collaborative manner by the stakeholders, many of which are in the room today. In the interconnection space, what does that mean? That means that content providers, such as Netflix and ISPs, large or small, work together to make the traffic flow in an efficient manner. It’s in both of our interests, because our joint consumers, our customers, consumers, want access to great content and are willing to pay for good quality broadband to access great content. So what does it mean in practice? Netflix has invested over a billion dollars in its own content delivery network, Open Connect. We have over 6,000 server locations around the world, which means that when you press play on Netflix, you’re actually streaming from right around the corner. It means no terabits of streaming over a long distance. and I’m here to talk about the long-distance network, no congestion of the long-distance backbone and unhappy dogs in the Korean households thanks to that. And to be clear, it’s not Netflix doing it on our own. It is working with ISPs to do it. It’s literally engineers sitting down in the same room, drinking coffee, sometimes drinking beer, and figuring out network planning together. And so it’s that joint work of the community that has achieved this important project, and we can talk about this now. We’re always competitive, sometimes, sometimes. I just wrote it down because the quote I couldn’t have written it better myself. Network use cylinder had increased, but due to technology development as well as competitive pressure, marginal network costs are observed to have declined to the point that they outweigh any increased costs associated with increasing network use. And the internet has, since it was created, managed to cope with traffic growth and more accentuated traffic peaks, all of which reflect changes in usage patterns as well as increased diffusion of internet access throughout societies. Bayreg considers that due to competition as well as technological progress, there is currently no indication that this is likely to change in the future. Okay. I think I’ve said my piece. I think it’s pretty self-explanatory. Just addressing the net neutrality point, I think if we boil it down very simply from a consumer perspective, net neutrality is about paying for one single broadband access and being able to access any content of your choice, whether it’s on Netflix, any other service. And network fees directly turn this principle upside down, because if there’s a toll at the entrance of your ISP network, then you don’t have the choice of the content. You can only access the content that has a special deal with your ISP. So, the user is not in control anymore, the gatekeeper is in control. That’s the fundamental contradiction. And by the way, in the entertainment world, we know exactly what it looks like when there’s no such neutrality. It’s called cable, and it sucks. That means that you’re buying a cable broadband and you’re subject to carriage disputes. Oh, the carriage provider don’t get along, you don’t have this channel or that channel. On the Internet, it’s simple, you pay for your broadband, you pay for your Netflix or your Disney or anything else, and you have the choice. I think it’s a much better system. So, in our engineering discussions, you know, between ISPs and content to figure out the servers and the interconnection, yes, there’s one moment at the end of the meeting, you figure the plan out, you drink all the coffee, and there’s, oh, by the way, my boss says, you need to pay for this interconnection. And maybe the other side will be, well, we think maybe you should pay for the interconnection and access the content. Is that a good model? Yeah, no, that’s not a good model. All right, let’s move on. That’s hardly a market failure. It’s just the way the business is done. Now, I wanted to address, I think Claudia mentioned a lot of interesting points, right? I don’t mean to say that everything is fine on the Internet, there’s no issue to resolve. I think, you know, we’re gathering at IGF every year because there are still very interesting questions to resolve. And I want to mention a few of them, right? Websites are still being throttled today, even including in developed nations. There’s a net neutrality case in Germany happening at the moment. We still have unconnected people, billions of people around the world that are still not connected to the Internet. And geopolitical risk is creating risk of splinternet. Those are the real issues, not the network fees, right? And so the good news is that there are existing good solutions that work for many of those problems. I’ll mention some of them. The first one is the most obvious. First, do no harm, right? I’m often asked, like, well, yeah, but isn’t there a compromise to be found in this fair share? Let me be crystal clear, if you are looking to solve a problem that does not exist, there is no compromise to be made. That’s a solution in search of a problem. Now on the supply side for connectivity, competition has been proven over and over again to be a great way to stimulate investment and stimulate affordability. Pro-competitive policies should be considered whenever they are helpful, of course. And then there’s potentially a coverage gap that can be addressed through subsidies. I think even bigger is a demand gap. We were talking about Latin America. I’m always fascinated by the figures that GSMA releases for Latin America. I may be misquoting the numbers, but directionally, I think there’s over 90% of people covered by 4G networks and I think only around 60% adoption. That means people are covered by the network. However, either they choose or they cannot afford to actually subscribe. That is the adoption gap. And that is a demand gap. Streaming services like Netflix contribute to demand, of course, to the Internet. There’s a causal link between the availability of video on demand and then broadband adoption, adoption of faster speed, willingness to pay, and consumer surplus. So that is a way to address the demand gap. Of course, that is not the only way because, as you well know, it’s not just about entertainment on the Internet. It’s also about access to information, access to public critical infrastructure, and so on and so forth. And so in terms of policies, I think if I want to quickly recap, and I know we need time for the questions as well, discard the false good ideas, do no harm, move on from the debates of the past. Pro-competitive policy to stimulate the supply side, potentially targeted subsidies, but also pro-demand policies. And the demand, again, is generated by the content, by the availability of the online services. Nobody buys a broadband connection to see the little blinking lights on their router. Well, actually, maybe I do. I like to have a super fast fiber at home in Paris and see those light blink really, really fast. But I don’t think that’s the majority of people. And so there’s often this idea of, well, shouldn’t we tax the online companies to fund the infrastructure? That’s looking at the problem exactly backwards, because you’re going to compress the demand by suppressing taxing the demand for the thing you actually want to stimulate adoption of in the first place. That’s not going to work. Thank you.

