APAC BYTES - 08 MAR 2019 - International Institute of Communications

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APAC BYTES - 08 MAR 2019 - International Institute of Communications
08 MAR 2019

              APAC
              BYTES
CONTENTS
AUSTRALIA .................................................. 2         NEW ZEALAND .......................................... 10

CHINA .......................................................... 3     PHILIPPINES .............................................. 11

HONG KONG................................................ 4            SINGAPORE ............................................... 12

INDIA ........................................................... 5    SOUTH KOREA .......................................... 13

INDONESIA .................................................. 6         TAIWAN .................................................... 14

JAPAN .......................................................... 7     THAILAND ................................................. 15

MALAYSIA .................................................... 8        VIETNAM .................................................. 16

MYANMAR .................................................. 9

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Facebook and Google Critical of ACCC Approach

                                                                                                         AUSTRALIA
Facebook has termed the ACCC’s digital platforms inquiry as “intrusive” and reiterated that “people,
not regulators” should be allowed to determine the content of their newsfeeds. The social media
giant, in an unpublished submission to the ACCC, felt there was no basis for appointing a govt Ad
Regulator or a govt News Ranking Regulator, as the ACCC has the authority to investigate and
intervene; especially if there is sufficient evidence of contravention of the Competition and
Consumer Act or the Australian Competition Law.
▪ Google’s rebuttal deems the additional regulatory oversight proposals as also unnecessary given
    the ACCC’s preliminary report does not identify any specific anticompetitive action taken by
    Google that favours its own products over others. Google feels the regulatory review of its
    algorithms and recommendation engines would lead to lower quality search results, and
    disputed several other claims made by the ACCC in terms of referrals made to news publishers.
▪ Twitter feels the monitoring of its ranking of news and journalistic content would be
    inappropriate because the service uses algorithms “different” from other services and content is
    often dictated by the whom the users follows, not by the platform itself.
 Impact Analysis: While Facebook is seeking minimal govt oversight, its missteps have lost it the
    trust of many of its users. In fact, the users themselves are the ones clamouring for greater govt
    oversight by applying pressure on their elected representatives to review the data collecting
    habits of these companies and demonstrate greater transparency in their business practices –
    part of which include the selling of data to third parties.

ASIC Reviewing ePayments Code
The Australian Securities and Investments Commission (ASIC) has put out the first of two
consultation papers for the review of the ePayments Code, a voluntary code of practice that
regulates e-payments, online payments, credit/debit card transactions, and Internet and mobile
banking. Submissions are welcome until 5 Apr.
▪ The review, which takes place every five years, is to assess the Code for its fitness for purpose,
    effectiveness, and relevance in the face of new fintech innovation.

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NDRC Lays out Plan to Transform GBA into Technology Hub

                                                                                                           CHINA
Following the unveiling the Greater Bay Area (GBA) Development Blueprint, NDRC has also outlined
the strategic plan of its key initiative to turn GBA into an international innovation and technology hub
– rivalling the Silicon Valley.
▪ A taskforce will be formed to steer the strategic plan that involves ironing out discrepancies in
     IPR protection policies and market regulations, technology commercialisation, as well as
     nurturing IT talent.

China Calls for 30% Cut in Mobile Access Cost
Despite all three mobile operators slashing their service charges by 60% in 2018, Premier Li Keqiang
has called for an additional 30% reduction in mobile access fees. He stressed the importance of high-
speed broadband services in enhancing education and medical services in rural areas during the NPC
annual meeting.
▪ CEO of Netease and Xiaomi echoed the govt’s call and suggested the deployment of online digital
    schools, medical wearables, and IoT applications in rural communities once Internet access has
    been made more affordable.

TC260 Releases Draft Revision on Personal Information Security Specification
The Information Security Standardisation Technical Committee (TC260) has issued a draft revision of
the Personal Information Security Specification. Key amendments stipulated in the specification
include:
    1. Data controllers shall not request data subjects to provide consolidated consent to a bundle
         of services;
    2. If a data subject does not consent to using a specific service function, the personal
         information controller shall not refuse to provide the data subject with other services he/she
         chooses to use or reduce the service quality;
    3. When e-commerce platforms provide personalised and targeted recommendations, data
         subjects should be informed and provided with a simple opt out method; and
    4. Data controllers shall establish work flow and management mechanisms if they allow third-
         party service providers to access personal information through their service and specify their
         respective responsibilities and measures regarding information security.
 Impact Analysis: The comprehensive specification provides good practices for online service
    providers and app developers to benchmark with their personal data collection and information
    security policies. Although these standards are not mandatory or legally binding, they are
    indicative of the views of the regulators such as CAC on issues like bundled consent and third-
    party’s access to personal information. Hopefully govt agencies will also take these specifications
    into consideration when evaluating companies’ compliance with personal data protection
    regulations.

