Please find hereby Skype s response to the European Commission s consultation document.

Transcription

1 European Commission Directorate General Information Society and Media Luxembourg, 11 February 2011 Response of Skype Communications S.à.r.l. to the European Commission s consultation document: "Review of the functioning of Regulation (EC) No 544/2009 (the "Roaming Regulation ). Skype Communications S.à.r.l. (hereafter Skype is a Luxembourg-based provider of peer-to-peer software applications which enable Skype users to communicate with other Skype users, and enabling, optionally and where possible, certain forms of communication with the subscribers of electronic communications networks and services. Please find hereby Skype s response to the European Commission s consultation document. A. General Remarks Skype welcomes the opportunity to comment on the European Commission s public consultation on the Review of the Roaming Regulation. Skype s overall analysis of the current situation in the EU is as follows: a) No meaningful single market, and no meaningful competition, has developed for international wholesale mobile roaming (voice, SMS and data) within the EU. b) Potential/partial substitutes for international (wholesale and retail) mobile roaming (e.g. VoIP over mobile data, VoIP over WiFi) remain marginal in usage. This is notably due to the extremely high wholesale and retail prices for international mobile data roaming and impediments relating to numbering. It is also a fact that WiFi s availability and reach remains limited, and that many users experience difficulties in accessing/configuring WiFi, and that prices (wholesale and retail) for WiFi access are often high in their own right. As the 6 th BEREC Benchmark Skype February 2011 Page 1

2 Data Report 1 underscores, international retail mobile data roaming prices are orders of magnitude higher than domestic levels (domestic retail mobile data prices often being very high in their own right). c) Consumers of international retail mobile roaming for voice and SMS have been protected to some extent by the wholesale and retail caps that have been imposed by regulation. However, prices (both wholesale and retail) remain clustered around the caps imposed by regulation. d) Whilst international wholesale and retail mobile data prices have fallen, they remain at levels which severely dissuade usage, which in turns dissuades the usage of VoIP over mobile data. e) Usage of VoIP, peer-to-peer and other protocols which support VoIP and interpersonal Video over IP is being contractually and/or technically restricted by a substantial number of EU mobile network operators, or is made subject to specific surcharges imposed by mobile network operators, which further dissuades the usage of VoIP over mobile data. BEREC s response to the EC s consultation on the open Internet and net neutrality in Europe underscores this at page 3 2, including no less than 8 footnotes highlighting restrictions. Skype believes that this BEREC document understates the extent of restrictions that actually apply today, and understates the need for regulatory intervention accordingly. The above analysis of the current situation in the EU leads to inescapable conclusions, as follows: a) The situation needs to change, because EU citizens, public administrations and businesses are encountering unjustified restrictions and are being harmed by incurring unjustifiably high prices, which impede electronic communications and impede the take-up of information society services, which in turn dissuades participation in, and the development of, the Information Society. The situation also needs to change because the EU single market goals are not being achieved, and because competition is not meaningfully developing (competition being the key tenet of the regulatory framework for electronic communications). b) Given the limited effectiveness of the current Roaming Regulation (it has protected consumers to some extent on voice and SMS international retail mobile roaming prices, but has not achieved much else), there is a need for decisive EUlevel action Skype February 2011 Page 2

3 c) Capping international (wholesale and retail) mobile roaming prices probably remains relevant as a direct and predictable consumer protection measure, and needs in particular to be extended to international retail mobile data roaming, but this would only continue and extend the current approach. d) However, continuing with caps, and extending caps, would not contribute to enabling/promoting competition at wholesale and retail levels; would not enable the lifting of undue restrictions; and could fail to take account of the actual underlying costs of providing mobile services and the incremental cost of providing international mobile roaming. e) Therefore, structural intervention is necessary over and above the continuation of existing (wholesale and retail) caps for voice and SMS, and over and above the extension of caps to international retail mobile data roaming. f) Skype advocates a combination of: (i) (ii) (iii) Profound spectrum reform ( RSPP on steroids ), especially enabling unlicensed and shared spectrum in lower bands (<1 GHz, e.g. TV White Spaces) and in higher bands (e.g. 5 GHz), whilst actively envisaging other bands for each of unlicensed and shared use. A mandated wholesale access-based approach, in particular such that new pan-eu (mobile data) providers can genuinely emerge in addition to the operators of the underlying physical and transmission networks. The mandated access should be such that these new providers enjoy freedom to define their own product and pricing characteristics, including their own international roaming propositions (i.e. a greater level of autonomy than enjoyed by essentially all MVNOs as they are known today). The setting of international wholesale roaming mobile data caps in a manner (wholesale price structure, wholesale prices) which ensures that retail flat-rate mobile Internet offers can emerge, at non-dissuasive retail price levels for a level of usage which corresponds to the evolving day-to-day requirements of end-users in today s EU and in the EU of the coming several years. A possible model (which could exist in parallel with other models) would be for the wholesale price to be tied to an individual roaming user s usage, but for it not to be expressed per kilobyte or per megabyte, but to require wholesale-level daily/weekly/monthly offers, with generous (not necessarily unlimited) bandwidth caps for the Skype February 2011 Page 3

