WEBVTT 00:00:00.000 --> 00:00:20.009 36C3 preroll music 00:00:20.009 --> 00:00:26.269 Herald: The next talk is "5G & Net Neutrality". The status of the net 00:00:26.269 --> 00:00:30.869 neutrality reform in Europe and the presenter is Thomas Lohninger from 00:00:30.869 --> 00:00:35.760 epicenter.works and I'm very happy he's here today with us. So please give a big 00:00:35.760 --> 00:00:40.769 applause to Thomas Lohninger. Thank you. 00:00:40.769 --> 00:00:43.559 Applause 00:00:43.559 --> 00:00:50.090 Thomas Lohninger: Hello. Here we go again. Yeah. Hello and welcome, everybody. I'm 00:00:50.090 --> 00:00:56.229 going to talk a little bit about net neutrality. This is not my first talk 00:00:56.229 --> 00:01:00.770 about this issue here at congress. I originally joined the net neutrality 00:01:00.770 --> 00:01:06.170 debate because I really found it to be an important issue. I liked it as a 00:01:06.170 --> 00:01:11.299 philosophical concept of the Internet serving the edges and also because back 00:01:11.299 --> 00:01:15.070 then it was still a very young debate. You could still read up on all the legislation 00:01:15.070 --> 00:01:20.340 around the world because there was so little about it. And a decade later, there 00:01:20.340 --> 00:01:25.150 is more legislation, the debate has moved on a lot. Of course, in the U.S. it has 00:01:25.150 --> 00:01:30.600 been first and foremost after Trump repealed the Obama era rules. And in 00:01:30.600 --> 00:01:35.030 Europe, we feel like we're a little bit stuck in time. And I also want to explain 00:01:35.030 --> 00:01:39.370 where we currently are and where we are heading. So it is an update, but it's also 00:01:39.370 --> 00:01:43.400 an update with little bit of a perspective and might even have a silver 00:01:43.400 --> 00:01:48.700 lining. But before we do that, we first have to go back to the beginning and 00:01:48.700 --> 00:01:53.520 explain what net neutrality is. If you are in the U.S. and you ask anybody serving 00:01:53.520 --> 00:01:57.290 coffee on the train, they will know it. But in Europe, it is still something that 00:01:57.290 --> 00:02:02.760 maybe needs to be explained. In general, net neutrality means that all bits should 00:02:02.760 --> 00:02:07.470 be created equal, that the network should not make distinctions about our data 00:02:07.470 --> 00:02:12.400 packages, how important they are if the checksum is correct. Of course, if to 00:02:12.400 --> 00:02:17.280 check some is correct but also a lot like, is this a valid feature for this 00:02:17.280 --> 00:02:22.950 application? Is this a legal transmission? All of these decisions should not be made 00:02:22.950 --> 00:02:26.890 in the network because they should be made by the end points by the applications on 00:02:26.890 --> 00:02:32.680 either side. The easiest way to understand net neutrality is if you compare it with 00:02:32.680 --> 00:02:38.810 previous global telecommunication networks. In the television system you 00:02:38.810 --> 00:02:42.980 also have a global communication network but it takes a lot of money to actually 00:02:42.980 --> 00:02:47.560 have a voice there, to start a television channel. So you're just consuming, it is 00:02:47.560 --> 00:02:52.750 not a bidirectional network. Telephony allows that, it's a global network system 00:02:52.750 --> 00:02:57.590 but you have a central entity that decides if you're allowed to make that call and 00:02:57.590 --> 00:03:02.470 what the cost of that call per duration will be. That's not the case with the 00:03:02.470 --> 00:03:06.280 Internet. And in a way, net neutrality is just trying to protect these inherent 00:03:06.280 --> 00:03:11.080 principles that the Internet was born with from undue discrimination of network 00:03:11.080 --> 00:03:16.820 operators, of telecom companies, or ISPs. And telecom companies can discriminate or 00:03:16.820 --> 00:03:21.310 interfere with our traffic more or less in two ways. The first is technical by 00:03:21.310 --> 00:03:26.200 prioritizing or throttling certain data packages, also modifying them or blocking 00:03:26.200 --> 00:03:32.830 them completely. And the second way to influence them is by so-called zero rating 00:03:32.830 --> 00:03:37.911 by making certain data more or less expensive, cheaper, or more expensive, or 00:03:37.911 --> 00:03:43.420 as exempting certain applications from your monthly data cap at all. And that all 00:03:43.420 --> 00:03:50.290 creates a system where certain big players have it easier to get rich, to grow, to 00:03:50.290 --> 00:03:56.030 innovate, and others have a harder time to even being noticed or growing. And it can 00:03:56.030 --> 00:04:00.210 also be summarized by the principle of innovation without permission so that you 00:04:00.210 --> 00:04:05.290 can just start a new service, you don't need a license to start an app, 00:04:05.290 --> 00:04:10.580 you don't need to network to support your new functionality. The open layered 00:04:10.580 --> 00:04:17.079 architecture of the internet is protecting this innovative capacity, and that even 00:04:17.079 --> 00:04:25.360 allowed this young man in 2004 to create the Facebook.com in his college dorm. The 00:04:25.360 --> 00:04:30.229 total cost of operating the server in the beginning was 85$ per month. And you would 00:04:30.229 --> 00:04:32.879 ask yourself: "OK but isn't Mark Zuckerberg and Facebook really a horrible 00:04:32.879 --> 00:04:36.790 person, the company?" Yes, they are. That's also why they are against net 00:04:36.790 --> 00:04:43.090 neutrality these days. Facebook is one of the most violating companies around the 00:04:43.090 --> 00:04:49.230 world because their program free basic, is really the opposite of net neutrality. 