Skip to main content

On the Effects of Internet Consolidation
draft-mcfadden-cnsldtn-effects-04

Document Type Active Internet-Draft (individual)
Authors Mark McFadden , Dominique Lazanski
Last updated 2024-10-19
RFC stream (None)
Intended RFC status (None)
Formats
Stream Stream state (No stream defined)
Consensus boilerplate Unknown
RFC Editor Note (None)
IESG IESG state I-D Exists
Telechat date (None)
Responsible AD (None)
Send notices to (None)
draft-mcfadden-cnsldtn-effects-04
Internet Engineering Task Force                         M. McFadden, Ed.
Internet-Draft                             internet policy advisors, ltd
Intended status: Informational                               D. Lazanski
Expires: 22 April 2025                                  Last Press Label
                                                         19 October 2024

                On the Effects of Internet Consolidation
                   draft-mcfadden-cnsldtn-effects-04

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.

Status of This Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at https://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on 22 April 2025.

Copyright Notice

   Copyright (c) 2024 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

McFadden & Lazanski       Expires 22 April 2025                 [Page 1]
Internet-Draft          Effects of Consolidation            October 2024

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents (https://trustee.ietf.org/
   license-info) in effect on the date of publication of this document.
   Please review these documents carefully, as they describe your rights
   and restrictions with respect to this document.  Code Components
   extracted from this document must include Revised BSD License text as
   described in Section 4.e of the Trust Legal Provisions and are
   provided without warranty as described in the Revised BSD License.

Table of Contents

   1.  Introduction  . . . . . . . . . . . . . . . . . . . . . . . .   3
   2.  Acknowledgement of Other Drafts and RFCs on This Topic  . . .   4
   3.  Background to Consolidation Issues and the Role of
           Standards . . . . . . . . . . . . . . . . . . . . . . . .   5
   4.  Overarching Issues Related to Consolidation . . . . . . . . .   6
     4.1.  Essential Taxonomy of Internet Consolidation  . . . . . .   6
     4.2.  Technical . . . . . . . . . . . . . . . . . . . . . . . .   7
     4.3.  Economic  . . . . . . . . . . . . . . . . . . . . . . . .   7
     4.4.  Security  . . . . . . . . . . . . . . . . . . . . . . . .   9
   5.  Centralization versus Consolidation . . . . . . . . . . . . .  10
   6.  Can Consolidation be Measured?  . . . . . . . . . . . . . . .  10
     6.1.  Metrics for Specific Protocols in Relation to
           Consolidation . . . . . . . . . . . . . . . . . . . . . .  10
     6.2.  Metrics for Specific Services in Relation to
           Consolidation . . . . . . . . . . . . . . . . . . . . . .  11
   7.  Implications of Consolidation on Internet Architecture  . . .  12
     7.1.  The Changing Architecture of the Internet . . . . . . . .  12
     7.2.  The End-to-End Principle Redux  . . . . . . . . . . . . .  14
   8.  Intermediaries and Consolidation  . . . . . . . . . . . . . .  15
   9.  Implications of Consolidation on Protocol Design  . . . . . .  16
     9.1.  Does Protocol Design Really Affect Consolidation? . . . .  16
     9.2.  Case Studies in Consolidation and Protocol Design . . . .  17
       9.2.1.  DNS over HTTPS (DoH)  . . . . . . . . . . . . . . . .  17
       9.2.2.  Encrypted Server Name Indication (eSNI) . . . . . . .  18
       9.2.3.  Oblivious HTTP  . . . . . . . . . . . . . . . . . . .  18
   10. Potential Technical Risks . . . . . . . . . . . . . . . . . .  19
   11. IANA Considerations . . . . . . . . . . . . . . . . . . . . .  19
   12. Security Considerations . . . . . . . . . . . . . . . . . . .  19
   13. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . .  20
   14. References  . . . . . . . . . . . . . . . . . . . . . . . . .  20
     14.1.  Informative References . . . . . . . . . . . . . . . . .  20
   Acknowledgements  . . . . . . . . . . . . . . . . . . . . . . . .  22
   Authors' Addresses  . . . . . . . . . . . . . . . . . . . . . . .  22

McFadden & Lazanski       Expires 22 April 2025                 [Page 2]
Internet-Draft          Effects of Consolidation            October 2024

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" (see section
   2, below).

