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In short, we cannot find evidence that shows that zero rating creates harm. We find that<br />

zero rating has a negligible but not negative impact on the marketplace.<br />

Zero rating is one of a number of marketing techniques that mobile operators need to<br />

employ in competitive marketplace. For some operators in the study, they outcomes are<br />

the opposite predicted by critics. Some operators that deployed zero rating actually lost<br />

market share, and their zero rated applications were insignificant in terms of rank. We do<br />

not believe that this is a result of zero rating, but rather that zero rating is the result of<br />

the operator’s competitive situation. To rephrase Baumol, operators don’t deploy zero<br />

rating because they can, but because they must.<br />

It is strange however that a service that has such a minimal impact should be so<br />

maligned. It is also an inconsistent that zero rating is rampant across Internet<br />

applications and services (e.g. advertising supported games, search, social networks,<br />

music streaming etc) but arbitrarily prohibited on mobile broadband services.<br />

We noticed that in the three countries that advocates have a goal to make flat rate<br />

internet subscriptions and high data caps (preferably no data caps) the norm, if not the<br />

law. While such offers have appeal, they necessarily mean low volume users, whether by<br />

choice or budget constraint, are forced to pay more for internet access. Meanwhile high<br />

volume users, those who want to stream movies or play video games, pay<br />

proportionately less for their service. Such a situation would be a particular boon to<br />

companies such as Netflix, whose streaming service takes up a disproportionate share of<br />

mobile traffic. Thus it appears that campaigns against zero rating are waged as a way to<br />

pressure mobile operators to change their pricing in favor of users who consume high<br />

volume video and against those users who have never used the Internet but want an<br />

incentive to try.<br />

Zero Rating - <strong>Layton</strong>/Calderwood<br />

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