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…AND HOW TO

SOLVE THEM
ISSUES IN THAILAND

UPDATE TO THE PRESENTATION AT



ยุคของการเปลียนแปลงในธุ
รกิจโทรคมนาคม PRESENTATION BY
งานวิศวกรรมแห่งชาติ 2560 ALLAN RASMUSSEN
THAILAND’S TELECOM MARKET – AN UNLEVEL PLAYING FIELD
www.yozzo.com

MOBILE OPERATORS PLAYING FIELD MVNO’S PLAYING FIELD

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
www.yozzo.com

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

AS OF JANUARY 2018 ONLY


2 MVNO ARE LEFT
i-Kool 3G (Loxley) & Buzzme (formerly IEC3G)

THE FIRST MVNO’S IN THAILAND FAILED BECAUSE OF THE FOLLOWING REASONS

INSUFFICIENT NETWORK CAPACITY AT LAUNCH UNLEVEL PLAYING FIELD – (UNRESOLVED)


INSUFFICIENT MVNO EXPERIENCE AND QUALITY POOR PLANNING AND EXECUTION
POOR MVNO CONTRACTS AND REGULATION LEGACY SYSTEMS AND RED-TAPE
THAILAND’S “SUPERBOARD” FAULTS THE REGULATOR NBTC FOR MVNO FAILURE
www.yozzo.com

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:

“…NBTC should issues regulations for mobile


virtual operators to support more of them in
the Industry, which should benefit consumers.”
WHAT HAS THE REGULATOR NBTC DONE ABOUT IT?
www.yozzo.com

Pronoun
not anything; no single thing.

Adjective
having no prospect of progress; of no value
BUT CONTINUES TO SELL MVNO LICENSES
www.yozzo.com

MVNO LICENSES ISSUED IN THAILAND AS OF APRIL 2018

54 COMPANIES
HAVE OBTAINED A MVNO LICENSE IN THAILAND
ONLY 9 HAVE LAUNCHED – 6 ARE STILL ALIVE
BEHIND THE NUMBERS
www.yozzo.com

APPROXIMATELY

1/3 OF THE COMPANIES


WHO HAVE OBTAINED A MVNO LICENSE IN THAILAND
HAVE FOREIGN INVESTMENT/SHAREHOLDERS
SOME OF THE NAMES BEHIND THE MVNO LICENSES
www.yozzo.com

• SB Telecom (Thailand) Co., Ltd. - Softbank


• Mobile Innovation Co., Ltd. - NTT DoCoMo
• NTT Comm. (Thailand) Co., Ltd. - NTT
• VM Digital (Thailand) Co., Ltd. - Axiata
• BT Siam Co., Ltd. - British Telecom
• Tune Talk (Thailand) Co., Ltd.- Celcom
• Lyca Mobile (Thailand) Co., Ltd. - Lycamobile
• J-Communications Service Co., Ltd. - KCS Japan
• Tesco Mobile (Thailand) Co., Ltd. – Tesco Mobile

• Advanced Wireless Network Co., Ltd. - AWN (AIS)


• Advanced Info Service (AIS) PCL. - AIS
• UIH Co., Ltd. - DTAC founder/Chairman
• Acumen Co., Ltd. - JASMINE
• Real Move Co., Ltd. - TRUE
• Loxley PCL - LOXLEY
MVNOS, ARE AN INTEGRAL PART OF THE GLOBAL MOBILE LANDSCAPE
www.yozzo.com

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
www.yozzo.com

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.

THE CLEAR INTERNATIONAL EVIDENCE IS THAT MVNOs HAVE DELIVERED:


 More consumer choice
 Innovative pricing plans
 Innovative products and services
 innovation in, and better customer service
www.yozzo.com

Meanwhile back in Thailand…


THAILAND’S TELECOM ECOSYSTEM – THE MOBILE NETWORK OPERATORS
www.yozzo.com

THE MOBILE NETWORK OPERATORS


AIS, DTAC AND TRUE + THE TWO STATE ENTERPRISE OPERATORS: CAT TELECOM AND TOT

STATE ENTERPRISE STATE ENTERPRISE


THAILAND’S TELECOM ECOSYSTEM – THE TELECOM REGULATOR
www.yozzo.com

THE NATIONAL BROADCAST AND TELECOM COMMISION (NBTC)


