IFF Submission to TRAI on the Free Data Consultation

June 29, 2016

IFF has consistently advocated for an equal rated model in which there is no restriction or incentives to restrict user choice. This needs to be implemented urgently without violating net neutrality to bring a large number of Indians online who get a full chance at engaging with the diversity of the open internet.

The submission which can be accessed here (link) was based on the following points:

● It voiced concern that that the certainty brought through clear rule making of the Differential Tariffs Prohibition Regulation may be undermined by the models proposed under the Free Data Consultation Paper.

● It cited available empirical data that makes a case against providing access through free data models which restrict user choice;

● In response to Query No. 4 appropriate regulatory action is needed to prevent circumvention of the discriminatory tariff regulation by TSPs building large CECN (Closed Electronic Communications Networks) which are otherwise offered to users for zero rated services.

IFF's submissions are with the intent of suggesting a clear regulatory path and removing any ambiguity on economic forms of discrimination.

After this, attention can be devoted to addressing technical forms of discrimination and addressing all remaining harms which emerge from violating Network Neutrality.