00:04:49.230 --> 00:04:52.330 What they are doing there is basically creating a walled garden for the global 00:04:52.330 --> 00:04:57.090 south. The most vulnerable people on this planet that do not get the full internet 00:04:57.090 --> 00:05:03.919 access but what they got is a way of being marketed to via their Facebook services, 00:05:03.919 --> 00:05:09.160 of course, without any privacy. And similarly, also, Netflix was once a 00:05:09.160 --> 00:05:14.710 company strongly on our side supporting net neutrality. And then when it was clear 00:05:14.710 --> 00:05:19.730 that Trump would repeal the Obama era net neutrality rules, the Netflix CEO said to 00:05:19.730 --> 00:05:24.380 their shareholders: "Don't worry, we are now big enough that we can survive without 00:05:24.380 --> 00:05:28.690 net neutrality." So inherently, this principle protects the underrepresented 00:05:28.690 --> 00:05:35.020 voices and the small players, the ones that still need to grow. And it is not the 00:05:35.020 --> 00:05:38.850 silver stick that will solve all of the problems from the previous talk to 00:05:38.850 --> 00:05:43.331 problems we have with the big platforms but if we lose net neutrality, we more or 00:05:43.331 --> 00:05:47.389 less freeze the current dominant players forever because it would be really hard 00:05:47.389 --> 00:05:53.970 for anybody else to ever become as big. And so it's all about that right column 00:05:53.970 --> 00:05:59.710 here. Where are we in Europe? In Europe, we started the discussion around net 00:05:59.710 --> 00:06:03.790 neutrality in 2011/12. There were the first non-binding resolutions of the 00:06:03.790 --> 00:06:10.020 parliament calling for net neutrality protections. And it all culminated in 2013 00:06:10.020 --> 00:06:13.759 when the commission released their proposal for really an anti net 00:06:13.759 --> 00:06:19.350 neutrality bill. So we have to turn the ship 180° around to get it back on track. 00:06:19.350 --> 00:06:23.979 And we did that with the savetheinternet.eu campaign, which was 00:06:23.979 --> 00:06:28.670 hosted by big coalition of NGOs all around Europe. And we followed the legislative 00:06:28.670 --> 00:06:33.419 process for two and a half years with seven iterations of that campaign always 00:06:33.419 --> 00:06:38.490 changing our means from faxing to the parliament to making phone calls to just 00:06:38.490 --> 00:06:43.180 mass bombarding the embassies to sending comments to the regulators in the 00:06:43.180 --> 00:06:48.200 consultation period. We also demonstrated in Riga, in Barcelona, in Bonn, in 00:06:48.200 --> 00:06:53.539 Brussels, in Vienna. And at the end we got a net neutrality law. The open internet 00:06:53.539 --> 00:07:00.419 regulation was adopted in 2015 and it was further, then, implemented by the BEREC 00:07:00.419 --> 00:07:04.840 guidelines that are kind of the handbook for the guys who actually have to enforce 00:07:04.840 --> 00:07:09.039 the law, telecom regulators. And telecom regulators will be important in the rest 00:07:09.039 --> 00:07:15.320 of the talk because that's where the action currently lies. And so this was in 00:07:15.320 --> 00:07:20.260 2016. And in January of 2019, we released this report, which was really more 00:07:20.260 --> 00:07:26.610 academic exercise of summarizing everything that has happened since. So 00:07:26.610 --> 00:07:29.511 it's really the one thing you should read if you want to know how a t neutrality 00:07:29.511 --> 00:07:34.289 has played out over the past two and a half years. That's a table of content and 00:07:34.289 --> 00:07:39.720 there's a lot of it in there from analyzing 800 pages of annual reporting, 00:07:39.720 --> 00:07:44.740 going through case law, and looking ahead about 5G. But the most important thing 00:07:44.740 --> 00:07:48.350 was the chapter about zero rating, because that's where the debate currently is 00:07:48.350 --> 00:07:53.620 focused on in Europe. And in order to bring this debate back to a factual basis, 00:07:53.620 --> 00:07:59.420 we actually did a lot of work. With doing a complete survey of all zero rating 00:07:59.420 --> 00:08:04.710 offers in the European economic area. I don't think that anything like this was 00:08:04.710 --> 00:08:11.789 ever done before also because it wasn't easy. We went through 32 countries. So all 00:08:11.789 --> 00:08:15.840 of the European economic area that this law applies to, including Switzerland, 00:08:15.840 --> 00:08:20.810 because we have German speakers in our team, so it was not that hard. That meant 00:08:20.810 --> 00:08:26.660 in total, going through the websites of 225 mobile operators, both those that have 00:08:26.660 --> 00:08:32.140 their own network as well as the virtual ones. And we collected the data with in 00:08:32.140 --> 00:08:37.250 total five people that spoke six languages and worked for over four months on this. 00:08:37.250 --> 00:08:44.279 We found 186 net neutrality violations in the form of zero rating programs. And all 00:08:44.279 --> 00:08:49.079 of that data is openly accessible. It's linked in the report. It's all online in a 00:08:49.079 --> 00:08:55.629 free format and used under a CC BY-SA license, so share alike. 00:08:55.629 --> 00:09:02.699 Applause 00:09:02.699 --> 00:09:06.829 I've given that talk in front of many regulators. You're the first ones to 00:09:06.829 --> 00:09:11.559 applaud. I really like that. And the SA, of course, because we think this data 00:09:11.559 --> 00:09:17.010 should remain free. We can always disagree on the interpretation but at least the 00:09:17.010 --> 00:09:23.270 facts, the data itself should be openly accessible to everybody and scrutinized by 00:09:23.270 --> 00:09:27.679 everybody as well. And I've seen other people actually using that data for 00:09:27.679 --> 00:09:33.720 commercial purposes, which we would even allow but not sharing it back, which is a 00:09:33.720 --> 00:09:39.699 sad thing. So what is in that dataset? You could see this zero-rating is really a big 00:09:39.699 --> 00:09:45.129 problem. All but two European countries, you have these problems. Finland doesn't 00:09:45.129 --> 00:09:49.160 have that problem because they don't have data caps anymore. If you buy a SIM card 00:09:49.160 --> 00:09:53.699 in Finland, you'll get a flat rate. The only distinction there is the speed, the 00:09:53.699 --> 00:09:58.649 bandwidth that is available to you. But you know, I have no data caps at all and 00:09:58.649 --> 00:10:02.950 Bulgaria also doesn't have zero-rating. If we look at the application side and that's 00:10:02.950 --> 00:10:08.420 actually the very interesting takeaway for you. These are the applications that most 00:10:08.420 --> 00:10:15.050 profit from zero-rating. So WhatsApp leads before 50 zero-rating deals in Europe. And 00:10:15.050 --> 00:10:20.339 the second to follow is Facebook and also Facebook messenger in there. In total, 00:10:20.339 --> 00:10:24.959 many of these companies that profit are from the U.S., only 3 European 00:10:24.959 --> 00:10:31.179 applications are actually in the top 20 of zero-rating. And that is the overall 00:10:31.179 --> 00:10:38.360 number and there we just looked at the geographical home of the applications in 00:10:38.360 --> 00:10:43.330 the classical zero-rating programs. You know, the ones where you have a youth 00:10:43.330 --> 00:10:50.100 tariff in Portugal and you can pick either