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Protocol and Engineering Effects of Consolidation
draft-lazanski-consolidation-04

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Authors Dominique Lazanski , Mark McFadden
Last updated 2022-07-24
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draft-lazanski-consolidation-04
Independent Submission                                      D. Lazanski
Internet Draft                                         Last Press Label
                                                            M. McFadden
                                          Internet policy advisors, ltd
Intended status: Informational                            July 24, 2022
Expires: January 24, 2023

             Protocol and Engineering Effects of Consolidation
                    draft-lazanski-consolidation-04.txt

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Abstract

This document contributes to the continuing discussion on Internet
consolidation. Over the last several years there have been many types
of discussions around consolidation at a technical level, an economic
or market level and also at an engineering level. This] document aims
to discuss recent areas of Internet consolidation 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.........7
      4.1. The Changing Architecture of the Internet.................7
      4.2. The End-to-End Principle Redux............................8
   5. Implications of Consolidation on Protocol Design..............10
      5.1. Does Protocol Design Really Affect Consolidation?........10
      5.2. Case Studies in Consolidation and Protocol Design........10
         5.2.1. DNS over HTTPS (DoH)................................10
         5.2.2. Encrypted Server Name Indication (eSNI).............11
         5.2.3. Privacy Pass........................................11
   6. Potential Technical Risks.....................................12
   7. Security Considerations.......................................13
   8. IANA Considerations...........................................13
   9. Conclusions...................................................13
   10. References...................................................13
      10.1. Informative References..................................13
   11. Acknowledgments..............................................15

1. Introduction

The origins of the Internet was and continues to be decentralised.
Resilience, security and best-effort delivery of data and information
on all layers of the Internet works best in a decentralised manner. But
over the last several years there have been discussions on how the
Internet is becoming "centralised" or "consolidated".

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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]

As defined in draft-nottingham-avoiding-Internet-centralization-04
"centralization" as the ability of a single entity or a small group of
them to exclusively observe, capture, control, or extract rent from the
operation or use of an Internet function. Furthermore, "centralisation"
as noted in the Internet of three Protocols is that one or two or three
single protocols are being used for everything rather than one protocol
for one operation as is a guiding principle of protocol design until
now.

The Internet is being centralised and, thus, consolidated on all layers
of the Internet and it is essential to recognise the technical,
political and economic reasons for this happening. The rest of this
draft will focus on different aspects of the issue of consolidation.

2. Background to Consolidation Issues and the Role of Standards

The Internet is being consolidated at all layers, from the application
layer to the network layer. In the context of search online 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.

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In other market consolidation cases, fewer Internet standards are in
play.  In the case of home assistant tools such as the Amazon Echo 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.

In years past, 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.

Both the Internet Society and participants of the IETF have published
on the subject of consolidation in 2019. At the IAB's Design
Expectations vs. Deployment Reality in Protocol Development Workshop
2019 a handful of the participants discussed concentration and
consolidation. 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]

The 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

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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 by way of platform consolidation,
as mentioned above. But consolidation also has led to the development
of protocols which are developed and used by these few, large Internet
companies to control traffic flow and data capture as well.

Overarching technical issues related to consolidation include an over-
reliance on one or two entities and a handful of protocols. Certain
stakeholders who have developed and implemented these protocols manage
the updated and upgraded versions of the protocols.

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 major web platforms, have dominated
the development of protocols recently and the development QUIC, DoH and

"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. By
forcing the concentration of the data at the endpoint, the data is
consolidated into the service provider at that endpoint.

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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
policymakers and politicians to be at the application layer.

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.

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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 required updates to many DNS
servers and operating systems. The implementation of this protocol
enables circumvention of DNS filtering which ISPs offer for protection
from malicious websites and software on the network.

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 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 for
another 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

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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 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

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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 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.

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?

As noted in "Internet of Three Protocols" draft, "One of the guiding
principles of designing a protocol in the original Internet community
was "the protocol is not complete when everything possible has been
added, but rather when everything possible has been removed."  This is
so that security, scalability, resilience and observability can be
ensured. However, the recent trend has been towards having a few
protocols, but having those protocols do all things.

Though Internet protocol development should be multistakeholder, but
standards development is 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
group wound 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.

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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. 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

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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.

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,

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spam, DDoS and etc if DNS management is consolidated into a few
operators.

5. Reduced diversity in the Internet ecosystem. Diversity creates
greater redundancy, resilience and agility to respond to attacks,
outages and network issues.

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.

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 document requests no actions on the part of IANA.

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/

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[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.

[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, Internet 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

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[15]  Consolidation In the Internet Economy, Internet Society,
2019.https://future.internetsociety.org/2019/consolidation-in-the-
internet-economy

[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
United Kingdom
Email: dml@lastpresslabel.com

Mark McFadden
Internet policy advisors ltd
Chepstow
United Kingdom
Email: mark@internetpolicyadvisors.com

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