W15615

BHARTI AIRTEL’S “AIRTEL ZERO”: VIOLATION OF NET NEUTRALITY?1

Susmi Routray, Boishampayan Chatterjee and Gunjan Malhotra wrote this case solely to provide material for class discussion. The
authors do not intend to illustrate either effective or ineffective handling of a managerial situation. The authors may have disguised
certain names and other identifying information to protect confidentiality.

This publication may not be transmitted, photocopied, digitized or otherwise reproduced in any form or by any means without the
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Copyright © 2015, Richard Ivey School of Business Foundation Version: 2015-12-23

On April 6, 2015, Bharti Airtel Ltd. (Airtel) — India’s largest telecom provider and a leading global
telecommunications company — launched Airtel Zero.2 According to Airtel, Airtel Zero was an “open
marketing platform that will allow customers to access mobile applications at zero data charges.”3 This
platform was beneficial for application developers, as customers would be able to access applications free
of cost. Immediately after its launch, the platform was subjected to severe public criticism on the grounds
of violating the net neutrality principle, which advocated that there should be no differentiation among
over-the-top (OTT) players and that all legal content should be available to customers without any form
of prioritization. Subsequently, Flipkart — one of the most prominent Indian e-commerce companies —
pulled out of the platform, stating that Airtel Zero violated net neutrality.4 Was Airtel Zero a potential
threat to net neutrality? With the impending decision of the government of India on the regulatory
framework for OTT services, would Airtel Zero stand out as a viable platform?

THE TELECOM INDUSTRY IN INDIA

In the previous decade, India had witnessed tremendous growth in the telecom sector. In this sector, India
was the second-largest market in the world. The success of the telecom sector in India was attributed to
the liberal policies of the government of India and the deregulation of foreign direct investment, low
tariffs and falling handset prices. This sector had created employment and had become the fastest-
growing sector in the country.5

The Mobile Internet Market in India

There had been a surge in the mobile Internet market in recent years. According to a report by the Groupe
Speciale Mobile Association (GSMA) in collaboration with the Boston Consulting Group, the Indian
mobile sector was expected to contribute US$400 billion to India’s gross domestic product. This sector
was forecasted to generate approximately 4.1 million additional jobs by 2020.6 As per the Telecom
Regulatory Authority of India (TRAI) report for 2014, there were around 970 million mobile subscribers
in India (see Exhibit 1). Among the dominant players in the telecom industry, Airtel led the market with a

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22.4 per cent market share in terms of mobile subscriber base, followed by other major players such as
Vodafone with 19 per cent, Idea Cellular with 16 per cent and Reliance Communications with 11 per
cent7 (see Exhibit 2).

According to another TRAI report, by the end of September 2014, there were 254.4 million Internet
subscribers.8 Further, the number of broadband connections had increased from 13.81 million in 20129 to
75.73 million in September 2014.10 It was anticipated that by June 2015, there would be 213 million
mobile Internet users. The Internet and Mobile Association of India and the Indian Market Research
Bureau’s international “Mobile Internet in India” report from January 2014 projected a 23 per cent rise
over a six-month period.11 A Microsoft report indicated that India would emerge as a leading player by
2025, with 700 million Internet users, which would be approximately 14.9 per cent of all global Internet
users.12 Further, the mobile application market had been projected to reach US$100 billion at a compound
annual growth rate (CAGR) of 70.4 per cent during 2012–2015.13 The availability of cheaper smartphones
and increased mobile connections would further encourage the growth of this market. The graph in
Exhibit 3 shows the growth of smartphone subscribers in India from 2010 to 2014. According to a report
by the International Data Corporation, total mobile services market revenue in India was predicted to
reach US$37 billion in 2017.14 In addition, the GSMA report predicted that by 2020, two out of every
three mobile connections would be through smartphones. Moreover, it was expected in the report that
India would become the fourth-largest smartphone market in the world.15