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Budget Allocates Significant Funding for R&D

                                                                                                           HONG KONG
The 2019-20 Budget sees the allocation of funding to the universities and Cyberport to bolster
innovation and technology development.
▪ The govt will set aside HKD16bn (USD2.05bn) for University Grants Committee-funded
    universities to enhance campus facilities for R&D activities.
▪ To attract and nurture IT talent, the monthly allowance for local researchers who join the IT
    industry will increase to a maximum of HKD21,000 (USD2,700) while HKD500m (USD63.7m) will
    be allocated to the “IT Innovation Lab in Secondary Schools Programme.
▪ The govt also earmarked HKD2bn (USD0.25bn) to subsidise manufacturers on a matching basis to
    set up smart production lines under a “Re-industrialisation Funding Scheme”.
 Impact Analysis: Despite the govt’s emphasis on the importance of having a holistic strategy and
    the development of “talent-intensive" industries, the 2019-20’s resource allocation on
    innovation and technology continues to focus on enhancing infrastructure such as expanding the
    Cyberport and R&D facilities in the universities. There is a lack of new policies to cultivate local
    talent and increase their competitiveness. Measures such as the Researcher Programme and the
    Postdoctoral Hub Programme are carried forward from the 2018-19 Budget. While the Greater
    Bay Area (GBA) will present research collaboration opportunities for local startups and
    enterprises, Hong Kong needs to compete with other core cities in GBA for IT talent. The talent
    drain issue will become more acute should the city fail to attract or keep top-notch R&D
    professionals.

China Introduces Measures to Facilitate Hong Kong Entrepreneurs and Talent Flow
During the second plenary meeting of the Leading Group for the Development of the GBA, the
Central Govt announced further policy measures to facilitate Hong Kong residents, especially
professionals engaged in research and high-end jobs, to work and pursue their career in the GBA.
▪ High-calibre, in-demand talent from Hong Kong will enjoy a tax relief through subsidies from the
    provincial govts to offset the differences in personal income tax rate. Cross-border stays that last
    for less than 24 hours will not be counted towards the 183 days of presence in the Mainland
    which determines whether global taxation will apply.
▪ Young entrepreneurs from Hong Kong and Macao are encouraged to start businesses in the nine
    Mainland cities while municipal govts in Guangdong will provide funding support to education
    and research institutes in Hong Kong to strengthen cross-border technological collaboration.

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Cabinet Approves National Policy on Software Product 2019

                                                                                                       INDIA
MeitY has released the “National Policy on Software Product 2019”, which is aligned with other govt
initiatives such as StartUp India, Make in India, Digital India, and Skill India.
The vision of the policy is to:
▪ Promote a sustainable Indian software product industry;
▪ Nurture 10,000 tech startups and generate employment for 3.5 million people by 2025;
▪ Create a talent pool for software product industry;
▪ Build a cluster-based innovation driven ecosystem.
 Impact Analysis: The policy, as approved by the Cabinet, could potentially encourage innovation,
     startups, and the creation of intellectual property in India by fostering greater collaboration
     between govt, industry, academia, and other stakeholders.

TRAI to Hold OHD on Regulatory Framework for OTT in end-Mar
TRAI has announced its first Open House Discussion (OHD) on its Consultation Paper on “Regulatory
Framework for Over-The-Top (OTT) Communication Services”.
▪ TRAI had, however, initially aimed to release its recommendations by end-Feb following an OHD
   with industry stakeholders.

DoT Sets Up a Panel to Give Views on 5G Trial Spectrum within 30 Days
The DoT has set up a committee to recommend the scope of 5G trials in India within 30 days. The
committee will also give its recommendations on the size, quantum, pricing, and other aspects for
offering trial spectrum for 5G trials.
▪ It will also share its recommendations on relevant issues as envisaged in the National Telecom
    Policy 2018.

