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ISSUES IN THAILAND
Without some form of regulatory measures and changes as described in this presentation, Thailand’s telecoms market will remain an unleveled playing
field, where competition and innovation of mobile services, and thereby the digital economy, may not evolve as it should - or at all.
The Government has provided the platform for private industries to participate and form the final stages of Thailand 4.0 – however the current regulation
from NBTC - or lack off, has not been able to follow suit, but only concentrated on the existing silos in the market instead of getting all the wheels to spin.
MVNO’S IN THAILAND – WHY IT FAILED
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In 2009 five MVNO’s where given a license by the telecom regulator NBTC to operate as MVNO’s on the state enterprise telecom operator TOT
In 2016, The Inspection and Evaluations Commission (also known as the “Superboard”) of the National Broadcasting
and Telecommunications Commission (NBTC), failed the telecom regulator and concluded that:
Pronoun
not anything; no single thing.
Adjective
having no prospect of progress; of no value
BUT CONTINUES TO SELL MVNO LICENSES
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54 COMPANIES
HAVE OBTAINED A MVNO LICENSE IN THAILAND
ONLY 9 HAVE LAUNCHED – 6 ARE STILL ALIVE
BEHIND THE NUMBERS
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APPROXIMATELY
Over the past 18 years, MVNOs have helped stimulate competition With a predicted compound annual growth rate (CAGR) of over 10%
in the mobile market, launching innovative tariffs and services and in the forecast period to year 2020, the Asia Pacific region is home
attracting niche consumer segments at a lower cost than mobile to the world’s fastest growing MVNO sector, even more than the
network operators (MNOs). In Europe virtually every cable and highly competitive MVNO markets of Europe and North America.
fixed-line operator has a mobility strategy, largely based on MVNO Grand View Research
TODAY, MVNOS HAVE REACHED 214 MILLION USERS WORLDWIDE, AND IS ESTIMATED TO GROW TO 300 MILLION USERS AND A $70 BILLION VALUE IN 2020
Overall connection growth for mobile phone service around the world was Ovum predicts that nearly 24% of all new subscriber connections over the
about 4.5% end of 2015. MVNO connections are growing at about 18% per next 5 years will come from MVNO subscribers. Although the current
annum 4 times faster than the average rate for the mobile industry. market represents less than 10% of these connections, they expect it triple
• 1000+ INDEPENDENT MVNOS WORLDWIDE By 2020, IDC predicts that 30% of the top 500
• MVNOS INCREASED 70% BETWEEN 2010 AND 2015
• 73 COUNTRIES HAVE MVNOS IN OPERATION companies in Thailand will see the majority of their
• MVNOS ACCOUNT FOR 14% OF THE TOTAL EU MARKET business depend on the ability to create digitally-
• EUROPE IS HOME TO: 600 MVNOS, APAC: 140, US: 111 enhanced products, services and experiences
• 1 OUT OF 10 PEOPLE IN AUSTRALIA IS A MVNO CUSTOMER
Source IDC Thailand
…AND HAVE DELIVERED
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THE RATIONALE FOR THE INTRODUCTION OF MVNO, INCLUDE - BUT ARE NOT LIMITED TO:
Stimulate competition,
Efficient utilization of network resources,
Introduce new or better services aligned to lifestyle propositions currently unserved/underserved,
Promote investment opportunities for local and international businesses in the telecom market.
Consequently, MVNOs are intended to support innovation, bridge digital divide, and contribute to the growth in the ICT sector to
ensure the achievement of the broader industry and DIGITAL ECONOMY OBJECTIVES.
MVNO
MVNO
MVNO
MVNO’S CAN CONNECT TO MNO’S DIRECTLY MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA
The MVNO enters into an agreement with the MNO to obtain access to airtime at A MVNA is an entity, who buys large bulk of airtime from the MNO, and then
wholesale rates, and then sets its own retail price and service. The MVNO either has wholesale it to several MVNOs (Economies of scale). The MVNOs buys the
to invest in its own telecom operational systems or employ the services of a MVNE. airtime from the MVNA and sets its own retail price and service to end-users.
