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Showing posts with label Paid Priority. Show all posts
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Thursday, July 13, 2017

Both sides are wrong in the Net Neutrality debate

I've been watching the ongoing shouting-match about Net Neutrality (in the US & Europe) with increasing exasperation. Recently there was a "day of action" by pro-neutrality activists, which raised the temperature yet further.

The problem? Pretty much everyone, on both sides (and on both sides of the Atlantic), is dead wrong a good % of the time. They're not necessarily wrong on the same things, but overall the signal-to-noise ratio on NN is very poor.

There are countless logical fallacies perpetrated by lobbyists and commentators of all stripes: strawman arguments, false dichotomies, tu-quoque, appeals to authority and all the rest. (This is a great list of fallacies, by the way. Everyone should read it). 

Everyone's analogies are useless too - networks aren't pipes, or dumb. Packets don't behave like fluids. Or cars on a road. There are no "senders". It's not like physical distribution or logistics. Even the word "neutrality" is dubious as a metaphor. The worst of all is "level playing field". Anyone using it is being duplicitous, ignorant, or probably both. (See this link).

I receive lots of exhortations from both sides - I get well-considered, but too-narrow network-science commentary & Twitter debates from friend & colleague Martin Geddes. I read detailed and learned regulatory snark and insider stories from John Strand. I see telco/vendor CEOs speaking (OK, grandstanding) at policy conferences. I get reports of egregious telco- and state-based blocking of certain Internet services from Access Now, EFF and elsewhere. I see VCs and investors lining up on both sides, depending on whether they have web interests, or network vendor/processing positions. I watch comments from the FCC, Ofcom, EU Commission, BEREC, TRAI and others - as well as politicians. And I read an absolute ton of skewed & partial soundbites from lobbyists on Twitter or assorted articles/papers.