WhatsApp or Telegram or you have YouTube 00:10:50.100 --> 00:10:55.189 is for free. Some ISP is actually do that. And if you just look at these close 00:10:55.189 --> 00:11:00.339 programs of only have hand selected applications, the majority of the apps are 00:11:00.339 --> 00:11:04.829 from the U.S., of course, the big incumbents. But there is also around a 00:11:04.829 --> 00:11:11.310 third of applications which are of zero- rating programs which are open. Open 00:11:11.310 --> 00:11:16.269 programs allow other applications to join. Think of StreamOn here in Germany or 00:11:16.269 --> 00:11:21.879 Vodafone Pass or smartnet in Portugal. These programs are actually trying to 00:11:21.879 --> 00:11:26.739 balance the scale a little bit. They are actually trying to learn from our critique 00:11:26.739 --> 00:11:32.970 and allow other applications to join. And then if we add those to statistics, we 00:11:32.970 --> 00:11:37.170 see that the majority of apps are suddenly from the same country where the internet 00:11:37.170 --> 00:11:40.790 service is offered. All of these local radio stations in Germany, for some 00:11:40.790 --> 00:11:44.769 reason, join StreamOn in order to be exempt from the data volume, the 00:11:44.769 --> 00:11:49.569 ridiculously low data volume from Deutsche Telekom. And then into second place is 00:11:49.569 --> 00:11:54.420 still have the U.S. and most interestingly, the European economic area. 00:11:54.420 --> 00:12:00.670 So apps from other EU countries are really down below. So one could easily make the 00:12:00.670 --> 00:12:05.060 interpretation of that data that we actually create new barriers for cross- 00:12:05.060 --> 00:12:10.779 border provisioning of services in the European digital single market. And if you 00:12:10.779 --> 00:12:17.109 then just count, how many of these zero- rating programs does an app usually join. 00:12:17.109 --> 00:12:21.149 You have a stark pick fit one to three and then it drastically goes down until you 00:12:21.149 --> 00:12:26.570 have the 31 - 52 column at the right, which is the top 20. So there is an 00:12:26.570 --> 00:12:30.600 inherent difficulty to actually sign up to these so-called open nondiscriminatory 00:12:30.600 --> 00:12:36.459 zero-rating programs. What Europe has created here is actually another reason 00:12:36.459 --> 00:12:40.790 why it will be difficult for the European internet industry to be competitive 00:12:40.790 --> 00:12:46.360 because these are all new entry barriers into markets in other EU countries. And we 00:12:46.360 --> 00:12:51.639 really have to explain this to the regulators. And if you just go and take the 00:12:51.639 --> 00:12:55.059 perspective of an application, you want to join a zero-rating program, what do you 00:12:55.059 --> 00:12:59.929 have to do? First, you have to find out that it even exists. We did that mapping 00:12:59.929 --> 00:13:04.639 because we didn't know. And there is no agency that also sells that data. So 00:13:04.639 --> 00:13:07.529 obtaining knowledge about the programs that you might want to join because you 00:13:07.529 --> 00:13:12.990 might want to offer a competitive service to people in that country of that ISP is 00:13:12.990 --> 00:13:17.759 the first step. And then secondly, you have to request the documents, sign an NDA 00:13:17.759 --> 00:13:22.309 even, to even find out how the open Internet works with this mobile operators. 00:13:22.309 --> 00:13:26.649 Third, you have to read the contract for which for many start-ups is already a 00:13:26.649 --> 00:13:31.359 problem. Sign it and prepare for the liability because you are liable for 00:13:31.359 --> 00:13:37.029 wrongfully billed data volume, which can be really problematic. If your app is 00:13:37.029 --> 00:13:43.619 producing a lot of data or widely used by certain people. The technical aspect that 00:13:43.619 --> 00:13:47.819 comes into play here is that of course you are then responsible for providing 00:13:47.819 --> 00:13:53.559 identification criteria. If suddenly your data packages need to be counted 00:13:53.559 --> 00:13:58.949 differently, go against not a general data volume but an application specific volume 00:13:58.949 --> 00:14:03.569 per month or are completely exempt from the data cap. Then you, in order to make 00:14:03.569 --> 00:14:07.850 that assessment, need to identify those data packages, which of course only works 00:14:07.850 --> 00:14:13.439 with deep packet inspection in most cases. In some cases, you also have to modify 00:14:13.439 --> 00:14:19.879 your service in order to even enter into that deal. Spotify in Germany with 00:14:19.879 --> 00:14:24.940 StreamOn only wanted their premium customers to benefit from the zero-rating. 00:14:24.940 --> 00:14:29.459 And they tried to separate the ad-based free version of the Spotify program from 00:14:29.459 --> 00:14:34.569 the premium customers that are paying. They tried for four months. Then they gave 00:14:34.569 --> 00:14:39.449 up. So the business decision of that app provider was directly affected by these 00:14:39.449 --> 00:14:45.439 zero-rating programs. Next, whenever you make a change to your own service or 00:14:45.439 --> 00:14:49.949 infrastructure, you change your CDN provider or whatever you have to give 30 00:14:49.949 --> 00:14:56.629 days prior notice to the ISP so that they can change their DPI equipment to adopt 00:14:56.629 --> 00:15:01.799 this change, which of course is a big hindrance for innovation and in some 00:15:01.799 --> 00:15:06.490 contracts that we've analyzed, it also includes giving access to beta versions of 00:15:06.490 --> 00:15:10.959 your own app. And lastly, in the case of Vodafone, you also have to sign and 00:15:10.959 --> 00:15:17.730 execute marketing agreement so they want to advertise with your app. So there is a 00:15:17.730 --> 00:15:22.350 lot of hoops to jump through in order to be admitted into one of these zero-rating 00:15:22.350 --> 00:15:26.100 programs. So you'd think at least they'd do a lot of effort on the telco side to 00:15:26.100 --> 00:15:31.519 make it easier for you. So for this survey, we actually created a fake 00:15:31.519 --> 00:15:36.569 application and we tried to apply to zero- rating programs. We said "Hello. We are a 00:15:36.569 --> 00:15:40.569 student group. We are working out of a garage. We have that cool app. We want to 00:15:40.569 --> 00:15:44.119 join your program." And we just counted the duration until we got a response. In 00:15:44.119 --> 00:15:49.649 two cases we got a response within a day, in five cases we got a response