4 relevant day/week/month period, corresponding to the evolving day-today requirements of end-users in today s EU and in the EU of the coming several years. A system to measure and communicate the volume of individual users usage to the wholesale purchaser, and which can be immediately presented onwards to the roaming user, should be included in this model. (iv) (v) (vi) The setting of international retail mobile roaming data caps as a safeguard measure, with an explicit requirement in the regulation to the need for this to enable mobile Internet access, and to ensure that the objectives of iii) are effectively achieved and hopefully by far exceeded. This is essential given the increasing importance of the Internet for today s end-users. Clear guidance from the European Commission on the ex-ante principles underpinning the protection of the open Internet, i.e.: (i) definition of Internet access (evolving over time), (ii) recommendation that all end-users should be able to have access to the entirety of the global best-efforts Internet (fixed and mobile), and (iii) specifying the scope of reasonable traffic management, as exceptional, relevant, proportional, efficient, transparent and non-discriminatory. For further details, please refer to Skype s response 3 to the EC consultation on the open Internet and net neutrality in Europe. Note: We are not opposed to combining these elements with further elements such as encouragement of WiFi deployment, carrier selection type measures, etc. but we do strongly believe that each of the elements listed in points (i) through (v) are essential to achieve meaningful progress on international mobile roaming and the mobile Internet within the EU, in line with the Single Market goal. As a final, but very important, remark, we wish to explicitly caution the European Commission and other EU institutions against over-expectations/over-reliance on VoIP over WiFi and against inflated expectations around LTE mobile networks. We naturally strongly support stimulation of WiFi. Indeed we offer SkypeAccess which aggregates over third-party WiFi hotspots and access points world-wide, which are transparent for the Skype user to access and for which the Skype user can pay easily using Skype credits through the Skype software application ( Tools menu in Skype 5.0). However, the WiFi hotspots or open access points available in the EU 3 ents/07internet_application_content_providers/skype.pdf Skype February 2011 Page 4

5 cover only a very small proportion of the EU territory, and even though installation proceeds apace, it cannot be expected that WiFi as we know it today will reach anywhere near ubiquity (certainly not by 2015). Ensuring that WiFi in TV White Spaces or in other <1GHz bands can develop is essential, but this cannot reasonably be expected before The same is true for other technologies that could be used in TV White Spaces or other low frequency bands, or shared with licensed use. Similarly, LTE networks operated by mobile network operators will take many years to reach widespread coverage (certainly not ubiquity by 2015), have not been tested under the load of a large user base, and will to a very large extent be operated by the same mobile network operators which today apply contractual and/or technical restrictions on VoIP and other protocols, and/or apply retail surcharges for the use of VoIP. Therefore, the last thing Skype would wish to see happen, is the EU institutions concluding that VoIP over WiFi or VoIP over LTE would represent some kind of panacea, justifying a misguided laisser-faire approach on wholesale and/or retail international mobile data roaming. Much as we would like to see VoIP over WiFi and non-discriminatory VoIP over LTE develop on a massive scale, telecommunications history teaches us, and statements made by the mobile telecommunications industry indicate, that it would be an error to assume that this will happen sui-generis. B. Response to the Questions of the European Commission Please find below Skype s responses to the consultation questions, with reference to our overall analysis and the points we advocated in Section A. above which constitute the core of this response. Question 1: To what extent do you believe that the current regulation achieved its objectives in terms of: (a) Contributing to the single market for roaming services? (b) Ensuring consumer protection? (c) Promoting competition? Please explain and substantiate your responses with data where possible. Question 2: Do you consider that regulatory intervention for roaming services is needed beyond June 2012? Please consider voice, SMS and data roaming services separately. In particular, if you consider that the Roaming Regulation should expire in June 2012, please explain why, and describe how you consider that the market for roaming services will evolve in the absence of regulation. Skype February 2011 Page 5

