Protocol and Engineering Effects of Consolidation
draft-lazanski-consolidation-02
Independent Submission D. Lazanski
Internet Draft Last Press Label
M. McFadden
Internet policy advisors, ltd
E. Lear
Cisco Systems
Intended status: Informational July 12, 2021
Expires: January 12, 2022
Protocol and Engineering Effects of Consolidation
draft-lazanski-consolidation-02.txt
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Abstract
This document contributes to the ongoing discussion surrounding
Internet consolidation. Though there has been much interest in the
topic, the conversation has waned. This document aims to discuss
recent areas of Internet consolidation that are technical, economic
and engineering focused and provide some suggestions for advancing
the discussion.
Table of Contents
1. Introduction...................................................2
2. Background to Consolidation Issues and the Role of Standards...3
3. Overarching Issues Related to Consolidation....................5
3.1. Technical.................................................5
3.2. Economic..................................................6
3.3. Security..................................................7
4. Implications of Consolidation on Internet Architecture.........8
4.1. The Changing Architecture of the Internet.................8
4.2. The End-to-End Principle Redux............................9
5. Implications of Consolidation on Protocol Design..............11
5.1. Does Protocol Design Really Affect Consolidation?........11
5.2. Case Studies in Consolidation and Protocol Design........11
5.2.1. DNS over HTTPS (DOH)................................11
5.2.2. Encrypted Server Name Indication (eSNI).............12
5.2.3. Privacy Pass........................................12
6 Potential Technical Risks...............................13
6. Actions for the IETF, IRTF and IAB............................14
7. Security Considerations.......................................15
8. IANA Considerations...........................................15
9. Conclusions...................................................15
10. References...................................................15
10.1. Informative References..................................15
11. Acknowledgments..............................................17
1. Introduction
Internet consolidation has been under discussion for the last
several years. The 2019 Internet Society's "Global Internet Report:
Consolidation and the Internet Economy" highlighted issues in this
topic and kicked started a series of discussions and publications
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around consolidation. Furthermore, a draft for the Internet
Architecture Board (IAB) discussed issues of economic and technical
consolidation. [1] Despite community interest, the draft expired
without additional work or publication.
Further discussions on this issue have stalled in recent months as
we have been faced with the Covid-19 pandemic and all of the
challenges that this brings to working and living. This draft aims
to reengage with the issues of Internet consolidation and bring
together current discussions and trends.
2. Background to Consolidation Issues and the Role of Standards
Internet consolidation is "the process of increasing control over
internet infrastructure and services by a small set of
organizations." [2] Let us consider two general categories of
concentration: "player" and "layer". By player concentration, we
mean the aggregating of a market to a small number of providers for
a particular service. Layer concentration means the combining of
functions within a given layer. An example of "player" concentration
would be a relatively small number of email service providers who
offer billions of users email service. Or the number of web search
providers or even web browser offerings. [3]
The Internet is being consolidated at all layers, from the
application layer to the network layer. Large companies, like
Facebook and Google, account for a significant amount of the content
and applications that are used online today. However, several of
these large companies are dominating the development of protocols
which fundamentally changes the way in which the Internet works and,
ultimately, drives the traffic - and data - into the hands of a few
companies. For example, Google has 81% of all searches online and
94% of all mobile searches as of 2020. [4]
Market consolidation is not limited to the Internet. It happens
when economies of scale provide highly aggregated firms an
advantage. For the last three decades, we have witnessed
concentration occurring not only in telecommunications, but in the
financial sector as well, just to name one other example.[5] The
acceleration of consolidation has been assisted by "cloud"
technologies, such as occurred with email. In the case of email,
the service providers make use of SMTP to exchange messages, IMAP to
provide those messages to a user interface, and HTTP, HTML, and
JavaScript to present those messages directly to a user's browser.
In other market consolidation cases, fewer Internet standards are in
play. In the case of home assistant tools such as the Amazon Echo
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or Google Home Assistant, communication from these devices to their
respective clouds is largely proprietary in nature. In particular,
the information models and schemas they use are not exposed to the
outside world. This is because the bulk of the service is performed
by the cloud, with relatively little processing occurring in the
home. This two-sided model eliminates the lengthy standards
development process, thereby permitting faster service improvements.
