Serious Concerns Ignored by Ritva Siren's paper of May 12th.

["pierceswanson " <pierceswanson@xxxxxxxx>]

Previous comments on this forum have raised several key issues and concerns in respect 
to the Nokia led .Mobi: (1) it is a short term response to a temporary need: 
downloading tailored services on small screen devices (2) this need is currently solved 
by other existing technologies, such as server based compression (3) it covers only 
part of the telecom space (4) it is fragmenting the Telecom addressing architecture, 
thus stifling Telecom competition (5) it has anti-trust implications on both sides of 
the Atlantic (6) it is a disguised attempt for mobile operators to gain a key lock over 
the whole Telecom industry.

Ritva Siren has not responded to questions in her 9 paragraph letter posted on May 
12th. 

Paragraph 1: This is a poor attempt to discredit any comments not specifically answered 
by this response. Furthermore, by referencing Ritva Siren's previous posted comments, 
which were equally superficial, Mobi JV is not advancing the understanding of 
participants in this forum.

Paragraph 2: It combines an unsupported statement - (i) mTLD is a key component to 
achieve mass market user-friendly mobile services - an obviously ill-thought and self 
serving economic principle - and (ii) success of business and users are inseparable - 
to bury the underlying anti-trust issue? Free markets allow profit, but sanctions 
monopoly, especially for mass market products and services.

Paragraph 3:  Fragmentation of the Telecom addressing structure suggested by the Mobile 
operators is justified by the existing naming practices of the Internet, thus avoiding 
the debate and key questions behind subregistration of subscribers under Telco's domain 
names and the introduction of a network access specific TLD. Why stifle Telco 
competition by fragmenting a universal addressing space when it runs counter to the 
very essence of the Internet?

Paragraph 4: This paragraph is boilerplate intellectual mash potatoes. It is trying to 
explain the poor use of internet mobile services by supposed attempts by unknown actors 
to restrict the mobile industry's innovation. It seems to forget that the main 
hindrances to Internet mobile access have been (1) limited bandwidth (2) a very poor 
marketing of WAP data channel (3) a gross overcharge of key mobile services such as 
SMS, MMS, roaming and access from fix to mobile (4) a de facto cartelization of 
national markets, once saturation is close. These are the real issues that are not 
discussed in Mobi JV response of May 12th.

Paragraph 5: This paragraph tries to justify the tailored approach service, and 
therefore .MOBI, by the permanence of a structural gap in capacity between fixed line 
and WAN or WLAN access. It is based on a gross misunderstanding: the issue is not 
difference in capacity, a relative and theoretical concept, but absolute level of cheap 
capacity available for mobile users, a very practical concern. Quite frankly, with G3 
and Wifi, there is now sufficient bandwidth for the foreseeable future to provide a lot 
of quite sophisticated services. The real issue is not technical, but marketing, with 
an interesting paradox: most services still need to be invented, killer applications 
are the least bandwidth-hungry and expensive, whilst bandwidth absorbing ones are not 
necessarily the most mass market appealing: who cares about videoconferencing if it 
cannot send cheap SMS? 

Paragraph 6: This paragraph is at best abstruse. In reality its purpose is to cover up 
the central contradiction in the .MOBI application: mobile communication is only one 
part of the much larger telecom space, whose addressing structure must not be 
fragmented as it would stifle competition between mobile and other forms of access. 
Accepting real competition accruing to the benefit of the Community, means implementing 
a unique, universal and single-operated naming structure for the whole Telecom space, 
which excludes an mTLD. And remember: the need for reformatting websites for handsets 
may be gone within the next 2 years for most services. Both are content related 
applications, but one bolsters competition and the other stifles it.

Paragraph 7: Representation does not mean influence. Any kid with no political science 
background can see that the .MOBI sponsoring organization is and will be driven by 
service operators for their benefit, not for the community. This is the second major 
contradiction of the .MOBI application.

Paragraph 8: There is no justification for Nokia to keep some of the .MOBI application 
undisclosed to the public. Revealing the entire application is the only way to for the 
community to assess Mobi JV's real intentions. 

Paragraph 9: Nobody can disagree that innovation comes from different approaches, and 
that mTLD is one of the possibilities offered to address future communications. But 
this again is not the issue. The real one is that a centralized, unique and universal 
addressing structure protects the Community by triggering competition across the whole 
Telecom industry, whilst the mTLD will restrict it by favouring mobile operators over 
others. What the Nokia response refuses to understand, or to acknowledge, is that this 
perception of anti-competitive practices is not the result of Nokia's presence, but the 
accumulation of a formidable group controlling all the operating software of the mobile 
industry, registering subscribers at the third level and the strategic choice, i.e. to 
create a restrictive mTLD as opposed to participating in a global open Telecom TLD.

Nokia's response is long on intention but short on facts. 

--
Pierce Swanson



















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