   Internet consolidation is "the process of increasing control over
   internet infrastructure and services by a small set of
   organizations." [1] 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.  [Litmus] Or the number of web
   search providers or even web browser offerings.  [Statista] Indeed,
   the Internet has changed from being about bits on the wire and
   connectivity to the services and content it provides at the
   application layer.

   As defined in RFC9518 [RFC9518] "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.

   In this draft we argue that not all consolidation is related to
   economics.  In fact, the design of specific features of protocols can
   lead to consolidation in delivery of services at the application
   layer - and sometimes lower layers.  We believe that is what RFC9518
   argues that protocol designers should avoid.  We agree, provide
   examples and suggest that not everything in this problem space "is
   simply a question of economics."

   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.

McFadden & Lazanski       Expires 22 April 2025                 [Page 3]
Internet-Draft          Effects of Consolidation            October 2024

2.  Acknowledgement of Other Drafts and RFCs on This Topic

   This document recognizes that the topics of protocol design and
   centralization have been addressed by several people.  In this
   section we take a moment to recognize that we are not the first to
   come to this topic, nor will we be the last.  Our purpose is to
   examine the forms of centralization and how protocol design impacts
   them.

   In section 1 above we cited the RFC that discusses centralization in
   Internet protocols and relates it to consolidation of power.[RFC9518]
   The draft goes on to identify possible reactions to centralization
   and specifically what Internet protocols should do to limit or
   mitigate centralization.

   Another draft (now expired) explored a slightly different angle.  In
   draft-arkko-iab-internet-consolidation-02, the authors consider the
   topic from the perspective of how available technology and Internet
   architecture drives different market directions.[Arrko1] This draft
   ends with a call to action that emphasizes open interfaces, specific
   standardization choices and the benefits of open source development
   and the need for further research.

   Another important contribution to the discussion is a paper
   "Centrality and the Internet" published by Geoff Huston on his
   blog.[Huston] The paper explores the historical precedents for
   consolidation and the consequences of having large organizations
   control important parts of specific sectors of the economy.  It
   finishes with a look at the role of regulation in ensuring that the
   market functions properly and the impact of advertiser funding in
   creating a small number of dominating incumbents.

   Another recent paper, by a team from The Netherlands and Brazil,
   examines consolidation in the hosting industry.[Zembruzski] The paper
   focuses on that industry and shows how it is heavily concentrated: 10
   hosting providers account for most of the hosting for all TLDs
   considered.  While European ccTLDs have a strong hosting industry,
   US-based providers have been continuously conquering the market,
   especially in the high end of it - the popular domain names, which
   poses challenges for the European Union's goals of digital
   sovereignty.

   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[Arrko2], with

McFadden & Lazanski       Expires 22 April 2025                 [Page 4]
Internet-Draft          Effects of Consolidation            October 2024

   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".[Arrko2] 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.  [Lazanski]

   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 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.

3.  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 84% of all searches online.[Statista] But 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.
   Concern is growing over the fact that financial institutions are only
   using cloud services from a handful of cloud service
   providers.[Bankingdive] The acceleration of consolidation has been
   assisted by cloud technologies, such as occurred with email.  Thanks
   to ease of use enabled by cloud hosting, services like email and
   online payments can be accessed via a web browser.

   General purpose, more broadly capable platforms will increasingly
   have an advantage.  Specialized players must not only be better than
   their general purpose competitors to survive, they must be
   significantly better.  One theoretical advantage of general-purpose
   platforms is their streamlined user experience.  For instance, users
   do not need multiple logins or to navigate various user interfaces,

McFadden & Lazanski       Expires 22 April 2025                 [Page 5]
Internet-Draft          Effects of Consolidation            October 2024

   reducing cognitive load.  Given the current market's preference for
   and emphasis on user experience, specialized players must prioritize
   the user experience in their offerings.  They may also need to form
   partnerships to address some of their perceived weaknesses.