On the Internet over previous decades, numerous Internet Service
Provider (ISP) markets were subject to deregulation, disaggregation
of customers by regulatory requirement, consolidation, and to some
extent, re-regulation.
Standards have been viewed as a means to prevent barriers to entry.
During the 1980s, AT&T was required to abide by standards as part of
the consent decree that resolved antitrust litigation, leading to
the ability of anyone to connect a telephone to its network. By
1994 standards were recognized as a means to prevent technical
barriers to trade (TBT) during the Uruguay Round of the World Trade
Organization.
As mentioned, both the Internet Society and participants of the IETF
have recently published on the subject of consolidation. At the
IAB's Design Expectations vs. Deployment Reality in Protocol
Development Workshop 2019 a handful of the participants discussed
concentration and consolidation. [4] Andrew Sullivan looked at three
types of concentration in open protocols; web services, network
services and standardisation. Both Christian Huitema and Julien
Maisonneuve noted concentration, which leads to consolidation, as an
effect of economies of scale and network effects in business models
in the implementation of business practices. Jari Arkko discussed
the impacts of consolidation on the Internet infrastructure in a
document for the IETF[6], with the document identifying issues
including loss of resilience and increased risk of surveillance. It
goes on to note that "it seems prudent to recommend that whenever it
comes to Internet infrastructure services, centralised designs
should be avoided where possible".[7] From networks to applications,
the overarching theme was that consolidation is taking place from
one end of the Internet to the other. Additionally, the Journal of
Cyber Policy published a special edition on Consolidation of the
Internet. Topics in this special issue included market concentration
and security, DNS consolidation, supply chains, interoperability and
Internet architecture. However, much is still yet to be discussed on
consolidation at most layers of the Internet stack. [8]
Recently, the US has scrutinized Internet platform services. The
release of report Investigation of Competition in Digital Markets in
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October 2020 [9] showed that both concentration and consolidation in
the online marketplace has left consumers with little choice, again
at the application layer. Additionally, the US Justice Department
announced it is suing Google for Antitrust violations on 20 October
2020.[10] Both the report and the lawsuit show that concentration of
power of Internet platform services has alarmed the House of
Representatives and the Department of Justice to the point of
investigation and possible criminal charges. None of this would have
happed without consolidation of the application layer. The EU has
been investigating the 'gatekeeper' status of big tech. [11] Recent
reports reveal that the EU is considering ex ante solutions to the
issue of the dominance of certain, large platforms. Such remedies,
being discussed in the European Commission to date, include
mandatory data sharing and/or mandatory interoperability
requirements.[12] Such remedies seek to address the dominant market
share of application layer services by American tech companies in
Europe.
The rhetoric and discussion of consolidation primarily focuses on
Internet services and data. However, it is important to draw
attention to the issues and risks of consolidation at other layers
of the Internet beyond just the application layer. The application
layer is directly user facing and, as a result, is what users
experience. But the underlying infrastructure and protocols are also
going through consolidation as they develop. The complete end to end
encryption model forces data into endpoints which consolidates data
into and handful of companies. Furthermore, protocol standards are
facilitating this consolidation.
The QUIC protocol is an example of the consolidation between layers
of the Internet - and not at the application layer. Designed and
deployed as a transport layer protocol, it effectively replaces TCP
at the network layer while also adding improved security. The result
is the merging or consolidation of three layers. QUIC should improve
efficiency and delivery of applications, but also forces all data to
be managed at the endpoint, which in this case is a browser, making
it more difficult to manage traffic at the network layer.
3. Overarching Issues Related to Consolidation
3.1. Technical
Consolidation has led to the development of a few, large Internet
companies which consumers are using, as mentioned above. But
consolidation also has led to the development of a protocols which
are developed and used by these few, large Internet companies to
control traffic flow and data capture as well.
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Overarching technical issues related to consolidation include an
over-reliance on one or two entities and a handful of protocols.
Large stakeholders who have developed and implemented these
protocols control the rollout of upgraded versions without
competition of even knowledge of it due to the lack of diversity in
the market.
For example, over 80% of the web browser market is held by two
browsers: Chrome and Safari. Chrome alone accounts for 65% of the
market overall [13] The makers of Chrome and Safari, Google and
Mozilla, have dominated the development of protocols recently and
the development QUIC, DoH and TLS.