Over-the-Top Applications and Services

Since the inception of the Internet in 1980, it had grown in scope and size and had been providing a whole
range of services to telecom subscribers in India. It provided applications and services in entertainment,
information, education and e-commerce. Content provided over mobile phones was collectively known as
OTT applications and services. OTTs used telecom service provider (TSP) networks to access the Internet
and provided applications and services to telecom subscribers. OTT applications were broadly classified
as messaging and voice services such as Skype, Viber, Google Talk, hike messenger, WhatsApp and
Facebook; e-commerce sites like Amazon and Flipkart; and audio/visual content providers like
YouTube.16 These OTT applications generated revenues for TSPs through data usage by subscribers. In
India, OTT applications did not pay anything additional to TSPs for the use of their infrastructure. The
advancement of mobile technology — resulting in increased data storage and processing power, user-
friendly and customizable interfaces, and high data rate connectivity provided by TSPs — had made OTT
applications and services very popular. Moreover, increased smartphone penetration had enabled further
growth of the OTT market. OTT applications and services would impact the revenue of three real-time
application verticals — video, voice and messaging of TSPs.17

Impact of OTTs on the Traditional Revenue Stream of TSPs

In India, the traditional revenue-generation models for telecom operators were voice and messaging
services. In the past few years, value-added services (VASs) had also become an important means of
revenue generation. Among the various VASs, major services included interactive Short Message Service
(SMS) such as for information on sports or weather, as well as ringtones and colour ringback tones. A
TRAI report stated that the growth in VASs contributed around 10–14 per cent of the total revenue of
mobile TSPs. Moreover, SMS contributed greatly in the revenue generation of mobile VASs in India.
This rapid growth was a result of a reduction in the cost of VASs, upgrades in handset quality, and a
lower age profile of mobile users.18

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Innovative OTT applications and services were increasingly becoming a challenge for traditional TSP
services — mainly voice and messaging. These OTT applications and services had impacted the
traditional revenue streams of TSPs. According to TRAI’s consultation paper published in March 2015,
worldwide annual SMS traffic was around 8.16 trillion messages in 2013, while that for OTT/app players
was 18.3 trillion messages.19 In the recent past, there had been a decline in SMS traffic for telecom
operators (see Exhibit 4). For example, the revenue from SMS and VASs out of the total mobile revenue
for Airtel had dropped by 3.5 percentage points from 9.1 per cent to 5.6 per cent between 2012–13 and
2013–14, while data revenue had increased by 4.6 percentage points.20 A similar trend had been observed
for Vodafone as well, whose messaging revenue had fallen by 12.7 per cent while data revenue had
grown by 41 per cent over the same time period (see Exhibit 5).21 Further, subscribers were shifting to
OTT applications and services, such as WhatsApp and hike messenger, which embedded text messages
with audio and video. These applications were free and subscribers only paid for data usage. This
phenomenon had led to a decrease in the messaging traffic of TSPs by 18 per cent — from 5,346 million
messages in June 2013 to 4,367 million in June 2014. This decline in SMS revenue had an implication of
approximately ₹37–40 billion22 per annum for TSPs.23 Further, the TRAI report anticipated that voice
telephony might migrate telecom completely to Voice over Internet Protocol (VoIP). In India, this
migration might take time due to low Internet penetration. Most mobile subscribers were still using 2G,
which resulted in quality issues for VoIP. Moreover, the calling rates had been very low and competitive
in India, so subscribers might not shift to VoIP in the near future. However, since international calling
rates were high, international calling might get impacted, which might not affect the revenue of TSPs
significantly, as it would be less than 10 per cent of the total revenue.24

Traffic congestion due to OTT applications and services had been leading to increased infrastructure
demand on Internet service providers (ISPs) and TSPs. Moreover, cloud computing had changed the way
people used handheld devices. Cloud computing had brought about newer OTT applications and services
such as Dropbox and Google Drive, which enabled users to upload data to different storage areas that
would be accessible via the Internet. This uploading and downloading of data and mobile application
usage exerted pressure on the infrastructure of TSPs, thereby leading to congestion.25 To ease this
congestion, TSPs had to make huge investments in infrastructure.

In a way, the advancements of OTT applications and services had become paradoxical for TSPs. On one
hand, the advancements enabled them to increase their revenue due to increased data usage, but on the
other hand, these OTT applications and services were slowly eating into their traditional source of
revenue. In order to cope with this scenario, TSPs were coming up with new service offerings.