Fabro Steibel: Thank you, Thomas. Now we have 13 minutes. By the end of it, they cut my mic. So we need around 10 minutes for the table to reply to a question. So we have three minutes for collecting questions. We can start here. Please be aware of the person next to you.

Louvo Gray: Thank you very much and much appreciated for facilitating this very important discussion. My name is Louvo Gray. I am from the South African Internet Governance Forum. And I run an internet service provider in South Africa. So given Africa’s urgent need to expand affordable internet access to over 1 billion unconnected people, how do we then ensure that the global network fee models do not create new financial barriers for African-owned networks, content creators, and also users trying to participate meaningfully in the digital economy? Because I think one of the discussions we are not having is that traditionally, the undersea cables were owned by your Dacha telecoms, which are consortiums of telecommunications companies. And most of those cables have reached end of life, are now reaching end of life. And the new generation of undersea cable owners are the very same content creators we’re trying to influence. The telcos want to introduce network fees for.

Fabro Steibel: Thank you very much, we go for the next one on site.

Rian Duarte: Hello, my name is Rian Duarte, I’m from the Brazilian Association of Internet Service Providers. We have been an active voice against network fees in Brazil. We represent small ISPs and small businesses in Brazil. We have been working with the Brazilian government for a number of years. We have been working with the Brazilian government for a number of years. We represent small ISPs and small and medium operators in Brazil. As you may know, Brazil has a rich ISP system with over 20,000 small and medium companies holding over 60% of fixed broadband market share. Unfortunately, as has been shown by the panel, our regulator continues to hold debates on this topic, even though big telcos have not been able to produce concrete evidence of a problem to be solved. But on the other hand, we are happy to see a push against network fees from our parliament with law proposals prohibiting this practice and we would urge other countries to follow suit. And my question is a very simple one, what else is there to be done to overcome this debate so we can focus on actual solutions for connectivity?

Fabro Steibel: Thank you very much, we go for the last question.

Frode Kieling: Yes, I’m Frode Kieling from Telco, 200 million customers in Asia and in Nordic. I’m surprised about the panel here, we have just one side presented here, one view. So, next time I suggest to get some, we’ll talk about the challenges that the telcos and the ISPs see. Because the fundamental principle in Internet was that there was an equal share of traffic. I send as much traffic as I receive from you. And that was the founding principle. Today, it’s about maybe 70-80% of the traffic I’ve seen in some operations. It comes from a handful of big CDNs, Netflix, Google. and some others. So it’s very unbalanced. But the thing here is that the revenues for the telcos is sinking. And that is the perceived challenge that the telcos experience. And we see the revenues created on the content providers, like Netflix, is going straight up. But the infrastructure needs to be paid for. And there are three ways to do this. You can have network fees or you can break the net neutrality to get some extra revenues. And the third option is to lay all the costs on the customers. And that is an issue when you at the same time talk about the connected and unconnected. So what I hear from you, you want the customers to take all the costs.

Fabro Steibel: Yes, thank you. Sorry, we have nine minutes, so no time for new questions. Let’s go.

Pablo Barrionovo: Thank you. My name is Pablo Barrionovo from Telefonica. I think it would have been interesting to have a telecom operator seated in this table when talking about network fees. Sometimes the multi-stakeholder model is not so multi, I see. In my opinion, we may agree that we have a problem. There is a problem. And the problem is the sustainability of the model. And of course, it is always interesting to talk, to try to find solutions to the problems we have. But sincerely, I’m not sure that what has happened here today can be considered a dialogue. Thank you very much.

Fabro Steibel: Thank you. J.S., do you want to go for concluding remarks?