IS IN CHARGE OF SPECTRUM, LICENSES AND REGULATION

STATE ENTERPRISE STATE ENTERPRISE

470MHz 900MHz 900MHz 850MHz 850MHz


1500MHz 1800MHz 1800MHz 1800MHz 1800MHz
2100MHz 2100MHz 2100MHz 2100MHz
2300MHz
THAILAND’S TELECOM ECOSYSTEM - SPECTRUM CAPACITY TO MVNO’S
www.yozzo.com

MVNO

10% 10% 10%


STATE ENTERPRISE STATE ENTERPRISE

470MHz 900MHz 900MHz 850MHz 850MHz


1500MHz 1800MHz 1800MHz 1800MHz 1800MHz
2100MHz 2100MHz 2100MHz 2100MHz
2300MHz
900MHz, 1800MHz & 2100MHz SPECTRUM LICENSES
STATES 10% OF THE CAPACITY MUST GO TO MVNO’S
HOWEVER IT IS ONLY CAT TELECOM (850MHz) AND TOT (2100/2300MHz) WHO HOST MVNO’S
www.yozzo.com

MVNO

STATE ENTERPRISE STATE ENTERPRISE

470MHz 900MHz 900MHz 850MHz 850MHz


1500MHz 1800MHz 1800MHz 1800MHz 1800MHz
2100MHz 2100MHz 2100MHz 2100MHz
2300MHz
900MHz, 1800MHz & 2100MHz SPECTRUM LICENSES
STATES 10% OF THE CAPACITY MUST GO TO MVNO’S
HOW MVNO’S CONNECT 1 OF 2
www.yozzo.com

MNO MNO MVNA


MVNO
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
www.yozzo.com

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.
www.yozzo.com

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

Prior to Thailand's 2100 MHz 3G auction in 2012, the NBTC


released the following criteria and procedure for the spectrum

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

2100 MHz 2100 MHz 2100 MHz


AND DESPITE THE MVNO CRITERIA AND CAPACITY ON THE 900MHz & 1800MHz LICENSES www.yozzo.com

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.

900 MHz 1800 MHz 900 MHz 1800 MHz


www.yozzo.com

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
www.yozzo.com

TRUE subsidary AIS subsidary DTAC subsidary


TrueMove is a MVNO SBN is a MVNO DTN is a MVNO
on CAT’s 850MHz on TOT’s 2100MHz on TOT’s 2300MHz
www.yozzo.com

THE MNO WALL SOLUTION


THE MNO WALL SOLUTION
www.yozzo.com

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…

“THEN OPEN THIS GATE - TEAR DOWN THIS WALL”


THE MNO WALL SOLUTION
www.yozzo.com

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
www.yozzo.com

NO MVNO = NO NEW LICENSE


The NBTC has been very active in making sure that terms and conditions, such as minimum roll out
coverage, license payments, maximum retail pricing, etc. has been followed by the 900/1800/2100MHz
auction winners, while zero attention - nor consequences has been given regarding the MVNO capacity.

NBTC is planning an auction for one 850MHz and


three 1800MHz spectrum licenses in 2018. It would
suit the regulator well to live up to its reason to
exist, by facing the issue of un-used MVNO capacity
among the three existing spectrum license holders.

One suggestion would be to add to the auction


terms and conditions, that in order to participate in
the upcoming spectrum auction, an existing license
holder, who has not yet lived up to the terms and
conditions in its previous spectrum license
regarding MVNO capacity, would have to launch at
least one MVNO, on their networks in order to
participate in the spectrum auctions. The mobile
network operators should be given a maximum
period of 60 days to present an MVNO proposal.
www.yozzo.com

PROBLEM #2 IN THAILAND
NO FULL MVNO
NO FULL MVNO’S ALLOWED IN THAILAND = NO CONTROL OF THEIR OWN BUSINESS
www.yozzo.com

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
www.yozzo.com

A Full MVNO has complete control over its own business, SIMs, customers and services due to certain core network elements such as:

ELEMENT FUNCTION ADVANTAGE TO FULL MVNO

• Controls call routing • Ability to have independent wholesale relationships


Mobile Switching Centre
MSC • Generates usage information for voice / SMS routing

• Location information (current cell, current VLR) and


• Handles all packet switched data within the
user profiles (IMSI, addresses)
SGSN Serving GPRS Support Node network, i.e. the mobility management and
• Session Management
authentication of the users. Charging Functions
• Authentication and Identity Check

• Map and control internet gateways


GGSN Gateway GPRS Support Node • Manages subscriber access to Internet network
• Monitor / control data usage

• 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

Full MVNO’s can:


• Have their own roaming and interconnect agreements with other MNOs.
• Gain insights into customer or machine (M2M/IoT) profile.
• Create ‘stickiness’ with customers, where the customer will be under greater control of the MVNO.
• Offer a fixed line convergence proposition, where technical integration may be important.
AS WELL AS TACKLING DIVERSE, URGENT AND SIMULTANEOUS DEMANDS ON A HOURLY BASIS
www.yozzo.com

1 OTT MVNO wants to launch zero rating service on videos from


its own portfolio to compete in the market against HBO, Netflix

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

4 Bank MVNO wants to utilize bulk of sales-force


tomorrow to visit its premium customers to make a
one-day only offer for rate plan upgrades
10 KEY DRIVERS FOR FULL MVNO
www.yozzo.com

❶ Ownership of the subscriber's mobile phone number


❷ Collection of inbound termination rates INCREASING FOCUS


Deliver specific IoT/M2M Solutions
Negotiation of own roaming rates
ON DIFFERENTIATION,
❺ Create stickiness – reduce churn SEGMENTATION AND
❻ Greater technical independence
CUSTOMER LOYALTY
❼ Access to network intelligence
❽ Ability to monitor data usage
❾ Increased negotiation power A FULL MVNO DELIVER LONGER
❿ Easier to switch host MNO
TERM VALUE TO THE MNO
MVNO POSITIONING
www.yozzo.com

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

LOW PRICING HIGH


NOT ALLOWING FULL MVNO KILLS INNOVATION AND CREATES AN UNLEVEL PLAYING FIELD
www.yozzo.com

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

LOW PRICING HIGH


EXAMPLE TODAY www.yozzo.com

Let’s say Thailand wins 4-0 over


Singapore in football, and the whole
country is celebrating the victory on
social media. The MVNOs also
wants to join the celebrations by
providing the customers with a 20%
discount on all voice calls

THAILAND vs. SINGAPORE


4-0
IN THAILAND TODAY
www.yozzo.com

This is how it ”works” today in Thailand if MVNO’s want to introduce new promotions, service - or tackle issues

WEEK 1 WEEK 3 MONTH ? MONTH ?

Fax your request Present your case at a Internal meeting at the


Wait for result
to the MNO meeting with the MNO MNO to approve or not
EXAMPLE TODAY www.yozzo.com

…Meanwhile Thailand will have


lost to another country in both
football and innovation
HOW COME OPERATOR’S MVNO SUBSIDIARIES ARE ALLOWED TO OPERATE AS FULL MVNO’S?
www.yozzo.com

TRUE subsidary TrueMove AIS subsidary SBN DTAC subsidary DTN


operates as a FULL MVNO operates as a FULL MVNO operates as a FULL MVNO
on CAT’s 850MHz on TOT’s 2100MHz on TOT’s 2300MHz

LINE MOBILE operates


as a FULL MVNO
TRUE SUBSIDARY REALMOVE MVNO SETUP ON CAT TELECOM 850MHz
www.yozzo.com


CAT resells 80% of the
network capacity to
MVNO RealMove, ❺
leaving 20% to CAT
itself and its MVNOs

CAT outsource network


❶ operations and network BFKT MVNO REALMOVE
management to BFKT


BFKT builds and
operates the network TRUE TRUE
subsidiary subsidiary
infrastructure

CAT Telecom leases the


equipment from BFKT ❸
15,000 base stations
CAT Telecom’s own
Total remaining network capacity to
MVNOs ~2.3 mio subscribers ❻ retail service MY CAT

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.