THE EVOLUTION OF AIRTEL ZERO

Airtel, a telecom giant in India with operations in 20 countries across Asia and Africa, was headquartered
in New Delhi, India. The company was launched on July 7, 1995, as a public limited company.26 It was
listed on the Bombay Stock Exchange and the National Stock Exchange of India. In terms of subscriber
base, Airtel ranked fourth amongst global telecommunication companies.27 In India, Airtel’s product
offerings included 2G, 3G and 4G wireless services, high-speed digital subscriber line broadband, fixed
line services, mobile commerce, Internet Protocol television, Direct-to-Home television and enterprise
services including national and international long-distance services to carriers.28 As of February 2015,
Airtel reportedly had over 319 million customers across its operations.29

The company launched Airtel Zero on April 6, 2015. According to the company, this would enable
application developers, big or small, to provide mobile application services free to its customers. Further,
it would help to increase and revive the interest of existing customers and attract potential new ones.30

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Further, the platform was expected to become popular with customers, as they would be able to access
mobile applications at zero data charges and at the same time would be encouraged to try out new
applications which would be made available free of cost. Srinivasan Gopalan, director of consumer
business at Airtel, said, “Airtel Zero is free for each and every customer and offers the same speed to all.
Further, it charges the same amount to each company for data without any discrimination.”31 Airtel
believed that Airtel Zero would be a win–win platform that would benefit not only its customers but also
the application developers registered on its platform. Customers would enjoy free data access to mobile
applications signed up with Airtel Zero, as data charges would be borne by application providers. This
would empower small and big companies in India to acquire more customers by providing them with a
level playing field. The platform would contribute towards the national agenda of the government of India
with a focus on digital inclusion and the “Make in India” campaign.32

Currently, small-time developers and start-ups spent money on digital marketing and advertising. If these
application developers would register with the Airtel Zero platform, customers would be provided with
free access to these applications. Thereafter, Airtel would provide information to its customers about
these free applications that would enable them to enjoy these applications at zero data charges. Customers
would be able to use these applications even if their mobile balance became zero. This process would
enable developers to reach out to their customers at a lower cost than traditional marketing channels. As
Airtel Zero was proposed to be an effective marketing strategy for OTT application developers, Gopalan
stated, “We invite all application developers to register their interest in ‘Airtel Zero’ and see the
compelling reach it can deliver to Airtel’s 200 million plus customers across India.”33

AIRTEL ZERO AND NET NEUTRALITY: A DEBATE

Net neutrality or open Internet advocated that a consumer should be able to access any legal content on
the Internet. However, ISPs would not be able to prioritize any content or web site; they would not be
allowed to provide faster Internet connections to certain content or block any content. In other words, all
web sites had equal priority. Since the time of its inception in the 1980s, the Internet had generally been
working on the principle of net neutrality. This had also been one of the most important reasons for its
exponential growth over the years. TSPs used the same principle of telephony on the Internet and had
become ISPs by providing unrestricted and uninterrupted Internet services.34

Was Airtel Zero Violating Net Neutrality?

Ever since its launch, Airtel Zero had been under scrutiny over whether it violated the principle of net
neutrality. After the launch of Airtel Zero, online campaigns alleged that the platform violated the net
neutrality principle. One such campaign, Save the Internet, claimed that Airtel Zero would narrow down
consumers’ Internet choices by grouping carriers (TSPs) with Internet applications and services.35 Airtel
Zero was criticized because the very nature of the platform prioritized certain content or web sites on the
Internet.36 Consumers would get free access only to those web sites that were registered with Airtel,
thereby leading to differentiation in price and Internet speed among various sites. For net neutrality, it was
fundamental that there be zero discrimination in accessing any legal content on any web site, and Airtel
Zero appeared to violate this principle. Platforms like Airtel Zero meant that TSPs would be in a position
to ensure that certain sites were faster and more expensive than others. This would imply that end users
would lose the freedom to visit any legal web site by merely paying a flat uniform tariff to TSPs.

In support of net neutrality, Flipkart walked away from its decision to tie up with Airtel Zero to provide
free data services to customers,37 citing violation of net neutrality38 (see Exhibit 6).

