Independent Submission                                      D. Lazanski
Internet Draft                                         Last Press Label
                                                            M. McFadden
                                          Internet policy advisors, ltd

Intended status: Informational                             Oct 24, 2022
Expires: April 24, 2023

             Protocol and Engineering Effects of Consolidation

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Copyright Notice

   Copyright (c) 2022 IETF Trust and the persons identified as the
   document authors. All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
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   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, a
   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...................................................3
   2. Background to Consolidation Issues and the Role of Standards...3
      2.1. Process...................................................4
   3. Overarching Issues Related to Consolidation....................5
      3.1. Economic..................................................5
      3.2. Security..................................................6
   4. <Implications of Consolidation on Internet Architecture........7
      4.1. Changing Internet architecture............................7
      4.2. 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........................................12
   6. Potential Technical Risks.....................................12
   7. Security Considerations.......................................13
   8. IANA Considerations...........................................13

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   9. Conclusions...................................................13
   10. References...................................................13
      10.1. Normative References....................................13
   11. Acknowledgments..............................................15

1. Introduction

   The Internet itself is a decentralised network of networks.
   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" and

   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-05
   "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

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. Today's traffic over the
   Internet is primarily derived from search and content companies. The
   current set of Internet protocol standards, often originating from

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   work at one of these companies, has facilitated the push to a more
   consolidated Internet.

   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.

   Since 2019 a number of organisations and individuals published on
   the subject of consolidation. Most notably the Internet Society
   focused on consolidation as a key topic for their 2019 Global
   Internet Report [4] Additionally, the Journal of Cyber Policy
   published a special edition on Consolidation. Topics in this special
   issue included market concentration and security, DNS consolidation,
   supply chains, interoperability and Internet architecture. [5]

   Discussion of consolidation primarily focuses on Internet services
   and data. However, there is more to consolidation than just
   applications and services. 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 transport layer protocol
   development is focused on the end-to-end encryption model which,
   when implemented, forces data to the end points. Thus, the data is
   managed at the endpoints only and not managed throughout its entire
   transit. This results in a limited number of available options for
   the use of the data.

   The QUIC protocol is an example of the consolidation between layers
   of the Internet. 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 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 or application, making it
   more difficult or impossible to manage traffic at the network layer.

2.1. Process

   Another key point to make is that the process of standards
   development impacts the outcome and adoption of the standard. This
   is key for consolidation. Though Internet protocol development

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   should be multistakeholder, standards development is subject to
   vested interests, personal approaches and commercial realities. [6]
   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.

3.  Overarching Issues Related to Consolidation

   In A Taxonomy of Internet Consolidation, a new draft by Mark
   McFadden, a set of typologies for Internet consolidation is clearly
   and concisely outlined. Four main areas, namely economic, traffic
   and infrastructure, architectural and service and application
   consolidation create a taxonomy that can be used to articulate the
   different issues and challenge of consolidation.

   Consolidation has led to the use of a few, large online platforms
   which is facilitated by choice and market consolidation. But
   consolidation also has led to the development of a protocols manage
   traffic flow and capture data. The over-reliance on one or two
   entities for delivery of that use a small handful of protocols has
   led to technical dependencies on these 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 [7] 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.

3.1. Economic

   According to the Internet Society's 2019 report, consolidation is
   broadly defined as, "economic activities that either support the
   Internet or are fundamentally dependent on the Internet's

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   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.

   However, consolidation also has upsides. 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.

   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

3.2. Security

   Consolidation of protocol development has facilitated the secure,
   end to end encryption of information going over networks in recent
   years. New technologies such as DNS-over-HTTPS (DoH), Oblivious DNS
   over HTTPs (ODOH)and DNS-over-TLS (DoT) standardised through the
   IETF allow for confidential look up of DNS queries. However, it has
   required updates onto many DNS servers and operating systems. The
   implementation of these protocols enable 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

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   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

   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. [10] While this was resolved within a working day,
   one of the main causes of the outage was a consequence of 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 [11]

   On 22 June 2022 Cloudflare suffered an outage that lasted just over
   an hour and impacted 19 data centers. Though the outage was due to a
   misconfiguration that was quickly resolved, the impact of the outage
   renewed calls for a critical look at decentralising the Internet. A
   handful of cloud and infrastructure providers are responsible for
   global connections. This outage was a reminder of the need to think
   about resilience and security in global Internet connectivity. [12]

4. Implications of Consolidation on Internet Architecture

4.1. Changing Internet architecture

   The phenomenon of consolidation may be in the eyes of the beholder.
   A government may see market failure or a need for regulation. [13] 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.