6 Answer to Q1 (a) Neither before, nor after, the adoption of the Roaming Regulation have meaningful single European markets (wholesale and retail) for international mobile roaming existed. National wholesale and retail markets do exist, and there is limited wholesale competition at national level between the national mobile network operators in attracting international roaming traffic to their network, but this competition is for marginal traffic that is not covered by bilateral/reciprocal deals. We discuss the national retail level under (c) below. Overall, we do not believe that the current regulation has materially achieved its objective of contributing to a single market for roaming services. (b) Consumers of international retail mobile roaming for voice and SMS have been protected to some extent by the wholesale and retail caps that have been imposed by regulation. The current regulation can therefore be considered a relative success in this specific area, depending on one s assessment of the retail price levels that were imposed and have resulted from the regulation. However, with prices for voice and SMS (both wholesale and retail) remaining clustered around the caps imposed by regulation, it cannot be considered an unqualified success. More substantially, whilst international wholesale and retail mobile data prices have fallen, they remain at levels which severely dissuade usage, which in turns dissuades the usage specifically of VoIP over mobile data, and it is clear that consumers are not adequately protected with regard to mobile data and especially not with regard to the mobile Internet. (c) We have discussed wholesale competition in (a) above. At the retail level, it is not clear that competition has increased, and in fact it may have decreased over the past several years (also prior to the introduction of the first regulation), as a result of the introduction of SIM cards which steer the user to specific foreign mobile networks with which wholesale bilateral/reciprocal deals have been concluded. Only the most sophisticated users override this steering. Whilst we have seen a few offers emerge that are aimed at attracting (mainly heavy) voice, SMS and data roaming users, we doubt that these have attracted substantial usage, and hence their competitive effect has been very modest at best. Answer to Q2 The existing regulation has protected consumers to some extent on voice and SMS international retail mobile roaming prices, but has not achieved much else, and consumers have notably been exposed to international retail mobile data roaming pricing which severely dissuades usage. It therefore seems to us that the inescapable conclusion is that regulatory intervention for roaming services remains warranted beyond June 2012, with a determined focus on mobile data and with an explicit Skype February 2011 Page 6

7 requirement in the regulation to the need for this to enable mobile Internet access, and with several additional structural measures in addition to caps. B.1 Maintain current approach Question 3: Do you consider that the current model of regulation would be effective in the future in light of the desired objectives? Will this approach ensure adequate consumer protection and help stimulate competition? Is it efficient and coherent with EU policies? Question 4: If this model is suitable in principle, what modifications may be required in order to achieve a well functioning single market for roaming services? Should this approach be combined with other options? Answer to Q3 The current model of regulation has protected consumers to some extent on international retail mobile roaming prices for voice and SMS, but it has not achieved much else. It could remain effective, if continued into the future, to achieve an extent of consumer protection on voice and SMS through caps. However, the application of the current model has failed to deliver for consumers with regard to international roaming for mobile data (wholesale prices have fallen, but this has not prevented the application of dissuasively high retail tariffs for mobile data, and it has not prevented the imposition of undue restrictions or conditions by some mobile network operators on the use of mobile data). This is in no small part due to the fact that the current model did not include measures on international retail mobile data roaming and the mobile Internet, and did not include measures to prevent undue restrictions/conditions. Adjustment of the model, notably to include regulation of international retail mobile data roaming, with an explicit requirement in the regulation to the need for this to enable mobile Internet access, seems justified as a first response to an evident failing. The current model of regulation has, however, not (or only very marginally) helped to stimulate competition. Answer to Q4 We do not see how the current model of regulation, or its extension (e.g. a more stringent wholesale mobile data cap, introduction of a retail mobile data cap, ex-ante action against undue restrictions/conditions) would be effective if the goal (as is explicitly specified in Q4) is to achieve a well-functioning single market for roaming services. Wholesale price regulation, and where applicable retail price regulation, are not, in and of themselves, a solution to achieve a single market. Skype February 2011 Page 7

