Welcome to 2020 and before us the start of the new year and, more importantly, the start of a new decade. So lets start out with a strong, confident approach and make sure we all understand this newish technology called eUICC, eSIM, and even iSIM.
This Part 2 of the discussion will refine and define observations that have been generally stated in Part 1 (R6); examine more closely eSIM and eUICC aspects. Due to the huge amount of material that needs to be condensed, as per the last post (Part 1) a heavy use of references will be given for further reading or in support of observations made in Part 2. Moreover, Part 2 will need to be posted in sections (Part 2.1, Part 2.2, etc.) so as not to blur the concepts being discussed and overloading the reader with excessive information in a blog post.
CONNECTIVITY - AA.35
To foster the goal of seamless global connectivity GSMA has developed and published 'AA.35' (R7). In brief, this document defines the GSMA's policy and procedures for global vision for the creation and adoption of Industry specifications. It is an important document, and not just from a management perspective or GSMA's paternal role, but explains the how's and why's of how various aspects of operability, interoperability and interworking essential in the telecommunications ecosystem requires to have a balanced approach. That means with respect to the GSMA membership (the participants):
"Industry Specifications are defined in AA.35 as "any specification for: (i) common adoption ; and (ii) repeated implementation, application and functioning ; and (iii) general use, operations and support in multiple segments of the telecommunication ecosystem ; or (iv) consistent testing, verification and certification; of technology that would directly and materially affect simultaneously mobile network operators and non-mobile network operator participants within the mobile industry ecosystem. Industry Specifications do not include specifications that: (i) only affect interoperability or interworking between mobile network operators ; or (ii) do not add additional specifications to technical solutions ." AA.35 section 3 .3." (R8)
Observation: In a nutshell interpretation of the above it seems to me might suggest those who voluntarily enter into creating or participating with Industry specification may, as a case in point, be making a form of Hippocratic Oath: "make a habit of two things - to help or at least to do no harm."** (R9). I have suggested 'Oath': as it is already international recognised; Antitrust seeks to prevent harmful restriction; GSMA is seeking international acceptance of AA.35; and participants undertake not to be the cause-bringer of harmful disruption.
A further glimpse into why AA.35 is an important document can be found in the DoJ response Wednesday, November 27, 2019 (R10) to the Business Letter Review. I think once I read the DoJ's release I could envisage eUICC, eSIM, and iSIM having more appeal to handset manufacturers to open up a technology-advantage over older handsets and create a competitive-advantage. Three pertinent paragraphs in the DoJ release that are supportive of that are:
"The GSMA expressed its intent to adopt the new procedures in a request for a business review letter from the Antitrust Division. After completing its investigation, the division is today issuing a business review letter that expresses concern about the past procedures and some of the resulting provisions in the standard. The letter concludes, however, that the proposed changes appear to adequately address those concerns. In light of these planned changes, the Antitrust Division has no present intention to bring an enforcement action against the GSMA or its mobile network operator members." (para 2)
So there is, at present, no barrier enforced/encumbent barrier deterring adoption.
" “I am pleased that the GSMA is ready to use its standard-setting process to create a more consumer-friendly eSIM standard,” said Assistant Attorney General Makan Delrahim. “The GSMA’s old procedures resulted in certain eSIMs rules that benefitted only its incumbent mobile network operators at the risk of innovation and American consumers. The new procedures proposed going forward significantly reduce that risk and should result in new innovative offerings for consumers.” " (para 3)
The principle of a level playing field (commonality) brought about by consumer-friendly eSIM standard will have a huge appeal to suppliers and consumers alike. I suppose (in an imaginative way) this might be thought about in terms similar to that when 'Java' first came out - hiding the complexities of a range of disparate devices/systems in order that they may communicate together.
" "The mobile communications industry has begun to migrate away from traditional SIM cards—a removable plastic card that is preprogrammed to connect to a single mobile network—and toward innovative eSIMs, which perform the same function as a SIM card but are soldered into the device and capable of being remotely programmed and re-programmed to connect to different operators’ mobile networks. The mobile industry refers to this process as Remote SIM Provisioning (RSP)." " (para 4)
And finally, acquisition of an approved profile using GSMA's development called Remote SIM Provisioning (RSP), what I would describe as being similar to a Passport Office. If you don't have a Passport, you can't travel.
In the next article (Part 2.1) I will define and refine further handling GSMA Documents and Standards (3GPP/ETSI) that is discuss how we use standards and how Documents have influence.
(R6) https://trewmte.blogspot.com/2019/12/esim-observing-possible-outcomes-part-1.html
(R7) Provisions for the Policy and Procedures for Official Document in relation to Industry Specifications - AA.35 Version 1.0.0 - 1 5th March 2019
(R8)CLIFFORD CHANCE US LLP Confidential Treatment Requested by Clifford Chance US LLP on Behalf of The GSM Association July 25, 2019 addressed to Assistant Attorney General Antitrust Division Department of Justice (document released by DoJ following its Antitrust review in Business Request Letter from the GSMA legal advisors).
(R9) **Epidemics I:XI. The commonly cited Jones translation follows Littre and goes: "make a habit of two things —to help, or at least do no harm" (Hippocrates [1923a]). Jonsen notes that the Greek text does not contain the words "at least." Jonsen AR. "Do No Harm." Ann Int Med 1978;88:827-32. I have used a later translation (Hippocrates [1950]).
(R10) Department of Justice Office of Public Affairs Justice Department Issues Business Review Letter to the GSMA Related to Innovative eSIMs Standard for Mobile Devices Wednesday, November 27, 2019
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