   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, ATT 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.

   The QUIC protocol[RFC9000] 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.

4.  Overarching Issues Related to Consolidation

4.1.  Essential Taxonomy of Internet Consolidation

   Discussions at the IETF (and elsewhere) have shown that different
   people have different views of how consolidation expresses itself.
   While there is little argument that the increasing control of
   Internet infrastructure and services is being coalesced into the
   hands of a small number of organizations.  However, that
   consolidation expresses itself in a variety of ways.

McFadden & Lazanski       Expires 22 April 2025                 [Page 6]
Internet-Draft          Effects of Consolidation            October 2024

   Another draft suggests a potential taxonomy of consolidation and
   proposes four main categories: [McFadden]

   *  Economic consolidation

   *  Traffic and infrastructure consolidation

   *  Architectural consolidation

   *  Service and Application Consolidation

4.2.  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.

   "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 [RFC8890]
   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.

4.3.  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."[ISOC] 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

McFadden & Lazanski       Expires 22 April 2025                 [Page 7]
Internet-Draft          Effects of Consolidation            October 2024

   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.

   Economic analysis of these dominant players often focuses on the
   network effects they exploit.  While this draft does not intend to
   explore the broader question of what, precisely, a network effect
   actually is, one definition could be the negative relationship
   between product/service price and network/service delivery size.
   There has been past research into finding evidence of network effects
   in markets such as home computers, ATMs, and spreadsheet programs.
   In these studies there is plausible evidence that network effects are
   in play, however the problem is to determine whether a given change
   in the relationship between price and the market is the result of
   network effects or some other underlying economy of scale in the
   particular market in question.  In light of this, one researcher hass
   said that "if future empirical work were to show that network effects
   are merely theoretical concepts, then government antitrust
   authorities should treat Internet-related markets like any other sort
   of product market or distribution channel in determining the presence
   (or lack) of viable competition."

   Indeed, the same research led to the following conclusion: "even if a
   case can be made that market power follows from network effects, it
   may be difficult to identify how a firm's market dominance followed
   from its conscious exploitation of existing network effects through

McFadden & Lazanski       Expires 22 April 2025                 [Page 8]
Internet-Draft          Effects of Consolidation            October 2024

   some sort of "attempt at monopolization".  Establishing this latter
   condition will likely raise a host of other, relatively messy,
   questions.  For example, what constitutes predatory or exclusionary
   conduct, and how should entry barriers be evaluated in a market
   characterized by network effects?"

   The market should be a primary 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.

   Economics is driving protocol design in a couple of different ways.
   First, participation in standardization is open and free, at least in
   one sense and for the IETF.  However, attending the IETF in person
   requires a financial commitment - not just for registration, but the
   travel, hotel and expenses are costly.  The very organizations that
   can afford to attend in person are the ones facilitating
   consolidation.

4.4.  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.

McFadden & Lazanski       Expires 22 April 2025                 [Page 9]
Internet-Draft          Effects of Consolidation            October 2024

   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.  [Fastly] 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.  [CircleID]

5.  Centralization versus Consolidation

   The words "centralization" and "consolidation" are often used
   interchangeably when discussing the idea of concentration within the
   internet.  However, centralization and consolidation are, in fact,
   different.  Consolidation is an economic choice one that is driven by
   economies of scale and efficiencies of work.  Consolidation through
   economic choices causes the outcome to be a centralized way of
   building Internet architecture and, thus, a centralized market with
   limited choices of technical and service options.

   Another draft [Arrko2] carefully considers the distinction between
   centralization and consolidation and concludes that decentralized
   technology - by itself - does not guarantee decentralized outcomes.
   That same draft describes consolidation 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."  That draft is careful to identify "Centralization" as the
   source of consolidation.

6.  Can Consolidation be Measured?

   While it is possible to describe the effects of Internet
   Consolidation, is it possible to measure them?  Several researchers
   have tried to establish metrics and then identify datasets that can
   be used as the source for measurements.