8 If, by contrast, the goal is to achieve a reduction of (wholesale and retail) prices, which is clearly needed for retail mobile data, we believe that the model of regulation has some merits, in that it can directly and predictably reduce retail prices that are deemed to be too high. As had been stated in Section A. above, Skype believes that, in order to achieve the single market goals, to achieve competition, and to achieve genuine socio-economic benefits, it is inescapable that the current model must be extended, as well as combined with several other elements introduced concurrently. B.2 Wholesale and transparency measures only Question 5: Would regulation of wholesale prices charged to MNOs, combined with transparency measures, be effective, efficient and coherent in light of the single market objective? Would the benefits of regulated wholesale rates be passed through to consumers? Answer to Q5 Experience with mobile data in the EU to-date (retail prices far in excess of wholesale cap; international roaming retail prices being an extreme multiple of domestic mobile data prices domestic prices themselves being high; restrictions on the mobile Internet) has shown conclusively that the answer to these two questions is negative. There are no reasons to assume that this would change going forward. Note: We do not understand why the European Commission appears to be suggesting limiting the beneficiaries of wholesale roaming to MNOs. Enabling MVNOs (and new access takers, and essentially anyone discussed below) to arrange their own wholesale roaming seems essential to overcome existing dysfunctions. B.3 Regulation of retail data roaming charges Question 6: Do you consider that retail regulation of data roaming prices is necessary? If not, what are the likely market developments post-june 2012? Question 7: If retail regulation of data roaming prices was necessary, what would be an appropriate model for such regulation? Skype February 2011 Page 8

9 Answer to Q6 and Q7 Capping international retail mobile data roaming prices is necessary as a direct and predictable consumer protection measure at the latest as of 1 July 2012, combined with an explicit requirement in the regulation to the need for this to enable mobile Internet access, the implementation of wholesale regulation and structural measures, and pending the effects of structural measures. Skype advocates an approach combining wholesale caps and retail caps, in the following manner, which represents a substantial variation of the current per-volume wholesale-only approach: a) The setting of international wholesale roaming mobile data caps in a manner (wholesale price structure, wholesale prices) which ensures that retail flat-rate offers (including mobile Internet offers) can emerge, at non-dissuasive retail price levels for a level of usage which corresponds to the evolving day-to-day requirements of end-users in today s EU and in the EU of the coming several years. A possible model (which could exist in parallel with other models) would be for the wholesale price to be tied to an individual roaming user s usage, but for it not to be expressed per kilobyte or per megabyte, but to require wholesale-level daily/weekly/monthly offers, with generous (not necessarily unlimited) bandwidth caps for the relevant day/week/month period, corresponding to the evolving dayto-day requirements of end-users in today s EU and in the EU of the coming several years, taking explicit account of end-users requirements for mobile Internet access. A system to measure and communicate the volume of individual users usage to the wholesale purchaser, and which can be immediately presented onwards to the roaming user, should be included in this model. b) The setting of international retail mobile roaming data caps as a safeguard measure, with an explicit requirement in the regulation to the need for this to enable mobile Internet access, to ensure that the objectives of a) are effectively achieved and hopefully by far exceeded. This is essential given the increasing importance of the Internet for today s end-users. B.4 Approaches based on prices and conditions similar to those prevailing in the domestic markets Question 8: Please indicate the advantages and disadvantages of these approaches, relative to each other and to the current model of price capping, considering also competition aspects such as the possibility of margin squeeze? Skype February 2011 Page 9

10 Answer to Q8 Roaming prices based on domestic prices in the home market Whilst this may offer improved transparency to consumers (although it involves challenges relating to the variety of mobile packages that exist or relating to averaging which would then again cause a loss of transparency), it would not protect consumers from undue restrictions/conditions, it would not protect consumers from unduly high prices, it would - on present evidence of what drives consumers choice of operator - most likely not enhance competition (the same set of players would be active on the market, with broadly the same incentives), and would not create a single market. Roaming prices based on domestic prices in the visited country We fail to see how this would protect consumers from undue restrictions/conditions, protect consumers from unduly high prices, enhance competition (the same set of players would be active on the market, with broadly the same incentives), or create a single market. B.5 Separate sale of roaming services - decoupling of roaming from mobile services bundles Question 9: In general, would these decoupling approaches be effective in terms of stimulating greater competition for roaming services? Would all customer segments be able to benefit? Would such increased competition be sufficient to give consumers an effective choice of roaming services at (near) domestic prices? Question 10: Would such 'structural' approaches be efficient? What are the technical implementation issues associated with these approaches? Answer to Q9 Overall, we are sceptical of the likely effectiveness of the suggested decoupling approaches, as is discussed below. Carrier Pre-select (CPS) in the domestic market We understand that Switzerland and some Middle Eastern countries have implemented CS or CPS for outbound international mobile voice calls (but not roaming) for many years, but in the absence of genuine cost-orientation obligations or effective implementation, the effect has been limited. Skype February 2011 Page 10