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Airtel’s Response to the Net Neutrality Issue

In response to Flipkart’s announcement, Airtel said, “The statement made by Flipkart regarding their
decision not to offer toll free data service to their customers is consistent with our stand that Airtel Zero is
not a tariff proposition.”39 According to Airtel, it would be a platform where any application provider
would provide its services free of cost to its customers. Thus, it was net neutral, as it did not discriminate
on content and tariffs and also lowered the cost of Internet usage. However, the online campaign Save the
Internet argued that Airtel violated the basic principle of net neutrality, as it differentiated on pricing and
Internet speed among web sites. As an example they cited how, during the 2010 Indian Premier League,
Airtel prioritized YouTube streaming and provided users with faster access by raising the Internet speed
to two million bits per second.40

The Cellular Operators Association of India (COAI), a representative of the Global System for Mobile
Communications telecom companies, which included Airtel, Vodafone and Idea Cellular, had confirmed
that it supported net neutrality. In view of this, COAI said that it was willing to discuss the prevalence of
net neutrality and also simultaneously would create a favourable business environment within which the
telecom industry could operate in India.41

AIRTEL ZERO AND COMPETING PLATFORMS

Airtel Zero was not the only platform offering services at zero data charges. Another such platform was
Internet.org, developed by Facebook and launched on August 20, 2013.42 The platform provided free
access to subscribers of Reliance Communications. This included Wikipedia, WikiHow, Facebook,
Facebook Messenger and various other web sites and e-commerce sites. Facebook had partnered with six
telecom companies — namely, Samsung, Ericsson, MediaTek, Nokia, Opera and Qualcomm. Using
Opera Mini or UC Browser, Reliance subscribers would log onto Internet.org. These browsers were
preloaded on many low-end smartphones. Subscribers would be charged for data usage if they were not
partners of Internet.org.43

According to Facebook, the idea behind the platform was to provide Internet access to the “two-thirds of
the world that does not have internet access.”44 The free mobile platform had been launched by
Internet.org in developing countries such as India, Ghana, Colombia, Kenya, Tanzania, Indonesia and
Zambia. This application enabled its customers to use mobile applications such as AccuWeather,
Facebook and Google free of charge.45 In India, Internet.org had come under severe criticism from OTT
players, start-ups and the general public for violating net neutrality. This had led to companies such as
Cleartrip, New Delhi Television and The Times Group pulling out from the platform.46

This raised a big question — were these platforms violating net neutrality? Given that both sides had put
forward their views on this, the future of these platforms depended on the government of India’s decision
on net neutrality. Therefore, it became important to understand the perspective of other countries on net
neutrality and the solutions adopted by them.

GLOBAL PERSPECTIVES ON NET NEUTRALITY

The regulation of OTT services and issues related to net neutrality had drawn considerable attention
worldwide. The response to net neutrality and the regulation of OTT services by countries had been
mixed. For example, the United States, the European Union and Japan were more in favour of net
neutrality and open and non-discriminatory Internet access than countries like China and those in the

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Middle East. In July 2010, Chile became the first nation in the world to protect the principles of net
neutrality in a law. The Chilean general telecommunications law ensured that ISPs would not differentiate
between content, services and applications, and would provide equal access to all.47 However, ISPs were
allowed to offer tiered pricing and different speeds to end users instead of charging a flat fee. Among the
active reformers, the United States had released a new draft of network management rules, wherein the
Federal Communications Commission guiding principles required broadband providers to not block,
throttle or prioritize Internet content and traffic.48

Among European countries, Holland’s net neutrality law had come into effect in January 2013. This law
prohibited any discriminatory practices by network operators in the context of OTT service usage.49 On
June 30, 2015, the European Commission reached an agreement to guarantee an open Internet and
preserve the net neutrality principle. To create an integrated European market, synchronized rules were
adopted across national borders.50 In China, the content provided by regional ISPs was controlled by the
government. Access to the Internet by ISPs was also regulated by the government; basically, ISPs were
owned by the government.51 Japan and Hong Kong followed net neutrality principles, whereas South
Korea’s telecom regulator had announced net neutrality and Internet traffic management guidelines
whereby telecom operators could demand additional charges by customers for VoIP application usage.52

The Indian government would be formulating policies regarding net neutrality. It had formed committees to
understand the implications of net neutrality regulations. It had also been taking opinions from the general
public to understand the issue in its totality. Further, the government had been consulting TSPs and OTT
players to arrive at a decision on whether OTT applications and services must be regulated.

