Orion Calltech to train on Drishti's award-winning Call Center Software - General Topics

Hi,
Drishti-Soft Solutions, a leading provider of communications solutions, announces its association with one of the largest call center training institutes with over hundred centers in India- Orion Calltech. The underlying objective of this association is to train students on Drishti's groundbreaking Call Center technology- DACX.
It has been observed that the 'On-Floor' time in a call center reduces from three weeks to less than a week when agents are trained on Drishti's software. Technical training is an important aspect of call center operations. Not only is it a complex procedure, but also a time consuming affair. Customers, these days, expect call center agents to resolve their queries in the least possible time, yet in the best possible way. That is why the call center workforce must be adept at managing technology to facilitate higher First Call Resolution (FCR), more live connects and higher operational efficiencies.
For most of the call centers, retaining their agents is perhaps the biggest concern. High attrition rates in the call center industry create a space that is generally filled by housewives or fresh graduates. It is a fairly decent assumption that such recruits have inadequate tech knowhow. Training costs for a new agent can sometimes be as much as five times higher than costs associated with re-training an experienced agent. Moreover, it has been found that it costs around three month's agent's salary to a call center if an agent leaves after being trained. Talking in larger terms, say a call center with 150 seats (attracting 30% attrition rate), the amount translates to Rs 2-3 million every year.
Orion Calltech wanted to provide a remedy to such training and attrition related issues. They wanted to address the aforementioned issues and provide a proposition to the call centers. "We were basically looking for simulation solution for live contact center environment. The problem was that since we are spread all over India and that PDS (Predictive Dialing System) entails detailed maintenance; gathering manpower (which is not out mainstay) was becoming cumbersome. Drishti, therefore, came up with a Localized IP-Contact Centre Simulation on a PDS model. That meant lower variables to maintain because all of our centers could access this resource without having the required technical know-how. Drishti has been very co-operative towards our unforeseen needs" said Manish Agarwal, Director, Orion Calltech.
Orion Calltech has over a hundred training centers spread across India. Such a vast training network commissioning Drishti's technologies would enhance Drishti's brand image in the BPO industry.
Training agents on IT enabled systems (i.e. ITes) is thus indispensable for call centers if they want to minimize cost and time. Training agents on Drishti's software would ensure that they learn the ins and outs of ITes, thus eliminating the need to re-train agents. Hence, agents trained on Drishti's software contribute to the overall productivity of the call center from day one. Comments Mr. Bishal Lachhiramaka, CEO, Drishti-Soft Solutions- "Agents being trained on DACX from a reputable institute like Orion Calltech shall benefit our clients and partners greatly".
Drishti's call center software DACX Ameyo offers holistic contact management capabilities for domestic as well as international call centers. Comments Mr. Sanjeev Kothari, Director, Orion Educare Pvt. Ltd.-"Drishti has provided us a very good solution, and mapped all our requirements through its innovative centralized contact center module. This would enable us to provide training on real call center applications & dialers to our 100+ centers all over India".
Agents being trained on Drishti's software will learn about call management, predictive, progressive and preview dialing, IVR, CTI, ACD, reporting, supervision, quality monitoring and collaboration capabilities. This would prove to be highly beneficial (in terms of productivity) to call centers.
About OrionCalltech
Orion Calltech was established in the year 2005 with the sole aim of empowering its students with a deep understanding of the BPO industry. Orion Calltech is time tested and trusted pre-process training institute accepted and approved by whole ITes Industry.
An ISO 9001:2000 Institute in Eastern India, it provides Dual Certification, which includes International Certification from City & Guilds, UK.
About Drishti
Drishti is a leading provider of Contact Center Software & Enterprise Communications Solutions. Drishti's award-winning flagship offering - DACX Contact Center Suite has been a huge success in India and Philippines within a short span of two years. Drishti creates innovative Communications technologies for the next-generation Enterprises, empowering them to dynamically manage their Business Processes. Drishti's customers enjoy significant benefits in terms of increase in efficiency levels, reduction in operational costs, flexibility to grow, consistent user experience and a demonstrable ROI.
