Video Games Europe Contribution: EC Exploratory consultation on the future of the electronic communications sector

Executive Summary

  • Video Games Europe believes that the introduction of network fees in the EU would not be of benefit to consumers and to the Internet ecosystem in general.
  • In addition to many legal, technical and practical difficulties, the introduction of network fees in the European Union would be incompatible with the principle of net neutrality adopted in the Open Internet Regulation.
  • Video Games Europe disagrees with the assumption that Content and Application Provers (CAP’s) free ride on connectivity infrastructure: Content generates demand for connectivity in a mutually reinforcing virtuous cycle, where competition in both markets is stimulated, to the ultimate benefit of consumers, CAPs and ISPs.
  • Content and security updates for video games are distributed via the internet, some of which are required by the Digital Content Directive: network fees would effectively impose a burden on video game publishers to carry out a legal obligation.
  • New technologies such as cloud have the potential to make a significant reduction in the carbon footprint generated by access/delivery of content such as video games. Its actual environmental impact is dependent on multiple variables outside the control of Content and Application Providers.