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Kominfo to Reach 4G LTE Targets

                                                                                                      INDONESIA
Kominfo plans to reach 100% of its target coverage of 4G LTE by end 2019.
▪ Kominfo has stated they have achieved 97% coverage of the total population in 514
   districts/cities in Indonesia through Telkomsel.

BI to Issue QR Code Standard Regulation
BI has stated it will issue a regulation standardising the use of QR codes.
 Impact Analysis: BI has previously flagged the need for alignment, and this recent announcement
    is in response to the array of QR codes that deviate from a common standard, due to the number
    of financial service providers utilising QR codes, and retailers providing QR code facilities.

Huawei Collaborates with Telkomsel and XL Axiata
Huawei has struck separate partnerships with both Telkomsel and XL Axiata.
▪ XL Axiata and Huawei have collaborated to build a next-gen all-optical network in preparation for
   an anticipated 5G rollout.
▪ Telkomsel and Huawai have signed an MoU and will cooperate on future evolution, technology
   innovation via the Joint Innovation Centre 5.0, digital services exploration, and talent
   development.
 Impact Analysis: Despite the hesitation and criticism other countries have expressed regarding
   Huawei (including the US and Australia), we are unlikely to see these same discussions
   throughout Southeast Asia. Indonesia, and these recent partnerships, are a great example of this
   as they’re willing to continue to develop their ecosystem, support the Digital Indonesia 2025
   vision, and become the largest digital economy in Southeast Asia through whatever means
   necessary.

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Cabinet Approves Bill to Separate Mobile Phone and Data Costs

                                                                                                         JAPAN
Following approval from Prime Minister Shinzo Abe’s cabinet, the bill to amend the
Telecommunications Business Law now moves to the Diet. The govt is aiming to pass the bill in the
current session, which will run through Jun.
▪ The amended bill will bar MNOs from bundling their connection fees with the price of the mobile
    handset. SoftBank and KDDI have acknowledged their compliance to the new rules, while NTT
    DoCoMo is expected to adopt the changes from Mar onwards.
 Impact Analysis: Currently the three MNOs in Japan control approximately 90% of the domestic
    mobile phone market in the country and their system of bundling has long been criticised as a
    tool for keeping their subscriber fees high. This proposed amendment will hopefully even out the
    playfield between the MNOs and MVNOs. This change is also likely to provide consumers with
    more freedom when it comes to porting their numbers or changing their handsets.

Japan to Unleash National Digital Currency J-Coin Pay
60 financial institutions (FIs), including Mizuho, Japan Post Bank, Ogaki Kyoritsu Bank (OKB), Bank of
Toyama, Shinsei Bank, and Sumitomo Mitsui Trust Bank, have launched a digital currency platform
called “J-Coin Pay”. Users will be able to make payments, receive transfers, and perform other
financial transactions via the designated smartphone app.
▪ The new national digital currency is being launched prior to the upcoming Tokyo 2020 Olympics.
     Non-Japanese customers visiting the country will be able to utilise the service through
     partnerships with non-Japanese QR code operators.
 Impact Analysis: Contrary to popular belief, the J-Coin Pay will be not be launched by
     cryptocurrency nor will it use blockchain in any form. A QR-code payment system is perhaps the
     better alternative, making it easier for international businesses to add the feature to their
     service.

Japan Watchdog Launches Probe on Shopping Websites
The Fair Trade Commission has launched an investigation into the practices of major online shopping
mall operators to weed out any abuse between the platforms and their sellers. Companies subject to
the investigation include: Amazon Japan, Rakuten, and Yahoo Japan.
▪ The Commission will also be conducting a survey of developer of apps for Apple, Google, and
    other smartphone platforms.

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Data Protection Remains a Priority

                                                                                                         MALAYSIA
Communications and Multimedia Minister Gobind Singh Deo stated that citizen privacy and
information security were top priorities of the govt. It would also welcome technological
investments, but only if they upheld the interest and security of the people.
 Impact Analysis: The remarks by the Minister come in light of a report Facebook had targeted
    legislators and regulators around the world. With promises of investments or threatening to
    withhold them, the company pressured them to lobby on its behalf against data privacy
    legislation. Malaysia is one of the dozens of countries included in the report, with promises of a
    new data centre and job creation used to push for legislative guarantees. Recently, regulators
    and policymakers have been spurred into action and are keeping a much closer watch on data
    collection practices of Internet companies like Facebook. This could lead to more punishments
    and restrictions on its data policy practices, adversely impacting its advertising business.