Drishti's innovative solutions are running successfully at more than 200 client locations across India, Bangladesh, Philippines, Dubai and the US, as recognized by the three awards: IP Contact Center Technology Pioneer Award 2008, Member's Choice Award 2008 (Best ACD/Switch, Best in Class Overall Category Winner- Best Outbound Solution and Highly Recommended Best After Sales Support) and BPONews Best Contact Center Solution 2007.

Yeah for most of the call centers, retaining their agents is perhaps the biggest concern. High attrition rates in the call center industry create a space that is generally filled by housewives or fresh graduates...
__________________
Call Center Software

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Job Opening: Mobile Application Developer - MOGA| Woodinville, WA

Location: Woodinville, WA
Divison: Consumer Products
Direct Report: TBD
Employment Type: Salaried; Exempt
Qualifications & Experience
5+ years of relevant experience in software development, information systems or equivalent technical environment; minimum 1-year experience in development utilizing Android SDK; iOS and/or WP7 a plus.
Proven experience delivering successful software, including customer-facing mobile applications, preferably game apps currently available via Google Play, Xbox LIVE and/or the App Store.
Solid understanding of in-app analytics and PII best practices.
BA/BS in Computer Science or related field preferred; Interactive Design a plus.
Skills & Traits
Passion for app development, focus on UX/UI, strong project management skills and attention to detail are required.
Proficiency in Java, Android SDK frameworks, XML, web-service technologies, emerging web standards (i.e., HTML 5), analytics tools (i.e., Omniture, Google Analytics).
Ability to plan, drive and complete projects. A thinker and a doer.
Excellent verbal and written communication skills.
Strong problem solving abilities including an ability to influence internal stakeholders.
Ability to take initiative and demonstrate leadership.
Desire to work hard, learn fast, generate ideas and make things happen the best way in a changing environment. Willingness to do whatever it takes to get the job done.
Professional disposition/appearance, and positive attitude and outlook.
Excellent interpersonal and relationship building skills.
Interest in video games a plus.
Duties & Responsibilities
Develop mobile applications for BDA’s Consumer Products division, creating simple interactions for complex functionality.
Work with supervisor and co-workers to prioritize projects, app features and deliverable timelines for maximum business impact.
Manage requirements, documentation, testing and participate in troubleshooting efforts within a highly matrixed organization.
Work with supervisor and creative staff/contractors to drive the process of UI design, apply user tests, specify user flows/screens and direct graphical design within the framework of BDA’s consumer brands, owning the day-to-day execution in the form of design comp reviews, functional reviews with development teams, and presentations to internal stakeholders.
Serve as company-wide mobile app subject matter expert (SME).
Coordinate content delivery with BDA’s consumer packaging teams and websites, including PowerA.com and MUNITIO.com.
Participate in creative brainstorm meetings to provide input for fresh, new ideas, vision and project direction.
Develop and maintain an effective, positive working relationship with other BDA teams and individuals.
Additional marketing responsibilities as assigned by supervisor.
Occasional weekend and evening hours required.
Contact
Melissa
Only local canidates or persons willing to relcoate will be considered (no relocation fee will be paid).
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{Official} Net neutrality for India! We will make trai aware of our rights.

This message is only for people who live or vote in India. If you are not such a person, please forward it to someone who is.
What is net neutrality?
The principle that all traffic on internet should be treated the same.
No site will be sped up.
No website will be slowed down (throttling).
----------
So what's happening now?
TRAI consultation paper (open to comments till April 24) is the first step in potentially allowing operators to discriminate internet traffic.
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How does this impact me?
1. Your internet bill could go up.
2. Apps you love may no longer work.
ISPs and Telcos could charge you more. When you buy a 1 Gb data pack, you can use it for anything you wish. Without neutrality, you could be forced to buy a Skype pack for Skype calls, a video pack to watch YouTube and dailymotion.