Kyung Sin Park: Well, I’ll answer one question. I don’t, I mean, I’ve read a lot on the principles of the Internet, but I’ve never heard about equal share of traffic. I mean, when, when, I mean, the ISPs don’t, I mean, there is no cost differential whether traffic is going one way or the other. I mean, there is no increase in cost. So, I don’t know why you think that there has to be, on any road, why should the data travel, you know, equal amount of data should travel both ways.

Thomas Volmer: I can comment on this one, the point about traffic ratios. I think it’s important to be addressed because it’s part also of the history of transit and interconnection negotiations. I think, historically, Internet traffic has been routed on a hot potato basis. That means that if you have, let’s say, a French network and an American network interconnecting on both sides of the Atlantic, if you’re the net sender, you’re dropping, let’s say the French is the net sender, you’re dropping the traffic to the American network in Paris, and the American network has to carry it long distance. And vice versa, if you’re sending from the US, the French has to carry it long distance. So, there used to be on multi-location interconnect, hot potato routing, a benefit to being a net sender and a disadvantage to being a net receiver. That’s why, oftentimes, on long distance networks, you have ratio settlements agreements, and I think that’s fine, as you said, you know, it’s okay to have those agreements. That’s why, you know, it’s a well-functioning market because you have deals that reflect the underlying economics. However, the modern Internet does not function like that, certainly not for content delivery. What we do with OpenConnect, for example, is the opposite of hot potato routing. It’s actually the equivalent of cold potato routing, meaning that we bring the traffic all the way next to the user, to those networks. 6,000 Open Connect locations around the world. And so when you’re on a cold potato routing, whether the traffic flows in and out locally to Oslo does not make a difference. And this is why for such agreements, agreements typically between CDNs and operators, there’s no ratio concerns. And they are just the bits flow freely on a settlement-free basis. But to your point, long distance, backbone network, tier one networks, they typically would enforce ratio agreements. But if it comes from a terminating ISP wanting to charge CDNs on the basis of ratio, then you almost always know that this is a fake argument and more like a network fee type of, hey, I want to exploit my termination monopoly and violate net neutrality doing it.

Fabro Steibel: Thank you. So we have Claudia online. We go to Costas and then to Claudia.

Konstantinos Komaitis: Just very quickly, and Thomas just literally talked about and KS responded to the traffic question. One of the things that really surprises me in this conversation is, especially when I hear about the traffic, is that we’re talking, yes, there is a change in traffic. But then no one continues to say, oh, but some companies have actually built data centers and content delivery networks to ensure that actually this traffic does not become burdensome for ISPs. And the other point, we are literally, both in Europe and in Brazil, we are hearing small ISPs telling large telco operators that they don’t want this, that this system is going to disadvantage them. And we continue to beat the same drum. There are five companies in Europe that continue to beat the same drum saying, oh my god, but yes, we used to be so big. And right now, we’re not as big as other companies. Well, I’m sorry. They had 20 years to invest. They had 20 years to innovate. And we have not seen that. Literally, we have not seen that, and I still cannot understand why we need to be excusing the lack of innovation and start moving money around just because we have telcos being extremely unhappy with not being as big as they used to be.

Fabro Steibel: Thank you, Kostas. Claudia, online?

Claudia Ximena Bustamante: Yes. Regarding the questions, I want to address first that the sustainability issues that the telco operator has can be addressed in different ways. In the different spaces that we share with them here in the LATAM region, they indicate that there are different ways that could help them to grow the networks and to have better solutions for the users. For instance, reducing spectrum licensing fees, reducing the taxes that they are being charged by different laws, and reducing or adjusting the obligations for specific coverage in far and difficult access regions. Those are measures that the government could take to help them grow and to have more focused services and investments in the region. For that reason, there is no one specific answer to the discussion that we are having with them. Another thing that I would like to mention is that the regulatory framework they could develop in an experimental way that need a flexibilization of some specific regulations in place. In that context, we could help them to develop new services, new process to have better quality of service and adjust and change our regulatory framework if it’s needed. For that reason, I think as a government institution, we need to have these kind of spaces and explore different approaches to help the ecosystem growth. And I think the discussion is not only for one specific solution, but have different ways. And of course, multinational, multilateral cooperation in forums like Regulatel, for instance, that is our LATAM forum for regulators, could help us to find these different approaches.

Fabro Steibel: We have five seconds. Thank you very much for your participation. Sorry, Tatiana. Thank you for the words.

