CELLULAR
OPERATORS JOINT SUBMISSION
1.
INTRODUCTION
Vodacom (Pty) Ltd, MTN (Pty) Ltd and
Cell C (Pty) Ltd (“collectively referred to as the mobile operators”) welcome
the opportunity to comment on the Films and Publications Amendment Bill, B27 of
2006 (“the FP Bill”). We further request the Parliamentary Portfolio Committee
on Home Affairs (“the Committee”) to afford each
of us individually an opportunity to address them on our collective
concerns on the FP Bill as well as our individual initiatives to protect
children against age inappropriate content over mobile cellular phones.
The mobile operators recognise the
need for legislative certainty on the jurisdictional scope of the Films and
Publications Act, 2006 (“the Act”) over mobile content services and trust that
the FP Bill will provide a regulatory framework that is clear and certain for
regulation of the ever-changing mobile content services industry.
The mobile operators’ comments are
presented in the following manner:
-
Comments on specific
provisions of the FP Bill;
-
General principle
comments; and
-
Conclusion.
In this document the mobile operators’
suggested amendments to the draft Bill are, in the case of additions, marked in
bold and underlining; and in
the case of deletions marked in bold
and strikethrough.
2.
COMMENTS ON SPECIFIC PROVISIONS
OF THE FP BILL
2.1.
Proposed amendments to section 1
The mobile operators welcome the
proposed insertion of the definitions of ‘child abuse’, ‘classification office’
and ‘interactive computer game’. However, the mobile operators wish to highlight
the following issues with regards to these definitions:
(a)
The definition of child
abuse
The mobile operators have noted that
the definition of ‘child abuse’ seems to be restricted to sexual exploitation
of children in one form or another despite the fact that ‘child abuse’ is
something which (in some instances) extends beyond sexual exploitation of
children i.e. there are other types of abuse that may be perpetrated against
children. The Children’s Act, (Act No. 38 of 2005) clearly defines abuse as “any
form of harm or ill-treatment deliberately inflicted on a child”. The mobile operators
therefore suggest that the definition be expanded to cover other forms of abuse
against children or refer to the definition contained in the Children’s Act.
(b)
The definition of
‘chat-rooms’
Section 24C of the FP Bill refers to
internet service providers who provide child-orientated services, including
‘chat-rooms’. It is the mobile operators’
contention that internet service providers generally do not provide the chat-room
service, but rather, they host the websites. It is accordingly crucial that the
relevant distinction between the mobile operators and internet service
providers (who merely enable access to or host the service) and chat-room
service providers (who provide the chat-room service) be made.
Furthermore, the term “chat-room” is
not defined in the FP Bill. The mobile operators seek clarity on what
constitutes a ‘chat-room’ as contemplated in terms of the proposed section 24C,
in particular as it relates to the requirement that the provider of a
‘chat-room’ service must monitor such service to ensure that it is not
used for purposes of commission of crimes against children. Depending on what
constitutes a chat-room, the mobile operators are concerned that the
requirement for monitoring may potentially infringe customers’ rights to
privacy. In addition, monitoring of such hosted chat room services would be
beyond the abilities of the mobile operators to comply with as it is
practically impossible.
It is our
understanding that a chat-room is an
online (over the World Wide Web) site in which people hold discussions by
sending messages to people on the same site in real time. A chat-room
may be constituted of people that the user knows and has included on a “buddy”
list (peer to peer communication), or may be a discussion in which the user is
totally anonymous (i.e. general in nature, using the World Wide Web).
Thus there are two key
characteristics of chat-rooms: one, they are online; and two, they are
real-time. In our view, both characteristics must be present for a space to be
considered a chat-room. For example,
chat rooms (which are always online and real time and may be both general and
peer to peer) are distinct from discussion
groups or online forums, which although on-line, are not
real time and are strictly peer to peer. It should also be noted that
text-based services, such as SMS or MMS, would also not be considered chat-room
services as they are not on-line or real time and constitute strictly peer to
peer private communications.
In order to avoid uncertainty on the
issue, the mobile operators suggest the following amendment to section 24C. We
further propose the addition of a definition for ‘chat-room’:
|
24C (1) (a) …. “chat-room” means a World Wide Web site in which people
hold discussions by sending messages to people on the same site in real
time, both generally and on a peer to peer basis. |
2.2.
