You are here

Facebook

Debunking Edge Competition Premises in FCC 2015 Title II Broadband Order – FCC Comments

 

July 17, 2017

FCC Restoring Internet Freedom WC No. 17-108

Submission by Scott Cleland, Chairman, NetCompetition (An e-forum supported by broadband interests.)

 

 

Debunking Edge Competition Premises in FCC 2015 Title II Broadband Order – FCC Comments

In 2015, the FCC’s Title II Open Internet broadband order implicitly was based on three core competitive premises about “edge” competition and competitors, that are demonstrably false, which undermines the factual legitimacy and legal justification of the FCC’s 2015 Open Internet order, and which supports the current FCC’s Restoring Internet Freedom NPRM to overturn it.

Summary: The 2015 FCC’s three demonstrably false core competitive premises are:

 

Why Aren’t Google Amazon & Facebook’s Winner-Take-All Networks Neutral?

 

Ironically, the world’s leading winner-take-all Internet platforms -- Google, Amazon, and Facebook -- are the leading voices of the July 12th “Internet-wide Day of Action to Save Net Neutrality.” They want to pressure the U.S. FCC to maximally regulate ISPs as Title II telephone utilities, even though they don’t believe in operating neutral networks themselves.

Even more ironic, is this 1 min. Google-YouTube video -- by the Internet Association, “the unified voice of the Internet economy.” It defines net neutrality and what it wants the FCC to ban ISPs from doing. However, those banned behaviors closely describe how Google, Facebook and Amazon often operate. Awkward.

In yet another video supporting this Day of Action, three U.S. Senators video message said: “We believe the Internet is the extraordinary opportunity that gives everybody in America the chance to get ahead. We have to make sure it is not controlled by a handful of powerful corporations.”

This piece has two tasks.

Why US Antitrust Non-Enforcement Produces Online Winner-Take-All Platforms

If one considers the evidence, it is evident that U.S. antitrust enforcers have enabled the current “new normal” of online winner-take-all platforms: Alphabet-Google in e-information, Amazon in e-commerce, Facebook in e-social, Uber in e-transportation services, Airbnb in e-accommodation services, and a “unicorn” queue of online winner-take-all platform wannabes.

Summary of Conclusions

U.S. antitrust officials should be alarmed by the extreme early concentration of a relatively young twenty-year old, U.S. online company marketplace.

Five online winner-take-all platforms -- Google, Amazon, Facebook, Uber and Airbnb -- already command ~80% of U.S. online companies’ revenue share and market capitalization.

And they are collectively capturing 82% of U.S. online companies’ revenue growth share, meaning they are growing more dominant not less.

The Internet Association Proves Extreme U.S. Internet Market Concentration

Those who think the U.S. Internet market is competitive, and not extremely concentrated, need to read on.

In a nutshell, for the first time, publicly available evidence shows that the cumulative effect of well-known “winner-take-all” platforms (WTAPs) Google, Amazon, Facebook, and Microsoft, is a “four-winners-take-all Internet sector.” Four different dominant platforms collectively command ~80% of overall Internet market share in revenues, new absolute annual revenues generated, market capitalization, and employees.

Imagine if the 94% of the economy that is offline-based, were as extremely concentrated as the 6% of the economy that is online-based/the Internet sector, per the Internet Association.

That would be an offline economy with basically one information company, one sharing company, one retailer, and one business software company, that collectively commanded 80% revenue share of the 94% of the economy that is offline based with ~4,000 publicly traded companies.

Alphabet-Google Big Takeaways from Trump Antitrust Chief’s Senate Answers

Reportedly the EU will rule Google has abused its search dominance this summer, putting the growth and profitability of the ~30% European part of Alphabet-Google’s revenue base at risk.

The logical next important question will be if this EU antitrust enforcement means U.S. antitrust enforcement eventually will follow, expanding Alphabet-Google’s growth and profitability risk, to the combined ~80% U.S. and European revenue base of Alphabet-Google.