According to True’s conditions, the 4G roaming agreement is exclusively


for CAT, i.e. none the MVNOs will be able to use it.
AIS SUBSIDARY SBN MVNO SETUP ON TOT 2100MHz
www.yozzo.com


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.

Now a permanent deal, agreed and


approved by relevant agencies, AWN has
TOT outsource SBN added 15,000 base stations to TOT’s
❶ network build and existing 5,520 bringing the total to 20.520.
management to SBN AWN purchase 80% on a wholesale/resale
basis, of the total bandwidth capacity to
serve its own subscribers, and pay TOT an
❷ annual fee of THB 3.9 billion. In June 2017
AWN was switched to be Super Broadband
SBN builds and Network (SBN) another subsidiary of AIS.
operates the network AIS
SUBSIDIARY
infrastructure

TOT will use parts of the remaining 20% capacity
for TOT and wholesale the rest to MVNOs.
TOT will be able to use an
additional 15,000 base station ❸
bringing the total to 20,520
3G/4G Base stations
10% 3G/4G network capacity
to MVNOs on TOT ❻ 10% network
capacity to TOT
15,000
Total 3G/G base stations

20,520
DTAC AND SUBSIDARY TELEASSET AND DTN MVNO SETUP ON TOT 2300MHz
www.yozzo.com


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


TeleAssets builds but
may not operates the DTAC DTAC SUBSIDIARY
SUBSIDIARY DTAC TriNet Network (DTN)
network infrastructure


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.
www.yozzo.com

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
www.yozzo.com

PROBLEM #3 IN THAILAND
DOUBLE / TRIPLE LICENSE FEE
UNFAIR DOUBLE LICENSE FEE HURTING THE MVNO AND CONSUMERS
www.yozzo.com

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”.

❶ The operator pays NBTC 1.50% of revenue in license


fee + 3.50% of annual revenue in USO fee - Total 5%
❷ The MVNO also pays NBTC 1.5% of annual revenue in license
fee. It does not pay USO fee, as it dosen’t have spectrum.

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

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

As the mobile operator and MVNO each have to pay


the license fees of annual revenue, the same mobile
1 x 1.5% License Fees (MNO) = 1.5% REGULATOR signal (voice/sms/data) ends up having double the
TOTAL tax, when it ends up at the MVNO and its customers.
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5% 6.5%
UNFAIR TRIPLE LICENSE FEE HURTING THE MVNO, THE MVNA AND CONSUMERS
www.yozzo.com

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”.

❶ The operator pays NBTC 1.50% of revenue in license


fee + 3.50% of annual revenue in USO fee - Total 5%
❷ The MVNA also pays the NBTC 1.5%
of annual revenue in license fee
❸ The MVNO also pays NBTC 1.5%
of annual revenue in license fee.

Example: Example: Example:


The operator sells THB 100 worth of voice calling to The MVNA resells the now THB 105 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 the MVNO. I.e. THB 1,05 + 1.5% fee = THB 106,57 to customers THB 105 + 1.5% fee = THB 106,57

MNO MVNA MVNO



Voice call Voice call Voice Call
Voice call incl. Fees incl. Fees Incl Fee
THB 100 THB 105 THB 106,57 THB 108,17

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

As the MNO, MVNA and MVNO each have


to pay the license fee, the same mobile
1 x 1.5% License Fees (MNO) = 1.5% REGULATOR signal ends up having triple tax, when it
1 x 1.5% License Fees (MVNA) = 1.5% TOTAL arrives at the MVNOs and the consumers
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
8%
MVNO’S MAKES ITS BUSINESS ON MARGINS
www.yozzo.com

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
www.yozzo.com

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%
www.yozzo.com

PROBLEM #4 IN THAILAND
UNFAIR ADVANTAGE RESULTING IN ONE
PLAYER BEING ABLE TO PROVIDE LOWER PRICES
MVNO OR NOT
www.yozzo.com

In June 2017, DTAC launched the sub-brand MVNO LINE


MOBILE, and made it available across the 850MHz and
1800MHz network, which is under concession with CAT
Telecom - and DTAC’s own licensed 2100MHz network.

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.