HOW MVNO’S CONNECT 2 OF 2
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MVNO MVNO
MNO MVNE MNO MVNA/MVNE
MVNO
MVNO MVNO
MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNE MVNO’S CAN CONNECT TO MNO’S THROUGH A MVNA/MVNE
The MVNE provides infrastructure and services to both the MNO and MVNOs, The MVNA/MVNE purchases airtime in bulk from the MNO, adds the
which enables MVNOs to offer their services on the MNOs network. The MVNE operational telecom components on top, and then wholesales the airtime
provides services, such as billing, product setup, service delivery, customer care, and service as a full turnkey solution to MVNOs. The MVNA/MVNE also
fraud management, reporting, sale platforms, device and SIM management, etc. offers guidance during launch and operation as well as value added services.
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PROBLEM #1 IN THAILAND
THE MNO WALL
THE MNO WALL OF THAILAND www.yozzo.com
Somehow, and for some reason, none of the three MNOs AIS, TRUE or DTAC has had any
MVNOs operating on their networks, since the introduction of MVNOs in Thailand in 2009
NO
MVNO’S
DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 2100MHz LICENSES www.yozzo.com
16.5.1 The Licensee shall provide telecommunications network service with the minimum
capacity of 10 percent of its networks to the MVNO who is not the Connected Person in
the Shareholding Structure with any licensee when receiving such service request
As with the 2100 MHz spectrum, the NBTC also added a MVNO clause
in the terms for the 900 MHz and the 1800MHz licenses (2015/2016)
(1) The Licensee shall comply with the Commission’s Notification Regarding Mobile Virtual Network Operator Service 2013.
(2) The Licensee shall provide telecommunications network service at least 10 percent of its network’s capacity to MVNO(s)
that is/are not the connected person(s) with any licensee under this Notification, upon receiving such service request.
Yet, no MVNO’s
have launched on
AIS, DTAC or TRUE
HOWEVER, ALL THREE MNO’S HAVE LAUNCHED THEIR OWN MVNO’S ON CAT AND TOT
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Dear NBTC, if you seek (with the words from your own strategy statement) to manage spectrum allocation efficiently, Create equality
in communication infrastructure access and digital opportunity, develop competition, fairness and efficiency in communication
resource management toward Thailand's digital community and support and promote innovation and networking…
1. The NBTC should publish a clear policy statement requiring the telecom network operators to provision MVNOs on their network.
2. The NBTC should exercise its regulatory mandate to monitor the market and the negotiations to ensure that mobile network operators
conduct negotiations fairly and in good faith - and that the policy objectives of the mobile market are fulfilled.
3. The detailed terms and conditions of MVNO provisioning should first be left to the parties to negotiate on a purely commercial basis
4. It would be in the public interest for the NBTC to intervene, and assist the parties - or if necessary, settle and resolve in case a mobile
network operator is acting in bad faith, engaging in any form of anticompetitive conduct, or if, after a reasonable period (1 months) of in-
good-faith negotiations, a commercial agreement cannot be reached between the parties.
The NBTC should follow up on a monthly basis to see if there is a progress in on-boarding MVNOs, and take measures if not.
In addition, and as a last resort only, if no progress is made - a regulatory mechanism allowing the NBTC to intervene, to:
• Ensure fair and reasonable terms for access
• Safeguard fair and non-discriminatory competitive behavior
• Bring parties to the negotiating table at the earliest opportunity
• Introduce and safeguard the principle of in-good-faith commercial negotiations.
i.e., the mobile network operator shall enter into a wholesale agreement with the MVNO, within a period of 1 months from the date of issuing
a Letter of Intent (LoI) or Memorandum of Understanding (MoU) and submit a copy of the same to the NBTC (licensor).
NBTC would have the power to intervene in the agreement if deemed necessary by one of the parties.
The Regulations/Directives/Orders of NBTC in this regard would be binding on the telecom network operators and the MVNO.