Agreement points

Network fees lack evidence of market failure and are solutions in search of problems

Speakers

– Kyung Sin Park
– Tatiana Tropinem
– Konstantinos Komaitis
– Thomas Volmer

Arguments

Network fees are fundamentally flawed and create disasters in internet ecosystems, as demonstrated by South Korea’s experience with partial sender pay rules

Network fees proposals are solutions in search of a problem, with no evidence of market failure in various consultations

European telcos have been pushing network fees for years despite studies showing no market failure and well-functioning interconnection markets

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Summary

Multiple speakers agree that network fees are not justified by evidence and that current internet interconnection systems work well without regulatory intervention

Topics

Economic | Legal and regulatory

Network fees threaten net neutrality principles

Speakers

– Kyung Sin Park
– Konstantinos Komaitis
– Thomas Volmer
– Claudia Ximena Bustamante

Arguments

Net neutrality is essential for democratic participation and information revolution, preventing regression to telephony-style sender payment systems

Network fees would allow ISPs to prioritize traffic based on payment deals, undermining the principle that users should control content access

Network fees directly contradict net neutrality by creating tolls that limit user choice to content with special ISP deals

Net neutrality has been law in Colombia for 12 years, fostering innovation and open internet without discrimination

Summary

Speakers consistently argue that network fees would undermine net neutrality by giving ISPs control over content access and creating discriminatory treatment of traffic

Topics

Infrastructure | Human rights | Legal and regulatory

Multiple stakeholders invest in internet infrastructure, not just telcos

Speakers

– Kyung Sin Park
– Konstantinos Komaitis
– Thomas Volmer

Arguments

Content providers like Netflix invest heavily in CDNs and infrastructure, creating mutually beneficial relationships with ISPs

Multiple players invest in internet infrastructure including CDNs, cloud providers, and edge nodes, not just telcos

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Summary

Speakers agree that internet infrastructure investment is shared across multiple stakeholders, with content providers making significant investments in CDNs and other infrastructure

Topics

Infrastructure | Economic

Small ISPs oppose network fees

Speakers

– Rian Duarte
– Konstantinos Komaitis

Arguments

Small and medium ISPs in Brazil oppose network fees as they would disadvantage smaller operators

European telcos have been pushing network fees for years despite studies showing no market failure and well-functioning interconnection markets

Summary

Both speakers note that small ISPs are opposed to network fees, with only large telcos pushing for these mechanisms

Topics

Economic | Legal and regulatory

Similar viewpoints

Both speakers emphasize the collaborative nature of internet infrastructure management and the mutual benefits between content providers and ISPs through technical cooperation and shared investment

Speakers

– Kyung Sin Park
– Thomas Volmer

Arguments

Content providers like Netflix invest heavily in CDNs and infrastructure, creating mutually beneficial relationships with ISPs

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Topics

Infrastructure | Economic

Both speakers warn that network fees would fundamentally change the internet’s architecture and governance model, giving ISPs excessive control over content access and potentially fragmenting the global internet

Speakers

– Tatiana Tropinem
– Konstantinos Komaitis

Arguments

Network fees could fragment the internet by turning it into a telephone-like system requiring prior contracting

Network fees would allow ISPs to prioritize traffic based on payment deals, undermining the principle that users should control content access

Topics

Infrastructure | Legal and regulatory

Both speakers advocate for alternative policy approaches to address telecom sustainability concerns rather than implementing network fees

Speakers

– Claudia Ximena Bustamante
– Thomas Volmer

Arguments

Alternative approaches like reducing spectrum fees, taxes, and regulatory flexibility could better support telecom growth

Competition and pro-demand policies are more effective than network fees for stimulating investment and adoption

Topics

Economic | Legal and regulatory

Unexpected consensus

Evidence-based policy making approach

Speakers

– Claudia Ximena Bustamante
– Thomas Volmer
– Tatiana Tropinem

Arguments

Colombia is conducting comprehensive consultation to understand the ecosystem before determining if there’s a real problem requiring intervention

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Network fees proposals are solutions in search of a problem, with no evidence of market failure in various consultations

Explanation

Despite representing different stakeholder groups (regulator, private sector, civil society), these speakers all emphasize the importance of evidence-based decision making and comprehensive analysis before implementing policy changes

Topics

Legal and regulatory | Economic

Recognition of traffic management evolution

Speakers

– Claudia Ximena Bustamante
– Thomas Volmer
– Konstantinos Komaitis

Arguments

Traffic growth in Colombia has been normal (1.7 times in two years) due to local CDNs and compression advances

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Multiple players invest in internet infrastructure including CDNs, cloud providers, and edge nodes, not just telcos

Explanation

Speakers from different backgrounds acknowledge that modern internet architecture has evolved to handle traffic growth efficiently through technological advances and distributed infrastructure

Topics

Infrastructure | Economic

Overall assessment

Summary

There is strong consensus among most speakers against network fees, with agreement on lack of evidence for market failure, threats to net neutrality, and the collaborative nature of internet infrastructure investment. The main areas of agreement include opposition to network fees based on evidence, support for net neutrality principles, recognition of multi-stakeholder infrastructure investment, and preference for alternative policy approaches.