within a 00:15:49.649 --> 00:15:54.569 week, in one case within a month, and in half of the cases we never got a response 00:15:54.569 --> 00:16:00.220 at all - so not after three months, they never got back to us. So that truly shows 00:16:00.220 --> 00:16:04.499 that there is a big problem with these open programs. And I'm going to soon show 00:16:04.499 --> 00:16:10.549 you how the regulators have reacted to this report in their reform. But another 00:16:10.549 --> 00:16:15.009 more general thing is speed testing because in Europe, net neutrality also 00:16:15.009 --> 00:16:21.730 brought us the right to contractually agreed speeds, for our Internet access. In no 00:16:21.730 --> 00:16:26.830 other area and economy, You would buy up to 8 apples for 5€. But in Internet, for 00:16:26.830 --> 00:16:32.499 some reason, that's the case. And so the European Parliament was keen to adopt 00:16:32.499 --> 00:16:37.079 rules that were giving each and every consumer in their contract at a minimum, 00:16:37.079 --> 00:16:41.999 an average and the maximum speed that an ISP has to deliver. But how do you then 00:16:41.999 --> 00:16:45.629 measure the speed ? Speedtest.net is really not a good site if you look at 00:16:45.629 --> 00:16:49.089 their business model. So regulators are often the ones that should offer these 00:16:49.089 --> 00:16:56.269 speed tolls. And BEREC recently released an open source speed test measurement tool 00:16:56.269 --> 00:17:01.199 that hopefully will also change another problem that are going to show you. In 00:17:01.199 --> 00:17:05.360 Norway, the telecom regulator Nkom is actually really good at showing how the 00:17:05.360 --> 00:17:09.910 Internet is improving year by year in the country. And of course, fiber is hitting 00:17:09.910 --> 00:17:14.470 through the roof and it's really good. And in general, we see that the Internet is 00:17:14.470 --> 00:17:21.549 improving healthily and the supply is increasing to meet the demand. Austria - 00:17:21.549 --> 00:17:25.630 similar picture - regulators reporting the numbers every year. So we know how the 00:17:25.630 --> 00:17:29.309 Internet is actually developing in these countries. You would assume that in 00:17:29.309 --> 00:17:34.130 Western countries this is a given. It is also an obligation under the law. They 00:17:34.130 --> 00:17:38.049 really have to do that. But sadly, only eight countries are actually reporting 00:17:38.049 --> 00:17:44.169 figures. If the internet supply is actually increasing. Twenty three 00:17:44.169 --> 00:17:49.860 countries released no numbers at all about whether the internet capacity is actually 00:17:49.860 --> 00:17:54.230 constantly meeting the increasing demand, which we see as a big problem, 00:17:54.230 --> 00:17:59.260 particularly with 5G, because that will mean that the last mile will suddenly 00:17:59.260 --> 00:18:04.049 be very fast, but the rest of the network to core, the backhaul, this is where the 00:18:04.049 --> 00:18:08.279 next bottleneck will lie. And if we don't invest there soon enough, we'll really 00:18:08.279 --> 00:18:14.510 have a big infrastructural problem in the foreseeable future. So coming to the 00:18:14.510 --> 00:18:20.059 reform. So what is on the table? First, this is not a legislative reform. Contrary 00:18:20.059 --> 00:18:23.350 to the previous talk that I've given, this is not about engaging with the commission 00:18:23.350 --> 00:18:28.080 to parliament or the council. This is all about the regulatory community, like with 00:18:28.080 --> 00:18:33.080 the GDPR privacy law it's great when we as activists proud our head and shoulders that 00:18:33.080 --> 00:18:39.149 we actually managed to get a law approved and then the sad awakening comes. Okay. 00:18:39.149 --> 00:18:43.179 But the guys who are in charge with enforcing the law are really not 00:18:43.179 --> 00:18:47.529 particularly motivated to do so. And then you are stuck in Ireland with the data 00:18:47.529 --> 00:18:52.130 protection authority for years. And your biggest problem is that they are not doing 00:18:52.130 --> 00:18:56.919 their job. Similarly, in telecom regulation, what we have found is the 00:18:56.919 --> 00:19:01.900 biggest problem is to get the regulator to do their job. And that needs a lot of name 00:19:01.900 --> 00:19:06.950 calling and submissions and talks with them, which is really frustrating because 00:19:06.950 --> 00:19:12.000 it should not be the jobs of activists to enforce legislation. It should be the task 00:19:12.000 --> 00:19:19.720 of well funded regulators. So in that reform, we are kind of in the middle. The 00:19:19.720 --> 00:19:25.730 scope was released in 2018. In May, we had an official stakeholder workshop which 00:19:25.730 --> 00:19:31.039 went for five hours and was a busy gladiator debate. And October/November the 00:19:31.039 --> 00:19:34.610 draft guidelines were released and publicly consulted. About 50 stakeholders 00:19:34.610 --> 00:19:39.909 participated, we were one of them. And now BEREC has all of the input on their draft 00:19:39.909 --> 00:19:46.039 guidelines and most likely in Q1 2020 will see an interim report summarizing that 00:19:46.039 --> 00:19:50.580 consultation, which again will be consulted. We would like that to happen 00:19:50.580 --> 00:19:54.330 because it would allow us to respond to comments from the telecom industry and to 00:19:54.330 --> 00:19:59.529 kind of have a more Ping-Pong debate. And finally, that all should come to a close 00:19:59.529 --> 00:20:05.690 in June 2020 when the new rules are adopted. So now I'm gonna go into what is 00:20:05.690 --> 00:20:11.919 actually in that draft and what to expect content-wise from the topic. As you have 00:20:11.919 --> 00:20:15.750 seen in the title, what we are mostly talking about these days is 5G, the next 00:20:15.750 --> 00:20:19.820 mobile network generation. You must have heard about it. The telecom industry 00:20:19.820 --> 00:20:25.250 really has spent millions and millions in advertisement to make people interested in 00:20:25.250 --> 00:20:30.850 5G. We have that whole trade war between Trump and Huawei going on and there are 00:20:30.850 --> 00:20:37.029 people talking about health risk, which is mostly overblown but still 5G is really 00:20:37.029 --> 00:20:42.570 portrayed as the revolutionary new technology. Sadly, that's quite far away 00:20:42.570 --> 00:20:49.190 from the truth. 