ICLE Comments, Australian Competition and Consumer Commission’s Digital Platforms Inquiry
The analysis in the Australian Competition and Consumer Commission’s Preliminary Report for the Digital Platforms Inquiry is inadequate in several ways, most notably:
- It mischaracterizes the relationship between changes in the economics of media advertising and the rise of digital platforms such as Facebook and Google.
- Its analysis of the dynamics of media diversity is misguided.
- Its competition analysis assumes its results and makes unsupportable claims about the division of advertising markets.
- It is recklessly unconcerned with the freedom of speech consequences of its recommendations.
- It fails to recognize, and proposes to supplant, the ongoing social negotiation over data privacy.
- It provides a poor analytic base on which to make policy recommendations, as it applies a static, rather than dynamic, approach to its analysis.
There is a real danger that if the policy recommendations outlined in the preliminary report were to be adopted, Australian consumers would be severely harmed.