Following on the heels of our submission to the U.S. Federal Trade Commission last month, we have submitted a written filing to the European Commission Directorate-General for Competition, as part of a public consultation in advance of the Commission’s forthcoming January 2019 conference on competition challenges in the digital era. In our filing, we focus on two specific, related issues: the difficulty of measuring competitive harm in a data-powered and massively vertically integrated digital ecosystem, and the role played by interoperability (in particular, through technical interfaces known as APIs) in powering the internet as we know it.

Mozilla’s Internet Health Report 2018 explored concentration of power and centralization online through a spotlight article, “Too big tech?” The software and services offered by a few companies are entangled with virtually every part of our lives. These companies reached their market positions in part through massive innovation and investment, and they created extremely popular (and lucrative) user experiences. But we are headed today down a path of excessive centralisation and control, where someday the freedom to code and compete will be realised in full only for those who work for a few large corporations.

Our submission examines modern digital competition through the following key considerations:

Increasing centralisation poses competition concerns; Traditional metrics and tools are insufficient to promote competition; Interoperability is a powerful, ready-to-use key to unlock competition in the tech sector; and Changes to law, policy, and practice regarding internet competition should be grounded in technology and built to benefit all internet users and businesses.

The EU has a well established track record in enforcing competition in digital markets. We encourage the Commission to continue its leadership by embracing interoperability as a core principle in its approach to digital competition. If the future of the internet stays grounded in standards and built out through an ecosystem of transparent third-party accessible APIs, we can preserve the digital platform economy as a springboard for our collective social and economic welfare, rather than watching it evolve into an oligarchy of gatekeepers over our data.