"Did the IETF create a better internet when it approved DoH? There's
a lot of disagreement about that, but what has upset many is that
DoH was a surprise - the IETF standardised it without consulting
some who it was likely to affect," it says in RFC 8890 [14] However,
there was little multistakeholder consultation and discussion prior
to the adoption of DoH. This was more of a rapid development and
deployment process, without the market driving the use cases and
uptake. But what did drive the rapid development was the need for
Google, with 65% of the browser market, to ensure that the data
coming into and onto their services remained there. By forcing the
concentration of the data at the endpoint, the data is consolidated
into the service provider at that endpoint. Does this make a better
internet?
3.2. Economic
According to the Internet Society's 2019 report Consolidation In the
Internet Economy the Internet economy is broadly defined as,
"economic activities that either support the Internet or are fundamentally dependent on the Internet's existence."[15] Internet
applications, service infrastructure and access provision are the
primary three areas of economic activities on the Internet.
One focus of consolidation is around the concentration of power -
consumer, technical and financial - into a handful of large Internet
companies. The first point of engagement with any of these
companies, including Facebook and Google, is through consumer
applications. The ability to easily understand consolidation at an
application layer, because of the widespread and common use of
Facebook and Google, has caused the focus of consolidation and anti-
competitive issues from policy makers and politicians to be at the
application layer.
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However, consolidation doesn't always have its downsides.
Consolidation allows for economies of scale, investment in
infrastructure and the ability for small and medium enterprises to
buy and use services, like cloud storage, content distribution
networks and security technology, without having to build them from
the ground up every time. However, the lack of market diversity
means a lack of competition which, in turn means a lack of
innovation and a lack of consumer choice.
Amazon offers affordable cloud services and Cloudflare is one of
only a handful of companies that are content delivery networks at a
large scale. So large, in fact, that a substantial amount of
Internet traffic transits through Cloudflare's servers, though there
are many thousands of small CDNs. Rather than each and every
Internet application company create their own storage and content
delivery network, it is easier and more affordable to outsource both
to other companies. Because of the cost of CDNs at scale, few
companies offer these services.
The market should be a regulating factor in consolidation. New
entrants and competition in a market creates options for consumers
that potentially pulls them away from popular websites and
applications. When a market is not competitive or viable, regulation
and anti-trust measures can intervene to remedy a consolidated
market which is tending towards or has achieved monopoly status.
Legal and regulatory intervention, however, tends to create its own
set of issues as seen through several decades of EU intervention in
big tech starting with Microsoft in 2004. Unintended consequences
with regulatory or legal intervention may skew the market even
further.
3.3. Security
Consolidation of protocol development which has facilitated the
secure, end to end encryption of information going over networks in
recent years. New technologies such as DNS-over-HTTPS (DoH) and DNS-
over-TLS (DoT) standardised through the IETF process allow for
confidential look up of DNS queries. However, it has forced updates
onto many DNS servers and operating systems. This change in the look
up process is forcing the technology to develop in a way which has
narrowed the ability for companies and small industries to do DNS
look ups without updating out of date hardware and software, thereby
disenfranchising developing countries and smaller companies without
big budgets. This is a form of market consolidation based on
development choices by several large companies. These development
choices are often technically opaque without transparency of what
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happens when updates take place, resulting in more difficulty when
trying to troubleshoot security issues.
The development of these protocols, while providing increased
privacy and addressing issues concerning government surveillance,
have forced other unintended consequences which is promoting
consolidation.
Consequences of the security of the global Internet are evident. On
June 8, 2021, a global outage of Fastly, a content delivery network
(CDN), was caused by a software update which included an
undiscovered bug. [16] While this was resolved within a working day,
one of the main causes of the outage was a dependency on the limited
number of CDNs running services in the cloud. Other CDNs, which
resolved traffic via Fastly for redundancy, were also taken down as
a result of the Fastly outage. This dependency is caused by
consolidation and a concentration of infrastructure. A highly
consolidated CDN network facilitates a less secure environment
because of the weakening of resilience [17]
4. Implications of Consolidation on Internet Architecture
4.1. The Changing Architecture of the Internet
The phenomenon of consolidation may be in the eyes of the beholder.