6.1.  Metrics for Specific Protocols in Relation to Consolidation

   One approach is to concentrate on a specific protocol and then
   identify metrics associated with that protocol.  In research
   published in 2022, one metric was the embedded page resources
   measured by DNS A records in HTTP pages.  The researchers then
   identified datasets covering longitudinal measurements of DNS records
   for 166.5 million Web domains over five years and measurements of DNS
   records for Alexa Top 1 million over a month.  In addition, source

McFadden & Lazanski       Expires 22 April 2025                [Page 10]
Internet-Draft          Effects of Consolidation            October 2024

   datasets of measurements of page loads and renders for 4.3 million
   webpages, which include data on 392.3 million requested resources
   were identified.

   The researchers then define "CDI penetration" as the ratio of CDI-
   hosted objects to all measured objects, which is a metric used to
   quantify consolidation around CDIs.

   In the period covered by the datasets, the researchers found that a
   set of six CDIs delivered the majority of content across all
   datasets, with these six CDIs being responsible for more than 80% of
   all 221.9 million CDI-delivered resources (56.6% of all resources in
   total).

   The researchers noted both good and bad outcomes from this
   measurement, pointing in particular to the ability of a small number
   of CDIs to deploy new technologies like TLS 1.3 more quickly.  In
   summary, the researchers said, "Overall, these observations indicate
   a potential oligopoly, which brings both benefits but also risks to
   the future of the Web."

6.2.  Metrics for Specific Services in Relation to Consolidation

   Another research result is to merge three separate metrics in a
   combined score to represent the level of consolidation on a country-
   by-country basis.

   The first of these metrics starts by labeling all nameservers a
   website uses as private or third-party.  This methodology begins by
   issuing NS queries to all the nameservers the website uses without
   resolving those names.  Initially, the nameserver is categorized as
   "unknown."  Then, if the second-level domain is matched to the
   website's domain, it is classified as "private."  Finally, a set of
   heuristics are used to examine cases where a website's domain differs
   from the DNS server's domain.  For example, the SOA record for
   imdb.com is amazon.com, and its nameservers are Dynet and UltraDNS.
   In these cases, the website is labelled as using two third-party DNS
   providers.

   In addition, the researchers also measured the percentage of websites
   that are served by a single DNS provider (in other words, critically
   dependent on that provider) or served by multiple third-party DNS
   providers and the percentage of websites that are served by private
   and third-party DNS providers.

   The second of the three metrics used in this study uses a complicated
   methodology of analyzing the CNAMEs of all internal resources used on
   the website.  This also allows the categorization of CDNs as

McFadden & Lazanski       Expires 22 April 2025                [Page 11]
Internet-Draft          Effects of Consolidation            October 2024

   "private" or "third-party."  It is also possible to use the
   methodology to study websites redundantly provisioned by multiple
   CDNs.  Once again, by analyzing the CNAME records of internal
   resources for the website, it is possible to identify whether a
   "private" CND is in use, or if one or more "third-party" CDNs are in
   use.

   The final metric relates to websites that support HTTPS.  Using a
   similar approach as above, the methodology identifies whether the
   certificate authority in use is a "third-party" (for instance,
   DigiCert) or a private CA (for instance, a CA run by the company
   associated with the website).

   By combining these metrics, it is possible to answer empirical
   questions.  The researchers posed three distinct questions:

   *  How common is the third-party dependency of websites around the
      world?

   *  How much of this dependency is critical, dependent on a single
      third-party DNS or CDN provider?

   *  How concentrated is the market of third-party service providers
      within a country, region, and globally?

   While this study is a snapshot in time (the research was published in
   2023), what is undeniable is that you can identify metrics, study
   those metrics over time, and then draw conclusions about trends in
   consolidation in the market.  Both studies also show that it is
   possible to identify individual metrics associated with individual
   protocols and assess the extent and rate of change for the
   consolidation of individual protocols and technologies.

7.  Implications of Consolidation on Internet Architecture

7.1.  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.[Economist] 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.