Or you could be charged a different rate for each service. 4p/10 KB if you are browsing, but 10p/10 KB for VoIP calls. That would be like your milkman telling you 30 Rs/L if you make tea, but 75 Rs/L if you make milkshake.
You could be denied service as well. Telcos could decide that WhatsApp or Viber is eating into their sms revenue and block them completely.
Or Airtel could block gaana, saavn, hungama, rdio etc and allow access only to wynk (owned by airtel)
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Hmm.. I want to know more.
Sure follow the links here:
Well written article: http://www.firstpost.com/politics/b...trai-trying-screw-internet-users-2193321.html
A video explanation: https://m.youtube.com/watch?v=_G-OagxdCws
Another cool video: https://m.youtube.com/watch?v=mfY1NKrzqi0
Another video: https://youtu.be/uQjkCziopLA
Take some Action: http://www.savetheinternet.in/
----------
OK. Got it. What can I do?
Let TRAI know that you hate this idea. Go to http://www.savetheinternet.in/ and follow the instructions to email TRAI letting them know of your displeasure.
----------
Anything else I can do?
Yes. Inform family and friends about net neutrality and TRAI's attempts to kill it (under pressure from telcos probably).
You can also protest on https://www.change.org/p/rsprasad-t...e-how-they-want-to-use-internet-netneutrality
Contact your mp today http://j.mp/MailMyMP if there is no net neutrality, we will have to pay to use WhatsApp, Facebook, hike, Google, YouTube, etc.
Hashtag revolution #NetNeutralityIndia , #SaveTheInternet , #wewantnetneutrality and #TRAIDontevenTry
---------
Why do we need net neutrality?
India is a developing country. If there is no net neutrality, we cant develop ourselves.
Poor people; instead of getting onto the internet would stop using it completely as they wont be able to pay
Answers to those 20 questions (thanks to savetheinternet.in)
To the Chairman, TRAIThank you for giving me this opportunity to share my views on the consultation paper published by TRAI on March 27, 2015 titled "Regulatory Framework For Over-the-Top (OTT) Services”. I am worried that this consultation paper makes sweeping assumptions about the Internet, and does not take a neutral and balanced view of the subject of Internet Licensing and Net Neutrality. Any public consultation must be approached in a neutral manner by the regulator, so that people can form an informed opinion.I strongly support an open internet, for which I believe it is critical to uphold net neutrality and reject any moves towards licensing of Internet applications and Web services. I urge TRAI to commit to outlining measures to protect and advance net neutrality for all Indians. Net neutrality requires that the Internet be maintained as an open platform, on which network providers treat all content, applications and services equally, without discrimination. The TRAI must give importance to safeguarding the interests of our country’s citizens and the national objective of Digital India and Make In India, over claims made by some corporate interests.I request that my response be published on the TRAI website alongside other comments filed, in line with past practice regarding public consultations. I urge that TRAI issue a specific response to user submissions after examining the concerns raised by them, and hold open house discussions across India, accessible to users and startups before making any recommendations.
Question 1: Is it too early to establish a regulatory framework for Internet/OTT services, since internet penetration is still evolving, access speeds are generally low and there is limited coverage of high-speed broadband in the country? Or, should some beginning be made now with a regulatory framework that could be adapted to changes in the future? Please comment with justifications.