5G is an evolution. If you've listened to the talk yesterday 00:20:49.190 --> 00:20:53.429 morning in German about the path from 4G to 5G, you will know that technology wise 00:20:53.429 --> 00:21:01.010 5G is a very interesting technology. And as a nerd, I find it interesting but.. The 00:21:01.010 --> 00:21:04.529 only thing that's a given is that internet will become faster. All of the other 00:21:04.529 --> 00:21:08.840 promises you should take with a grain of salt. There are two particular 00:21:08.840 --> 00:21:14.880 technology aspects of 5G that I want to talk about in more detail. The first is 00:21:14.880 --> 00:21:21.620 Network Slicing. The title already gives it away. Network slicing means you slice 00:21:21.620 --> 00:21:29.149 the network and every slice, every layer has different quality characteristics. So 00:21:29.149 --> 00:21:32.419 it's basically QoS on the radio access layer. So it's basically allowing you to 00:21:32.419 --> 00:21:39.100 have one SIM card with several internet accesses to it. So you could have one that 00:21:39.100 --> 00:21:44.000 is very high bandwidth super fast for Netflix, one for very low latency for 00:21:44.000 --> 00:21:48.159 gaming, one for very low energy consumption. So when your battery goes 00:21:48.159 --> 00:21:53.590 below 20% or you'll have solar powered IoT sensors, then you might want to use that 00:21:53.590 --> 00:21:57.169 because you actually don't care about bandwidth, you don't care that much about 00:21:57.169 --> 00:22:02.610 reliability, but you only have tiny battery or solar power. And it actually is 00:22:02.610 --> 00:22:09.120 good that we'll have that technology. But the question is then who gets which slice? 00:22:09.120 --> 00:22:14.240 And that's where the regulators in the business models get back into gear. The 00:22:14.240 --> 00:22:18.860 one scenario in which we could see networks slices being marketed to us is an 00:22:18.860 --> 00:22:23.029 a per subscriber basis. So you have that one SIM card and it allows you to have 00:22:23.029 --> 00:22:27.919 several independent Internet access services that are also separated from each 00:22:27.919 --> 00:22:34.559 other. And you as a user are in control. Which app gets which slice? You should not 00:22:34.559 --> 00:22:37.770 assume that all of these slices will be flat rate. It could be that you have a 00:22:37.770 --> 00:22:42.510 normal internet access but a very high bandwidth or low latency slice is capped 00:22:42.510 --> 00:22:46.540 with two gigabytes per month. And so it actually is important that we as 00:22:46.540 --> 00:22:52.779 subscribers have a say in that. The second way in which network slices could hit us, 00:22:52.779 --> 00:22:58.110 is a specialized services. So, there the access service, the pipe, is the same 00:22:58.110 --> 00:23:04.120 thing as the application that runs over it. So it's no longer universal access. It 00:23:04.120 --> 00:23:07.440 is no longer something that connects you to the whole internet but it's basically 00:23:07.440 --> 00:23:13.590 just not a power plug but a Facebook plug. And we have few safeguards, five in total 00:23:13.590 --> 00:23:19.350 in the regulation that are kind of protecting us against specialized services becoming 00:23:19.350 --> 00:23:25.470 too widespread. But this is where we'll see a lot of "innovation" from the telecom 00:23:25.470 --> 00:23:30.320 industry to vertically integrate, try to have Facebook as a separately sold product 00:23:30.320 --> 00:23:37.270 or maybe Facebook, Oculus Rift, VR or maybe some IoT vertical integration, which 00:23:37.270 --> 00:23:41.649 some smart home shit. So stuff like that will most likely happen and 5G gives them 00:23:41.649 --> 00:23:47.539 more argumentation basis for these types of vertically integrated products. But 00:23:47.539 --> 00:23:52.990 that's something for the enforcement. And lastly, which was our original fear, is 00:23:52.990 --> 00:23:57.990 that a network license would be applied on a per application basis. So, Google could 00:23:57.990 --> 00:24:03.940 make a deal and suddenly they are under high reliability slice - always. And this 00:24:03.940 --> 00:24:09.259 is thankfully not the case in the current draft, so we could already prevent with 00:24:09.259 --> 00:24:14.090 the work in the previous years this scenario from being a likely result of 00:24:14.090 --> 00:24:20.529 that reform, which is good because as I show you later, these rules in Europe will 00:24:20.529 --> 00:24:25.850 have repercussions. The second technology aspect of 5G that merits some discussion 00:24:25.850 --> 00:24:31.610 is edge computing and it's kind of breaking the principle of end-to-end. You 00:24:31.610 --> 00:24:35.980 no longer have desktops or mobile devices that are connected to one Internet, 00:24:35.980 --> 00:24:40.670 whereas you have suddenly some computational power on the cell tower, on 00:24:40.670 --> 00:24:45.360 a very close datacenter connected with fiber lines so that the whole purpose here 00:24:45.360 --> 00:24:52.580 is very low latency. The industry is marketing this as something really great, 00:24:52.580 --> 00:24:57.190 something that will be heavily needed. Actually, there is very little real use 00:24:57.190 --> 00:25:02.570 cases out there that I think are realistic. The only one that we could find 00:25:02.570 --> 00:25:06.769 and that merits discussion is local dynamic maps. So it's basically if you 00:25:06.769 --> 00:25:12.850 think of a future in which self-driving cars all have their own sensory data and 00:25:12.850 --> 00:25:17.399 that sensory data is then cached in this edge-called cloud. So you have a 3-D 00:25:17.399 --> 00:25:23.499 model that knows from the car that has gone around the same curve for a minute ago that 00:25:23.499 --> 00:25:27.320 there is a traffic jam over there. And so your car would know before you even passed 00:25:27.320 --> 00:25:33.670 that curve. It is telling that even the European Commission backed a Wi-Fi based 00:25:33.670 --> 00:25:39.409 mesh network standard and not 5G, which means even that very weak example of edge 00:25:39.409 --> 00:25:44.769 computing is kind of discredited in Europe. So we have good cases for the 00:25:44.769 --> 00:25:49.299 global reform. And when we talk about 5G, it's important to stress that this is a 00:25:49.299 --> 00:25:55.120 global standard. 