NBTC invited DTAC and LINE to provide information regarding


the setup. NBTC pointed out amendments needed regarding
online SIM registration, marketing and customer support but
allowed LINE MOBILE to continue without a MVNO license.
850MHz
DTAC and LINE MOBILE insist, that despite LINE MOBILE not 1800MHz
2100MHz
having a MVNO license, there is no unfair advantage and the
country is still receiving full licensing fees from this setup.
IN-HOUSE SUB-BRAND = NO NEED FOR MVNO LICENSE
www.yozzo.com

In 2014, AIS launched a prepaid sub-brand called YOU!

The setup was build from scratch by AIS but with its own YOU!
SIM, branding, design, promotion packages, marketing, etc.

This is a sub-brand build, owned and maintained by AIS under


existing license and as such, it does not need a MVNO license.
BRAND LICENSING AGREEMENT = MVNO LICENSE
www.yozzo.com

Plenty of mobile operators have entered into joint ventures or


brand licensing agreements, where the operator buys access to
use the brand value of an existing brand i.e. brand recognition,
distribution, users/followers etc. MNO

Examples are:
• Australia: MNO Optus and Virgin Mobile
• America: MNO Sprint and Virgin Mobile

Virgin Mobile, is/has been a sub-brand MVNO in Australia,


Canada, Qatar, India, UAE and the US.

Energy drink Red Bull is/has been a sub-brand MVNO in Austria,


Belgium, Hungary, Poland, South Africa and Switzerland.

This is a sub-brand MVNO and as such, it needs a MVNO license.


MNO/MVNA/MVNO – WHOLESALE AGREEMENTS
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Own
MNO
Subscribers

Retail

LINE MOBILE MVNO


Agreements

Brand Capacity Retail Cost Revenue Commision


Licensing based pricing Minus Plus Share based

MVNO MVNO MVNO MVNO MVNO MVNO

Subscribers Subscribers Subscribers Subscribers Subscribers Subscribers


TO BE - OR NOT TO BE A MVNO – IT NOT A QUESTION
www.yozzo.com

DTAC DEFLECTS LINE MOBILE LICENSE CRITICISM


https://www.bangkokpost.com/tech/local-news/1331395/dtac-deflects-line-mobile-licence-criticism

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
www.yozzo.com

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.

❶ DTAC pays NBTC 1.50% of revenue in license fee


+ 3.50% of annual revenue in USO fee - Total 5%
❷ The MVNO also pays NBTC 1.5% of annual revenue in license
fee. It does not pay USO fee, as it dosen’t have spectrum.

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

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

As the mobile operator and MVNO each have to pay


the license fees of annual revenue, the same mobile
REGULATOR signal (voice/sms/data) ends up having double the
1 x 1.5% License Fees (MNO) = 1.5% TOTAL NOW tax, when it ends up at the MVNO and its customers.
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5% 6.5% 5%
DTAC AND SUBSIDARY TELEASSET AND DTN MVNO SETUP ON TOT 2300MHz
www.yozzo.com

If LINE MOBILE connects to DTN, which is a MVNO on TOT’s 2300MHz spectrum


then it must obtain a MVNO license, as the 2300MHz isn't’ DTN’s network but TOT’s

LINE
MOBILE
LINE MOBILE WHAT WILL HAPPEN ON 2300MHz
www.yozzo.com

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

❶ TOT pays NBTC 1.50% of revenue in license fee + 3.50%


of annual revenue in USO fee - Total 5%
❷ As a MVNO DTN also pays the NBTC 1.5% of annual
revenue in license fee. LINE Mobile pays nothing
❸ The MVNO also pays NBTC 1.5%
of annual revenue in license fee.

Example: Example: Example:


TOT resell THB 100 worth of voice calling to the DTN and LINE Mobile sells the now THB 105 worth of voice The MVNO sells the now THB 105 worth of voice calling
MVNO DTN which is THB 100 + 5% total fee = THB 105 calling to customers I.e. THB 1,05 + 1.5% fee = THB 106,57 to customers THB 105 + 1.5% fee = THB 106,57
MVNO DTN
TOT
LINE
MOBILE MVNO

Voice call Voice call Voice Call
Voice call incl. Fees incl. Fees Incl Fee
THB 100 THB 105 THB 106,57 THB 108,17

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

As the MNO, MVNA and MVNO each have


to pay the license fee, the same mobile
1 x 1.5% License Fees (MNO) = 1.5% REGULATOR signal ends up having triple tax, when it
1 x 1.5% License Fees (DTN) = 1.5% TOTAL NOW
arrives at the MVNOs and the consumers
1 x 1.5% License Fees (MVNO) = 1.5%
1 x 3.5% USO Fee (MNO) = 3.5%
8% 6.5%
www.yozzo.com

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
www.yozzo.com

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
www.yozzo.com

NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO


NBTC wants the MVNO part on the MVNA license to take over
customers, in case the MVNO client goes out of business!!!