No new regulatory framework in the telecom sector is required for Internet services and apps - and no such regulation should come into effect in future either.This question incorrectly presumes that regulation of the Internet is absent and there is a need to create it. Additionally, the technical language of “Over-the-Top” applications used in the consultation paper fails to convey that it is truly referring to the online services and applications which make today’s Internet which we all use; Facebook, Ola, Zomato, Paytm, WhatsApp, Zoho and Skype etc. The Internet is already subject to existing law in India - any extra regulatory or licensing regime will only be detrimental to the customer and to Indian firms developing online services and apps.Under the current regulatory framework, users can access the internet-based services and apps either for a low fee or for free where the application owners make money by selling advertisements based on user data. With additional regulations and licenses, it will make it expensive for these services to reach out to their customers eventually leading to higher prices and undesirable levels of advertising - which is against the public interest and counterproductive.It appears that the telecom companies are shifting goalposts. Many telecom companies have earlier argued in the consultation paper floated by TRAI on mobile value added services (MVAS) that it was not necessary to regulate these value added services. They said MVAS are already governed by general laws under the Indian legal system and comply with the security interests as they operate on the networks of legitimate telecom license holders. Internet platforms also are regulated and governed by general laws in addition to specialised laws such as the Information Technology Act, and the same treatment should be extended to them as well.As TRAI said previously in its recommendations after consulting on MVAS regulation:“The Authority preferred least intrusive and minimal regulatory framework and thus no separate category of licence for value added services is envisaged. After second round of consultations, the Authority is also not favoring registration of Value Added Service Providers (VASPs) or content aggregators under the “Other Service Provider (OSP)” category.”“Content shall be subject to relevant content regulation and compliance of prevailing copyrights including digital management rights and other laws on the subject (para 3.12.2). The content is subjected to content regulation/ guidelines of Ministry of Information and Broadcasting, Information Technology Act, 2000, Cable Television Networks (Regulation) Act, 1995, Indian Copyright Act etc., as amended from time to time. The content regulation shall be as per law in force from time to time. There should be consistency in the treatment of content across all kinds of media including print, digital/multimedia to avoid any discrimination. (para 3.13.3):”
Imposing a licensing and regulation regime carry significant risks of destroying innovation. Launching new services and features will take more time and will make it difficult for new startups with low cash reserves to enter the market. It will basically ring the death knell for the country's fast-growing digital media sector.
Question 2: Should the Internet/OTT players offering communication services (voice, messaging and video call services through applications (resident either in the country or outside) be brought under the licensing regime? Please comment with justifications.
Firstly, there is no need for licensing of internet based communication service providers. To suggest such a move further points towards the TRAI consultation being tilted in favour of telecom operators.
Secondly, fundamentally both Internet-based communication services and non-communication services are the same. They sit on top of the network provided by telecom operators. And the spectrum that telecom operators utilise to offer this network on pipe is already licensed, hence there is no need for additional licensing.
This issue also needs to be looked at from another perspective. Many non-communication services on the Internet also offer real-time chat or video interaction features for the benefit of customers, which will be affected by bringing such services under a licensing regime.
The extent of innovation we have witnessed over the years has been greatly aided by the low cost of entry. Any form of regulation or licensing will increase the entry cost, thereby hindering innovation and equal opportunity to startups to establish themselves in the market. Behind every Zoho, WhatsApp and Skype there are numerous failures. Licensing will essentially increase the cost and likelihood of failure - and greatly discourage innovation.
Question 3: Is the growth of Internet/OTT impacting the traditional revenue stream of Telecom operators/Telecom operators? If so, is the increase in data revenues of the Telecom Operators sufficient to compensate for this impact? Please comment with reasons.
There is no evidence of data revenues cannibalizing revenues from voice or SMS. In fact, data usage is soaring and it is driving the demand for telecom networks.
The question fails to acknowledge that revenue from data services also fall under the traditional revenue streams category as per the Unified Access License Agreement
[http://www.dot.gov.in/access-services/introduction-unified-access-servicescellular-mobile-services]. So, to assume that data services are impacting the growth of “traditional revenue streams” is wrong.
Services such as Skype and WhatsApp have specific use cases. They are not, and should not be, considered as substitutes to voice calling or SMS. For instance, calls made using VoIP don’t have the same clarity that we have on voice calls. Moreover, services such as WhatsApp are used for real-time chatting as opposed to SMS. Voice and SMS have their own benefits and use cases, so do VoIP and internet messaging. Customers should be free to pick and choose among these.