THE MNO WALL SOLUTION
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PROBLEM #2 IN THAILAND
NO FULL MVNO
NO FULL MVNO’S ALLOWED IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS
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This table from the NBTC shows which elements are allowed and not in Thailand for MVNA’s and MVNO’s
ELEMENTS / LICENSE TYPES FULL MVNO MEDIUM MVNO THIN MVNO MVNA
SPECTRUM N/A No No No
NETWORK ELEMENTS
BTS/Node B N/A No No No
BSC/RNC N/A No No No
SWITCHING AND DATA NETWORK MSC/GMSC N/A No No No
SGSN N/A No No No
GGSN N/A No No No
HLR/AUC/EIR N/A No No No
Voice Mail N/A Yes No Yes
SUBSCRIBER REGISTRATION, VAS, SMSC N/A Yes No Yes
INTERNET, APPLICATION PLATFORMS VAS N/A Yes No Yes
IN N/A Yes No Yes
IP Router N/A Yes No Yes
Billing N/A Yes Yes Yes
Customer Care N/A Yes Yes Yes
RETAIL ELEMENT Customer Ownership N/A Yes Yes Yes
Tariff & Product Development N/A Yes Yes Yes
Brand visibility to end user N/A Yes Yes Yes
Retail sale N/A Yes Yes Yes
SIM BRANDING N/A Yes Yes Yes
FULL MVNO = CONTROL AND FLEXIBILITY TO PROVIDE INNOVATIVE SERVICES
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A Full MVNO has complete control over its own business, SIMs, customers and services due to certain core network elements such as:
• Registers SIM cards • Own dedicated IMSI series, Allocate special numbers,
• Stores subscriber information and privileges activate / deactivate services like SMS, outgoing
HLR Home Location Register
• Maps internet access point to each subscriber calls, roaming, international calling etc.
• Shares subscriber information when roaming Management of internet AP
MVNO
6 Ethnic MVNO wants to launch 2 Travel & Leisure MVNO needs to urgently
mothers day promotions before MVNO MVNO resolve customer billing disputes before start
competitor launches its promotions of Songkran holiday season tomorrow
5 Retail MVNO wants to provide extra 3 Retail MVNO wants to access its user usage
bonus points in loyalty program to drive data) to better address the needs and wants
sales this weekend MVNO MVNO of its own customers
MVNO
As a FULL MVNO the MVNO can have control over services they can offer in the market,
and thereby the flexibility to innovate and compete on new service offerings in the market
INNOVATIVE
IoT/M2M
MVNO’s MVNO’s based on
value addition
SERVICE OFFERING
MVNO’s based
on convinience
Traditional
”No frills” Mobile Operators
MVNO’s
The MVNOs will not be able to compete on neither services, pricing - or introducing new innovations to the market, thereby
giving the traditional mobile network operators an unfair advantage, severely limiting innovation and competition in the market
INNOVATIVE
SERVICE OFFERING
Traditional
Mobile Operators
This is how it ”works” today in Thailand if MVNO’s want to introduce new promotions, service - or tackle issues
❹
CAT resells 80% of the
network capacity to
MVNO RealMove, ❺
leaving 20% to CAT
itself and its MVNOs
❷
BFKT builds and
operates the network TRUE TRUE
subsidiary subsidiary
infrastructure
❼ A new 4G roaming deal between CAT/True Move, will see True pay a 1,9 mio subscribers
rental fee of THB 4.1 bn in cash to CAT within 8 years for the use of CAT’s
850MHz spectrum, and a barter deal (valued at THB 5.2 bn) giving CAT
access to some of True’s 4G network on 1800/2100MHz within 10 years.
❹
TOT resells 80% In September 2016, TOT and AWN, a
network capacity from subsidiary of AIS, signed a 6 month trial
the 20,320 base station contract where AWN would roam on TOT’s
to the MVNO SBN 2100MHz network.