3GPP, an international body is standardizing the technology for 00:25:55.120 --> 00:26:01.080 5G and now it's being rolled out step by step in the rest of the world. The U.S., 00:26:01.080 --> 00:26:04.389 of course, will not be helpful with that because they are heavily investing in 5G 00:26:04.389 --> 00:26:08.490 but they are no longer net neutrality standards to test this new technology 00:26:08.490 --> 00:26:14.110 against. Canada, great net neutrality law, but not taking a front seat approach to 00:26:14.110 --> 00:26:19.540 5G. So they are not actively engaging with it. India great net neutrality, again not 00:26:19.540 --> 00:26:24.659 interested in 5G yet. South Korea, actually, our colleagues there could 00:26:24.659 --> 00:26:31.419 prevent a repeal of the net neutrality legislation in South Korea. But they tried 00:26:31.419 --> 00:26:38.009 to regulatory sandbox net neutrality from 5G to just let the net neutrality rules 00:26:38.009 --> 00:26:42.360 that are already weak in South Korea to begin with not apply to that technology. 00:26:42.360 --> 00:26:46.330 So Europe is kind of the first world region that tries to square these two 00:26:46.330 --> 00:26:52.410 things together. And that's why our approach here might be quite influential. 00:26:52.410 --> 00:26:57.559 Also, if you think of the whole ecosystem because what does it mean if we have user 00:26:57.559 --> 00:27:01.549 controlled network slices? That means that on my mobile device, I need to somehow 00:27:01.549 --> 00:27:06.490 also decide which application gets which slice at which time. And so Google and 00:27:06.490 --> 00:27:13.990 Android - ähm Google and Apple (Freud) come into play here as well. Another issue 00:27:13.990 --> 00:27:20.029 that we did not at all expect to fight about is parental control filters. So when 00:27:20.029 --> 00:27:23.179 we fought about this law in the parliament and in the council in the 00:27:23.179 --> 00:27:28.399 trial, we always had that looming danger of parental controls, like in the UK. You 00:27:28.399 --> 00:27:32.750 buy an internet subscription and you have a porn filter on it by default. We could 00:27:32.750 --> 00:27:36.570 kill this in trial. So parental controls were struck out of the law books 00:27:36.570 --> 00:27:41.710 and for some weird reason I would call it lobby pressure. The regulators wanted to 00:27:41.710 --> 00:27:47.059 allow this in this reform and we've shot heavily against it. We got even support 00:27:47.059 --> 00:27:51.220 from the consumer protection organizations, from BEUC, and we hope 00:27:51.220 --> 00:27:56.029 that we can actually prevent this because what would it mean? It would mean that 00:27:56.029 --> 00:28:01.330 suddenly in the terms of services, you can circumvent net neutrality. Usually an ISP 00:28:01.330 --> 00:28:05.320 is, of course, not allowed to just randomly block websites but parental 00:28:05.320 --> 00:28:09.720 controls are exactly that. If you want to do parental control filtering do it on the 00:28:09.720 --> 00:28:16.340 device but not in the network. Blocking should always happen on the edge of the 00:28:16.340 --> 00:28:20.919 application, not on the network site. The picture is more interesting when we talk 00:28:20.919 --> 00:28:26.399 about zero rating cause they actually took many of our ideas and also from our report 00:28:26.399 --> 00:28:32.179 into consideration. The draft that was released in October actually contains even 00:28:32.179 --> 00:28:36.429 the same language of open zero rating programs. And it says they have to be 00:28:36.429 --> 00:28:41.870 fair, everyone needs to get a response, they have to be reasonable, so all 00:28:41.870 --> 00:28:45.820 documentation should be made public, they have to be transparent, so if WhatsApp 00:28:45.820 --> 00:28:50.059 calls or Spotify ads are actually counting towards you data cap and are not zero- 00:28:50.059 --> 00:28:55.889 rated, you should least tell the customer and they have to be non-discriminatory. So 00:28:55.889 --> 00:28:59.919 Vimeo gets the same response time as YouTube. These are all our critical 00:28:59.919 --> 00:29:04.200 points. I'm very thankful that they have listened to us but sadly, they are also 00:29:04.200 --> 00:29:09.249 allowing ISP to simply don't give a fuck and have non-open programs, so they have 00:29:09.249 --> 00:29:14.309 not drawn a red line. They have not said clearly we have these types of zero-rating 00:29:14.309 --> 00:29:18.160 programs, which are okay and then we have all of these others that you have to 00:29:18.160 --> 00:29:27.200 follow these rules for. And that is just a level of lack of opportunity and a missed 00:29:27.200 --> 00:29:32.100 opportunity for the regulators because whenever the rules are fuzzy and 00:29:32.100 --> 00:29:37.679 unclear,that only creates problems further down the road in enforcement. The last 00:29:37.679 --> 00:29:41.450 issue was also kind of unexpected. In the beginning, because I thought we've solved 00:29:41.450 --> 00:29:46.970 that. Deep packet inspection. So deep packet inspection means when an ISP is 00:29:46.970 --> 00:29:51.309 looking into your data packages. So he's looking closely into what you are actually 00:29:51.309 --> 00:29:57.429 doing online, your concrete user behavior. The domains you access, the URLs you 00:29:57.429 --> 00:30:01.399 access, that means your sexual preferences, your news preferences, which 00:30:01.399 --> 00:30:06.169 videos you have watched, all of that. Usually that should be prohibited. 00:30:06.169 --> 00:30:10.110 Everything that's payload of transport layer 4 should be off limit for an ISP. 00:30:10.110 --> 00:30:14.169 That's the general definition of deep packet inspection. And actually we thought 00:30:14.169 --> 00:30:19.210 that we've won that. But then there were rumors that deep packet inspection, they 00:30:19.210 --> 00:30:24.380 want to open it up and allow it again. So we launched an open letter which was 00:30:24.380 --> 00:30:29.639 signed by 45 NGOs, academics, and privacy experts. But we still felt like this is a 00:30:29.639 --> 00:30:35.309 hard push. We knew the regulators on the other side - Germany is one of them - that 00:30:35.309 --> 00:30:40.830 were just because of lobby pressure, really asking for ex post allowing deep 00:30:40.830 --> 00:30:50.980 packet inspection. And in that moment, Gandalf came and we really got support 00:30:50.980 --> 00:30:56.240 from an unexpected friend. The highest data protection body in the European 00:30:56.240 --> 00:31:03.159 Union, EDPB, issued a letter to BEREC and saying that the board considers the 00:31:03.159 --> 00:31:07.341 processing of data such as domain names and URLs by Internet access service 00:31:07.341 --> 00:31:12.659 providers for traffic management and billing purposes, it's unlawful unless 00:31:12.659 --> 00:31:18.470 consent of all users is obtained. And that is interesting because of course all users 