A government may see market failure or a need for regulation. [18] A
civil society advocate may see it from the point of view of privacy
or free speech. For the purposes of this draft we view it from the
perspective of the underlying architecture of the public Internet.
Consolidation in the Internet's architecture is not a new
development. The approach of providing intermediaries to deliver
service or content rather than the more traditional end-to-end
approach has been in place for more than a decade. However, it is
possible to argue that the architecture of the Internet has changed
dramatically in the last decade.
The architecture of the Internet is always changing. New services,
applications and content mean that the market creates new ways to
deliver them. Consolidation clearly has economic, social and policy
issues, but it is important to understand how consolidation affects
the underlying architecture of the Internet. The impact of
intermediaries on architecture is often not obvious.
The use of intermediaries in the Internet's architecture may include
the use of third parties to provide services, applications or
content. In the early days of the Web, this was evident when
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rendering a web page that included content from multiple sources. In
today's Internet the intermediaries are not so obvious.
Authentication servers, content distribution networks, certificate
authorities, malicious content protection and DNS resolution
services are all examples of tools provided to the Internet by
intermediaries - often without the knowledge or approval of both
endpoints.
Having intermediaries embedded in the architecture is a different
effect from having them embedded in the service structure. The
domination by a few companies of the content and application layer
is largely an economic effect of scale. On the other hand, there is
a prevalent belief that the Internet puts intelligence at the edge.
While that may have been true in the past, it is hard to argue that
this is a feature of the contemporary Internet.
There is a suggestion that the network simply provides for the
transport of data. There are almost no network connections like that
in today's Internet. A consumer's view of the Internet is limited
by unseen intermediaries of many types - some delivering positive
services, others not. In either case, a consumer on the Internet
seldom makes choices about those intermediaries: they are simply
part of the fabric that makes up the Internet.
It is into just consolidation from the perspective of a consumer.
Almost all important parts of the architecture have been affected by
consolidation: DNS resolution, access service, transit provision,
content distribution and authorization. Consolidation in these areas
has a direct effect on engineering and protocol design.
4.2. The End-to-End Principle Redux
The end-to-end principle is the idea that reliability and
trustworthiness reside at the end nodes of networks rather than in
the network itself. In other words, the idea was that the network
itself was dumb and intelligence was at the edge or end. However,
Internet architecture is evolving in such a way that this principle
is changing.
Networks and the devices on the networks are acting as access
consolidators. While, in the past, the network was a simple
transporter of bits, today's networks see intermediaries
consolidating both access and the delivery of information (e.g.
streaming media). For example, 5G will allow for different services,
systems and use cases at a very specific level. Network slicing in
5G will concentrate services like video on demand into concentrated
- and consolidation - areas on a network. [19] In other words, as
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specific types of services are relegated to a segregated part of a
network, the availability and access of that service is limited to
accessing a specific network. Depending on the type of device or
maturity of the network infrastructure available at the point of the
attempted access, options for access might be limited. If a network
slice on 5G is where a specific service is located, for example, but
it is only possible to use a 3G mobile network, then the service is
unavailable. Thus, the service is only available on a consolidated
part of the mobile network.
Another change is how the layers of the Internet, as discussed in
the QUIC example, are consolidating. Differentiation among layers is
fading fast with the development of applications which require
network access and control.
Rapidly, the end-to-end principle is becoming the edge-to-edge
principle. The layers of the internet are morphing into several
consolidated layers and it is becoming difficult to differentiate
between the end or edge, and also nearly impossible to ensure the
reliability of the internet because of it. But the important part of
this is the network is not dumb. Data processing, storage and highly
evolved services (including custom data and metadata processing at
the edge) means that the 'dumb' network is no longer dumb.
If the number of organizations that provide those "network services"
that we rely upon is small, our dependence is higher. In extreme
cases of engineering, we put ourselves at risk of engineering a
single point of failure. But also if organisations can't and won't
enter the market, the market is left with very few options and
choices. If the number of organizations that provide those "network
services" that we rely upon is small, our dependence is higher. In
extreme cases of engineering, we put ourselves at risk of
engineering a single point of failure.