20,520
DTAC AND SUBSIDARY TELEASSET AND DTN MVNO SETUP ON TOT 2300MHz
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❹
TOT Pcl is the 3rd largest shareholder in DTAC with 5.58% shares
TOT resells 60% of the
network capacity to
MVNO DTN, leaving ❺
40% to TOT itself
and its MVNOs
TOT outsource
❶ network build to TeleAsset
MVNO DTN
TeleAssets
❷
TeleAssets builds but
may not operates the DTAC DTAC SUBSIDIARY
SUBSIDIARY DTAC TriNet Network (DTN)
network infrastructure
❸
TOT leases the
equipment from
TeleAssets
Base stations
20% network capacity to
MVNOs on TOT ❻ 20% network
capacity to TOT
TOT selected DTAC, as its partner to deploy 4G LTE Year 1: 1,769
services using the 64MHz TOT was given by NBTC on Year 2: 8,455
the 2300MHz band. The proposal is a copy of the Year 3: 14,994
TRUE/CAT 850MHz setup, and involves DTAC’s wholly Year 4: 20,367
Year 5: 21,217
owned subsidiary TriNet purchasing 60% of TOT’s
capacity for a fixed annual payment of THB 4.5 billion.
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THE SOLUTION
Allow Full MVNO’s to level the playing field, foster innovation and
competition - for the benefit of the consumers and Thailand 4.0
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PROBLEM #3 IN THAILAND
DOUBLE / TRIPLE LICENSE FEE
UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS
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In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNOs and consumers, as the NBTC is charging double fees on one ”signal”.
Example: Example:
The operator sells THB 100 worth of voice calling to The MVNO sells the now THB 105 worth of voice calling
the MVNO which is THB 100 + 5% total fee = THB 105 to customers THB 105 + 1.5% fee = THB 106,57
MNO
MVNO
❸
Voice call Voice Call
Voice call incl. Fees Incl Fee
THB 100 THB 105 THB 106,57
1.50% License Fee Unlevel playing field as the MNO can MVNO License
3.50% USO Fee sell directly to its customers for just Fee 1.5%
THB 105 vs. the MVNOs THB 106,57
In 2009 the NBTC introduced Mobile Virtual Network Operator (MNVO) license along with a license fee scheme up to 1.5% of yearly revenue.
However, the setup of the license fees causes the burden to be pushed to the MVNA, the MVNO and consumers, as the NBTC is charging triple fees on one ”signal”.
1.50% License Fee Unlevel playing field as the MVNO License MVNO License
3.50% USO Fee MNO can sell directly to its Fee 1.5% Fee 1.5%
customers for just THB 105
vs. the MVNOs THB 108,17
MVNO
MVNO’s makes its profit on the small margins between the The unfair double, and triple taxation changes the
costs of purchasing airtime in wholesale from the MNO (or timeline significantly for the MVNO to reach financial
MVNA) and the retail price. They need to operate a lean breakeven – if ever - given that the current fee structure
and flexible setup, with low operation costs (small staff, setup not only adds additional costs, but also provides
low office rentals, cheap distribution) as every baht counts. the mobile operators with an unfair pricing advantage
VERSUS
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THE SOLUTION
Let the MNO and MVNO (and MVNA) split
the 1.5% license fee like we do with VAT
i.e. MNO 0.75% and MVNO 0.75% = 1.5%
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PROBLEM #4 IN THAILAND
UNFAIR ADVANTAGE RESULTING IN ONE
PLAYER BEING ABLE TO PROVIDE LOWER PRICES
MVNO OR NOT
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The sub-brand MVNO was launched without a MVNO license. DTAC LINE
DTAC claims it is not a MVNO - but that LINE MOBILE (which is SUBSCRIBERS MOBILE
a MVNO in Japan), is a service of DTAC's subsidiary DTN, who
has entered into a brand licensing deal for the rights to use
LINE MOBILE in Thailand, against a nondisclosed royalty fee.
The setup was build from scratch by AIS but with its own YOU!
SIM, branding, design, promotion packages, marketing, etc.
Examples are:
• Australia: MNO Optus and Virgin Mobile
• America: MNO Sprint and Virgin Mobile
Own
MNO
Subscribers
Retail
In this article published in the Bangkok Post on 26 September 2017, CEO of DTAC,
Lars Norling states why he thinks LINE Mobile does not need a MVNO license
“Mr Norling intimated that the contract was not exclusive, which suggests
that Line can partner with AIS and TrueMove to provide similar services”.