11 We do not understand why the European Commission appears to be suggesting limiting the beneficiaries of CS/CPS for roaming to MNOs/MVNOs, as this would restrict competition to a small group of domestic players, being precisely those players which have not vigorously competed for international roaming customers in the past (or in the case of many MVNOs, not been allowed by their host network operator and by historic industry arrangements to arrange their own wholesale roaming). We do note that the European Commission suggests an obligation to provide MVNOs with wholesale roaming access, which is intrinsically welcome, although still restricts access to a specific category of domestic market participants. Also on present evidence of what drives consumers choice of operator it seems unlikely that there would be great customer interest in contracting with an additional provider just for roaming, especially if the offers are likely not to be very aggressive as a result of being limited to being available only from existing domestic MNOs/MVNOs. Carrier Pre-select (CPS) in the visited network and Choose operator at the border (based on local retail price) Similar to the fact that, today, only the most sophisticated end-users choose to override the steering by their SIM card to a particular roaming bilateral, we doubt that end-users would be inclined to shop around when in the visited country (between providers they might not know) in this model, and they could even be overwhelmed by choices (or would the home operator be entitled to restrict choice?). Providers would have to engage in deploying widespread aggressive advertising, which likely would siphon away cash for actual operations of these providers. Answer to Q10 Irrespective of our doubts about effectiveness of these approaches, we believe that technical implementation of these approaches is readily feasible, and that the European Commission should be very wary of any claims made to the contrary. Such claims were made every time an access obligation was mandated in the telecommunications sector, and issues or alleged issues were overcome. B.6 Spot-trading of wholesale roaming Question 11: How feasible/efficient is the establishment of a spot trading market for wholesale roaming? Would this approach lead to competitive wholesale rates? How effective would this approach be in terms of achieving competitive retail rates? No comment. Skype February 2011 Page 11

12 B.7 Access-based approaches Question 12: For each of options (i) to (iii) above please indicate whether such approaches can stimulate additional competition for roaming services. In order to achieve significant reductions in roaming prices do you consider that these 'accessbased' approaches may need to be combined with other forms of wholesale price regulation (i.e. between MNOs) and/or retail price regulation? Please explain. Answer to Q12 Option (i): Mandated wholesale roaming access for MVNOs, in visited networks This option could stimulate some increased competition, but we do not understand why the European Commission appears to be suggesting limiting the beneficiaries to MVNOs, as this would likely restrict competition to a small group of domestic players. Also, in this model, the host MNO may (still) be in a position to exercise pressure on the MVNOs not to compete vigorously across all market segments (domestic, international outbound, roaming, SMS, data), as has often been the case (MVNOs have often been restricted to niches, or have been allowed to compete strongly on only one component of a cluster/bundle, against less attractive wholesale conditions or even restrictions on other components). Option (ii): Host network wholesale roaming cap On a stand-alone basis, all this option adds is the removal of certain commercial behaviour engaged in by some host MNOs towards their MVNOs. We do not believe that it would achieve substantial change compared to the status-quo. As an incremental add-on to option (i), it would stimulate some increased competition, but we do not believe that it would be strongly transformational, notably due to the restriction of competition to a small group of domestic players. Option (iii): Mandating full MVNO access in the home market for all services This option, if well-defined and well-executed, could strongly stimulate additional competition, for roaming services and beyond. Given the experience with MVNO access to-date in most EU Member States, this form of mandated wholesale mobile access should be defined in such a manner that it ensures that the access takers enjoy freedom to define their own product and pricing characteristics, including their own international roaming propositions (i.e. a greater level of autonomy than enjoyed by essentially all MVNOs as they are known today). This may entail making explicit allowance for purchasing not only mobile access and call origination as defined in Skype February 2011 Page 12