Maxis and Huawei Partner on 5G
Maxis has signed an MoU with Huawei to accelerate the implementation of 5G technology in
Malaysia. The partnership will focus on 5G trials with end-to-end systems and services.
 Impact Analysis: While Maxis had already begun focusing on live trials and investments in
   network infrastructure, partnership with Huawei, a global leader in telecommunications
   equipment, will help further expand its business to consumers and businesses. The partnership
   however, comes at the time when the US is pushing for a ban on Huawei’s 5G network
   equipment. EU, Canada, Britain, and Germany are also considering a potential ban. While the
   Malaysian govt has not made an official decision, and the MCMC is still conducting its study on
   Huawei’s technology, this MoU signals the country’s intent to proceed with 5G technology. In
   Apr, Cyberjaya and Putrajaya will become the first cities in Malaysia to begin 5G tests. Plans are
   also in place to launch 5G pilots in Perak by Jul.

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Govt Helpless Against Dishonest Telecoms

                                                                                                    MYANMAR
The govt has acknowledged the difficulty it is facing in stopping telecom operators that impose
surcharges on customers, as shutting them down for even an hour could hamper communications in
the country.
▪ According to U Hla Moe, Deputy Minister of Transport and Communications, mobile phone users
    are being subjected to unreasonable charges or have been charged for more than actually used,
    without their knowledge or consent. Laws and sanctions can, however, be slapped on erring
    telcos. This includes warnings, temporary suspensions, or licence revocations – but they are
    impossible to enforce in practice.
▪ The Ministry will study whether it would be possible to sue these operators under section 66(c)
    of the Telecommunications Law, which states it is a punishable offense to “steal, cheat, or
    misappropriate any money and property by using any Telecommunications Network”.

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5G Spectrum to be Auctioned off in Early 2020

                                                                                                          NEW ZEALAND
The first 5G spectrum allocation is expected to be the 3.5GHz band, with national spectrum rights
coming into use starting Nov 2022. The govt is also working with Maori to address spectrum related
Treaty of Waitangi issues, so as to free up the 3.5GHz spectrum for auction.
▪ A consultation on the auction process is expected to take place in H2 2019. MNOs had been
    hoping to get their hands on 5G spectrum at an earlier date, in preparation for the 2020-21
    America’s Cup to be held in Auckland.
▪ The govt also released a Cabinet paper on the allocation of radio spectrum for 5G mobile
    services, which sheds more light on the process.
 Impact Analysis: The auction of 5G spectrum opens up some interesting possibilities around the
    entry of a new service or a new provider. The govt is leaning towards introducing limits on the
    amount of national 5G spectrum given to any single operator, so as to inhibit stronger players
    from shutting out smaller players or potential new entrants.

Payments NZ Releases First API Standards
The first APIs are for Payment Initiation and Account Information. They are part of a common API
standards management framework and ecosystem intended to propel innovation in digital financial
services by embracing openness.
▪ The APIs follow a year of cooperation and numerous pilots between Payments NZ and the
    industry; principally working with ANZ, Kiwibank, Mero Limited, ASB, BNZ, Westpac, Datacom,
    Paymark, and Trade Me.
▪ Organisations can now register in the coming months to become users of the new APIs.

Productivity Commission to Look at the Future of Work
The New Zealand Productivity Commission will carry out research on the future impacts of
technological change, its potential disruption on the local workforce, and ways of managing these
impacts. A discussion paper will be issued in Apr, with a final report likely to be delivered by 31 Mar
2020.
▪ The Commission will also examine how New Zealand can better position itself to fully realise the
    potential for economic productivity and social prosperity.

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Candidates to Register Social Media Pages, Websites Ahead of Election Campaigns

                                                                                                           PHILIPPINES
Ahead of the Senate and General elections on 19 May, the Commission on Elections (Comelec) has
reminded candidates to formally register on all online platforms they wish to campaign on, including
those being used by their supporters.
▪ Online campaign posts are subjected to monitoring and regulation under Comelec
    Resolution 10488, where unregistered sites will be recommended to be taken down.
 Impact Analysis: Social media now plays a significant role in elections, particularly in the
    Philippines, where social media usage is one of the highest in the world. Aside from its wider
    reach and ability for anyone to share their opinion however, social media can also be used as a
    ‘misinformation’ tool, by creating filter bubbles and use to share ‘fake news’ and thus needs to
    be monitored and regulated carefully.