This remark clearly shows that LINE is a partner and not part of DTAC or
DTN and therefore need a MVNO license to operator on DTAC’s network
LINE MOBILE UNFAIR ADVANTAGE
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Line Mobile is given the unfair advantage of being able to provide lower prices than rest of the players in the market, as it doesn't have
to shoulder the extra cost of a MVNO licensing fee, and the country is also not benefitting, as it won't receive MVNO licensing fees.
Example: Example:
The operator sells THB 100 worth of voice calling to the The MVNO sells the now THB 105 worth of voice calling
MVNO which is THB 100 + 5% total fee = THB 105 to customers THB 105 + 1.5% fee = THB 106,57
LINE
MOBILE MVNO
❸
Voice call Voice Call
Voice call incl. Fees Incl Fee
THB 100 THB 105 THB 106,57
1.50% License Fee Unlevel playing field as LINE Mobilecan MVNO License
3.50% USO Fee sell directly to its customers for just Fee 1.5%
THB 105 vs. the MVNOs THB 106,57
LINE
MOBILE
LINE MOBILE WHAT WILL HAPPEN ON 2300MHz
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If DTAC allows the LINE Mobile customers to use its new setup on TOT’s 2300MHz, questions is how does the NTBC plan to bill the license
fee. The 2300MHz is the spectrum of TOT and DTN is a MVNO – Will the NBTC allow the MVNO DTN to provide access to LINE Mobile
1.50% License Fee MVNO License Unlevel playing field as the MVNO License
3.50% USO Fee Fee 1.5% MVNO can sell directly to its Fee 1.5%
customers for just THB 106.57
vs. the MVNOs THB 108,17
THE SOLUTION
LINE Mobile is a MVNO and must obtain a
MVNO license, pay fees and compete on
the same terms as the rest of the market
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PROBLEM #5 IN THAILAND
NBTC ISSUES A LICENSE THAT IS
BOTH AN MVNA AND AN MVNO
NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO
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MVNA
OK!
MVNO
COMBINED MVNA/MVNO LICENSE = CONFLICT ON INTEREST
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MVNA
This will further manifest itself in negotiations of packages, fees, terms and
conditions, as the MVNA will always have more power in any outcome and
be able to control the competition (MVNO clients) = non level playing field.
COMBINED MVNA/MVNO LICENSE
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MVNA
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THE SOLUTION
If the NBTC absolutely have to issue licenses, then there should be one
license for MVNA and another for MVNO. It is two different setups.
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PROBLEM #6 IN THAILAND
NO PLANS FOR MVNO’S
GOING OUT OF BUSINESS
THE NUMBER YOU HAVE DIALED IS NO LONGER IN SERVICE
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OUT OF BUSINESS
AND THEN WHAT?
NO PLANS FOR MVNO’S GOING OUT OF BUSINESS
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MVNO
?
MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S THROUGH SEVERAL MVNA’S
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MVNA MVNA
MVNO
?
ALL-IN-ONE
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ONE MVNO, WHO HAS AGREEMENT WITH TWO MNO’S, IS SELLING WHOLESALE TO NON-MVNO’S, WITHOUT A MVNA LICENSE
The MVNO is selling SIMs and airtime to unlicensed outlets, as well as acting as a MVNA to MVNOs by selling airtime and SIM packages.
MVNO
COMPANY COMPANY
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THE SOLUTION
1. A protection plan should be part of the MVNO Agreement between the host operator and the MVNO. I.e. The Agreement
shall include provisions covering the expiration, termination or suspension of the Agreement and shall contain an adequate
protection plan for MVNO customers and their payments, including processes and information to subscribers on refund
process, number porting options, and the continuation of uninterrupted services (taken over by the host operator), if the
customer chose not to de-activate, or port out three months after the announcement of service termination.
2. The NBTC should issue a mandatory Code of Practice notification to all new and existing MVNOs and host operators, to
include the amendment to its MVNO agreements mentioned above, as well that both the host operators and the MVNOs
from the date of the notification, are required to, provide mobile number portability services for at least three months after
the date of service stop to allow affected customers to port out their mobile numbers to other service providers.