Hello handsome MVNO,


Welcome! I will make
special price just for you!
MVNO

MVNA
OK!
MVNO
COMBINED MVNA/MVNO LICENSE = CONFLICT ON INTEREST
www.yozzo.com

NBTC ISSUES A LICENSE THAT IS BOTH AN MVNA AND AN MVNO


How can you, as a MVNO client, who want to use the service of the MVNA be
sure that it will take care your interest when it is also a competing MVNO?

Three down, five


more to go, and the
world is my oyster
MVNO

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
www.yozzo.com

YOU MUST FILL OUT ALL THE BOXES


This also means that when a MVNA is applying for a license, the NBTC wants the
MVNA to provide written information on call center, customer support, distribution
and marketing plans towards end-users, which the MVNA will never use…

MVNA
www.yozzo.com

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.
www.yozzo.com

PROBLEM #6 IN THAILAND
NO PLANS FOR MVNO’S
GOING OUT OF BUSINESS
THE NUMBER YOU HAVE DIALED IS NO LONGER IN SERVICE
www.yozzo.com

OUT OF BUSINESS
AND THEN WHAT?
NO PLANS FOR MVNO’S GOING OUT OF BUSINESS
www.yozzo.com

THE INTENTION IN REAL LIFE X 3


Section 20 of the Telecommunications Act of 2001 stipulates that: At a meeting on January 17, 2017, at the NBTC commission, TOT
The licensee shall not suspend or terminate the service, in whole or requested guidelines from the NBTC, to suspend the service with
in part, unless permitted by the Commission under the criteria and MVNO Mojo3G on grounds that the MVNO had defaulted on
payments to TOT since 2015 but TOT had continued the service.
procedures prescribed by the Commission.
And Section 22: The licensee shall, without delay, inform the Despite Section 20 on notifying the NBTC in advanced, the MVNO,
Secretary General of the following events: (5) any case that affects, had not submitted such a plan to the NBTC at the time of the
meeting taking place. Instead it was suggested that customers, could
or may affect, the business operation or the supply of service of the
voluntarily transfer to TOT, and that the MVNO must inform the
licensee as prescribed in notification of the Commission. customers on the suspension of service in order for the customers
In case of (5), the licensee shall inform the Secretary General to cancel the service, and get remaining funds back.
immediately when the events occur. The Secretary-General shall,
This is not the first time, and it will not be the last that a MVNO goes
without delay, submit the matter to the Commission after having
out of business. Prior to Mojo3G, it was MVNO 365 communication,
been informed. In this regard, the Commission shall have the power and in June 2017 the MVNO i-mobile followed suit, but did however
to prescribe certain conditions for the licensee to perform for the inform the NBTC first. Before approving the exit request, NBTC, TOT
prevention of damages to public interest. and i-mobile had to figure out how to handle the remaining users.
MVNO’S IN THAILAND ARE ALLOWED TO CONNECT TO SEVERAL MNO’S
www.yozzo.com

MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S


This provides a dilemma in case the MVNO ends its service.
Which MNO has to take over the MVNO subscribers, CAT or TOT?

MVNO

?
MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S THROUGH SEVERAL MVNA’S
www.yozzo.com

MVNO’S IN THAILAND CAN CONNECT TO SEVERAL MNO’S THROUGH MVNA’S


This provides a dilemma in case the MVNO ends its service.
Which MNO has to take over the MVNO subscribers, CAT or TOT?

MVNA MVNA

MVNO

?
ALL-IN-ONE
www.yozzo.com

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.

• Who owns the numbers – the MVNO or the companies?