THE ROAD AHEAD FOR AIRTEL ZERO

Voice revenue contributed almost 80 per cent of the overall revenue of TSPs. The January–March Q4 FY
2014 earnings of Airtel and others had confirmed the worst fears of TSPs that their voice revenue was
under pressure due to the growing dominance of OTT operators. Airtel had been impacted the most due to
OTT applications. Airtel’s messaging services had dropped by 4.5 per cent from Q4 FY 2013 to Q4 FY
2014. Its share of VAS revenue out of total mobile services revenue had dropped by almost 3 per cent
from Q3 FY 2013 to Q4 FY 2014. However, its data revenue had increased by almost 4.6 per cent from
Q4 FY 2013 to Q4 FY 2014.53 In this changing scenario, with an increased penetration of mobile Internet,
TSPs were becoming heavily dependent on data revenue. This was corroborated by Airtel’s 2014 Q4
results, wherein data revenue had grown by 70.4 per cent on a yearly basis and voice revenue had been
either static or declining.54 This would not be a financially viable scenario under the current traffic
structure for TSPs, as a one-minute voice call cost around 50 paise,55 whereas an Internet call of the same
duration cost only around four paise.56

The Indian government would make a decision on what regulatory regime it would follow with regard to
OTT services, bearing net neutrality in mind. In light of Airtel’s and Idea Cellular’s Q4 FY 2014 results
wherein voice revenue had declined significantly,57 if the government decided that it was time to regulate
OTT services, how would this impact consumer welfare and market competitiveness? How would Airtel
Zero be impacted? On the other hand, if the preserved net neutrality, would the current Airtel Zero
business model be viable? In either case, what would be the road ahead for the Indian telecom industry in
general and Airtel in particular?

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EXHIBIT 1: GROWTH IN WIRELESS SUBSCRIBER BASE

1200

1000
Subscribers in millions

800

600

400

200

0
Jun‐10 Dec‐10 Jun‐11 Dec‐11 Jun‐12 Dec‐12 Jun‐13 Dec‐13 Jun‐14 Dec‐14
Year

Subscriber base in millions

Source: Compiled by case authors based on statista, “Total Number of Mobile Wireless Subscribers in India from June 2010
to December 2014 (in millions),” www.statista.com/statistics/328003/wireless-subscribers-in-india, accessed August 31,
2015.

EXHIBIT 2: MOBILE SUBSCRIBER BASE (MILLIONS) — DECEMBER 2014

250 217.2
200 178.6
150.5
150
106.2
100 80.3 78.6 66.1
43.6
50
0

Source: Compiled by case authors based on live mint, “India Telecom Subscriber Base Reaches All-Time High at 970
Million,” February 8, 2015, www.livemint.com/Industry/xtzOSEoyOi4BFIqKYpuQeI/Telecom-subscriber-base-reaches-
alltime-high-at-970-million.html, accessed May 4, 2015.

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EXHIBIT 3: NUMBER OF SMARTPHONE SUBSCRIBERS (MILLIONS)

160
140
120 140

100 117

80
86.5
60
40
20 33.2
20.75
0
2010 2011 2012 2013 2014

Smartphone Subscribers (millions)

Source: The Economic Times, “Smartphones Ruled Indian Market in 2010,” December 31, 2010,
http://articles.economictimes.indiatimes.com/2010-12-31/news/27580349_1_smartphones-mobile-phone-makers-sales-of-
mobile-phones, accessed August 17, 2015; TechCrunch, “BRIC-Smartphone-Penetration-1,”
http://techcrunch.com/2013/01/17/nielsen-smartphone-battle-ready-to-rage-in-brazil-russia-india/bric-smartphone-
penetration-1, accessed August 17, 2015; Communities Dominate Brands, “Smartphone Penetration Rates by Country! We
Have Good Data (finally),” December 12, 2011, http://communities-dominate.blogs.com/brands/2011/12/smartphone-
penetration-rates-by-country-we-have-good-data-finally.html, accessed August 17, 2015; A. Rai, “India Had Third Largest
Smartphone Base with 117M Users in 2013; to Grow 45% in 2014: Mary Meeker Report,” techcircle.in, May 29, 2014,
http://techcircle.vccircle.com/2014/05/29/india-had-third-largest-smartphone-base-with-117m-users-in-2013-to-grow-45-in-
2014-mary-meeker-report, accessed August 17, 2015; The Economic Times, “India to Have 651 Million Smartphones, 18.7
Million Tablets by 2019,” February 3, 2015, http://articles.economictimes.indiatimes.com/2015-02-
03/news/58751662_1_networking-index-azmobile-users-population, accessed August 17, 2015.