Ensure subscribers are automatically absorbed by the Host Operator (no end-user action or consent required) if they choose
not to port out, three months after the announcement of service termination.
3. To minimize the impact on various stakeholders, the NBTC should publish a Service Cessation Alert Notice standard sample
format to be used for host operators to notify the NBTC, and one Service Cessation Alert standard sample to be used by
MVNOs to inform the NBTC, affected customers and the public.
SOLUTION: IF A MVNO GOES OUT OF BUSINESS
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MVNA
CUSTOMERS
THE HOST MNO HAS TO TAKE OVER THE REMAINING CUSTOMERS
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MVNA
IF A MVNA GOES OUT OF BUSINESS
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MVNA
THE HOST MNO TAKES OVER AND MAKE SURE THE MVNO’S ON THEIR NETWORK CAN CONTINUE
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PROBLEM #7 IN THAILAND
BUREAU-CRACY AT NBTC
KILLING INNOVATION
MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE
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FILL-OUT & HAND-IN THE APPLICATION NBTC OFFICER HAS TO UNDERSTAND & APPROVE
NBTC has added their own little notice to the act regarding license approval.
The NBTC officer can decline the application if he/she doesn't understand, either due to language, the service, network etc.
LICENSE APPLICATION BUREAU-CRAZY
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HOWEVER…
The NBTC officer will not uderstand new innovative service from the MVNO and decline it
because he/she is responsible, and it does not fit the boxes. Therfore all MVNOs are the same
in Thailand - even MVNAs have to use the MVNO application form which makes no sense
?
LICENSE APPLICATION BUREAU-CRAZY
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THE MVNO LICENSE IS GIVEN BASED ON THE APPROVED AND PROVIDED INFORMATION
I.e. The information given and approved is part of the license – License valid for 5-years
BUREAU-CRACY KILLS INNOVATION AND OPENS FOR CORRUPTION
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SAY NO!
There are people who are either The setup opens a ”backdoor for
direct employees or have very further corruption.
close ties with employees at the
NBTC, who provide a service in Because…
which they guarantee you a
license for the price of THB The MVNO license is valid for 5-
50,000-100,000. years and consist of the
information provided in the
We are aware of some who have application. That information is
used the service and has been however outdated because it has
awarded the mentioned license. to fit the old standard and
knowhow from the officer.
Question is how many have used
this ”service” and how is it even Once the MVNO launch in the
possible that this can take place real world with technology and
considering the license approval interfaces according to updated
process involves several stages standards the regulator can come
and departments/boards? back at anytime and say the
MVNO is not operating according
The license approval process is to the license (information
long, slow and non-transparent, provided in the license) and
and NBTC will drive you in circles. demand they stop operation – or
This further helps trigger the solve it with a brown envelope.
interest in ”guaranteed license” TO CORRUPTION
GETTING A LICENSE WITHOUT AN AGREEMENT
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Question: How does a MVNO without a host operator agreement fill out 9,10, 11, 12?
Answer: They fill in ALL operators as example and use a network diagram from the 90’s
THE SOLUTION
• Update the license application to the present and amend it from time to time.
• Drop the added clause that the officer has to understand, approve and be responsible.
• There is no reason to provide a license prior to an agreement with a MNO/MVNA/MVNE.
• Introduce a real MVNA license application = do not use the MVNO application it’s not the same.
DISCLAIMER
Some statements made in this material are forward-looking statements with the relevant assumptions, which are subject to various risks and
uncertainties. These include statements with respect to corporate plans, strategies and beliefs and other statements that are not historical
facts. These statements can be identified by the use of forward-looking terminology such as “may”, “will”, “expect”, “anticipate”, “intend”,
“estimate”, “continue” “plan” or other similar words. The statements are based on our assumptions and beliefs in light of the information
currently available to us. These assumptions involve risks and uncertainties which may cause the actual results, performance or achievements to
be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. Please
note that the company and executives/staff do not control and cannot guarantee the relevance, timeliness, or accuracy of these statements. All
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Presentation by Yozzo Co.,Ltd. www.yozzo.com March 2016