Why do the answers of President Trump’s nominee for DOJ Antitrust Chief, Makan Delrahim, to the Senate Committee overseeing his confirmation process, merit close attention as it pertains to Alphabet-Google’s U.S. antitrust risk?

Mr. Delrahim’s is highly likely to be confirmed by the Senate to head the DOJ Antitrust Division, and it is likely to occur in June.

Thus, his written answers under oath to the Senate Judiciary Committee represent the best accessible, most-recent, most-reliable, forward-looking evidence upon which to discern the general direction Mr. Delrahim and U.S. antitrust enforcement is likely to pursue on the Google antitrust matter.

NetCompetition: Broadband Utility Regulation Proponents’ Hypocritical Focus

FOR IMMEDIATE RELEASE, May 18, 2017, Contact:  Scott Cleland 703-217-2407

 

What’s Wrong with This Picture? Pressure Groups and their Netopolies-Funders: Google, Facebook and Amazon, Hypocritically Demand Utility Regulation of Competitive Broadband ISPs to Prevent Commercial Discrimination or Blocking When the Netopolies are the Actual De Facto Utilities that Discriminate and Block as a Key Part their Business Models  

 

WASHINGTON D.C. – The following may be attributed to Scott Cleland, Chairman of NetCompetition:  

 

“Title II broadband regulation proponents sacrifice their credibility when they claim competitive companies are monopolies that require the strongest possible utility regulation, while simultaneously claiming Internet monopolies like Google, Facebook and Amazon, are competitive companies that should have no regulation at all.”

 

 

New Evidence Google Facebook Ad Cartel Crushing Competition Market Failing

Let’s see what a winner-take-all, market failure looks like as it is happening before our eyes.

The Goobook digital ad cartel is continuing its outsized, abnormally-fast, revenue growth on top of the largest digital ad revenue bases by far. Consequently, their few remaining platform digital advertising competitors are weakening significantly per 1Q17 earnings reporting and other information.

This is how the relevant market players did in 1Q17.

Google (which is 90% digital advertising) grew revenues at a 22% annual rate, or an absolute revenue increase of +$17b to total $95b for the last year.

Facebook (which is basically all advertising) grew revenues at a 49% annual rate, or an absolute revenue increase of +$10b to total $30b for the last year.

HBO’s John Oliver needs a 'net neutrality' reality check – The Hill Op-ed

 

Please don’t miss my latest The Hill Op-ed: “HBO’s John Oliver needs a 'net neutrality' reality check.”

 

Internet giants, not broadband providers, are the top threat to consumers – The Hill Op-ed

Please don’t miss my latest The Hill Op-ed: “Internet giants, not broadband providers, are the top threat to consumers”.

 

 

Why Title II Net Neutrality Directly Conflicts with Consumer Privacy

At best the notions of net neutrality and consumer privacy are somewhat in tension.

At worst, they are in opposition, and harm consumer privacy as happened when the Wheeler-FCC subordinated the goal of what’s best for consumer privacy to the conflicting and overriding goal of what was best for imposing maximal, Title II net neutrality.

Net neutrality and consumer privacy are in tension because they are very different concepts, priorities, and approaches for the handling of information online.

However, the original tension between the FCC’s first concept of net neutrality and consumer privacy was very limited because the Martin-FCC’s 2005 Internet Policy Statement on net neutrality was an extension of the Powell-FCC’s “Internet Freedoms” concept of net neutrality, and both approaches were consumer-first, i.e. very clearly centered around what consumers could expect from the Internet.

What thrust them into the more opposing concepts that they are today?

It was when net neutrality flipped from being primarily a consumer-centric principle to an edge-provider centric principle defined by Google, Amazon, Facebook and Netflix; and from the enforcement of a general broadband nondiscrimination principle, to the preemptive imposition of “the strongest possible,” specific, utility rate regulation framework – i.e. Title II of the 1934 Communications Act -- on a competitive industry that had done nothing wrong to warrant it.

Pages

Q&A One Pager Debunking Net Neutrality Myths