EXHIBIT 4: USAGE — CHAT VERSUS SMS VERSUS VOICE (PER DAY)

30
25
20
15
10
5
0
Jul‐11
Jul‐12
Jul‐13

SMS per day Chat mins per day Calls per day

Source: Compiled by case authors based on M. Ghosh, “Death of SMS: Indians Are Now Sending Only 2 SMS Per Day!”
Trak.in, September 28, 2013, http://trak.in/tags/business/2013/09/28/death-sms-indians-sending-2-sms-day, accessed
August 17, 2015.

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EXHIBIT 5: BHARTI AIRTEL VAS REVENUE — SMS VS. DATA

12.00

10.00
Percentage Share

8.00

6.00 Messaging and VAS as % of

mobile revenue
4.00
Data as % of mobile
2.00 revenue

0.00

Year

Source: Compiled by case authors based on M. Ghosh, “Death of SMS: Indians Are Now Sending Only 2 SMS per Day!”
Trak.in, September 28, 2013, http://trak.in/tags/business/2013/09/28/death-sms-indians-sending-2-sms-day, accessed
August 17, 2015; S. Mitra, “Telcos’ Revenue Focus Turns to Messaging Apps as SMS Fades,” Business Standard, January
24, 2014, www.business-standard.com/article/companies/telcos-revenue-focus-turns-to-messaging-apps-as-sms-fades-
114012300985_1.html, accessed August 17, 2015.

EXHIBIT 6: OFFICIAL STATEMENT FROM FLIPKART

We at Flipkart have always strongly believed in the concept of net neutrality, for we exist because of the
Internet. Over the past few days, there has been a great amount of debate, both internally and externally,
on the topic of zero rating,58 and we have a deeper understanding of the implications. After reviewing
implications of zero rating deeply, we reached the conclusion that it doesn’t meet our standards of net
neutrality and violates the principles that we stand for. Based on this, we have decided on the following:

 We will be walking away from the ongoing discussions with Airtel for their platform Airtel Zero
 We will be committing ourselves to the larger cause of Net Neutrality in India. We will be internally
discussing over the next few days, the details of actions we will take to support the cause
 We will be working towards ensuring that the spirit of net neutrality is upheld and applied equally to all
companies in India irrespective of the size or the service being offered and there is absolutely no
discrimination whatsoever

Source: NextBigWhat, “Exclusive: Flipkart Pulls Out of Airtel Zero Partnership!” www.nextbigwhat.com/flipkart-airtel-zero-2-
297, accessed August 18, 2015.