McFadden & Lazanski       Expires 22 April 2025                [Page 12]
Internet-Draft          Effects of Consolidation            October 2024

   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
   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.

McFadden & Lazanski       Expires 22 April 2025                [Page 13]
Internet-Draft          Effects of Consolidation            October 2024

7.2.  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.  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.

McFadden & Lazanski       Expires 22 April 2025                [Page 14]
Internet-Draft          Effects of Consolidation            October 2024

   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.

8.  Intermediaries and Consolidation

   Internet privacy concerns have encouraged protocol designers to take
   a more aggressive approach to ensuring privacy in communications.  In
   the past, a secure channel using technologies such as TLS or IPsec
   provided a way to ensure that point-to-point communications was
   protected while information was in transit.  Providing privacy (and
   authentication of the data stream) occurred between the endpoints of
   communication.

   However, it became widely recognized that this was insufficient.  In
   particular, a secure channel between two endpoints does not guarantee
   that the information will remain private at the endpoints.  As the
   importance of privacy increased, so too did the attempt to fashion
   protocols that increased the protection of the data a the endpoints.

   A draft from the IAB describes the technique for separating the data
   and metadata visible to diverse parties in network communication as
   "privacy partitioning."[IABPartitioning] It notes that a group of
   IETF working groups are using this intermediary strategy as a
   protocol-based, technical approach to improving privacy at the ends
   of network connections.  The working groups involved include OHAI,
   MASQUE, Privacy Pass and PPM.  All four have in common a general
   strategy of using an intermediary to provide a higher level of
   privacy for endpoints.

   The use of intermediaries is nothing new: we have had HTTP proxy
   services in the Internet almost since the advent of the Web. What has
   changed is the dominance of privacy preservation in protocol design.
   The intermediaries that provide the privacy partitions are in a
   special and notable place in a network connection.  The former end-
   to-end principle drops away and in its place are two connections: one
   between an end user and the intermediary and the other between the
   intermediary and the requested service or application.

McFadden & Lazanski       Expires 22 April 2025                [Page 15]
Internet-Draft          Effects of Consolidation            October 2024

   The risk of consolidation to the is approach would mean that a
   dominant set of large companies provide the intermediary services.
   That would lead to the possibility of collusion with the consequence
   that no privacy was actually provided.  A centralized service
   providing the "privacy partitioning" could log requests and share
   information about patterns of use or actual, specific user
   information.

   The result is that "privacy partitioning" needs to be considered as
   part of the consolidation landscape.  The result of having a very
   small number of dominant providers acting as the intermediaries would
   lead to some of the same risks as economic or traffic consolidation
   already exhibit.

9.  Implications of Consolidation on Protocol Design

9.1.  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.[IABProDevWkSshp] Developing
   protocols, and standards more generally, takes time, much discussion
   and a bottom-up approach.  However, commercial organizations have
   different goals in the process of trying to standardize protocols.
   Larger organizations have more resources dedicated to protocol and
   standards development.  Larger organizations 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.

   There is clear evidence that concentration in the marketplace
   redistributes risk.  In fact concentration can change who is the
   target of attacks or malware.  Large operating systems, platforms,
   protocols and organizations often act as magnets for malicious
   activity.  In addition, some organizations attempt to reduce their
   risk by transferring their security requirements to larger
   organizations (for instance, CDNs or cloud service providers).
   However, that transfer can lead to the redistribution of the attacks:

McFadden & Lazanski       Expires 22 April 2025                [Page 16]
Internet-Draft          Effects of Consolidation            October 2024

   for instance, a smaller organization that was once "under the radar"
   is now subject to all the attacks on the larger infrastructure
   provider.  This is an example of the fact that when major providers
   of infrastructure fall victim to attacks, the impact can be far more
   significant than when the systems are highly distributed.

9.2.  Case Studies in Consolidation and Protocol Design

9.2.1.  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.[RFC8484]

   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.  [Arrko2] 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.  [Bates] 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

McFadden & Lazanski       Expires 22 April 2025                [Page 17]
Internet-Draft          Effects of Consolidation            October 2024

   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.