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   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

   Having intermediaries embedded in the architecture is a different
   effect from having them embedded in the service infrastructure. 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. A consumer on the Internet
   seldom makes choices about those intermediaries: they are simply
   part of the fabric that makes up the Internet.

   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. 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

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   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 act 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. [14] 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. In other words, if a handful of organisations enable end to
   end encryption and those same organisations also offers services at
   the edge, then only a handful of organisations provide the entire
   value chain. This is consolidation.

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   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.

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

   So, in effect, the protocols themselves are becoming consolidated.
   The point of protocol design is not to develop all things on one
   protocol, but to have a protocol that improves the sustainability of
   the Internet.

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.[15] 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. [16] Currently, there
   are many thousands of DNS 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

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   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. [17] 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 is '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.[18] 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.

   eSNI can be implemented by a "fronting" service which protects a
   hidden service behind it. Because the client will not verify the
   identity of this fronting service, server spoofing attacks are
   possible. Indeed, the fronting service could be pressured by
   attackers. The fronting service then becomes a rich source of

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   information about client connections and an attractive attack
   surface for adversaries.

    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.

   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 current architecture of privacy pass
   strictly limits the number of participants (so-called Attesters or
   Issuers). The current architecture suggests a non-protocol approach
   to addressing the centralization problem (through a multi-
   stakeholder governance model) and also suggests a different approach
   where a quorum of parties acted in a way where clients would have
   more opportunities to switch between attestation participants.

   However, neither of these approaches is required by the Privacy Pass
   architecture document and the centralization problem created by the
   specification of the protocol is left to implementations to solve.

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
   DoH Implementation Risks [19], 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.

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   3. Increased security issues caused by the reduction of number of
   recursive DNS operators. [20] 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

   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 memo contains no instructions or requests for IANA.

9. Conclusions

   This document seeks to further continue the discussion on
   consolidation. As argued above, Internet consolidation is happening
   at different places and different layers of the Internet and ongoing
   discussions, particularly in DINRG group.

10. References

10.1. Normative References

   [1]   Considerations on Internet Consolidation and the Internet
            Architecture [draft-arkko-iab-internet-consolidation-02].

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      [2]   IBID

      [3]   Google has over at least 80% worldwide market share.


      [5]   Centralised Architecture in Internet Infrastructure [draft-
            arkko-arch-infrastructure-centralisation-00]page 5.

      [6]   Dominique Lazanski, Governance in international technical
            standards-making: a tripartite model, Journal of Cyber
            Policy, 4:3, 362-379, 2019.

      [7]  RFC 8890, The Internet is for End Users. Nottingham, Mark.
            August 2020.

      [8]  Consolidation In the Internet Economy, Internet Society,


      [10]  Fastly Blog, June 8, 2021.

      [11]  The Deeper Root Cause of the Fastly and Akamai Outages,
            CircleID, June 28, 2021

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      [13]  See Google, antitrust and how to best regulate big tech,
            Economist, 7 October 2020

      [14]  What is Network Slicing?

      [15]  DNS over HTTPS (doh)

      [16]  At the time of writing, the Firefox browser presents a list
            three pre-configured resolver options to North American
            Cloudflare, NextDNS and Comcast.

      [17]  Cloudflare DNS goes down taking a large piece of the
            with it, 17 July 2020.

      [18]  TLS Encrypted Client Hello draft-ietf-tls-esni-07


11. Acknowledgments

   Many thanks to all who discussed this with us, especially Jason
   Livingood and Eliot Lear.

   This document was prepared using

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Authors' Addresses

   Dominique Lazanski
   Last Press Label
   London, UK


   Mark McFadden
   Internet policy advisors ltd
   Chepstow, Wales, UK


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