The trend toward highly specific and concentrated processing, as
well as the drive for highly customised applications and services
will drive the Internet away from an end-to-end principle. This will
create not a network of networks, but a mesh. If the mesh is
dependent on a small number of very large providers through
consolidation, we will have engineered a single source of failure
into the Internet.
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5. Implications of Consolidation on Protocol Design
5.1. Does Protocol Design Really Affect Consolidation?
There is an idealized view of collaborative, multistakeholder
approaches to Internet protocol development that it is democratic
with all parties thinking about the greater good, like in the IETF.
In reality, protocol development and standards are subject to vested
interests, personal approaches and commercial realities.[20]
Developing protocols, and standards more generally, takes time, much
discussion and a bottom up approach. However, commercial
organisations have different goals in the process of trying to
standardize protocols. Larger organisations have more resources
dedicated to protocol and standards development. Larger
organisations with staff specifically dedicated to standards tend to
have the ability to push for their proposals and their protocols.
There is no coincidence that these companies are the ones that have
facilitated consolidation on a commercial level and are facilitating
consolidation on a protocol level.
5.2. Case Studies in Consolidation and Protocol Design
5.2.1. DNS over HTTPS (DOH)
The development of encrypted DNS, specifically DNS-over-HTTPS (DoH),
has been driven by a desire to show full end-to-end encryption of
network connections. The protocol was completed and the DoH working groupwound up in March 2020 despite the absence of both resolver
discovery and selection mechanisms. This may be addressed in the
future.[21]
Client software is developing with interim discovery solutions which
almost always favour the large, cloud-based resolver operators.
This is leading to a situation where users are being presented with
a very small number of pre-configured resolver options irrespective
of their location - in some client software as few as three or four
options may be presented. [22] Currently, there are many thousands
of servers operating without DoH.
It is likely that most of the DNS traffic will be consolidated onto
a handful of global operators, if multiple options for discovery
mechanisms are not developed. The impact that such a loss of
diversity of providers may have on the long-term resilience of DNS
should not be underestimated. [23] Nor should the attractiveness of
these potential network chokepoints to attack be overlooked either
to access consolidated data or launch an attack from.
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One danger is that if DNS traffic is concentrated onto a small
handful of global operators and turned 'automatically-on' the result
would be default adoption by the vast majority of the Internet's
clients. The suggestion that there were mechanisms for users to
opt-out would not matter in the face of statistics that regularly
show that users almost never change default settings. Currently, the
deployment approach for DoH is opt-in. For CDNs, DoH default-on
would disrupt and render CDN geolocation designed to manage traffic
flows more efficient closer to the desired delivery location. Thus,
protocol design decisions that are enshrined in default settings
will become the norm. In this case, default on, which facilitates
consolidation, will become standard.
By routing the DNS over HTTPS, it becomes much easier to track user
activity through the use of cookies. Therefore a protocol that was
developed to enhance user privacy and security could actually
undermine both: privacy through the use of cookies and security by
consolidating DNS traffic onto far fewer resolver operators that are
far more attractive targets for malicious actors of various types.
5.2.2. Encrypted Server Name Indication (eSNI)
Options to encrypt the Server Name Indication (SNI) have been
explored in the TLS working group but to date it has not been
possible to develop a solution without shortcomings. This flaw in
the encrypted SNI (eSNI) options under evaluation required a rethink
in the approach being taken.
The solution now proposed, Encrypted Client Hello (ECH, previously
called ECHO) assumes that private origins will co-locate with or
hide behind a provider (CDN, application server etc.) which can
protect SNIs for all of the domains that it hosts.[24] Whilst there
is logic in this approach, the consequence is that the would-be
standard encourages further consolidation of data to aid privacy.
What it does not appear to consider is the attractiveness of this
larger data pool to an attacker, compared with more dispersed
solutions.
5.2.3. Privacy Pass
The Privacy Pass protocol provides a set of cross-domain
authorization tokens that protect the client's anonymity in message
exchanges with a server. This allows clients to communicate an
attestation of a previously authenticated server action, without
having to reauthenticate manually. The tokens retain anonymity in
the sense that the act of revealing them cannot be linked back to
the session where they were initially issued.
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For Privacy Pass to succeed clients must be able to acquire tokens
that they can later redeem with greater privacy and anonymity. This
document does not discuss the goals of privacy or anonymity.
