In its submission to the Department of Telecommunications, Facebook has said that more than 17 million people have expressed support for its Internet.org services, via SMS and the Internet.org Facebook page. The company has made a 9.9 mb PDF with comments available via a dropbox link in its submission. A sample from the PDF:

MediaNama’s take: Facebook ran what are, in our opinion, misleading campaigns asking people to support Internet.org. As indicated in this Quartz story, it didn’t give people an option to not support Internet.org, or give it a thumbs down. It was also misrepresented its Internet.org group of services as free Internet services.

Already explicitly told @facebook 3 times I don’t support Internet. Org. Now they remove “No” button. #shameless pic.twitter.com/w5hIo90oOS — Brij Bhasin (@brijbhasin) August 19, 2015

Apart from this it’s important to note that the DoT never said that comments could have been sent via platforms other than MyGov:

@nixxin @lmirani @mojorojo Govt didn’t say FB was an acceptable medium for sending comments. Am I allowed to conduct a survey of my own? — Aritra Das (@the_kindly_1) August 24, 2015

Our fisking of Facebook’s comments (pdf) to the DoT on Net Neutrality:

Facebook: We oppose attempts by operators to block or throttle Internet traffic, or create special paid “fast lanes”. But net neutrality is not in conflict with working to get more people connected. We believe that the principles of net neutrality must coexist with initiatives to expand access to the Internet.

MediaNama’s take:

1. Internet.org allows operators to block sites: When it was relaunched in May, Internet.org’s terms and conditions said that, “Operators may decline services that cause undue strain to networks, or breach legal or regulatory requirements.” Now they’ve been modified to be far more vague: “Submission and/or approval by Facebook does not guarantee that your site(s) will be made available through the Internet.org.”

Therefore, Internet.org isn’t an “open” platform that allows access to all of the Internet, and Facebook’s submission claims one thing, while its terms and conditions allow another.

Also read:

2. Internet.org violates Net Neutrality: Note how Facebook positions Net Neutrality as merely being about blocking and throttling, avoiding any mention of price discrimination, which is a net neutrality issue, and has been banned in countries like Chile, Norway, Netherlands, Finland, Iceland, Estonia, Latvia, Lithuania, Slovenia, Malta and Japan. Regulators in Norway, Germany and Austria have publicly said that zero-rating infringes net neutrality. (source: ToI and DFMonitor)

Facebook: To address the barriers of affordability and awareness, Facebook partners with local carriers to offer free basic services to people. People can browse a set of useful health, employment, search, social and local information services without incurring any data charges. These free basic services are accessible through the Internet.org app or through a simple web browser.

MediaNama’s Take:

1. Facebook is falsely positioning Internet.org as targeting poor people: If you see the advertisement from Reliance Communications, Internet.org’s telecom partner, it targets students.

2. Ignores the fact that there are neutral ways of providing free access: A false premiss is being created, that you cannot have access without violating Net Neutrality. As Mitchell Baker, Chairwoman of the Mozilla Foundation pointed out, their partnership with Grameenphone in Bangladesh allows users to receive 20 MB of data usage for free each day, in exchange for viewing an advertisement. Ozone Networks, an Indian WiFi provider does ad-supported WiFi too. Orange and Mozilla are experimenting with a model in multiple African African and Middle Eastern markets, where users purchasing a $40 (USD) Klif phone receive unlimited talk, text, and 500 MB a month for 6 months.

Facebook: (i) Internet.org is not a “gatekeeper” and is open to all developers: The Internet.org platform is an open program that lets developers easily create services and gives people choice over the free basic services they can use. Our goal with Internet.org is to work with as many developers and entrepreneurs as possible to extend the benefits of connectivity to diverse, local communities. The guidelines for developers to use the platform are that services should encourage the exploration of the broader Internet wherever possible; use data very efficiently; and meet various technical specifications. You can read more at:https://developers.facebook.com/docs/internet-org/participation-guidelines.

MediaNama’s Take:

1. If it is open, then why do developers have to go through an approval process from Facebook and the telecom operators Why do they have to conform to Facebook’s terms and conditions, which include rewriting URL’s, removal of embedded content? To quote the Internet.org participation guidelines: “In order for your content to be proxied as described above, your URLs may be re-written and embedded content (like javascript and content originating from another domain) removed. In addition, secure content is not supported and may not load.”

2. According to Facebook’s terms and conditions, which are applicable to Internet.org partners they get a license for the content on partner sites:

1. For content that is covered by intellectual property rights, like photos and videos (IP content), you specifically give us the following permission, subject to your privacy and application settings: you grant us a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with Facebook (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it.

2. When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period of time (but will not be available to others).

3. Facebook collects data on users of their partners websites: This, the user doesn’t really belong to the partner, but to Facebook.

“We collect information when you install, run or use any of our services, including the free websites and services provided through Internet.org. Please read our full Data Policy and Cookies Policy, which explain how we receive, use and disclose this info about you.”

Facebook: (iii) Internet.org brings new people online faster: July 2015 in fact marks the one-year anniversary of the introduction of the Internet.org app in its first country, Zambia. We’ve found that Internet.org brings new users onto mobile networks on average over 50% faster after launching free basic services. This means that if 1,000 peoplewho were brand new to the Internet were signing up per month for mobile data services before launching Internet.org, 1,500 people sign up per month after launching Internet.org.

MediaNama’s Take:

1. Not really bringing people online in droves in India: In fact, as per Facebook’s own data, of the 800,000 users on Internet.org in India, it said that only 20% had never used the Internet before. This indicates that users are switching to Internet.org from paid access to the open Internet. If you see the advertising from Reliance Communications, it appears that the company is using Internet.org to pull in customers from other telecom operators, rather than get new people online.

2. No data to ratify the claim that Internet.org brings people online 50% faster in India. How do you even prove this? Secondly, if you look at Internet growth data in India (sample copy), we really don’t have a problem signing new users up, so far.

Facebook: (iv) Internet.org encourages access to the broader Internet and bridges the“connectivity gap”:The Internet.org business model of partnering with local carriers will be successful only if new users access the broader Internet by buying paid data 3 plans. Because local carriers can’t afford to offer free Internet access, the program is designed only to serve as an onramp for users to the broader Internet. Our data shows that Internet.org accomplishes this goal of encouraging users to explore the wider Internet. In fact, more than half of the people who come online through Internet.org are paying for data and accessing the Internet within the first 30 days.

MediaNama’s Take: If Internet.org is a promotional scheme, then why is it permanent? Why can a user continue on Internet.org forever (or as long as telecom operators allow it), instead of being forced to switch within a week or a month? How is it encouraging broader access to the web? Why can’t we choose more neutral ways of giving access, or why can’t telecom operators just run promotional schemes offering 50 mb free Internet for everyone, like they did with SMS, where they offered users free SMS for a month?