Consensus level

High level of consensus among the majority of speakers (6 out of 8 substantive speakers) opposing network fees, with only telecom industry representatives supporting them. This strong consensus suggests that network fees face significant opposition from diverse stakeholders including academics, civil society, regulators, content providers, and small ISPs. The implications are that network fees proposals may struggle to gain broad support in policy discussions, and alternative approaches to addressing connectivity and infrastructure challenges may be more viable.

Different viewpoints

Fundamental premise of network fees and traffic imbalance

Speakers

– Kyung Sin Park
– Thomas Volmer
– Frode Kieling

Arguments

Park: I don’t, I mean, I’ve read a lot on the principles of the Internet, but I’ve never heard about equal share of traffic. I mean, when, when, I mean, the ISPs don’t, I mean, there is no cost differential whether traffic is going one way or the other.

Volmer: However, the modern Internet does not function like that, certainly not for content delivery. What we do with OpenConnect, for example, is the opposite of hot potato routing. It’s actually the equivalent of cold potato routing, meaning that we bring the traffic all the way next to the user

Kieling: Because the fundamental principle in Internet was that there was an equal share of traffic. I send as much traffic as I receive from you. And that was the founding principle. Today, it’s about maybe 70-80% of the traffic I’ve seen in some operations. It comes from a handful of big CDNs

Summary

Kieling argues that the internet was founded on equal traffic sharing and current imbalances justify network fees, while Park and Volmer dispute this historical claim and argue that traffic direction doesn’t create cost differentials in modern internet architecture with CDNs and cold potato routing.

Topics

Infrastructure | Economic

Evidence of market failure and need for regulatory intervention

Speakers

– Tatiana Tropinem
– Konstantinos Komaitis
– Pablo Barrionovo
– Frode Kieling

Arguments

Tropinem: Network fees proposals are solutions in search of a problem, with no evidence of market failure in various consultations

Komaitis: European telcos have been pushing network fees for years despite studies showing no market failure and well-functioning interconnection markets

Barrionovo: In my opinion, we may agree that we have a problem. There is a problem. And the problem is the sustainability of the model.

Kieling: Telcos face revenue challenges while content providers’ revenues grow, creating sustainability concerns for infrastructure investment

Summary

Tropinem and Komaitis argue that consultations and studies show no market failure exists, while Barrionovo and Kieling contend there are real sustainability problems with telco revenues declining as content provider revenues grow.

Topics

Economic | Legal and regulatory

Multi-stakeholder representation in the debate

Speakers

– Pablo Barrionovo
– Frode Kieling
– Fabro Steibel

Arguments

Barrionovo: I think it would have been interesting to have a telecom operator seated in this table when talking about network fees. Sometimes the multi-stakeholder model is not so multi, I see.

Kieling: I’m surprised about the panel here, we have just one side presented here, one view. So, next time I suggest to get some, we’ll talk about the challenges that the telcos and the ISPs see.

Steibel: Brazil has done a consultation twice. We have evaluated all contributions and split from those supporting network fees and rejecting network fees. Basically, big telcos are one side, the others are in the others

Summary

Telecom representatives criticized the panel for being one-sided against network fees, while Steibel acknowledged the clear division between big telcos supporting network fees and most other stakeholders opposing them.

Topics

Legal and regulatory

Unexpected differences

Historical principles of internet traffic exchange

Speakers

– Frode Kieling
– Kyung Sin Park
– Thomas Volmer

Arguments

Kieling: Because the fundamental principle in Internet was that there was an equal share of traffic. I send as much traffic as I receive from you. And that was the founding principle.

Park: I don’t, I mean, I’ve read a lot on the principles of the Internet, but I’ve never heard about equal share of traffic.

Volmer: I think it’s important to be addressed because it’s part also of the history of transit and interconnection negotiations… However, the modern Internet does not function like that

Explanation

This disagreement was unexpected because it revealed fundamental differences in understanding internet history and technical architecture. Park, a law professor specializing in internet governance, directly contradicted Kieling’s claim about equal traffic sharing being a founding principle, while Volmer provided technical context about how modern CDNs have changed traffic patterns. This suggests deeper disagreements about the technical and historical foundations underlying the network fees debate.