9.2.2.  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.[ECH] 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.

9.2.3.  Oblivious HTTP

   Oblivious HTTP (OHTTP)[OHTTP] is a relay based intermediary system
   that attempts to provide an extra layer of privacy by incorporating
   per-message encryption in the relay exchange.  A client sends a
   request to an Oblivious Relay which is not allowed to read its
   contents.  The request is forwarded to an Oblivious Gateway which is
   able to decrypt the messages but does not know the identity of the
   client or any metadata (for instance, source IP address) related to
   the client.

   The key to OHTTP's privacy features is that the client metadata and
   request data are separated into separate contexts: the goal is that
   no entity (other than the client) can see both contexts.

   The major risk in OHTTP is collusion across those contexts.  If a
   small number of providers of the OHTTP services dominated, the risks
   of collusion might be expanded - specifically, protections against
   collusion and the exposure of user identifying information would be
   greater in a marketplace without a variety of servers to provide the
   service.

McFadden & Lazanski       Expires 22 April 2025                [Page 18]
Internet-Draft          Effects of Consolidation            October 2024

10.  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 [Arrko3], 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][Bates] 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.

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

11.  IANA Considerations

   This memo includes no request to IANA.

12.  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.

McFadden & Lazanski       Expires 22 April 2025                [Page 19]
Internet-Draft          Effects of Consolidation            October 2024

13.  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.

14.  References

14.1.  Informative References

   [Arrko1]   Arrko, J., "Considerations on Internet Consolidation and
              the Internet Architecture [draft-arkko-iab-internet-
              consolidation-02] (Expired)", 2019.

   [Arrko2]   Arrko, J., "Centralised Architecture in Internet
              Infrastructure [draft-arkko-arch-infrastructure-
              centralisation-00] (Exxpired)", 2020.

   [Arrko3]   Livingood, J., "Centralized DNS over HTTPS (DoH)
              Implementation Issues and Risks,
              [https://datatracker.ietf.org/doc/draft-livingood-doh-
              implementation-risks-issues/] (Expired)", 2020.

   [Bankingdive]
              Industry Dive, Informa, "Cloud providers pose potential
              risk to banking sector: Treasury report", 2023,
              <https://www.bankingdive.com/news/cloud-providers-pose-
              potential-risk-banking-sector-treasury-report/642428/>.

   [Bates]    Bates, S., Bowers, J., Greenstein, S., Weinstock, J., and
              J. Zittrain, "Evidence of Decreasing Internet Entropy: The
              Lack of Redundancy in DNS Resolution by Major Websites and
              Services [https://hbswk.hbs.edu/item/evidence-of-
              decreasing-internet-entropy-the-lack-of-redundancy-in-dns-
              resolution-by-major-websites-and-services]", 2018.

   [CircleID] CircleID, "The Deeper Root Cause of the Fastly and Akamai
              Outages", 2021, <https://www.circleid.com/posts/20210628-
              the-deeper-root-cause-of-the-fastly-and-akamai-outages/>.

   [ECH]      Rescorla, E., Oku, K., Sullivan, N., and C. Wood, "TLS
              Encrypted Client Hello
              [https://datatracker.ietf.org/doc/draft-ietf-tls-esni/]",
              2023.

McFadden & Lazanski       Expires 22 April 2025                [Page 20]
Internet-Draft          Effects of Consolidation            October 2024

   [Economist]
              The Economist, "Google, antitrust and how to best regulate
              big tech", 2020,
              <https://www.economist.com/business/2020/10/07/google-
              antitrust-and-how-best-to-regulate-big-tech>.

   [Fastly]   Fastly Blog, "Target of the June 8th Outage", 2021,
              <https://www.fastly.com/blog/summary-of-june-8-outage>.

   [Huston]   Huston, G., "Centrality and the Internet
              [https://www.potaroo.net/ispcol/2021-06/centrality.html]",
              2021.

   [IABPartitioning]
              Internet Architecture Board, "Partitioning as an
              Architecture for Privacy", 2023,
              <https://datatracker.ietf.org/doc/draft-iab-privacy-
              partitioning/>.