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ENDNOTES
1
This case has been written on the basis of published sources only. Consequently, the interpretation and perspectives
presented in the case are not necessarily those of Bharti Airtel Ltd. or any of its employees.
2
Airtel, “Airtel Launches ‘Airtel Zero’: A Win-Win Platform for Customers and Marketers,” www.airtel.in/about-bharti/media-
centre/bharti-airtel-news/corporate/airtel+launches+-+airtel+zero-+a+win-win+platform+for+customers+and+marketers,
accessed April 20, 2015.
3
Ibid.
4
ET tech, “Flipkart Pulls out of Airtel’s Net Neutrality Violating Airtel Zero,” April 14, 2015,
http://tech.economictimes.indiatimes.com/news/internet/flipkart-pulls-out-of-airtel-zero/46916526, accessed April 20, 2015.
5
India Brand Equity Foundation, “Indian Telecom Industry,” www.ibef.org/industry/telecommunications.aspx, accessed May
10, 2015.
6
Shine.com, “Telecom Industry,” http://info.shine.com/industry/telecom/9.html, accessed May 10, 2015.
7
live mint, “India Telecom Subscriber Base Reaches All-Time High at 970 Million,” February 8, 2015,
www.livemint.com/Industry/xtzOSEoyOi4BFIqKYpuQeI/Telecom-subscriber-base-reaches-alltime-high-at-970-million.html,
accessed July 10, 2015.
8
Telecom Regulatory Authority of India, “The Indian Telecom Services Performance Indicators, July–September 2014,”
January 29, 2015, www.trai.gov.in/WriteReadData/PIRReport/Documents/Indicator-Reports29012015.pdf, accessed May
10, 2015.
9
Telecom Regulatory Authority of India, “Annual Report 2011-12,” www.trai.gov.in/WriteReadData/Miscelleneus/Document/
201301150318386780062Annual%20Report%20English%202012.pdf, accessed May 10, 2015.
10
Telecom Regulatory Authority of India, “The Indian Telecom Services Performance Indicators, July–September 2014,” op. cit.
11
Internet and Mobile Association of India, “India to Have 155Mn Mobile Internet Users By March ’14,” January 1, 2014,
www.iamai.in/PRelease_detail.aspx?nid=3240&NMonth=1&NYear=2014, accessed May 5, 2015.
12
India Brand Equity Foundation, “Indian Telecom Industry,” op. cit.
13
Global Exhibition on Services, “IT, ITES and Telecom,” www.gesdelhi.in/it-telecom-sector-exhibition.html, accessed July 7, 2015.
14
India Brand Equity Foundation, “Telecom Sector in India,” www.ibef.org/industry/telecommunications.aspx, accessed
August 28, 2015.
15
Ibid.
16
Telecom Regulatory Authority of India, “Regulatory Framework for Over-the-Top (OTT) Services,” March 27, 2015,
www.trai.gov.in/WriteReaddata/ConsultationPaper/Document/OTT-CP-27032015.pdf, accessed May 6, 2015.
17
Ibid.
18
D&B, “Operational Performance,” https://www.dnb.co.in/IndianTelecomIndustry/OperationalPerformance.asp, accessed
May 10, 2015.
19
Telecom Regulatory Authority of India, “Regulatory Framework for Over-the-Top (OTT) Services,” op. cit.
20
S. Mitra, “Instant Messaging Apps Eat Away SMS Revenue,” Business Standard, June 7, 2014, www.business-
standard.com/article/companies/instant-messaging-apps-eat-away-sms-revenue-114060700740_1.html, accessed May 10, 2015.
21
Ibid.
22
US$1 = ₹63.3662 on July 7, 2015.
23
Telecom Regulatory Authority of India, “Regulatory Framework for Over-the-Top (OTT) Services,” op. cit.
24
Ibid.
25
Ibid.
26
Airtel, “Company Profile,” www.airtel.in/about-bharti/investor-relations/company-profile, accessed April 20, 2015.
27
Ibid.
28
Ibid.
29
Airtel, “Airtel Launches ‘Airtel Zero’: A Win-Win Platform for Customers and Marketers,” op. cit.
30
Ibid.
31
The Financial Express, “Is Airtel Zero Violating Net Neutrality?” April 15, 2015, www.financialexpress.com/article/industry/
tech/is-airtel-zero-violating-net-neutrality/62733, accessed April 21, 2015.
32
Airtel, “Airtel Launches ‘Airtel Zero’: A Win-Win Platform for Customers and Marketers,” op. cit.
33
Ibid.
34
The Times of India, “What Is Net Neutrality and Why It Is Important?” January 20, 2014, http://timesofindia.indiatimes.com/
tech/tech-news/What-is-net-neutrality-and-why-it-is-important/articleshow/29083935.cms, accessed May 6, 2015.
35
The Economic Times, “Airtel’s ‘Pledge’ on Net Neutrality Questioned,” April 20, 2015, http://articles.economictimes.india
times.com/2015-04-20/news/61339500_1_airtel-s-net-neutrality-savetheinternet, accessed May 6, 2015.
36
Quora, “Do You Believe the Email for Clearing Misconceptions around Airtel Zero from Airtel’s CEO?” www.quora.com/
Do-you-believe-the-email-for-clearing-misconceptions-around-Airtel-Zero-from-Airtels-CEO, accessed May 6, 2015.
37
Bennett, Coleman & Co. Ltd., “Flipkart Pulls Out of Airtel’s Net Neutrality Violating Airtel Zero,” The Economic Times,
http://articles.economictimes.indiatimes.com/2015-04-15/news/61180325_1_mukesh-bansal-largest-online-retailer-flipkart-
net-neutrality, accessed May 10, 2015.
38
NextBigWhat, Official Statement from Flipkart, www.nextbigwhat.com/free-whatsapp-facebook-netneutrality-297,
accessed May 10, 2015.
39
“Exclusive: Flipkart Pulls Out of Airtel Zero Partnership!” NextBigWhat, www.nextbigwhat.com/flipkart-airtel-zero-2-297,
accessed August 18, 2015.