Proposed amendments to section 2
(a)
Reference to broadcasting
The stated objective of protecting
children from potentially disturbing, harmful or age-inappropriate materials in
interactive computer games or provided on sites accessible via mobile cellular
telephones is highly commendable. However, the mobile operators caution that
the wording of section 2(a), in so far as it provides for the regulation of
‘broadcasting’, may be in contravention of section 192 of the Constitution
(Constitution of the Republic of South Africa Act No. 108 of 1996).
In terms of section 192 of the
Constitution, broadcasting must be regulated by an independent authority (i.e.
ICASA) in the public interest. The mobile operators are of the view that due care
should be taken in finalising the FP Bill to balance the government’s legal
obligation to protect children and the constitutional right to freedom of
expression.
In this regard, the mobile operators
believe that the Committee should take into account the provisions of the Electronic
Communications Act, 2005; the Broadcasters’ Code of Conduct as well as other
self-regulatory measures such as the WASPA Code of Conduct and Advertising
Guidelines which all seek to ensure protection of children against
age-inappropriate broadcasts. It is the mobile operators’ view that the
legislature should not duplicate the regulatory framework applicable to
broadcasters through the FP Bill. The Films and Publications Board should, in
the mobile operators’ view, focus primarily on the proliferation of
technologically enabled ‘non-broadcast’ content provided over a variety of mediums.
The mobile operators accordingly
suggest that reference to the word ‘broadcasting’ be deleted from section 2(a).
(b)
Reference to mobile
cellular telephones
It is also noted that the proposed
amendments to section 2(a) make reference to ‘mobile cellular telephones’. Although
the mobile operators accept that it is important to clarify the ambit of the
legislation and jurisdiction of the Board over content provided via cellular
telephones, we submit that it is not appropriate to refer to a specific medium
or technology in the objects of the legislation i.e. reference is not made to
other mediums such as computers, televisions, magazines etc. It is important to distinguish between the
transport medium and the actual content sent across it.
It is submitted that a technology
neutral approach must be taken to regulation of the use of ‘mobile cellular
telephones’ as a medium for provision of content is in fact covered in terms of
paragraph (i) of the definition of publication contained in the primary legislation.
To the extent that the Committee is of the view that the definition of
‘publication’ is inadequate and does not clearly cover mobile cellular
telephones, it is our view that it is the definition that requires amendment
and clarification, not the objects of the Act. Furthermore, where users are accessing the
internet by means of a mobile cellular telephone, then the inclusion of
reference to “the internet” which is already included in the objects, is
sufficient.
The mobile operators therefore
suggest the following amendments to section 2:
|
2. The objects of the Act shall be to- (a)
regulate the creation, production, possession (b)
make the use of children in pornographic publications,
films, interactive computer games |
2.3.
Proposed insertion of section 9A
The mobile operators welcome the
establishment of a classification office and support the provisions which set
out the office’s composition, powers as well as functions. However, we are concerned
that given the vast number of items which will require classification in the
mobile content services industry, the Board might be afflicted with capacity
constraints. This might (unintentionally) result in the hampering of the
development and growth of the mobile content services industry. The concern
around potential capacity constraints is further exacerbated by the fact that section
9A does not make any provision for time-frames within which content items
should be submitted for classification and the time within which they must be
classified upon submission. Though such issues can be dealt in terms of
regulations contemplated in section 9A(2)(f)(i) or (iv), the mobile operators
submit that provision should be made for co-regulation with industry on this
issue. (Please see paragraphs 2.5 and 3.1 for a detailed discussion on the
issue).
2.4.
Proposed insertion of section 15A
Though the mobile operators accept
that it is important for compliance officers to have wide-ranging enforcement powers,
we submit that their powers to order the removal of material ‘allegedly’
displayed, offered or sold in contravention of a decision of the Board as
contemplated in terms of section 15A(1)(b)(iv), should not be unfettered. In
particular where a decision of the Board on a particular material is still
subject to review and or appeal in terms of section 20 of the Act, the
classification officers’ powers to order its removal must be limited.
The mobile operators thus suggest
that section 15A(1)(b)(iv) be amended by the addition of a proviso to
subparagraph (iv) as follows:
|
(iv)
order that films, interactive computer games and publications being offered
for sale or hire that do not comply either with the requirements of this Act
or any decision of the Board with regard to the distribution of that film,
interactive computer game or publication, be removed from any display or
offer for sale or hire until such products comply with the requirements of
this Act or with decisions of the Board with regard to their distribution: Provided that where the decision of
the Board is subject to review and or appeal in terms of this Act, a
classification officer shall not have the discretion contemplated in terms of
this subparagraph. |
2.5.