   [IABProDevWkSshp]
              Internet Architecture Board, "Design Expectations vs.
              Deployment Reality in Protocol Development Workshop",
              2019, <https://www.iab.org/activities/workshops/dedr-
              workshop/position-papers/>.

   [ISOC]     The Internet Society, "Consolidation In the Internet
              Economy", 2019, <https://future.internetsociety.org/2019/
              consolidation-in-the-internet-economy>.

   [Lazanski] D. Lazanski, Journal of Cyber Policy, "Governance in
              international technical standards-making: a tripartite
              model, Journal of Cyber Policy", 2019,
              <https://www.tandfonline.com/doi/
              full/10.1080/23738871.2019.169.6851>.

   [Litmus]   Litmus Software, Inc., "Email Market Share", 2022,
              <https://www.litmus.com/blog/email-client-market-share-
              april-2022/>.

   [McFadden] McFadden, M., "A Taxonomy of Internet Consolidation
              [https://datatracker.ietf.org/doc/draft-mcfadden-
              consolidation-taxonomy/]", 2024.

   [OHTTP]    Thomson, M. and C. Wood, "Oblivious HTTP
              [https://www.ietf.org/archive/id/draft-thomson-http-
              oblivious-01.html]", 2023.

McFadden & Lazanski       Expires 22 April 2025                [Page 21]
Internet-Draft          Effects of Consolidation            October 2024

   [RFC8484]  Hoffman, P. and P. McManus, "DNS Queries over HTTPS
              (DoH)", RFC 8484, DOI 10.17487/RFC8484, October 2018,
              <https://www.rfc-editor.org/info/rfc8484>.

   [RFC8890]  Nottingham, M., "The Internet is for End Users", RFC 8990,
              DOI 10.17487/RFC8990, August 2020,
              <https://www.rfc-editor.org/info/rfc8890>.

   [RFC9000]  Iyengar, L. and M. Thomson, "QUIC: A UDP-Based Multiplexed
              and Secure Transport", RFC 9000, DOI 10.17487/RFC9000, May
              2021, <https://www.rfc-editor.org/info/rfc9000>.

   [RFC9518]  Nottingham, M., "Internet Centralization: What Can
              Standards Do? [RFC9518]", 2023.

   [Statista] Statista, "Search Engine Market Share Market Share", 2022,
              <https://www.statista.com/statistics/216573/worldwide-
              market-share-of-search-engines/>.

   [Techcrunch]
              TechCrunch, "Cloudflare DNS goes down taking a large piece
              of the Internet with it", 2020,
              <https://techcrunch.com/2020/07/17/cloudflare-dns-goes-
              down-taking-a-large-piece-of-the-internet-with-it/>.

   [W3Counter]
              Awio Web Services LLC, "Browser and Platform Market Share
              January 2021", 2021,
              <https://www.w3counter.com/globalstats.php>.

   [Zembruzski]
              Zembruzski, L., Sommese, R., Granville, L.Z., Selle
              Jacobs, A., and M. Jonker, "Hosting Industry
              Centralization and Consolidation
              [https://ieeexplore.ieee.org/abstract/document/9789881/]",
              2021.

Acknowledgements

   Many thanks to all who discussed this with us, especially Jason
   Livingood, Geoff Huston and Jari Arkko.

   Many thanks to all who discussed this with us in DINRG in 2021, 2022,
   2023, and 2024.

Authors' Addresses

McFadden & Lazanski       Expires 22 April 2025                [Page 22]
Internet-Draft          Effects of Consolidation            October 2024

   Mark McFadden (editor)
   internet policy advisors, ltd
   6 Bridge Street
   Chepstow
   NP16 5EY
   United Kingdom
   Phone: +1 608 504 7776
   Email: mark@internetpolicyadvisors.com

   Dominique Lazanski
   Last Press Label
   London
   United Kingdom
   Email: dml@lastpresslabel.com

McFadden & Lazanski       Expires 22 April 2025                [Page 23]