• Which MNO has to take over the MVNO subscribers if it closes?
• If a MVNO can wholesale then why do we need a MVNA license?
• Who are the subscribers – The two companies or the companies subscribers?

MVNO

COMPANY COMPANY
www.yozzo.com

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
www.yozzo.com

MVNO MVNO MVNO MVNO MVNO

MVNA
CUSTOMERS
THE HOST MNO HAS TO TAKE OVER THE REMAINING CUSTOMERS
www.yozzo.com

MVNO MVNO MVNO MVNO

MVNA
IF A MVNA GOES OUT OF BUSINESS
www.yozzo.com

MVNO MVNO MVNO MVNO MVNO

MVNA
THE HOST MNO TAKES OVER AND MAKE SURE THE MVNO’S ON THEIR NETWORK CAN CONTINUE
www.yozzo.com

MVNO MVNO MVNO MVNO MVNO


EXAMPLE: SCOPES OF 3 MONTHS TERMINATION PLAN
www.yozzo.com

PRE-LAUNCH STAGE 1 STAGE 2 STAGE 3


MVNO provides the NBTC SERVICE TERMINATION REFUND CONTINUITY OF SERVICE
before service launch with a
MVNO issue a notice 3 months MVNO to provide: Main concern for subscribers:
notice which include:
before termination to:
• The subscribers with the choice • Continue to have access.
• Details and terms regarding
• NBTC to port or terminate. • Able to obtain refund.
termination of service plan
• Host operator (or MVNA) • Refund of unused prepaid
from the contract with host
• Subscribers deposit. Subscribers Service Continuity Plan
operator (or MVNA).
• Unused credit transfer to new
Notice shall include: service provider. • Subscribers who have not yet
• Information on MNP. ported will automatically
• Date of termination. • Weekly report to NBTC during continue to have access.
• Refund period for prepaid the 3 month termination • MVNO handover HLR and
customers. process. customer database to host
• Service continuity options. operator.
• Contact information. Refund process to be completed 3 • Host operator takes over the
• MNP process. month after service termination remaining customers.
notice. • Utilization of remaining /
transferred prepaid value.
• Submit final report to NBTC.
www.yozzo.com

PROBLEM #7 IN THAILAND
BUREAU-CRACY AT NBTC
KILLING INNOVATION
MVNO LICENSE APPLICATION IS IN-CORRECT AND NOT UP-TO-DATE
www.yozzo.com

TERMS AND APPLICATION FOR MVNO IN


THAILAND IS ABOUT 15-YEARS TO OLD

The application seems to be a copy and paste from old


applications and various countries in early 2000’s

In mid-2017 the NBTC added a MVNA license to the market


without request for consulting or public hearing, ending up
using the MVNO application for MVNA license as well.
LICENSE APPLICATION BUREAU-CRAZY
www.yozzo.com

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
www.yozzo.com

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
www.yozzo.com

ONCE APPROVED, THE OFFICER HANDS THE APPLICATION TO A BOARD


WHO HANDS IT TO NBTC’S BOARD FOR APPROVAL AND SIGNATURE
LICENSE APPLICATION BUREAU-CRAZY
www.yozzo.com

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
www.yozzo.com

THE OFFICER BECOMES A SINGLE GATEKEEPER, WHICH OPENS FOR CORRUPTION

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
www.yozzo.com

Thailand is among few, if not the only country in the world,


where you can get a MVNO license without some sort of
agreement (MoU) with a mobile operator (or MVNA/MVNE)
GETTING A LICENSE WITHOUT AN AGREEMENT – HOW?
www.yozzo.com

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

…and who would buy equipment BEFORE


having an MNO agreement AND a license?
www.yozzo.com

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.

BUT BETTER YET…


• Drop the need for MVNA/MVNO application/license altogether in-line with other countries who no longer issues MVNO licenses.
Doing so would make sense, as most of the issues releated to MVNO in Thailand, as discussed in this presentation would need an
update or be removed. We are aware that NBTC is very keen on licenses in order to collect fees, and we therefor suggest a solution,
where NBTC could maintain a very simple MVNO and MVNA license scheme, purely for the sake of collecting its license fees.
Copyright © 2018 Yozzo Co.,Ltd. All Rights Reserved.

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

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