Proposed amendments to section 18
Though the operators welcome the
requirement that all persons who distribute or exhibit films or interactive
computer games for purposes of the Board’s official records must be registered,
we are concerned about the requirement that such registrants submit such films
or interactive computer games for examination and classification by the Board
prior to their distribution or exhibition. This requirement poses a significant
threat to the survival of the mobile content service providers for the
following reasons:
-
The classification of all individual content items in the
mobile content services industry will hamper innovative provision of services. It
is important to note that the key success factor for mobile content is that the
material be up-to-date and refreshed frequently. Therefore it will be impractical
for each content item (e.g. ringtones, video clips, pictures, logos etc) to be
individually classified prior to it being made available on the distribution
network i.e. the time lapse between submission of the content item to the
Board, the actual classification thereof and the eventual posting of such item
for market offering will negate the demand for the commercial offering of the
content;
-
Mobile content services providers handle thousands of units
of content on a daily basis. It would therefore be logistically impossible for
them to sift through every piece of content for purposes of classifying it.
Even if they do manage to submit each piece of content to the Board for
classification, the Board may not be able (due to capacity constraints) to
timeously classify the content item for timeous provision to the market; and
-
The requirement for examination and classification of all content items does not seem to
serve any beneficial purpose i.e. if the primary purpose for classification is
to protect children against potentially harmful and ‘age-inappropriate content’,
the classification of content that is generally suitable for all ages will not
be of any concern or consequence. It is therefore suggested that only content
that is required to be restricted to certain ages should be classified. In
other words children’s content services should not be required to be submitted
for examination and classification.
In light of the above, particularly the
possible hampering of the development and growth of the mobile content services
industry, the operators suggest that a co-regulatory approach be taken. We propose
that the classification of certain content should be conducted by an existing
self-regulatory body in the industry, such as the Wireless Application Service Providers
Association (WASPA) or any other similar body established for such purpose.
However, the Board should have oversight of such industry body and should retain
its review powers to ensure that the norms and standards set by such
self-regulatory bodies are consistent with the legislative framework. (Please refer to the discussion on the co-ordination
between statutory regulation and self-regulatory measures in paragraph 3.1.
below).
In conjunction with the legislative
amendments suggested under paragraph 3.1 below the mobile operators suggest
that section 18 be amended as follows:
|
18(1)
Any person who intends to distribute or exhibit any film or interactive
computer game in the Republic shall in the prescribed manner on payment of
the prescribed fee- (a)
register with the Board as a distributor or exhibitor of
films or interactive computer games; and (b)
submit for examination and classification any film or
interactive computer game that has not been classified, exempted or approved
in terms of this Act or the Publications Act, 1974 (Act No. 42 of 1974) Provided that where such person is a member of a
recognised industry body and is subject to such body’s code of conduct and
classification and or advertising guidelines as contemplated in section 18C
of this Act the film or interactive computer game shall be submitted to such
industry body’s classification committee for examination and classification. |
(The suggested wording to section
18C, which should be read with the proposed amendment to section 18(1) above
for completeness, is set out in paragraph 3.1 below).
2.6.
Proposed amendments to section 23
The mobile operators welcome the
proposed amendments to section 23 of the Act as contemplated in terms of the FP
Bill. It is the operators’ view that affording the Board the discretion to
exempt certain material subject to conditions it may deem fit will allow for
flexibility in the highly innovative content services industry.
However, the mobile operators are concerned
that the Board’s discretion appears to be limited to only films (as defined) in
terms of the proposed amendments to section 23(2) and does not take into
account other materials such as publications and interactive computer games. The
mobile operators are of the view that the wording proposed for the amendment of
section 23(2) would result in a fundamental limitation and negation of the
Board’s discretionary powers. In order to be meaningful, the Board’s
discretionary powers must be extended to other important content types offered
in the mobile content services industry and not only films.
The mobile operators have also noted
certain inconsistencies with respect to section 23(1), where it is stated that the
Board shall not prohibit the exhibition of films, or interactive computer games
to any person in the course of his / her business as distributor. It is noted
that the same exemption does not apply to “publications” as defined.