00:31:18.470 --> 00:31:24.279 means that it will never work because I as a customer of my telco, can maybe 00:31:24.279 --> 00:31:30.009 consent to that, but not the rest of the internet that might send a data package 00:31:30.009 --> 00:31:34.379 down my way. They're not just saying this for their net neutrality law, they are 00:31:34.379 --> 00:31:39.850 also saying it for their interpretation of e-privacy, of the GDPR, all of the other 00:31:39.850 --> 00:31:43.629 laws. So this is actually giving us even more sticks to go after deep packet 00:31:43.629 --> 00:31:48.009 inspection in the future of that legal opinion. And lastly, a completely 00:31:48.009 --> 00:31:53.659 unrelated reform but still plays into this whole thing. In Germany, you can pick your 00:31:53.659 --> 00:31:58.789 own router. It doesn't matter which ISP you have. You have the right to buy a 00:31:58.789 --> 00:32:03.370 router from anywhere, even an open source or libre one. And it needs to be able to 00:32:03.370 --> 00:32:06.929 connect to your internet access service. That is not the case in many European 00:32:06.929 --> 00:32:11.129 countries because it is often unclear where does the network actually end and 00:32:11.129 --> 00:32:15.289 where does my home network begin. And that network termination point is one of the 00:32:15.289 --> 00:32:21.809 things that the same body BEREC, the telecom regulators will decide for us. And 00:32:21.809 --> 00:32:26.030 again, it looks like we will win. Winning in this sense means that you will have it 00:32:26.030 --> 00:32:30.679 the freedom to choose your own router, you will have device freedom also in the 00:32:30.679 --> 00:32:35.690 customer premise equipment and the network ends at the socket, at the wall, at the 00:32:35.690 --> 00:32:39.779 antenna. So it's actually quite good for user choice. The only counterpoint that I have to 00:32:39.779 --> 00:32:44.039 give you, of course, when the network ends, net neutrality ends. But if your ISP 00:32:44.039 --> 00:32:49.289 tries to fuck you on your router, you can just replace it with another device. And 00:32:49.289 --> 00:32:53.150 that's it for the neutrality thing. And I think we still have some time for Q 00:32:53.150 --> 00:33:01.059 and A. Thanks. 00:33:01.059 --> 00:33:07.669 Applause 00:33:07.669 --> 00:33:18.159 Herald: Yeah. Thank you so much. And don't leave yet. I wanted to say support 00:33:18.159 --> 00:33:22.460 epicenter.work, support EDRi. We need support, we need people who believe in this and to 00:33:22.460 --> 00:33:29.869 fight for this and thank you. 00:33:29.869 --> 00:33:33.960 Applause 00:33:33.960 --> 00:33:41.309 Herald: Okay. So, do we have questions? We have questions from the Internet, maybe - 00:33:41.309 --> 00:33:48.470 not really. Number two, please. Mic 2: Yes. Have you seen any requirements 00:33:48.470 --> 00:33:53.450 in digital media playback for recording location information and identifying 00:33:53.450 --> 00:33:57.360 users? So especially the location information of media playback. 00:33:57.360 --> 00:34:04.100 Lohninger: I'm not sure I follow the question. So like... you mean like YouTube 00:34:04.100 --> 00:34:06.190 reporting the playback position of the audience? 00:34:06.190 --> 00:34:09.780 Mix 2: No, not the not the public playback position, the position or the location of 00:34:09.780 --> 00:34:14.480 the user that is playing back to media. Lohninger: I'm not sure that that would 00:34:14.480 --> 00:34:21.429 relate to this. So, the ISP, of course, knows in most cases where the user is, you 00:34:21.429 --> 00:34:30.299 know, in all cases actually, and the content provider, if it is not localizing 00:34:30.299 --> 00:34:35.960 the user on the app with the location, then the ISP at least would not share that 00:34:35.960 --> 00:34:41.790 location information. I also wouldn't know by which API or on which legal basis they 00:34:41.790 --> 00:34:46.330 could do that. I hope that answers the question, but I'm not sure. 00:34:46.330 --> 00:34:52.080 Herald: Okay, thank you. Okay, we have another question. Microphone four, please. 00:34:52.080 --> 00:34:58.569 Mic 4: Hi. Will the users have the same rights if they are not in the home country 00:34:58.569 --> 00:35:01.970 like if you are roaming? Lohninger: Yeah, that's actually an 00:35:01.970 --> 00:35:08.200 interesting question. So, the net neutrality regulation is also the roaming 00:35:08.200 --> 00:35:12.630 regulation in the EU. These two things a legally mixed together but they actually 00:35:12.630 --> 00:35:19.490 can be seen completely separate. So when you are roaming in another country, so my 00:35:19.490 --> 00:35:25.280 Austrian SIM card here in Germany, it is actually then the German provider that is 00:35:25.280 --> 00:35:30.869 physically providing me the Internet access service, which has to apply by the 00:35:30.869 --> 00:35:38.230 same European regulation for net neutrality. In most cases that would not 00:35:38.230 --> 00:35:45.390 mean that there is even a technical or legal connection to the customer, to the 00:35:45.390 --> 00:35:50.920 ISP in Austria that I have a contract with. Of course, it gets then interesting 00:35:50.920 --> 00:35:59.349 because that's mostly about the technical aspect when we look about zero rating. For 00:35:59.349 --> 00:36:03.359 most cases the zero rating would just not be possible. So if you have StreamOn in 00:36:03.359 --> 00:36:07.460 Germany, you are a customer of T-Mobile, you are going to Austria and you are in 00:36:07.460 --> 00:36:13.890 the network of some ISP, then the zero- rating would just not be possible and you 00:36:13.890 --> 00:36:18.690 would just have additional data volume given to you. There was actually a court 00:36:18.690 --> 00:36:25.060 case about that out of Germany and there's still ongoing litigation from the consumer 00:36:25.060 --> 00:36:31.450 protection NGO, VZBV in Germany against Vodafone around that same question. It 00:36:31.450 --> 00:36:37.119 might be differently if you are a German T-Mobile customer in Austria and roaming 00:36:37.119 --> 00:36:41.520 in the T-Mobile network there because technically I think it would be possible 00:36:41.520 --> 00:36:47.010 to then apply the zero-rating but I'm not sure if they actually do that. I think it 00:36:47.010 --> 00:36:50.310 would not be easy and the incentive usually would also not be there because 00:36:50.310 --> 00:36:55.890 these are very few edge cases that even to configure and maintain those wouldn't make 00:36:55.890 --> 00:37:01.900 a lot of sense. Herald: Okay, so next, we have a question 00:37:01.900 --> 00:37:09.020 from the Internet. Dear signal angel. Signal: So there was a question about DPI. 00:37:09.020 --> 00:37:15.250 Are data protection authorities doing anything about this and are there any 00:37:15.250 --> 00:37:20.940 enforcements in the European country? Lohninger: Sadly, no and no but I think 00:37:20.940 --> 00:37:28.579 there is definitely an opportunity there for enforcement action. And I know many of 00:37:28.579 --> 00:37:33.730 the people that work around strategic litigation and enforcement of the GDPR. 00:37:33.730 --> 00:37:38.440 They have their hands full because similar to net neutrality, the great law that 00:37:38.440 --> 00:37:44.150 we've written in the last year is not taken very seriously by the regulators. 