And I see the same, tired - often fallacious or irrelevant - arguments trotted out again and again. Let me go through some of the common ones:
  • Some network purists insist routers & IP itself are (at core) non-neutral, because there are always vagaries & choices in how the internals, such as buffers, are configured. They try to use this to invalidate the whole NN concept, or claim that the Internet is broken/obsolete and needs to be replaced. Other Internet purists insist that the original "end-to-end" principle was to get as close as possible to "equal treatment" for packets, and either don't recognise the maths - or suggest that the qualitative description should be treated as a goal, even if the precise mechanisms involve some fudges. Everyone is wrong.
  • In the US, the current mechanism for NN was to incorporate it under the FCC's Title II rules. That was a clunky workaround, after an earlier NN ruling was challenged by Verizon in 2011. In many ways, the original version was a much cleaner way to do it, as it risked less regulatory creep. Everyone is wrong.
  • Many people talk about prioritisation of certain traffic (eg movies) and how that could either (a) allow innovative business models, or (b) disenfranchise startups unable to match web giants' payments. Yet the technology doesn't work properly (and won't), it's almost impossible to price/market/sell/manage in practice, and there is no demand. Conspicuously, there have been no lobbyists demanding the right to pay for priority. There is no market for it, and it won't work. It's irrelevant. Everyone is wrong.
  • Some people assert that NN will reduce "investment" in networks, as it will preclude innovation. Others assert that NN increases overall investment (on networks plus servers/apps/devices). When I tried to quantify the possible revenues from 25 suggested non-neutral business models (link), I concluded the incremental revenue would barely cover the extra costs of implementation, if that. There are many reasons for investments in networks (eg 4G then 5G deployment cycles), while we also see CapEx being replaced by OpEx or software licences for managed or virtual networks. Drawing meaningful correlations is hard enough, let alone causation from an individual issue out of dozens. Everyone is wrong.
  • Most of the debate seems to centre on content - notably video streaming. This ties in with operators wanting to bundle TV and related programming, or Netflix and YouTube seen as dominating Internet traffic and therefore being pivot-points for neutrality. Yet in most markets, IPTV is not delivered via the public Internet anyway, and is considered OK to prioritise as it's a basic service. On the opposite side, upgrades to high-speed consumer broadband is partly driven by the desire for streaming video - revenues would fall if it was blocked, while efforts to charge extra fees to Netflix and co would likely backfire - they'd insist on opposite fees to be carried, like TV channels. Meanwhile, most of the value in the Internet doesn't come from content, but from applications, communications, cloud services and data transmission. However, they are all much techier, so get mostly overlooked by lobbyists and politicians entranced by Hollywood, Netflix or the TV channels. Everyone is wrong.
  • Lots of irrelevant comments on all sides about CDNs or paid-peering being examples of prioritisation (or of craven content companies paying for special favours). Fascinating area, but irrelevant to discussion about access-network ISPs. Everyone is wrong.
  • Lots of discussion about zero-rating or "sponsored data" paid for by 3rd-parties and whether they are right/wrong/distortions. Lots of debate whether they have to be offered to all music / video streaming services, whether they should just be promotional or can be permanent. And so on. Neither relate to treatment of data transmission by the network - and differential treatment of pricing is, like CDNs, interesting but irrelevant to NN. And sponsored data models don't work technically or commercially, with a handful of minor exceptions. Ignore silly analogies to 1-800 phone numbers - they are totally flawed comparisons (see my 2014 rant here). Upshot: zero-rating isn't an NN issue, and sponsored data (with prioritisation or not) doesn't work (for at least 10 reasons). Everyone is wrong.
  • Almost everyone in the US and Europe regulatory scene now agrees that outright blocking of certain services (eg VoIP) or trying to force specific application/web providers to pay an "access" toll fee is both undesirable or unworkable. It would just drive use of VPNs (which ISPs would block at their peril), or amusingly could mean that Telco1.com could legally block the website of Telco2.com, which would make make future marketing campaigns a lot of fun. In other words, it's not going to happen, except maybe for special cases such as childrens' use, or on planes. It's undesirable, regulatorily unacceptable, easy to spot and impossible anyway. Forget about it. Everyone is wrong.
  • Lots of discussion about paid-for premium QoS on broadband, and whether or not it should apply to IoT, 5G, NFV/SDN, network-slicing, general developer-facing APIs and therefore allow different classes of service to be created, and winners/losers to be based on economic firepower. Leaving aside enterprise-grade MPLS and VPN services (where this is both permissible and possible), there's a lot of nonsense talked here. For consumer fixed broadband, many of the quality issues relate to in-home wiring and WiFi interference, for which ISP-provided QoS is irrelevant. For mobile, the radio environment is inherently unpredictable (concrete walls, sudden crowds of people, interference etc). Better packet scheduling can tilt the odds a bit, but forget about hard SLAs or even predictability. Coverage is far more a limiting factor. Dealing with 800 ISPs around the world with different systems/pricing is impossible. The whole area is a non-starter: bigger web companies know how much of a minefield this is, and smaller ones don't care. Everyone is wrong.
In summary - nearly anyone weighing in on Net Neutrality, on either side, is talking nonsense a good % of the time. (And yes, probably me too - I'm sure people will pick holes in a couple of things here).


