In this report, we outline what classifieds, financial and social services OLX, Paytm and ShareChat said, respectively, about TRAI’s public consultation on the regulation of OTT services. OTT Service Providers are abbreviated to only OTTs in the report. Some of these points have been edited and paraphrased. ** Q1. Which service(s), when provided by OTT service provider(s), should be regarded as the same or similar to service(s) provided by the TSPs? Suggestions are required, naming OTT services with descriptions comparing them with services provided by TSPs. OLX According to the EU’s draft Electronics Communications Code, both substantial and ancillary service providers use TSPs’ network infrastructure, but only substantial OTT services compete with their traditional telecommunication businesses. Substantial OTT service providers should be regarded as the same/similar to TSP services, as they are substitutable and compete with them It would be arbitrary and anti-competitive to conflate substantial and ancillary OTT services, since nearly all OTT services have an element of communication. Paytm The following services by the OTT providers may be regarded as the same or similar to services provided by TSPs - Personal Messaging – Messages among individuals Messages from Businesses – Messages from businesses to Individuals Video and voice calling ShareChat TSPs hold a scarce resource, making them significantly distinct to online communications platforms. Commonality of a few aspects of the services provided by online communications platforms does not make them similar to TSPs. Q2: Are there issues related to lawful interception of OTT communication that are required to…
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