Topics

Infrastructure | Legal and regulatory

Small ISP perspectives on network fees

Speakers

– Rian Duarte
– Frode Kieling

Arguments

Duarte: Small and medium ISPs in Brazil oppose network fees as they would disadvantage smaller operators

Kieling: Telcos face revenue challenges while content providers’ revenues grow, creating sustainability concerns for infrastructure investment

Explanation

This disagreement was unexpected because it revealed a split within the telecom sector itself. While Kieling represented large telco concerns about revenue sustainability, Duarte showed that small and medium ISPs (representing 60% of Brazil’s broadband market) actively oppose network fees, suggesting the issue is not universally supported across the telecom industry but may primarily benefit large incumbent operators.

Topics

Economic | Legal and regulatory

Overall assessment

Summary

The discussion revealed sharp disagreements on three main areas: whether network fees address a real problem or create new ones, the historical and technical foundations of internet traffic exchange, and the adequacy of multi-stakeholder representation in the debate.

Disagreement level

High level of disagreement with significant implications. The debate appears polarized between large telcos seeking new revenue streams and most other stakeholders (including small ISPs, content providers, civil society, and some regulators) opposing network fees. The disagreements go beyond policy preferences to fundamental questions about internet architecture, market functioning, and democratic participation in internet governance. This polarization suggests that compromise solutions may be difficult to achieve and that the debate will likely continue across multiple jurisdictions.

Partial agreements

Similar viewpoints

Both speakers emphasize the collaborative nature of internet infrastructure management and the mutual benefits between content providers and ISPs through technical cooperation and shared investment

Speakers

– Kyung Sin Park
– Thomas Volmer

Arguments

Content providers like Netflix invest heavily in CDNs and infrastructure, creating mutually beneficial relationships with ISPs

Internet traffic growth over 25 years has been sustainable through collaborative stakeholder management

Topics

Infrastructure | Economic

Both speakers warn that network fees would fundamentally change the internet’s architecture and governance model, giving ISPs excessive control over content access and potentially fragmenting the global internet

Speakers

– Tatiana Tropinem
– Konstantinos Komaitis

Arguments

Network fees could fragment the internet by turning it into a telephone-like system requiring prior contracting

Network fees would allow ISPs to prioritize traffic based on payment deals, undermining the principle that users should control content access

Topics

Infrastructure | Legal and regulatory

Both speakers advocate for alternative policy approaches to address telecom sustainability concerns rather than implementing network fees

Speakers

– Claudia Ximena Bustamante
– Thomas Volmer

Arguments

Alternative approaches like reducing spectrum fees, taxes, and regulatory flexibility could better support telecom growth

Competition and pro-demand policies are more effective than network fees for stimulating investment and adoption

Topics

Economic | Legal and regulatory

Key takeaways

Network fees are fundamentally flawed solutions seeking problems that don’t exist, with no evidence of market failure found in consultations across Europe, Latin America, and other regions

South Korea’s implementation of partial sender pay rules in 2016 serves as a cautionary example, resulting in 8-10 times higher transit prices than other countries and driving services like Twitch to exit the market

Network fees directly undermine net neutrality principles by allowing ISPs to prioritize traffic based on payment deals rather than user choice, potentially fragmenting the internet into a telephone-like system

The internet’s current interconnection model is well-functioning, with multiple stakeholders (content providers, ISPs, CDNs) collaboratively investing in infrastructure through mutually beneficial relationships

Content providers like Netflix invest heavily in their own infrastructure (over $1 billion in CDNs with 6,000 server locations globally), reducing network burden through local content delivery

Small and medium ISPs oppose network fees as they would create disadvantages for smaller operators, with Brazil’s 20,000+ small ISPs holding 60% of the broadband market strongly opposing such measures

Alternative solutions exist for telecom sustainability concerns, including reducing spectrum fees, taxes, regulatory flexibility, and pro-competitive policies rather than forced money transfers between private actors

Resolutions and action items

Colombia will publish results of their comprehensive internet ecosystem consultation in the coming month to determine if regulatory intervention is needed

Colombia’s regulator will review their net neutrality regulatory framework following a Constitutional Court decision on differentiated service plans

Brazil’s parliament is pushing forward with law proposals to prohibit network fee practices

Continued monitoring and evidence-gathering on internet interconnection markets to inform policy decisions

Unresolved issues

The fundamental disagreement between telcos claiming revenue sustainability problems and other stakeholders arguing no market failure exists