In order to address these
inconsistencies and what we view as a fundamental limitation, the mobile operators
suggest the rewording of the proposed amendments to section 23(2) as follows:
|
23 (1)
The provisions of section 24A(1), (2)(a) and (3) shall not prohibit the
exhibition of any film, (2) The
Board may in its discretion and subject to such conditions as it may deem fit
to impose, either by means of a permit, issued in the prescribed manner, or
by notice in the Gazette, exempt
from classification any particular film, publication
or interactive computer game, any particular class of films, publications or interactive computer
games, or any film,
publication or interactive computer game intended for |
2.7.
Proposed amendments to section 24 read with proposed
insertion of sections 15A
Though the mobile operators welcome
the proposed amendments to section 24, we are concerned that in so far as the
provision relates to ‘the business of adult premises licensed in terms section
2 read with item 2 of schedule 1 of the Business Act No. 71 of 1991’, it does
not appear to take the matter much further for the mobile content services
industry.
The requirement that material
classified as X18 be exhibited or distributed only by persons who are holders
of licenses to conduct the business of adult premises raises the concern that,
in light of continuous technological advancements, it will still be impossible
for providers of mobile content as well as owners of local internet websites
providing adult content to comply with this provision. The mobile operators’
concern centres around the fact that the provisions fail to cater for what
could be termed ‘virtual business premises or e-business premises’. The
Business Act defines ‘business premises’ as “the premises upon, in or from
which the business is or is to be carried on”. The word premises is also
defined in the Business Act as including ‘any land, building, structure, part
of a building or a structure, or any vehicle, conveyance, vessel or aircraft’.
The proposed amendments reinforce
the notion that adult films, interactive computer games and publications should
only be accessible at physical locations. Further to the registration of physical
locations, the manner in which notification of the availability of such
information is envisaged in the FP Bill further reinforces this notion. For
example the proposed amendments make reference to inter alia;
- notices
stating that no person under the age of 18 years may enter the premises being
displayed,
- that such
adult films etc, should not be capable of being seen from any point outside the
premises, and
- the
requirements of section 18 are further re-enforced by section 15A(b) which
requires inter alia; production of
licence to conduct business of adult premises on inspection by compliance
officers.
The mobile operators wish to place
on record that during the ‘ICASA Roundtable on the Approach to Adult Content Regulation in Broadcasting and on Mobile Phones’
held on 23 November 2005 a recommendation was made that amendments be effected
to section 24 to make provision for virtual premises and related control
mechanisms to ensure that such virtual premises are only accessed by persons
over the age of 18.
In light of the above, the mobile operators
suggest that consideration be given to the following questions in this regard:
-
Is it the intention of the legislature to ‘render beyond
regulation’ or ‘effectively outlaw’ provision of X18 material through ‘virtual
premises’ but allow it via physical premises?;
§ if the answer is yes,
what would be the rationale for the distinction between the two and how would
such distinction be justified against the right to freedom of expression and
the right to freedom of trade, occupation and profession;
§ if the answer is no, what
would be the regulatory framework for ‘virtual’ mobile content providers
(particularly wireless application service providers) who wish to
electronically provide material classified as X18 to their customers?
-
Since the Business Act contemplates the licensing of adult
premises per specific areas /localities, what would be the area / locality of a
virtual premises?; and
-
Would the implementation of access control mechanisms by the
content providers suffice to address the concerns sought to be addressed by the
requirements for the licensing of physical premises?
Based on the answers to the
questions above, it may be necessary for the definition of ‘business premises’
and ‘premises’ in terms of the Business Act to be amended in order to avoid
undue prejudice to e-content services providers vis-à-vis their physical
premises counterparts. Alternatively a definition of ‘business of adult
premises’ which adequately caters for virtual premises should be inserted in
section 1 of the FP Bill.