So what's the answer?
  • First, tone down the rhetoric on both sides. The whole thing is a cacaphony of nonsense, mostly from lobbyists representing two opposing cheeks of the same arse. Acknowledge the hyperbole. Get some reputable fact-checkers involved, and maybe sponsored by government and/or crowdsourcing.
  • Second, recognise that many of the threatened non-neutral models are either impossible or obviously unprofitable. Arguing about them is sophistry and a waste of everyone's time. There are more important things at stake.
  • Thirdly, design and create proper field-trials to try to prove/disprove assertions about innovation, cost structures etc. Select a state, a city or a class of users, or speciallly-licensed ISPs to run prototypes and actually get some proper data. Don't try to change anything on a national or international basis overnight, no matter how many theoretical "studies" have been done. Create a space for operators and developers to try out creating "specialised services", see if they work, and see what happens to everything else. Then develop policy based on evidence - and yes, you'll have to wait a few years. You should have done it sooner instead of arguing. I suspect it'll prove my point 2 above, anyway
  • Fourth, consider "inevitabilities" (see this link for discussion). VPNs will get more common. NFV and edge-computing will get more common. Multiple connections will get more common. New networks (eg private cellular, LPWAN) will get more common. Multi-hop connections with WiFi and ZigBee & meshes will get more common. Devices & applications will fragment, cloudify, become "serverless", being componentised with micro-services, and be harder to decode and classify in the network. AI will get more common, to "game" the network policies, as well as help manage the infrastructure. All this changes the landscape for NN over the next couple of years, so we'll end up debating it all again. Think about these things (and others) now.
  • Six, try some rules on branding Internet / other access. Maybe allow specialised services, but force them to be sold separately from Internet access, and called something else (Ain'ternet? I Can't Believe it's Not Internet?)
  • Seven, get ISP executives (and maybe web/content companies' execs too) to make a public promise about acting in consumers' interests on Internet matters, as I suggested a few years ago - an IPocratic Oath. (link)
  • Eight, train and empower the judiciary to be able to understand, collect data and adjudicate quickly on Internet-related issues. It may be that competition law could be applied, or injunctions granted, even in the absence of hard NN laws. Let's get 24x7 overnight Internet courts able to take an initial view on permissibility of traffic management - not wait 2 years and appeals during which time an app-developer slowly dies.
  • Nine, let's get more accountability on traffic-management and network configurations, so that neutrality/competition law can be applied at a later date anyway. We already have rules on data-retention for customer calls & access to networks. Let's have all internal network configuration & operational data in ISPs' networks securely captured, encrypted, held in escrow and available to prosecutors if needed, under warrant. A blockchain use-case, perhaps? We're going to need that data anyway, to guarantee that customer data hasn't been tampered with by the network. 
  • Ten, ask software (and content and IoT device and cloud) developers what they actually want from the networks. Most seem to be absent from the debate - the forgotten stakeholders. Understand how important "permissionless innovation" actually is. Query whether they care about network QoS, or understand how it links to overall QoS which covers everything from servers to displays to device chipsets to user-interfaces. Find out how they deal with network glitches, dodgy coverage - and whether "fallback" strategies mean that the primary network is getting more or less important. Do they want better networks, are they prepared to pay for them - or would they just rather have better visibility and predictability of when problems are likely to occur?
Apologies for the length of this piece. I'll happily pay someone 0.0000001c for it to load faster, as long as the transaction cost is less than 5% of that.

Get in touch with me at information AT disruptive-analysis dot com if you'd like to discuss it more, or have a sane discussion about Neutrality and what it really means for broadband, policy, 5G, network slicing, IoT and all the rest.

Monday, July 18, 2016

My comments on BEREC's Net Neutrality guidelines consultation

I've been meaning to submit a response to the BEREC consultation on its draft implementation guidelines for the new EU Net Neutrality guidelines for some time. However, a combination of project-work and vacation has meant I've had to do just a fairly rapid set of comments at the last moment. 

I'm posting them here as a reference and further discussion-point. 

As a background, I think the guidelines are quite comprehensive - but have shifted the needle somewhat from the final EU regulation back towards the Internet-centric view of the world. However, the permissiveness around both zero-rating and (in certain circumstances) so-called "specialised services" seems a pragmatic compromise position. I tend to think that zero-rating is fine "in moderation" - it's basically the Internet equivalent of promotions and coupons. "Sponsored data" is an almost-unworkable concept anyway, so the regulatory aspect is largely irrelevant.

Specialised services are OK as long as they are genuinely "special" - something I've been saying for a long time (see post here). It should also be possible to watch for genuine innovation being catalysed / inhibited by the new rules - and then regulators and policymakers can take a more-educated view to revising them in a few years, based on hard evidence.

Anyway - the contents of my submission (reformatted slightly) are below:



Preamble

I am an independent telecom industry analyst and futurist, representing my own advisory company Disruptive Analysis. I advise a broad variety of telecom operators, network and software vendors, investors, NRAs, IT/Internet firms and others on technology evolution paths, business models and applications, and regulatory issues. I look at the issue of Net Neutrality particularly through the lens of what is, or what is not, possible – and also how the Internet value-chain, applications and user-behaviour are likely to evolve in future.

In the past, I have published research studies examining the possible roles and scale of “non-neutral” broadband & IAS business models. My primary conclusions have been that, irrespective of regulation, most proposed commercial models such as “paid prioritisation”, application-based charging or “sponsored data” are broadly unworkable, for many different technical and business reasons – such as growing use of encryption, plus the risks of false positives/negatives.

Overall, I see the guidelines as broadly positive, as they help clarify some of the many grey areas around implementing NN, and clearly try to close off future potential loopholes. Some aspects will likely be difficult to implement technically – notably the precise definitions and measurements of QoS / and “quality” – but the guidelines are good in setting the “spirit” of the law, even though in some cases the “letter” may be harder to achieve.