Instead, it identifies a problem related to the upper bound in
number of servers that affects the Privacy Pass ecosystem.
"Server centralization" is the strict limit or upper bound in the
number of servers available from which a client can acquire a token
for later redemption.
The architecture draft for Privacy Pass specifies an upper limit of
four for this upper bound. Four is a small number through which to
run authorizations. There is little room for mistakes or redundancy.
An upper bound to available Privacy Pass servers creates
architectural, engineering and practical problems for the deployment
of the protocol. Any successful deployment of Privacy Pass must find
mitigations for these problems.
6 Potential Technical Risks
There are a number of potential risks to the security, stability and
performance of the Internet and many of them are well articulated in
draft-livingood-doh-implementation-risks-issues-04, but some notable
ones are:
1. Significant operational shift of the global Internet from a
highly distributed to a centralised system. This would
impact both security and resilience.
2. Decreased stability due to the fact that a centralised
system will have higher fragility, fewer points of failure
and greater impact on the system when it does fail.
3. Increased security issues caused by the reduction of number
of recursive DNS operators. [see
https://hbswk.hbs.edu/item/evidence-of-decreasing-internet-
entropy-the-lack-of-redundancy-in-dns-resolution-by-major-
websites-and-services] Lack of distributed and recursive
DNS creates a lack of redundancy for when security attacks
hit parts of the Internet.
4. Loss of security threat visibility due to degraded ability
to use DNS blocklists and overall network management for
malware, phishing, spam, DDoS and etc if DNS management is
consolidated into a few operators.
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5. Reduced diversity in the Internet ecosystem. Diversity
creates greater redundancy, resilience and agility to
respond to attacks, outages and network issues.
6. Actions for the IETF, IRTF and IAB
This document proposes a set of concrete actions:
1] using MAPRG in the IRTF to attempt to establish metrics for
consolidation. The goal would be to attempt to gain consensus on
measurements for consolidation and a mechanism for gathering those
metrics over time to answer the question of how much and how quickly
the Internet is consolidating.
2] encouraging the consideration of consolidation in protocol design
either through the requirement of a new section in RFCs that
addresses consolidation or thorough guidance to area director
reviews of documents in IETF Last Call.
3] a new IAB workshop on the Implications of Consolidation on
Protocol Design with the goal of encouraging position papers from a
variety of stakeholders in the protocol design and implementation
process.
4] potentially expanding the human rights review process for
protocols to include examination of individual protocol design on
markets, enterprises and society.
5]attract and retain the participation of operators and implementors
who may be impacted.
6]ensure detailed community assessment of risks and issues. In
particular, assess the following issues:
. What is the threat model that makes this technical change
justifiable?
. What are the security and privacy implications?
. What are the implications for stability, operations, network
and systems administration, software development, diversity
and etc?
. Do the benefits outweigh any drawbacks?
. What alternatives to the changes could be made?
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7. Security Considerations
While this document does not describe a specific protocol, it does
discuss the evolving architecture of the Internet. Changes to the
Internet's architecture have direct and indirect implications for
the Internet's threat model. In another draft [25], we discuss how
the evolution of the Internet has changed the threat model.
Specifically, the changes to the end-to-end model (see section 4.2
above) have inserted new interfaces which must be reflected in
security considerations for new protocols.
8. IANA Considerations
This memo contains no instructions or requests for IANA. The authors
continue to appreciate the efforts of IANA staff in support of the
IETF.
9. Conclusions
This document seeks to rekindle and restart the discussion on
consolidation. As argued above, Internet consolidation is happening
at different places and different layers of the Internet. Though
there has been interest in the Internet consolidation in the past,
now is the time to start the discussions again.
10. References
10.1. Informative References
[1] Considerations on Internet Consolidation and the Internet
Architecture [draft-arkko-iab-internet-consolidation-02].
[2] IBID
[3] Google has over at least 80% worldwide market share.
https://www.statista.com/statistics/216573/worldwide-market-
share-of-search-engines/
[4] Investigation of Competition in Digital Markets, Subcommittee
on Antitrust, Commercial and Administrative Law of the
Committee on the Judiciary, United States House of
Representatives, 6 October 2020.
