Response to TRAI Consultation Paper on
Growth of Value Added Services and Regulatory Issues
Question 6.1. Does the existing definition of Value Added Services given
in license agreement for provision of Unified Access Services (UAS), as
mentioned in para 1.3, needs any modification or same can be incorporated for
the value added service provided through cellular mobile telephone networks,
including 3G, IP Multimedia System (IMS) and Next Generation Networks (NGN)
?. Please give your suggestions with reasons thereof.
Ans. Scope of Value Added Services should be broadened as beside UASL &
Mobile Telecom Operators, ISPs are also providing value added services.
Accordingly, scope of VAS should not be restricted to USAL and Cellular
Question 6.2 Whether there is a need to bring uniformity or clarity in the
licensing conditions of mobile telecom operators / access service providers
with regard to provision of value added services ?
Ans. No comments.
Question 6.3. Apart from the licensing obligation of intimation before
introduction of any new value added services and the measurers to facilitate
monitoring by security telecom operators ?
Question 6.4. Whether companies providing Mobile Value Added Services
who mainly act as contact providers or content aggregators and operate value
added services technology platform called value added service providers
(VASPs) need to be brought under the licensing regime or not ?
Ans. No. There is no need to create another license for “Value Added
Service Providers” as these services are being offered by existing Operators
including ISPs to the consumers. As such new license is not required.
Question 6.5 If license system is to be restored to for licensing of mobile value
added service (VAS) under the Indian Telegraph Act, 1885, what should be the
scope of license and other terms and conditions for such license ?
Ans. As mentioned above there is absolutely no need for a new license.
Question 6.6 What should be the licensing obligation for protecting copy rights,
including digital rights management, and infringement of other laws of the
country on value added service licensee ?
Ans. As mentioned above there is no need for a new license for value
added services. As far as copy rights including digital rights and
infringement of other laws are concerned it should be treated as per
respective prevailing laws. We are sure all the service providers are and will
be taking care of copy rights issues etc before offering any value added
services on their networks. Any infringement should be dealt in accordance
with prevailing land of law.
Question 6.7 What should be regulatory framework for content regulation ?
Please give suggestions with reasons thereof ?
Ans. Contents are very crucial for any services especially for the
Broadband. Contents in local/regional languages can do wonder in spreading
the reach of broadband in the every hook and corner of the country. There
is no need to regulate contents as it is not practically possible. There are
agencies such as CERT-In which are advising service providers to block
particular site in case it is showing objectionable materials. Accordingly,
there is no need to have another body to regulate content.
Question 6.8 Who should allocate short codes for value added services, in order
to have uniformity amongst all the telecom operators and also to enable
branding of value added services?? Please given your suggestions with reasons
Ans. DoT should allocate the short codes as per National Numbering Plan.
Question 6.9 Is there a need to regulate revenue sharing model or should it be
left to commercial negotiations?? Please give your suggestions with reasons
Ans. There is no need to regulate revenue sharing model and it should be
left to commercial negotiations. There are number of service providers and
content providers in the market. Both have ample choices to select the best
which suits their requirement and enter to the commercial negotiation. We
think that TRAI should not intervene in the commercial negotiations.
Questions 10. Any other suggestions with reason thereof for orderly
growth of mobile value added services including such services to be provided in
3G, NGN environment ?
Ans. No comments.