There is still no concrete evidence suggesting that the decline in the revenues from messaging and voice calling is due to the growth of revenues from data services, and statements from experts and industry experts appear to in fact point to there being no cannibalization of revenues.
Gopal Vittal, CEO, Airtel
“There is still no evidence that suggests that there is cannibalization,” he said when asked about whether data is cannibalizing Airtel’s voice business. On internet messaging cannibalizing SMS revenues, he said: “At this point in time is very, very tiny. And so it is not really material as we look at it.”
[http://www.medianama.com/2015/02/22...tion-of-voice-airtel-india-ceo-gopal-vittal/]
Vittorio Colao, CEO, Vodafone
“Growth in India has accelerated again (October-December), driven by data” [http://computer.financialexpress.com/columns/india-high-on-3g/9462/]
The company’s India unit grew by 15%, going past its counterparts during the quarter ending December as customers used its data services. [http://articles.economictimes.india...ervice-revenue-vittorio-colao-vodafone-india]
Question 4: Should the Internet/OTT players pay for use of the Telecom Operators network over and above data charges paid by consumers? If yes, what pricing options can be adopted? Could such options include prices based on bandwidth consumption? Can prices be used as a means of product/service differentiation? Please comment with justifications.
Internet-based services and apps don’t pay for telecom operators for using the network, and it should remain the same going forward. Forcing Internet-based services to pay extra for using a particular network negatively impact consumers and harm the Indian digital ecosystem. As mentioned in the above answer, data revenues of Indian telecom operators is already on an upswing and is slated to increase rapidly over the next few years, hence the argument for creating a new revenue source is not justified.
Charging users extra for specific apps or services will overburden them, which in turn will lead to them not using the services at all. It is also akin to breaking up the Internet into pieces, which is fundamentally against what Net Neutrality stands for. Also, the Internet depends on interconnectivity and the users being able to have seamless experience - differential pricing will destroy the very basic tenets of the Internet.
Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of Internet/OTT players? If so, what should be the framework to address these issues? How can the prevailing laws and regulations be applied to Internet/OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.
There is no regulatory imbalance in the environment in which the internet services and applications operate. In fact, the word “regulatory imbalance” is incorrect here. Telecom operators holds licenses to spectrum which is a public resource. Internet services and applications don’t have to acquire licenses. Moreover, there is a clear distinction between services provided by telecom operators and internet platforms—so no additional regulation is required.
Also, internet services and applications are already well-covered under the Information Technology Act, 2000 and Indian Penal Code, 1860. More importantly, internet services are intermediaries that allow a communication system for their users—and intermediaries cannot be held responsible for the acts of their users as per Section 79 of the IT Act, 2000. Our Supreme Court has recently ruled on this area in the Shreya Singhal versus Union of India case, holding that Internet content is protected by our Constitution’s right to free expression and setting out the acceptable limits for government regulation.
Question 6: How should the security concerns be addressed with regard to OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such OTT players? And, how can compliance with these conditions be ensured if the applications of such OTT players reside outside the country? Please comment with justifications.
The internet services and apps are well-covered under the existing laws and regulations. These include the Code of Criminal Procedure, Indian Telegraph Act, Indian Telegraph Rules, and the Information Technology Act and its different rules pertaining to intermediaries and interception. These different regulations allow the Indian government and law enforcement agencies to access the data stored by internet platforms when deemed legally necessary. Any additional regulations carry grave risk of breaching user privacy and would also require constitutional review - especially since the Government is still working on a proposed Privacy Bill.
The government and courts also have the power to block access to websites on the grounds of national security and public order. It has taken similar steps in the past and has been widely reported by the media. The transparency reports periodically published by major internet companies suggests Indian government routinely requests for user data and blocking of user accounts. Between July 2014 and December 2014, Indian authorities had 5,473 requests for data, covering 7,281 user accounts from Facebook and the company had a compliance rate of 44.69%. Google had a compliance rate of 61% with respect to the requests made by different government agencies across India.