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[5] Following An Unexpected Rebound In M&A, Businesses Are Banking
On A New Kind Of Dealmaking For Growth In A Post-Covid World
https://www.prnewswire.com/news-releases/following-an-
unexpected-rebound-in-ma-businesses-are-banking-on-a-new-kind-
of-dealmaking-for-growth-in-a-post-covid-world-301228786.html
[6] Design Expectations vs. Deployment Reality in Protocol
Development Workshop 2019, Intern Architecture Board
https://www.iab.org/activities/workshops/dedr-
workshop/position-papers/
[7] Centralised Architecture in Internet Infrastructure [draft-
arkko-arch-infrastructure-centralisation-00].
[8] IBID page 5.
[9] Journal of Cyber Policy, Volume 5, Issue 1 (2020) Special
Issue: Consolidation of the Internet
(https://www.tandfonline.com/toc/rcyb20/5/1)
[10] Investigation of Competition in Digital Markets, Subcommittee
on Antitrust, Commercial and Administrative Law of the
Committee on the Judiciary, United States House of
Representatives, 6 October 2020.
[11] Statement of the Attorney General on the Announcement Of Civil
Antitrust Lawsuit Filed Against Google, United States
Department of Justice, 20 October 2020.
https://www.justice.gov/opa/pr/statement-attorney-general-
announcement-civil-antitrust-lawsuit-filed-against-google
[12] Digital Services Act package, European Commission, ongoing
https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/12418-Digital-Services-Act-package-ex-ante-
regulatory-instrument-of-very-large-online-platforms-acting-
as-gatekeepers
[13] Browser & Platform Market Share January 2021
https://www.w3counter.com/globalstats.php
[14] RFC 8890, The Internet is for End Users. Nottingham, Mark.
August 2020. https://www.rfc-editor.org/info/rfc8890
[15] Consolidation In the Internet Economy, Internet Society, 2019.
https://future.internetsociety.org/2019/consolidation-in-the-
internet-economy
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[16] Fastly Blog, June 8, 2021.
https://www.fastly.com/blog/summary-of-june-8-outage
[17] The Deeper Root Cause of the Fastly and Akamai Outages,
CircleID, June 28, 2021
https://www.circleid.com/posts/20210628-the-deeper-root-cause-
of-the-fastly-and-akamai-outages/
[18] See Google, antitrust and how to best regulate big tech, The
Economist, 7 October 2020
https://www.economist.com/business/2020/10/07/google-
antitrust-and-how-best-to-regulate-big-tech
[19] What is Network Slicing? https://5g.co.uk/guides/what-is-
network-slicing/
[20] Dominique Lazanski, Governance in international technical
standards-making: a tripartite model, Journal of Cyber
Policy, 4:3, 362-379, 2019.
https://www.tandfonline.com/doi/full/10.1080/23738871.2019.169
6851
[21] DNS over HTTPS (doh)
https://datatracker.ietf.org/group/doh/about/
[22] At the time of writing, the Firefox browser presents a list of
three pre-configured resolver options to North American users:
Cloudflare, NextDNS and Comcast.
[23] Cloudflare DNS goes down taking a large piece of the Internet
with it, 17 July 2020.
https://techcrunch.com/2020/07/17/cloudflare-dns-goes-down-
taking-a-large-piece-of-the-internet-with-it/
[24] TLS Encrypted Client Hello draft-ietf-tls-esni-07
https://tools.ietf.org/html/draft-ietf-tls-esni-07
[25] An Internet for Users Again draft-lazanski-smart-users-
internet-00 https://tools.ietf.org/html/draft-lazanski-smart-
users-internet-00
11. Acknowledgments
Many thanks to all who discussed this with us, especially Jason
Livingood.
This document was prepared using 2-Word-v2.0.template.dot.
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Authors' Addresses
Dominique Lazanski
Last Press Label
London, UK
Email: dml@lastpresslabel.com
Mark McFadden
Internet policy advisors ltd
Chepstow, Wales, UK
Email: mark@internetpolicyadvisors.com
Eliot Lear
Cisco Systems (Switzerland) GmbH
Richtistrasse 7
CH-8304 Wallisellen
Switzerland
Email: lear@cisco.com
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