Listed below are comments that I feel could help to:

  • Clarify the guidelines further 
  •  Help future-proof them against changes in technology 
  •  Raise questions about possible evolution of the guidelines in response to those changes 
  •  Lock down a few additional possible loopholes
                                                                                                                       
Specific points on individual paragraphs: (reference to the guidelines doc here)

#10 – in locations where “WiFi guest access” is made available (eg visitors to a company’s offices), there is sometimes a sign-up or registration required, either via a splash-page, or simply via obtaining a password. Does this count as “publicly available”?

#11 – it should be clarified that there is a difference between corporate VPNs for connecting to a central site, and personal VPNs that are designed to secure/encrypt normal users’ access to the Internet. There is also a growing trend for corporate VPNs to be replaced by a new technology, software-defined WAN, which may itself use Internet access or even multiple accesses as transport.

#12 – Consideration of WiFi hotspots needs to distinguish between voluntary access (eg if a user obtains the cafĂ© password & registers independently) vs. automated “WiFi offload” by ISPs as an integral part of their IAS offering. The latter is a form of “public access”. Also, there are growing examples of ISPs using WiFi in public places, including outdoors, sometimes as part of “WiFi-Primary” public IAS.

#14 - It is worth distinguishing between capital-I “The Internet” (ie public Internet, addressable via the DNS system & IAS) and lower-case-I “internets” (internetworks) that are private domains.

#23-25 – This needs to reference what happens when “terminal equipment” becomes virtualised, through the imminent release of NFV (network function virtualisation) architectures. This could mean that either the “terminal” become a software-function in the ISPs’ data-centre, or could be (in part) pushed down as a “virtual network function” (VNF) to a general-purpose box at the customer site. Some providers are already discussing the concept of a “VNF AppStore” where the user can choose between different software “terminal” functions. It is unclear if this is permissible – or even mandatory.

#39 & #45 – the nature of software and Internet applications makes its increasingly hard to define categories. There are many blurred boundaries, overlapping categories, “mashups” and differentiated offers. How is the categorisation achieved, for example where a social network includes a large amount of video-streaming in its timelines? Is that equivalent to a “pure” video application? What about streaming of games? Is there a distinction between video-on-demand and live-streaming? This is particularly difficult where some functions such as voice communication are being included as “secondary features” embedded in many other applications, often via the use of 3rd-party platforms and APIs (application programming interfaces). There needs to be stronger guidance on how “categories” are defined and how disputed or ambiguous categorisation can be addressed.

#40 & #45 – a possible implementation option is to require ISPs to report the % of overall traffic (or % of particular user-classes) that is zero-rated.  If the total amount provided “for free” is less than (say) 10% of the total, it can a-priori be considered acceptable as it is unlikely to materially affect users’ choices. However, if it is higher this could trigger closely investigation by the NRA.

#43 – this section seems to focus more on established CAPs or possible new-entrants. It is unclear if this explicitly covers the needs open-source initiatives and general software-developers

#56 – There is a possible implementation option for NRAs to collect and hold configuration details for ISPs’ network equipment or software-equivalent VNFs, to allow retrospective analysis of network setup if disputes occur. This could be done on an encrypted / escrowed basis to maintain normal commercial confidentiality

#57 – the reference to encryption needs to explicitly include both app-level encryption (eg HTTPS / HTTP2) and more general “all-traffic” encryption using corporate or personal VPN “tunnels”

#57 & 58 – an implementation option for NRAs could be provision of a contact-point for internal ISP whistle-blowers to report infringement, or 3rd-party monitoring organisations (eg that use pattern-recognition to detect abuses)

#60 & #61 & #63 – categorisation is extremely hard, owing to application differentiation, complex hybrid and “mashup” applications, different levels of fault-tolerance built into applications by developers etc. For example, different VoIP applications use different approaches to error-correction, or are used differently (eg ordinary telephony vs. karaoke). In future there will also be a difference based on whether the application (at either end) is a machine rather than a person. Implied QoS when speaking to “Siri” or “Alexa” may have very different characteristics to speaking to a friend, despite being carried over VoIP. There may also be other dependencies – eg if network conditions have worse impact on badly-designed applications, or devices with other constraints (memory, CPU power, processing chips etc)

#64 – does “network management traffic” also include other types of operational (internal) ISP traffic such as billing records, customer-service inquiries & apps and so forth?