How to address legitimate infrastructure investment needs without implementing harmful network fee mechanisms

The lack of transparency in private interconnection agreements covered by NDAs, making it difficult to assess true market dynamics

Balancing the need to connect the unconnected with concerns about creating new financial barriers through network fees

The ongoing shift in undersea cable ownership from traditional telcos to content providers and its implications for internet governance

How to ensure multi-stakeholder representation in policy discussions, as telcos felt underrepresented in this particular panel

Suggested compromises

Exploring alternative regulatory approaches such as experimental frameworks that allow flexibility in specific regulations to help telecom growth

Implementing targeted subsidies for infrastructure development rather than forced private-to-private money transfers

Focusing on pro-competitive policies and demand-side stimulation rather than supply-side taxation

Addressing telecom sustainability through government policy changes (reducing spectrum fees, taxes, coverage obligations) rather than network fees

Developing transparent, evidence-based approaches through comprehensive market studies before implementing any regulatory changes

The sender payroll exactly undercuts this pro-democratic effect of the internet by taxing people for speaking online… Fight for net neutrality is not just to fight to continue information revolution, but also not to regress back to the world of telephony or postage, where the sender, whoever is speaking, has to pay the cost of delivering their messages.

Speaker

Kyung Sin Park

Reason

This comment reframes the entire network fees debate from a technical/economic issue to a fundamental democratic rights issue. By connecting network fees to freedom of expression and comparing it to authoritarian control of information, Park elevates the stakes of the discussion beyond mere business models to core democratic values.

Impact

This framing influenced the entire panel’s approach, with subsequent speakers like Fabro explicitly connecting network fees to freedom of expression issues. It established the moral and political foundation that other panelists built upon throughout the discussion.

So when this happens, you think that, oh, okay. So, today, Naver has a domestic platform, Naver has a game platform, so they should welcome this, because now one competitor is eliminated. No, Naver also opposes this law, because they know that if this law is accepted, it will consolidate the system where the content providers always have to pay to send traffic.

Speaker

Kyung Sin Park

Reason

This insight reveals the counterintuitive reality that even companies that might benefit from network fees in the short term oppose them because they understand the systemic damage. It demonstrates sophisticated strategic thinking about long-term consequences versus short-term gains.

Impact

This comment shifted the discussion from a simple ‘big tech vs. telcos’ narrative to a more nuanced understanding of how network fees create systemic problems that even potential beneficiaries recognize as harmful. It influenced later speakers to focus on systemic rather than partisan concerns.

Moving money from one private actor to another is really not a good idea. It’s actually a pretty lazy idea, if you think about it… Any proposal now that suggests a forced subsidy from one part of the Internet’s value chain to another through undue… The European Commission should really focus more on incentivizing investment in innovation rather than trying to transform the way those networks interconnect.

Speaker

Konstantinos Komaitis

Reason

This comment cuts through complex technical arguments to expose the fundamental policy flaw: network fees are essentially forced wealth transfers between private companies without addressing underlying issues. The characterization as ‘lazy’ policy is particularly provocative and memorable.

Impact

This framing influenced subsequent speakers to focus on alternative policy solutions rather than defending against network fees. It shifted the conversation from reactive defense to proactive policy alternatives, with later speakers like Claudia discussing spectrum fees and regulatory flexibility as better approaches.

The traffic is not created by the online services. It is requested by internet users. It is this traffic that those very users already pay for in the internet subscription and just as online service pays for their own internet access to send it. So to put it simple, there is no service free riding on the internet because data access and fees have already been paid.

Speaker

Tatiana Tropinem

Reason

This comment fundamentally challenges the core premise of network fees by reframing who ‘generates’ traffic. It’s a crucial conceptual clarification that exposes the logical fallacy underlying the entire network fees argument.

Impact

This reframing became a central theme that other panelists referenced and built upon. It provided a clear, simple counter-narrative to the ‘traffic generator’ argument that telco representatives later tried to defend, creating a clear conceptual battleground for the debate.

Nobody buys a broadband connection to see the little blinking lights on their router. Well, actually, maybe I do. I like to have a super fast fiber at home in Paris and see those light blink really, really fast. But I don’t think that’s the majority of people.

Speaker

Thomas Volmer

Reason

While humorous, this comment makes a profound economic point about demand creation and value chains. It illustrates how content drives infrastructure demand, not the reverse, which directly contradicts the logic of taxing content providers to fund infrastructure.

Impact

This comment provided a memorable way to understand the economic relationship between content and infrastructure, influencing the discussion toward demand-side solutions rather than supply-side subsidies. It helped crystallize the counterintuitive nature of taxing the very thing that drives infrastructure demand.