13 the 2003 edition of the European Commission s Recommendation on Relevant Markets, but also raw wholesale mobile network capacity (e.g. akin to fit for purpose wholesale broadband access, i.e. a Layer 2 transmission service with specified QoS parameters) without it being presented as, or broken down into, voice calls, SMS messages, or mobile Internet access. As is indicated in Section A. above (which provides a more extensive description), we believe that an access-based approach is necessary, but is only one piece of the puzzle, and we advocate this to be part of a combination involving also: profound spectrum reform, radically reduced wholesale mobile data roaming caps, the introduction of retail mobile data caps, with an explicit requirement in the regulation to the need for this to enable mobile Internet access, and EC guidance on the ex-ante application of the framework principles on the open Internet. We also noted in Section A. above that this does not exclude the addition of further options. B.7 Medium to long term view Question 13: In the medium to long term, markets and technologies will possibly evolve to the point where roaming services can be provided by different competing technologies. Such developments seem to be unlikely to be sufficient to eliminate or minimize roaming problems within 5 years. Do respondents share this view? Please explain. Question 14: Do respondents think that the Commission should pursue measures to accelerate these developments (e.g. to encourage the massive deployment of interconnected Wifi networks? What other measures could be considered? What will the impact be of the transition to an 'all IP' environment on roaming services? Answer to Q13 We agree with the analysis and with each of the suggestions made by the European Commission in the section on WiFi (encouragement through national broadband plans, collective spectrum use, single identification code). We also agree with the indication in Q13 that such developments are unlikely to be sufficient to eliminate or minimise roaming problems for the foreseeable future. With regard to all IP mobile data networks, we agree with the comments made by the European Commission, notably regarding the need for a competitively priced data roaming service, with the important caveat that there is no intrinsic guarantee that all IP mobile data networks will be operated on an open and non-discriminatory basis, will provide access to the open Internet, and will not be subject to deliberate contractual and technical restrictions at wholesale and/or retail level. In fact, the mobile network operators and their equipment suppliers are giving numerous Skype February 2011 Page 13

14 indications exactly to the contrary. Restrictions specifically to prevent the use of other technologies are widespread (see comments in Section A. above) and continue despite the very clear statement in Recital 40 of the Roaming Regulation (Regulation (EC) No 544/2009) that ( ) there should be no obstacles to the emergence of applications or technologies which can be a substitute for, or alternative to, roaming services, such as WiFi, Voice over Internet Protocol (VoIP) and Instant Messaging services. We therefore reemphasise that, in addition to work relating to international mobile roaming, and in addition to the need for reiterating this Recital in the form an Article in the next Roaming Regulation, in such a manner that it requires action against restrictions by national regulatory authorities, it is essential that the European Commission provides clear guidance on the ex-ante principles underpinning the protection of the open Internet, i.e.: (i) definition of Internet access (evolving over time), (ii) recommendation that all end-users should be able to have access to the entirety of the global best-efforts Internet (fixed and mobile), and (iii) specifying the scope of reasonable traffic management, as exceptional, relevant, proportional, efficient, transparent and non-discriminatory. Answer to Q14 Skype would support European Commission measures to accelerate deployment of WiFi networks, and even a single identification code (although SkypeID s can already be used to access over hotspots and access points). We believe that one of the most important possible initiatives in this regard is to enable unlicensed and shared spectrum in lower bands (<1 GHz, e.g. TV White Spaces) and in higher bands (e.g. 5 GHz), whilst actively envisaging other bands for each of unlicensed and shared use. As regards other measures, please refer to the list of measures we advocate in Section A. above. With regard to all IP mobile networks, please see also our response to Q13 above, and our response to the European Commission s Digital Dividend consultation 4, in which we discuss other measures relating to all IP mobile networks specifically (going beyond the pure spectrum-related aspects). B.8 Specific issues We have no comments on Questions ns/2009_digitaldividend/replies/107_skype.pdf Skype February 2011 Page 14

15 Should you require any additional information with regard to the contents of this response, please do not hesitate to contact us. We would be happy to engage with you to discuss in more depth the points raised here. Yours faithfully, Jean-Jacques Sahel Skype Director, Government and Regulatory Affairs Europe SkypeID: jsahel Skype February 2011 Page 15