#71 – does “alteration” cover so-called “optimisation”, whereby various content such as a video or image can be paused, down-rated, reformatted etc.? Does it also cover “insertion” of additional data such as tracking codes / “supercookies”, or additional overlay advertising? Are “splash pages” (eg for WiFi registration) allowed?

#89 – Dimensioning may well be affected by other constraints, such as spectrum availability, location, economics of network coverage/capacity, or “emergent” unexpected trends in demand

#98 & #123 – this appears to define specialised services as “actually being special” rather than those capabilities that are normally delivered over IAS. How are hybrid specialised/non-specialised services to be treated?

#101 & #104 – technologies such as SD-WAN (software-defined WAN) allow improved QoS by linking together multiple IAS connections, which in aggregate can perform as well (or even better/cheaper) than one QoS-optimised connection. Should NRAs consider this option when determining if specialised services are valid? See http://disruptivewireless.blogspot.co.uk/2016/06/arbitrage-everywhere-inevitable.html  and http://disruptivewireless.blogspot.co.uk/2016/03/is-sd-wan-quasi-qos-overlay-for.html for more detailed discussion of this point

#111 – It is important to recognise that VPNs are increasingly used by consumers as well as businesses, often to provide a secure & privacy-protected path to the Internet over both public IAS and localised WiFi hotspots. The guidelines should specifically reference consumer VPNs.

#113 to #115 & #117 & #119 – It may be difficult to guarantee coexistence of IAS and specialised services over cellular/other radio networks, where factors such as location in a cell, mobility, density of users, coverage/interference etc are non-deterministic. Potentially the guidelines could advise use of different spectrum bands for IAS and specialised services, to mitigate these problems.

#113 & #116 – in future 5G architectures, we may see a concept called “network slicing”, where the radio and core networks are logically divided into “slices” suitable for different application classes – either broadly between Internet & specialised services of different types, or resold more granularly a bit like “super-MVNOs” to particular 3rd-parties on a wholesale basis. Where those parties are themselves CAPs, this could make interpretation of this section very difficult. If Netflix or Google or even a rival ISP/telco buy rights to a “slice”, how do the guidelines apply?

#131 – This guideline should potentially also include information/transparent guidance for application developers, who may be creating applications intended to run over the IAS provided

#152 – should coverage maps be 2-dimensional, or also include z-axis detail (eg speed in a basement / on the 50th floor of a tower block)? How can such maps cope with the trend towards self-optimising / self-reconfiguring networks of various types?

#167 & #180 – NRAs should potentially seek to maintain records of network configuration status (which may change abruptly with the advent of NFV & SDN). This could perhaps be stored securely & reliably using technologies such as Blockchain.

#172 & #179 – monitoring of aggregate volumes of traffic subject to price-discrimination (eg % of IAS traffic that is zero-rated) would be useful


General comments:
  • There needs to be consideration of meshed, relayed or shared connections which run directly between users’ devices. In device-to-device scenarios, does the owner/operator of an intermediate device become responsible for the neutrality of the “onward” link to 3rd parties? (which could be via any technology such as WiFi, Bluetooth, wired USB port etc) 
  •  There needs to be consideration that some of the more invasive mechanisms for traffic discrimination and control will in future move from “the network” to becoming virtualised software (provided by an ISP) that reside in edge-nodes at the customer premise, or even in customers’ mobile devices. It is unclear how the implementation guidelines deal with predictable near/mid-term trends in NFV/SDN technology, especially where there is no clear “demarcation point” in ownership between ISP and end-user. 
  • Equally, in future there may well be CAP companies that offer their services “in the network” itself, also with NFV/SDN. There needs to be careful thought given to how this intersects with Net Neutrality guidelines 
  • The evolution of artificial intelligence & machine-learning means that workarounds or infringements may become automated, and perhaps even invisible to ISPs, in future. This may also impact the nature of QoS as used for different applications. See http://disruptivewireless.blogspot.co.uk/2016/04/telcofuturism-will-ai-machine-learning.html for more details 
  •  Where wholesale relationships occur – eg MNO/MVNO, “neutral host” networks using unlicenced-band LTE, or secondary ID on the same WiFi hotspot – and the traffic-management / IAS functions are co-managed, how do the guidelines apply? Which party/parties is responsible?

