[Japan] AIC Submits Comments on the Interim Report on Competitive Evaluation of Digital Advertising Market (July 2020)

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The Asia Internet Coalition (AIC) and its members express our sincere gratitude to the Digital Market Competition Headquarters (DMCH) for the opportunity to submit comments on the Interim Report on Competitive Evaluation of Digital Advertising Market.

We commend the DMCH for your efforts in drafting the Interim Report on Competitive Evaluation of Digital Advertising Market. Indeed, this interim report is timely given how the COVID-19 pandemic has essentially resulted to a huge surge in internet traffic as many countries have gone under lockdown. At a very basic level, in theory increased internet traffic means more visitors to publishers’ pages and therefore increased attention on digital ads. While we support these evaluation efforts by the DMCH, we wish to highlight some concerns on the intervention options proposed in the interim report. As such, please find appended to this letter detailed comments and recommendations, which we would like the DMCH to consider.