I’m surprised about the panel here, we have just one side presented here, one view… the fundamental principle in Internet was that there was an equal share of traffic. I send as much traffic as I receive from you. And that was the founding principle. Today, it’s about maybe 70-80% of the traffic… comes from a handful of big CDNs

Speaker

Frode Kieling

Reason

This comment introduced genuine opposition perspective and challenged the panel’s composition, forcing panelists to address the strongest version of the pro-network fees argument. The claim about ‘equal share’ as a founding principle was particularly provocative as it challenged historical narratives.

Impact

This intervention forced the panel to engage with the strongest counter-arguments rather than debating among themselves. It led to Park and Volmer providing detailed technical rebuttals about internet history and modern CDN architecture, elevating the technical sophistication of the discussion and exposing weaknesses in the telco argument.

But the thing here is that the revenues for the telcos is sinking… And we see the revenues created on the content providers, like Netflix, is going straight up. But the infrastructure needs to be paid for. And there are three ways to do this. You can have network fees or you can break the net neutrality to get some extra revenues. And the third option is to lay all the costs on the customers.

Speaker

Frode Kieling

Reason

This comment starkly frames the telco perspective as a zero-sum game and explicitly connects network fees to net neutrality violations. The honesty about breaking net neutrality as an option is particularly revealing and thought-provoking.

Impact

This comment forced panelists to address the economic sustainability concerns directly rather than dismissing them, leading to more nuanced responses about alternative policy solutions. It also made explicit the connection between network fees and net neutrality violations that had been implicit throughout the discussion.

Overall assessment

These key comments fundamentally shaped the discussion by establishing it as a debate about democratic values and systemic internet governance rather than merely technical or economic issues. Park’s framing of network fees as threats to democratic communication set the moral stakes, while technical interventions from industry representatives forced the panel to engage with the strongest counter-arguments. The most impactful comments either reframed fundamental assumptions (like who ‘generates’ traffic) or forced participants to address uncomfortable truths (like the economic pressures on telcos). The discussion evolved from a somewhat one-sided presentation to a more robust debate when challenged by telco representatives, ultimately demonstrating both the strength of the anti-network fees arguments and the genuine economic concerns driving the pro-network fees position. The interplay between these provocative comments created a more comprehensive and nuanced exploration of the issues than would have occurred without such challenges.

How do we ensure that global network fee models do not create new financial barriers for African-owned networks, content creators, and users trying to participate in the digital economy?

Speaker

Louvo Gray

Explanation

This addresses the specific impact on Africa’s urgent need to expand affordable internet access to over 1 billion unconnected people, considering the shift in undersea cable ownership from traditional telecoms to content creators.

What else can be done to overcome the network fees debate so we can focus on actual solutions for connectivity?

Speaker

Rian Duarte

Explanation

This seeks practical steps to move beyond the ongoing debate toward addressing real connectivity challenges, particularly relevant given Brazil’s rich ISP ecosystem.

How can the multi-stakeholder model be improved to ensure genuine representation of all perspectives, including telecom operators?

Speaker

Pablo Barrionovo

Explanation

This highlights concerns about balanced representation in policy discussions, suggesting the current panel lacked telecom operator perspectives.

What are the results of Colombia’s consultation on the Internet ecosystem and how will they inform policy decisions?

Speaker

Claudia Ximena Bustamante

Explanation

Colombia’s regulator indicated results would be available next month, which could provide important evidence for Latin American policy decisions on network fees.

How will Colombia’s Constitutional Court decision on net neutrality affect the regulatory framework for differentiated plans and network fees?

Speaker

Claudia Ximena Bustamante

Explanation

The court ruled against ISP-chosen differentiated plans, potentially requiring updates to Colombia’s net neutrality regulatory framework.

What alternative solutions exist to address telecom sustainability concerns without implementing network fees?

Speaker

Claudia Ximena Bustamante

Explanation

This explores various approaches mentioned by telcos including reducing spectrum fees, taxes, and coverage obligations, as well as regulatory flexibility for experimental services.

How can dispute resolution mechanisms be prevented from becoming backdoor network fees?

Speaker

Konstantinos Komaitis

Explanation

This addresses the concern that Europe is shifting from direct network fees discussions to dispute resolution mechanisms that could achieve the same result.

What will be the long-term sustainability of forcing big tech companies to pay telcos, and when might they choose to become ISPs themselves?

Speaker

Konstantinos Komaitis

Explanation

This explores potential market concentration risks if large technology companies decide to provide their own internet access rather than pay network fees.