On behalf of the Asia Internet Coalition (AIC) and its members, I am writing to express our sincere gratitude to the Minister of Science, Technology and ICT (“Ministry”) and the Government of South Korea for the opportunity to submit comments on the Enforcement Decree of the Telecommunications Business Act (“TBA or the Act”) amendments, which defines the requirements and responsibilities of “value-added telecommunications service providers” (VSPs).
Korea has one of the world’s most developed internet and digital economy ecosystems, and our member companies are significantly invested in Korea’s economic growth and development. We are committed to partnering with the Korean government to ensure a conducive and forward-looking regulatory environment that enables Korea to remain a digital leader and encourages innovation and investment that will create new jobs and economic opportunities in Korea.
Our member companies comprise leading internet and technology companies around the world that care deeply about the quality and reliability of their services, and strive to provide the most innovative and helpful platforms and services to their end users in Korea. They have played a pivotal role in keeping users connected to the world during the COVID-19 pandemic, and worked tirelessly with governments and internet service providers to meet user demand and recover quickly from disruptions, even in times of great uncertainty. Due to the nature of global data flows, internet and technology companies rely on the cooperation of internet service providers to effectively and reliably deliver their services to end-users. That is why we share the concerns of the Korea Internet Corporations Association (K-Internet) and other trade associations about the TBA and related Enforcement Decree, which is premised on shifting the burden of consistent and stable internet connection and service reliability to VSPs despite their lack of end-to-end control of the data.