Police to Validate Huawei Spying Claims
Following the warnings and allegations Huawei equipment could be used to spy on behalf of the
Chinese govt, the Philippine National Police (PNP) will verify any information regarding the security
risks.
▪ The PNP have not found any concrete evidence linking Huawei to such claims and thus
     has not barred Huawei from operating or bidding for tenders.
▪ PLDT has voiced its concerns over the US’ allegations and while it is still discussing
     procurement with Huawei, is also in talks with other vendors Ericsson, Nokia, and ZTE.
 Impact Analysis: While the US vs China/Huawei issue may ultimately be trade-motivated more
    than anything else, it is still causing a division between govts all around the world and telcos on
    who to ‘trust’. While Southeast Asia has largely appeared to be indifferent to the current division,
    Huawei has been a huge ally to many govts and is likely to continue to face little opposition in the
    region.

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Singapore Plans for 5G Roll-out by 2020

                                                                                                    SINGAPORE
The MCI’s expected roll-out of 5G by 2020 is seen as a move "to maintain Singapore's competitive
edge in connectivity".
▪ The IMDA will soon be launching a public consultation on regulatory framework and policy issues
    including the allocation of spectrum.
▪ Singtel, StarHub, and M1 have kicked off 5G trials with industry partners.

MAS Proposes New Security Guidelines for Financial Resilience
The MAS has released two consultation papers to introduce changes to the existing Technology Risk
Management (TRM) Guidelines and the Business Continuity Management (BCM) Guidelines,
requiring FIs to implement more measures to boost their operational resilience.
▪ The changes included guidance on cyber surveillance, secure software development, and the
   management of security risks posed by the IoT. The MAS also aims to boost the development
   of business continuity plans, to better account for interdependencies across business units
   within the FI and connections with external service providers.
▪ The public consultation runs till 8 Apr 2019.

MAS Unveils Plans to Form a New Technology Group
The MAS has announced new senior management changes and the establishment of a technology
group encompassing a data analytics group, information technology department, and technology and
cyber risk supervision department.
▪ The agreement will pave the way for Boost Malaysia (Axiata Digital’s m-wallet) to join VIA, the
    Singtel Group’s cross-border m-payment alliance; expanding the reach of the payment service
    for Singtel Dash and AIS GLOBAL Pay users already on VIA.
▪ Both Singtel and Axiata Digital also plan to jointly promote and drive cross-border payments to
    grow their respective user bases, merchant networks and explore collaboration around rewards
    or loyalty programmes.

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Confirmation of Amendments to Information and Communications Network Act

                                                                                                            SOUTH KOREA
The KCC has confirmed two amendments to the Act on Promotion of Information and Communications
Network Utilisation and Information Protection (“Information and Communications Network Act”).
They will be in effect from 19 Mar.
▪ According to Article 19, foreign offshore information and communication service providers
    meeting certain requirements must appoint a local representative responsible for domestic data
    privacy compliance.
▪ Article 63-1 mandates that prior consent be sought for the onward transfer of domestic
    information to a second foreign location. If consent was not sought in advance, or other protective
    measures not duly taken during the transfer of information, the penalty is KRW10m (USD8,800)
    per violation, up to KRW30m (USD26,500).
 Impact Analysis: These are the first of several amendments to the Information and
    Communications Network Act due to come into effect in 2019. They have been passed with the
    goal of aligning South Korea’s data protection standards with the EU’s GDPR to allow the free
    flow of personal data between both regions. The EU is a lucrative market for digital businesses
    and South Korea is unabashed about its plan to focus on the data economy to further propel its
    economic growth.

MSIT to Postpone 5G Commercialisation
The MSIT, earlier criticised for rushing to commercialise 5G mobile services by end-Mar, has officially
delayed the commercialisation of 5G mobile services. The MSIT will continue to consult with mobile
phone developers to finalise an appropriate launch date.
▪ The Ministry’s inability in preparing the country for commercialisation is evident as the
    developers have struggled to introduce 5G smartphones into the market on time. Both
    Samsung’s and LG’s 5G models are only expected to be released in Apr and May respectively.
▪ Telcos’ subscription plans have also not been finalised or approved.