Monday, April 20, 2015

Net Neutrality vs. Not: Four Unexplained Paradoxes

In all the media and lobbying furore about Net Neutrality, most of the discussion is about either political, ideological or academic angles. We regularly hear about the anti-capitalist risks of "regulating the Internet", the importance of Neutrality as a representation of free speech, or the theoretical efficiencies of two-sided markets and so on.

Frankly, all of those arguments will go on ad infinitum, because there is no objectively "right" answer to any of them. Unless regulators do multi-year massive field trials of neutral / non-neutral rules, there won't be any real data on actual consumer welfare, rates of innovation and so on. It will also just be rhetoric and theory.

But there is a particular subset of claims and assertions in the telecom/Internet industry which are mutually contradictory, where the industry itself has created a paradox. Regulators should challenge market participants to clarify the dichotomies, as a more rigorous thought process might lead to a few problems simply disappearing.

I've spotted four of these self-contradictions:

Paradox 1:
  • "There is a data tsunami, leading to congested networks and ultimately a 'capacity crunch' & so we need more spectrum"
  • "We want to zero-rate some mobile apps & give the data away for free"

Paradox 2:
  • "We can expose QoS capabilities to 3rd party app & content companies such as VoIP & videoconferencing players, monetising QoS capabilities in the network"
  • "People will use and value VoLTE & ViLTE, because it's the only QoS-managed voice and video service. The rest are best-efforts only"

Paradox 3:
  • "About 10-15% of cell sites face congestion"
  • "We're going to make a lot of money from paid prioritisation"


 Paradox 4:
  • "We're aiming for customers to move to larger data-plans, or incur overage fees"
  • "We'll sell sponsored data to content/app companies [at wholesale prices]"

Now, in all of these there's a little wiggle-room, despite the self-contradiction. 

It might be that operators carefully craft their zero-rating plans, so they only generate more (free) data traffic in uncongested areas, or at uncongested times. Or perhaps more cynically, creating more near-term congestion is a tactical positive, as it helps sway spectrum policy with longer-term benefits.

Perhaps operators will expose commercial QoS APIs only to those companies that don't offer competing VoIP/video communications services, or will price it on a discriminatory basis, so that VoLTE has a cheaper cost basis. Or maybe it will be "semi-skimmed QoS" available to app developers, with "full-fat QoS" only available for in-house services.

Maybe paid-prioritisation (let's assume it works; many think it doesn't) will be offered at such a small uplift of data transmission price, that content companies will be willing to buy it like an insurance policy, covering 100% of locations/times/users, even though they know that the risks are only real for 10% of locations, 10% of the time, for the 20% of users who aren't on WiFi anyway. Or perhaps they'll price it at a huge premium to the baseline cost, so that app devs will just use it in a real emergency situation.

Maybe telcos with sponsored data platforms can develop a mechanism that encourages use just for new mobile apps and content, rather than replacing retail data plans paid by users, with discounted wholesale traffic bought in bulk by content firms.

In my view, a lot of the supposed "use cases" and "business models" that opponents of Net Neutrality put up are straw-men. They simply don't work - either technically or commercially. Many of them will actually lead to lower revenues, or have unintended market and regulatory consequences. 


(If selling QoS to third parties is ever to become feasible, it will probably need laws for non-discrimination, transparent pricing & maybe even structural separation)

We already see the failure of AT&T's Sponsored Data programme to make any meaningful impact. We also see a lack of any app or content co's clearly asking for prioritisation to be sold to them - nobody actually wants it, at least on mobile networks. And I'm willing to bet that the first time a regulator asks a telco's execs why they need more spectrum, when they're generating excess traffic with free zero-rated usage, it will cease to be a big deal.

That's not to say that other Neutrality problems aren't real - there clearly is blocking of certain apps, or deliberate degradation/throttling of others. But many of the "hot topics" for activists and lobbyists are simply worthless, unworkable ideas. 

Regulators should focus on these apparent paradoxes - as clarifying the answers (and making all involved think through them clearly) - will make most of the points of contention simply evaporate.

These issues and many others are addressed in Disruptive Analysis research on new mobile data monetisation & "non-neutral" strategies. Click here for details.