00:37:44.150 --> 00:37:49.670 And I think it will again depend on activists or other entities bringing 00:37:49.670 --> 00:37:55.420 cases, bringing complaints to data protection authorities around DPI before 00:37:55.420 --> 00:37:59.750 we see actual movement there. Legally, I think particularly with that statement 00:37:59.750 --> 00:38:06.099 from the EDPB, it would be an easy win. So if somebody wants to earn spores or help 00:38:06.099 --> 00:38:11.099 of that, I think it's quite doable case to bring a complaint against DPI based on 00:38:11.099 --> 00:38:16.030 that legal opinion. Herald: So you're all part of it again. 00:38:16.030 --> 00:38:22.359 Number two, please. Mic 2: I want to ask, why the hell should 00:38:22.359 --> 00:38:29.510 the ISP mess around on layer 4 laugh , as you described it before? 00:38:29.510 --> 00:38:34.119 Lohinger: That is the current definition that we have, like the regulation says no 00:38:34.119 --> 00:38:42.480 monitoring of specific content. And BEREC interpreted that in 2016 it meaning pay a 00:38:42.480 --> 00:38:48.690 load of transport layer 4 should be off limit. That is the interpretation that the 00:38:48.690 --> 00:38:51.950 regulators have come up with. And that, of course, was also a political compromise 00:38:51.950 --> 00:38:58.750 like where do you draw the line? And so my slide there was really based on the 2016 00:38:58.750 --> 00:39:04.300 text of the guidelines. Herald: Okay. Number one, please. 00:39:04.300 --> 00:39:09.660 Mic 1: So currently an app developer has to apply for to an ISP to get zero-rated. 00:39:09.660 --> 00:39:14.119 What's to stop an ISP to just zero-rate an app on its own to gain some market 00:39:14.119 --> 00:39:17.119 advantage. Lohninger: They can. And there's nothing 00:39:17.119 --> 00:39:22.390 stopping it. And WhatsApp, for example, is easily just saying "Okay, here's how you 00:39:22.390 --> 00:39:29.609 zero-rate us and we don't even want to interact with you." There does not need to 00:39:29.609 --> 00:39:34.271 be a bilateral agreement. Of course, ISP then has the problem if the app provider 00:39:34.271 --> 00:39:39.299 changes their service or infrastructure and identification criteria should also 00:39:39.299 --> 00:39:45.350 change that the ISP needs to implement that change before it happens. And so 00:39:45.350 --> 00:39:48.980 that's the reason for the 30 day period. But again, that problem might not even 00:39:48.980 --> 00:39:54.910 exist for big providers that have dedicated IP addresses. If your services 00:39:54.910 --> 00:39:58.799 coming out of an CDN and then you would rely on SNI or other technologies to 00:39:58.799 --> 00:40:04.810 actually be identifiable. Herald: So we have one more minute and I'm 00:40:04.810 --> 00:40:10.510 sorry to say it's number 4. Thank you, others. And yeah, probably you can go to 00:40:10.510 --> 00:40:14.200 Epicenter Networks and contact Thomas there. Thank you. 00:40:14.200 --> 00:40:18.809 Mic 4: Hi. I'm very touched by your argument about regulation not being 00:40:18.809 --> 00:40:24.050 enforced right now in the EU. In France, it has been the case about video 00:40:24.050 --> 00:40:31.310 surveillance where the state has stated that CLIN, the regulators are a 00:40:31.310 --> 00:40:35.799 consultative authority. You know, they shouldn't enforce. That's what quite 00:40:35.799 --> 00:40:41.250 arterial the association that is doing most of the work about that said so. I 00:40:41.250 --> 00:40:44.430 don't know where we go from there. You know, I'm very scared. It's nice that 00:40:44.430 --> 00:40:47.430 you're doing... Herald: What is the question, please? We 00:40:47.430 --> 00:40:49.550 just have 20 more seconds. Mic 4: Sorry, my question is, what do you 00:40:49.550 --> 00:40:53.950 think we can do to help enforce regulation in the EU? 00:40:53.950 --> 00:40:59.280 Lohninger: Big question. There are many things there, like one of the things that 00:40:59.280 --> 00:41:04.950 is a positive development to look at a bright side is that more and more digital 00:41:04.950 --> 00:41:09.550 rights NGOs are warming up to strategic litigation. So ultimately, why are 00:41:09.550 --> 00:41:15.720 regulators not acting? Because on the one side, they have fundamental rights to law, 00:41:15.720 --> 00:41:19.420 consumer protection. And on the other side, you have a big, big company that 00:41:19.420 --> 00:41:24.240 will not accept their decision that it will bring them to court no matter what. 00:41:24.240 --> 00:41:28.270 And so if you're a small regulator with a limited budget, you can either take the 00:41:28.270 --> 00:41:33.740 uncomfortable decision that, you know, you will be sued for. Or just duck away and 00:41:33.740 --> 00:41:37.880 then the thing might be over. So that the risk assessment and the cost calculation 00:41:37.880 --> 00:41:42.750 is currently not in our favor. And that's why we need to bring more cases. We have 00:41:42.750 --> 00:41:48.579 to make regulators really bear a certain risk on both sides of the decision. And 00:41:48.579 --> 00:41:52.770 only then will the decision actually move more to the factual basis. And I mean, I 00:41:52.770 --> 00:41:57.670 know there are many problems in France but at least CLIN was one of the few DPAs that 00:41:57.670 --> 00:42:02.710 actually issued a few million penalties. So there is at least some silver lining. 00:42:02.710 --> 00:42:09.700 Herald: Okay, so complain. Support EDRi, support epicenter.works. Thank you 00:42:09.700 --> 00:42:12.460 for being here and given another applause to Thomas Lohninger. Thank you so much. 00:42:12.460 --> 00:42:13.460 Applause 00:42:13.460 --> 00:42:14.460 36c3 postroll music 00:42:14.460 --> 00:42:15.960 Subtitles created by c3subtitles.de in the year 2020. Join, and help us!