In this regard, the mobile operators
suggest that a proviso be added to section 24(1) to cater for “e-premises”. In
addition, it is proposed that a new section 24D be inserted to deal
specifically with requirements for virtual premises as follows:
|
24(1)
Any person may exhibit in public or distribute any film, interactive computer
game or a publication classified as X18 in terms of a decision of the Board
which has been published in the Gazette if such person is the holder of a
licence to conduct the business of adult premises, issued by a licensing
authority in terms of section 2, read with item 2 of schedule 1, of the
Business Act, 1991 (Act No. 71 of 1991), and if such exhibition or
distribution takes place from within premises forming part of a building: Provided that where the exhibition or
distribution takes place from a virtual business of adult premises the person
shall hold a classification certificate issued by the Board in terms of
section 24D. 24D
(1) For the purposes of this section the following shall mean: (a) ‘a virtual adult content business’ means a business
(such as a wireless application service provider) that provides mobile
content services suitable only to persons over the age of 18 from a virtual
premise which content is accessed remotely by customers through terminal
equipment or other electronic device; (b) ‘mobile content services’ includes text, pictures,
graphics, animation, games, video clips, music, sounds recording and
experiences such as gambling, competitions and voting lines accessed by and
provided to customers via a mobile cellular network but excludes person to
person communication and content accessed by customers; (c) ‘virtual premises’ means in respect of provision of
mobile content services, the point, whether physically existing or existing
by virtue of software, from which the provision of such services is
facilitated. (2) Any person who exhibits or
distributes films, interactive computer games or publications classified as
X18 through virtual premises must apply to the Board for registration as an
operator of a virtual adult content business. (3) The Board must issue such
person with a certificate of registration as
an operator of a virtual adult content business if such person: (a) is a member of, adheres to and
is subject to the adjudicative processes of a code of conduct of a
representative industry self-regulatory body recognised by the Board; or (b) has put in place, adequate mechanisms
to enable parents (and or guardians) to prevent their children from accessing
its adult mobile content services. |
2.8.
Proposed insertion of section 24C
Though the mobile operators
understand the rationale behind section 24C we would like clarity on and also draw
the attention of the Committee to the following issues:
-
What constitutes an ‘internet access and service provider’
as contemplated in terms of the section i.e. where access is provided through mobile
cellular technology such as GPRS or 3G bearer services is the ‘internet service
and access provider’ in such a case, the mobile operator or the party (ISP)
with whom the mobile operator has concluded a contract for provision of such
internet services? We believe that ISP’s are mostly internet access providers.
-
Though the mobile operators accept that service providers
should take measures to protect children imposed in terms of section 24C(1)(a),
it should be noted that it is not possible to guarantee that the child
orientated services are not used by persons wishing to commit offences against
children as such people are largely unknown until the offence is committed and
they are discovered;
-
The application of section 24C(1)(b) presents practical and
technical difficulties when applied to small mobile phone screens and or mobile
services that do not have ‘home pages’;
-
The classification of material according to age restricted
divisions is problematic in the mobile environment and the mobile operators
recommend that material in this environment be classified simply either as ‘restricted’ or ‘unrestricted’; and
-
The obligation imposed on service providers for the
provision of software to customers to enable filtering or blocking of
pornographic materials is welcomed as a concept, however meeting this
requirement is, for technical reasons, impossible. Amongst other difficulties,
there is no ubiquitous filtering software currently available anywhere that is
compatible with all handsets. Moreover many handsets are not advanced enough to
run the type of software contemplated. The mobile operators suggest the implementation
of other solutions (e.g. device agnostic, network based solutions) which can be
implemented across all handset devices irrespective of type.
3. GENERAL PRINCIPLE COMMENTS
3.1.
Co-ordination between statutory regulation and self-regulatory
measures
The mobile operators believe that
that the regulatory regime resulting from the proposed amendments should take
account of and leverage on the achievements of a number of self-regulatory
measures introduced by the mobile content services sector. In particular, given
the increase in the use of mobile phones for the distribution of content,
mobile operators and wireless application service providers have taken
pro-active measures and introduced and successfully implemented the
self-regulatory instruments such as the WASPA Code of Conduct (and Advertising
Guidelines) and the Mobile Operators’ Code for Self-regulation of Mobile
Content Services over the past year. Through these instruments the mobile
content services industry has committed itself and implemented the following
(amongst others):
-
WASPs are required to take reasonable steps to prevent
access by persons below the age of 18 to adult services. Failure to comply with
the commitments have resulted in sanctions being imposed on recalcitrant
members in terms of the WASPA Code (such sanctions include fines, suspension
and expulsion from WASPA and the blocking of such member’s access to a number /
service by the operators). The adjudicator appointed by WASPA to deal with
complaints lodged against members has contributed to effective enforcement of
the Code as well as increased compliance by members.
