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APC wishes to thank the ITU for the opportunity to respond to this open consultation held by the Council Working Group on International Internet-related Public Policy Issues (CWG-Internet) on public policy considerations for over-the-top services (OTTs).

With the steady expansion of affordable broadband services, OTTs are beginning to have a significant impact on some of the revenue streams of many traditional telecommunication infrastructure operators, especially those which have based their business models on bundling the provision of physical infrastructure with high-margin voice and messaging services, and then simply “bolting on” the provision of internet access. Similarly, national authorities that have continued to only focus on the regulation of traditional telecom infrastructure operators are now finding that these regulations are becoming less and less effective in achieving their goals.

While the precise definition of OTTs requires further clarity and agreement from all stakeholders, the rapid growth of internet-based communication and information services, particularly those that provide a more attractive alternative to the traditional voice and messaging services of telecom infrastructure operators, highlights the fact that business models for infrastructure provision, as well as national policies and regulations, need updating. In particular, the international/distance-independent nature of OTTs and other internet services creates a new dynamic that underlines the need for international multistakeholder and multilateral public interest-driven cooperation.