MSIT Rejected SK Telecom’s 5G Subscription Rates Plan
MSIT has rejected SK Telecom’s proposed 5G subscription rates plan on the basis it only provided the
fee structure for heavy data users, limiting the rights of light data users to select services. Moreover,
the fees were expensive and contradicted the govt’s agenda to reduce the telecommunication
spending of households.
▪ As market leader, SK Telecom had to seek approval for its subscriptions rates while KT and LG Uplus
    need only apprise the govt of theirs. The latter two are likely waiting for SK Telecom’s plan to be
    approved before designing theirs.
▪ SK Telecom plans to re-submit its proposal after a review.
 Impact Analysis: MSIT’s decision sheds light on the uphill task telcos have in hoping to recoup
    the significant investment they had made into 5G services. Focusing on heavy data users would
    have allowed telcos like SK Telecom to streamline their services towards the demands of these
    high-paying customers, and hence draw a higher profit margin. However, MSIT’s comments on
    the need to cater to light data users as well could now see telcos taking a longer time to recoup
    those investments, if they ever do. In addition, the lack of approval on the subscription rates plan
    could postpone the commercialisation of 5G mobile service, which was scheduled for launch in
    end-Mar.

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ITRI Establishes Smart Grid Academy and Development Alliance to Nurture Talent

                                                                                                      TAIWAN
To address the issue of insufficient talent and boost the development of smart technology, IoT, and
renewable energy, the ITRI has established a training programme titled the “Smart Grid Academy”.
▪ This initiative follows the establishment of the Smart Grid Management and Modernisation
    Office in Jul 2018.
▪ 24 professionals were recruited from different industries and academic areas to form the “Smart
    Grid Development Alliance" to serve as mentors. The training programme, scheduled to
    commence in Apr, will provide up to NTD1m (USD32,000) scholarships.

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NLA Approves Cybersecurity Bill and Personal Information Protection Act

                                                                                                         THAILAND
Both the Cybersecurity Bill and Personal Information Protection Act have been approved by the
National Legislative Assembly (NLA). The legislations will become laws once they are published in the
Royal Gazette.
 Impact Analysis: Leading up to the general election, which is scheduled to take place on 24 Mar,
    it was unclear whether these crucial laws will be passed. The Cybersecurity Bill had faced severe
    criticism from various stakeholders over the authority it awards the National Cybersecurity
    Commission. This includes access to computer systems believed to be involved in “critical
    cybersecurity threats” without a prior court order. Despite this backlash – which resulted in the
    Bill going through a number of public hearings over the past few months – the current lawmakers
    have managed to get the law passed, before the new govt comes into power. It remains to be
    seen what the final legislation looks like, but one shouldn’t expect any major changes in the high
    degree of powers granted to the National Cybersecurity Commission.

Telcos to Establish Dedicated Cybersecurity Team
Eight telcos have announced plans to set-up the Telecom Computer Emergency Response Team
(CERT) to monitor and prevent cyberattacks.
▪ The eight companies are TOT, CAT Telecom, Advanced Info Service (AIS), Total Access
    Communication, True Internet Corporation, Symphony Communication, CS Loxinfo, and United
    Information Highway.
▪ The Telecommunications Association of Thailand (TCT) claims the CERT will be self-regulated and
    is expected to be operational in 2020.
▪ The companies will share information on cyberattack warnings and collaborate on cyber-threat
    related analytics.
▪ With BOT already having a CERT in place, the above-mentioned Telecom CERT will be the second
    in the country to connect with the Govt’s CERT, which is operated by the ETDA.

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Govt Creating National Database and Public Service Portal

                                                                                                      VIETNAM
The govt is aiming to create a national database system and launch a national public service, in an
effort further transition the country towards e-governance. The service envisions connecting the
central govt to the multiple local govt portals for monitoring and further enhancement of public
service delivery.
▪ This is an initiative of the National Commission for e-Government, which was established in Sep
    2018.

Slow Take-up of Number Portability
The MIC has reported that after three months of deployment, from Dec 2018 to Feb 2019, only
115,185 subscribers had registered for number portability. However, the number of successful
network transfer subscribers during this period was 71.6 million.
 Impact analysis: Given that Vietnam's total mobile subscribers is approximately 120 million, and
   network transfers ran at approximately 60% for the initial three months of mobile number
   portability, it could be lack of consumer awareness stymying efforts, or also that Vietnamese
   subscribers are less attached to their mobile numbers.

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