Question 7: How should the OTT players offering app services ensure security, safety and privacy of the consumer? How should they ensure protection of consumer interest? Please comment with justifications.
Although user privacy and security is of paramount importance, additional regulation carries the inherent risk of breaching user privacy which is not in the consumer’s interest. The Information Technology Act, 2000 already addresses the security concerns of the user. But more importantly, any criminal act committed using these platforms can be tried under the Indian Penal Code. So, there is no need to burden the internet platforms with additional regulations.
Also, it is worth noting that many telecom companies in India have not made information publicly available as to whether and how they comply with regulations that guarantee security, privacy and safety of the customer. TRAI’s current paper fails to articulate why the internet services and apps should be brought under similar regulations.
Question 8:
In what manner can the proposals for a regulatory framework for OTTs in India draw from those of ETNO, referred to in para 4.23 or the best practices summarised in para 4.29? And, what practices should be proscribed by regulatory fiat? Please comment with justifications.
ETNO is similar to India’s COAI which makes it an industry lobby group. Understandably, the suggestions made by ETNO heavily favor the telecom companies and will be detrimental to customers if India refers to their suggestions.
ETNO’s stand have been widely criticized in the past. Europe’s own group of government regulators [Body of European Regulators for Electronic Communication (BEREC)]
http://berec.europa.eu/files/document_register_store/2012/11/BoR_(12)_120_BEREC_on_ITR.pdf ETNO’s proposals could jeopardize the “continued development of the open, dynamic and global platform that the Internet provides” which will “lead to an overall loss of welfare”. Additionally, the international free expression group Article 19 says ETNO’s proposal “would seriously undermine net neutrality.
According to Access Now, ETNO’s recommendations would have meant higher data charges for customers while from an entrepreneur’s standpoint, it will limit their ability to reach out to a wider market. For a small but fast growing startup and digital media sector in India, this can potentially ring the death knell. ETNO’s suggestions on this subject so far have failed to have been accepted by any government agency - including the regulators in their own host countries. It is therefore especially troubling that TRAI is choosing to make one of their proposals a pillar of this public consultation here in India.
Question 9: What are your views on net-neutrality in the Indian context? How should the various principles discussed in para 5.47 be dealt with? Please comment with justifications.
Net Neutrality, by definition, means no discrimination of traffic flowing on the internet with respect to speed, access and price. Chile and Brazil, which are developing countries just like India, have passed laws supporting net neutrality. This is in addition to government commitments to implement net neutrality legislation in the United States and European Union.
India has 1 billion people without internet access and it is imperative for our democracy to have an open and free internet where users are free to choose the services they want to access—instead of a telecom operator deciding what information they can access.
Internet apps and services are expected to contribute 5% to India’s GDP by 2020. That will only happen of entrepreneurs, big and small, have a level playing field that encourages innovation and non-preferential treatment—something that net neutrality ensures.
Assuming there is no net neutrality, only the big players will be able to strike deals with telcos while the smaller players remain inaccessible, which will go against the principles of net neutrality as listed below:
No blocking by TSPs and ISPs on specific forms of internet traffic, services and applications.
No slowing or “throttling” internet speeds by TSPs and ISPs on specific forms of internet traffic, services and applications.
No preferential treatment of services and platforms by TSPs and ISPs.
It is also worth noting that the proposed framework will give too much power in the hands of the telecom companies, which is not healthy for the ecosystem.
Question 10: What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? What should or can be permitted? Please comment with justifications.
This question assumes that traffic discrimination is necessary and is a norm. Rather, traffic discrimination should be an exception as it is against the principles of net neutrality.
In such exceptional cases, telecom companies need to have the permission of TRAI or other competent government agency through public hearing to carry out “traffic management” to ensure transparency in the entire process. Further, it should be kept in mind that such steps shouldn’t interfere with the access, affordability and quality of the services.