-
All WASPs providing content services by utilising the
network of any of the South African mobile operators are either members of
WASPA or are bound by the WASPA Code of Conduct. Though the Code is voluntary,
the manner in which the mobile operators’ relationships with the WASPs are
structured (i.e. the mobile operators either requires mandatory membership of
WASPA or compliance with the WASPA Code of Conduct) ensures that no WASPs fall
beyond the scope of the Code.
-
The mobile operators have, over the past year assisted WASPA
in enforcing the code by uniformly and collectively actioning recommendations
received from WASPA in exercising their contractual remedies to deal with WASPs
found to be in breach of the WASPA Code.
-
The mobile operators have also committed to take steps to
introduce access controls and filtering measures to prevent access by children
to age-inappropriate content services.
-
The mobile operators have also agreed to implement a
separate number range for adult content provided by WASPs. This will structure
the provision of the service and in so doing, assist WASPA, the mobile
operators and the general public, in particular parents, in identifying WASPs
that provide adult content, ensuring that some level of access control is
introduced (i.e. such as requiring the provision of credit card number or ID
number) and in monitoring the services of those WASPs that provide such
services without adhering to applicable codes.
The mobile operators believe that the
industry has had in-depth experience on matters relating to protection of
children from age-inappropriate mobile content which could be of benefit to the
Board and the Committee. The mobile operators are convinced that the technical
capabilities at the disposal of industry can and should help determine the type
of controls that should be implemented. It is in light of this fact that the mobile
operators suggest that instead of two separate parallel processes (i.e. the
Board’s statutory regulatory framework on the one hand and the industry’s self
regulatory instruments on the other), some form of co-regulatory framework be
established.
Such co-regulation can be
implemented by providing for recognition of self-regulatory bodies, their codes
of conduct as well as advertising / classification guidelines. Provision could
also be made for representation of the self-regulatory bodies on the regulatory
structures established in terms of the Act. It is only through this approach
that the Board can benefit from the experience of the self-regulatory regime of
the industry on the one hand, whilst the industry can gain exposure on the
implementation of the legislative framework by the Board for purposes of aligning
the self-regulatory measures to ensure consistency with the broader regulatory
framework where necessary.
The mobile operators therefore
suggest the insertion of the following provisions as section 18C to make
provision for co-regulation in appropriate instances:
|
18C (1) Any industry body that is
sufficiently representative of the persons who are in the business of distributing
or exhibiting films, publications or interactive computer games as
contemplated in terms of this Act must apply for registration and recognition
by the Board. (2) The Board must register and recognise the industry
body if such body’s membership has adopted- (a) a code of conduct enforceable against all its members;
and (b) classification and or advertising guidelines setting
out norms and standards for the protection of children against
age-inappropriate films, publications or interactive computer games. (3) The code of conduct contemplated in subsection
(2)(a) must- (a) prescribe procedures for making and dealing with
complaints; (b) provide for the appointment of an adjudicator to
deal with the complaints; (c) require that, in performing his or her functions
under the code, the adjudicator must have due regard to all applicable laws
including this Act; and (d) provide for the establishment of a classification
committee which will be responsible for enforcement of the industry body’s
classification and or advertising guidelines. (4) The classification committee contemplated in
subsection (3)(d) above shall be chaired by the adjudicator and comprise of
no more than four other members one of whom shall be an ex officio member recommended by the Board. (5) The adjudicator must on a quarterly basis prepare
and submit a report to the Board setting out (a)
the nature of
complaints dealt with during the period and their outcomes; (b)
the films and or
interactive computer games examined and classified by the classification
committee during the period; and (c)
any other matter
relevant to the effective functioning of the industry body and its
relationship with the Board. |
4. CONCLUSION
The mobile operators wish to express
their appreciation for the proposed amendments and recognise that the clarification
of the regulatory framework applicable to the mobile content services industry is
long overdue. However, in order for the legislative amendments to be effective,
it is important that the amended legislation takes into account the experience
and lessons of the industry (particularly that of the mobile content services
industry) to date. In this regard, the mobile operators trust that their concerns
and suggested amendments as set out in this submission, will receive favourable
consideration.
We reiterate that we are available
to make presentations to the Committee on this representation, as well as the
initiatives that we are each undertaking to address the challenges posed by the
provision of mobile content services to children.
*****