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40
Save the Internet, http://savetheinternet.in, accessed May 10, 2015.
41
The Economic Times, “Airtel’s ‘Pledge’ on Net Neutrality Questioned,” op. cit.
42
J. Constine, “Facebook and 6 Phone Companies Launch Internet.org to Bring Affordable Access to Everyone,”
TechCrunch, August 20, 2013, http://techcrunch.com/2013/08/20/facebook-internet-org, accessed May 10, 2015.
43
R. Alwani, “Facebook’s Internet.org Comes to India: Everything You Need to Know,” NDTV Gadgets, February 11, 2015,
http://gadgets.ndtv.com/internet/features/facebooks-internetorg-comes-to-india-everything-you-need-to-know-659505,
accessed May 10, 2015.
44
Internet.org, “About,” https://www.internet.org/about, accessed May 10, 2015.
45
T. Nath, “Internet.org: What It Is and How It Works,” Investopedia, www.investopedia.com/articles/investing/
021315/internetorg-what-it-and-how-it-works.asp#ixzz3YVibjbP9, accessed May 10, 2015.
46
The Indian Express, “Cleartrip, Media Firms Commit to Net Neutrality, Pull Out of Facebook’s Internet.org,” April 18, 2015,
http://indianexpress.com/article/technology/social/net-neutrality-cleartrip-pulls-out-of-facebook-rcom-internet-org, accessed
May 8, 2015.
47
L. Walker, “How Is Net Neutrality Working for the Countries That Have It?” newsweek, September 10, 2014,
www.newsweek.com/how-net-neutrality-working-countries-have-it-269632, accessed July 7, 2015.
48
J. Wakefield, “Net Neutrality Rules Passed by US Regulator,” BBC, February 26, 2015, www.bbc.com/news/technology-
31638528, accessed July 7, 2015.
49
EDRi, “Netherlands: Two Telcos Fined for Net Neutrality Violations,” February 11, 2015, https://edri.org/netherlands-two-
telcos-fined-for-net-neutrality-violations, accessed July 7, 2015.
50
European Commission, “Commission Welcomes Agreement to End Roaming Charges and to Guarantee an Open
Internet,” June 30, 2015, http://europa.eu/rapid/press-release_IP-15-5265_en.htm, accessed July 7, 2015.
51
T. Balek, “China Has Net Neutrality: Government Control of Internet Coming to America Too,” Watchdog Arena, February
23, 2015, http://watchdog.org/201765/china-net-neutrality, accessed July 3, 2015.
52
“Net Neutrality: The Emerging Debate in Asia,” Hogan Lovells Global Media and Communications Quarterly, 2014,
http://viewer.zmags.com/publication/70707126#/70707126/7, accessed July 7, 2015.
53
“OTT Impact Reflects in Idea Cellular, Airtel Fourth Fiscal Quarter 2014 Revenues,” Telecom Lead, May 2, 2014,
www.telecomlead.com/news/ott-impact-reflects-in-idea-cellular-airtel-fourth-fiscal-quarter-2014-revenues-83272-50461,
accessed July 31, 2015.
54
Airtel, “Bharti Airtel Limited – Media Release April 28, 2015,” www.airtel.in/wps/wcm/connect/738a139a-012f-4892-945e-
c8ba2c5b6866/Bharti+Airtel+Limited_Press+Release_March+31-2015.pdf?MOD=AJPERES&ContentCache=NONE,
accessed May 10, 2015.
55
INR₹1 = 100 paise; 1 paise = US$0.0002
56
The Financial Express, “Bharti Airtel Q4 Profit Drops 12.7%; Idea Cellular Net Up by 60%,” April 29, 2015,
www.financialexpress.com/article/companies/bharti-airtel-idea-cellular-numbers-reflect-net-reality-as-voice-revenue-
drops/67761, accessed May 10, 2015.
57
Business Standard, “Idea Cellular, Bharti Airtel Fall Post Q4 Results,” April 29, 2015, www.business-standard.com/
article/markets/idea-cellular-bharti-airtel-fall-post-q4-results-115042900473_1.html, accessed May 10, 2015.
58
The practice of allowing the use of apps free of data charges for the consumer by striking a deal with the telecom operator
was called zero rating. It was widely perceived as a violation of the principle of net neutrality, where all data was treated
equally regardless of its origin.

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