More importantly, https://ec.europa.eu/digital-agenda.../Traffic Management Investigation BEREC_2.pdf jointly by BEREC and the European Commission suggest that the propensity of the telecom operators to restrict access of internet services is high. The report noted that telecom operators were most inclined to block and throttle P2P services on mobile as well as fixed line networks. VoIP, on the other hand, was blocked mostly on telecom networks.
Keeping this in mind, TRAI needs to ensure that instances of discrimination of traffic should be few, far between and, above all, transparent
Continued
Question 11: Should the TSPs be mandated to publish various traffic management techniques used for different OTT applications? Is this a sufficient condition to ensure transparency and a fair regulatory regime?
The question is based on the premise that publishing various traffic management techniques for Internet services will ensure a fair regulatory regime and therefore such discrimination is permissible. As I have repeatedly said in the above answers, discrimination of services will not bring about a fair regime for users.
Further, a recent study [http://bit.ly/1D7QEp9] in the UK has pointed out that merely publishing data on traffic management will not translate into a fair regime. The study found that most consumers did not understand traffic management or use it as a basis for switching operators. Those who did do so comprised a group perceived to be small or insignificant enough that most network operators did not seek to factor them into their product decisions, despite some consumers’ complaints about traffic management. In India where awareness and activism on issues of net neutrality is considerably less, it is unlikely to play the critical role that the Consultation Paper suggests.
Question 12: How should a conducive and balanced environment be created such that TSPs are able to invest in network infrastructure and CAPs are able to innovate and grow? Who should bear the network upgradation costs? Please comment with justifications
The underlying assumption of the question suggests that currently there is an imbalance in the environment within which telecom operators and internet services operate. However, as I have pointed out it my previous answers, no such imbalance exists. Telecom firms and internet services have distinct functions. The former has to provide the infrastructure to access content and the latter has to provide the platforms for users to create content. As financial results of the telecom operators and analysis by various independent agencies have shown that revenues from data are soaring. So, it makes logical sense for the telecom operators to invest to upgrade and improve their network infrastructure.
On the contrary, I would argue that there is no incentive for the telecom firms to invest to upgrade their networks if they charge the CAP instead of charging the customer for data. They would seek to further increase its revenues coming from the CAPs, a move that will be disastrous for India's telecommunications industry.
Question 13: Should TSPs be allowed to implement non-price based discrimination of services? If so, under what circumstances are such practices acceptable? What restrictions, if any, need to be placed so that such measures are not abused? What measures should be adopted to ensure transparency to consumers? Please comment with justifications.
Discrimination of services in any form is detrimental for the growth of the telecom industry itself and there should be no circumstance for a telecom operator to do so. Given the diverse nature of the Internet, telecom operators should not be allowed to determine what type of service should get more priority. For example, a consumer in India probably relies on VoIP calls to keep in touch with people abroad and if there is throttling of these services, it infringes on the user’s fundamental right of freedom of expression. An Internet service that a telecom operator thinks which could lead to traffic congestion, might be vital to consumers. Further, a telecom operator might use throttling to further a service promoted by them and induce consumers into using them, thereby eliminating choice.
Transparency alone will not bring about a fair regime for users, and it is crucial that TSPs be prohibited from discriminating between services
Question 14: Is there a justification for allowing differential pricing for data access and OTT communication services? If so, what changes need to be brought about in the present tariff and regulatory framework for telecommunication services in the country? Please comment with justifications.
As I have argued in my previous answers, there should be no differential pricing for data access and internet services. Therefore, the need for a change in the tariff and regulatory framework is not required.
It is important to note that nearly one billion people still don't have internet access in India - which means telecom companies stand to gain substantially from their data services in the near future. Moreover, different pricing is tantamount to discrimination which goes against net neutrality.
As stated before, customers should be charged on the basis of volume of data used and not on the basis of the internet services they are accessing.
Question 15: Should OTT communication service players be treated as Bulk User of Telecom Services (BuTS)? How should the framework be structured to prevent any discrimination and protect stakeholder interest? Please comment with justification.
Treating OTT communication service players as Bulk User of Telecom Services again amounts to discrimination of data services and hence it should not be allowed. The question also further assumes that the stakeholders are only the telecom operators and not the consumers. If only the interests of the telecom operators are protected by treating services which compete with their traditional services differently rather than innovating themselves, it would lead to a situation of anti-competitiveness. Telecom companies have an interest in imposing their control over information and communication networks, but the price of that would mean stifling competition, increased barriers for innovation and business and eventually infringe on the fundamental rights of Indian citizens.
Question 16: What framework should be adopted to encourage India-specific OTT apps? Please comment with justifications.
A recent Deloitte report titled Technology, Media and Telecommunications India Predictions 2015 predicted that paid apps will generate over Rs 1500 crore revenues in 2015 (http://bit.ly/1alhH5S). Increased acceptance of paid apps can only be possible if there’s Network Neutrality. In fact, Deepinder Goyal, the founder and CEO of the highly successful app Zomato recently commented "Couldn’t have built Zomato if we had a competitor on something like Airtel Zero"
The moment an app developer/company is forced to tie-up with a telecom operator to ensure that users opt for it, an artificial prohibitive barrier will be created. All app developers and the companies behind them need to be provided an even playing field.
We also need more reports on the Indian app economy, to understand, firstly, how the adoption and usage of apps is changing and, secondly, to comprehend its impact on the Indian economy.
Question 17: If the OTT communication service players are to be licensed, should they be categorised as ASP or CSP? If so, what should be the framework? Please comment with justifications.
The question of categorising doesn’t even arise, because as mentioned earlier any extra regulations or licensing is going to be detrimental to the end user. Requiring licensing of online services and mobile apps under the current telecom framework in India will have enormous negative consequences. The impossibly onerous burdens imposed by such licensing would results in many such globally developed services and apps not being launched in India - and our own startup efforts to develop local versions of such apps being killed in their early stages. The net results would be decreased consumer benefit and a massive slowdown in innovation and reduced “Make in India” efforts due to the regulatory cost of doing business becoming very high.
Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.
Subscription charges for such apps need to be allowed to evolve as it would in a pure market economy. The subscribers (buyers) would want to pay the lowest possible price, and the app developers/companies (sellers) would want to charge as much as possible, eventually leading to a fair price.
Subscription charges for such Internet-based services have remained, more or less, quite low in India, especially because the cost of switching from one service provider to another is also quite low: This competition will ensure that charges remain fair, without the need to regulate them, going forward as well. As noted in response to earlier questions, existing Indian law also applies to online services - which would include the Consumer Protection Act and other regulations meant to prevent cheating or other illegal pricing issues.
Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.
As mentioned earlier, irrespective of what an OTT app is used for (communication, online shopping, etc) they’re all essentially Internet-based services, and hence there is no question of creating new regulatory measures.
Question 20: Are there any other issues that have a bearing on the subject discussed?
Here are the additional steps that I urge the TRAI to undertake in the interest of the public:
- Due to the absence of any formal regulations on net neutrality, TRAI should issue an order or regulation preventing network neutrality violations by telecom service providers. Some telecom companies have shown scant respect for the issues presently under consideration and despite its questionable legality have rolled out various services which violate network neutrality. Any delay in forming regulations or preventing them in the interim till the process is complete is only likely to consolidate their status. This is not only an affront to the Internet users in India but also to the regulatory powers of the TRAI.
- TRAI is requested to publish all the responses and counter responses to the consultation, including any other additional material, on its website.
- For better public involvement and awareness, open house debates should be held in major Indian cities after the consultation process is over.
In the US, there was a time when you had to pay for tethering. Imagine if it would happen in India

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