Letter to SUBTEL re Zero

To the Undersecretariat of Telecommunications: Mr. Pedro Huichalaf,

We write to you to ask for clarification regarding the official circular letter No. 40 /DAP 13221 /F­51, issued on April 14, 2014. In particular, we would like to clarify that this order does not apply to providing free mobile access to educational resources. In developing nations across the globe, the has partnered with mobile network operators interested in expanding their philanthropic operations to provide mobile access to Wikipedia without data charges through a project called Wikipedia Zero. is an ideal country for Wikipedia Zero because it has a great need for free knowledge and a high mobile penetration in urban and rural areas, providing the perfect setting to deploy the program.

“Imagine a world in which every single human being can freely share in the sum of all knowledge” – that is the vision statement that guides the Wikimedia Foundation, the non­profit organization behind Wikipedia. As the largest and most popular online encyclopedia in the world, Wikipedia has more than 30 million volunteer­authored articles in over 287 languages (including Spanish), and is visited by more than 490 million people every month, making it the largest collection of shared knowledge in human history. All the content on Wikipedia is provided under a Creative Commons license to encourage anyone to freely reuse and contribute to the content. That is why Wikipedia content can now be found in multiple third party applications and websites, like the Google Knowledge Graph.

Our mission is to empower a global volunteer community to collect and develop the world's knowledge and to make it available to everyone for free. In our pursuit of this mission to provide free access to knowledge, we recognize that the next billion people to discover the web will do it not on PCs, but by using mobile phones, which are less expensive and more widely available. However, the data charges that come with using mobile phones can impede people living in low­income communities and with less means. This is why we developed Wikipedia Zero, to provide a free educational resource for those who need it most. To date, we have launched Wikipedia Zero in 29 countries with the help of 34 operators, giving an estimated 350 million mobile subscribers free access to Wikimedia sites. We hope these numbers will grow as we continue to expand into Latin America.

Why Chile is Important

Chile is an important country for the Wikipedia Zero program because it has a great need for free educational resources, while also having an infrastructure to support the program due to its high mobile penetration. Over 3M Chileans are currently considered to be living under the poverty line according to the United Nations Development Programme's latest study. The lower income fraction of the population is in dire need of free education resources, particularly in rural areas. The prospect for implementing Wikipedia Zero is also very positive. Chile has a high mobile penetration with over 24M SIM cards in use in a country of 17M people. Chilean mobile carriers have a strong focus on education as part of their Corporate Social Responsibility values. Finally, Chile is recognized as a leading country in Latin America particularly with respect to telecommunication and it is often followed by other countries in the region. Chile therefore is the ideal country to become one of the first countries in Latin America to deploy Wikipedia Zero.

How Wikipedia Zero Operates

Wikipedia Zero is structured to enable universal access to knowledge in a non­rivalrous manner. When a mobile operator agrees to offer Wikipedia Zero, every user of that network is given free access to all of Wikipedia, even if they do not have a data plan. Wikipedia Zero does not have exclusive deals with mobile operators ­­ any and all mobile operators can offer it simultaneously, and we encourage them to! For instance, in , most carriers have signed on to provide their subscribers with free access to knowledge. Mobile operators therefore cannot use Wikipedia Zero in an anticompetitive manner. Moreover, Wikipedia Zero is not included in bundles of limited services or as part of commercial offers of the type that were discussed in your letter of April 14. Wikimedia does not pay mobile operators, and operators do not pay Wikimedia – it is a service offered only for humanitarian reasons. We are a non­profit, so there is no motivation to gain users other than to provide educational benefit to those users. Unlike some social media companies, we do not collect any personal information from users in order to generate advertising revenue. Carriers also do not collect this information as there is no deep packet inspection, monitoring, verification, or filtering of content. Finally, Wikipedia Zero is provided in all languages, to allow equal access to everyone.

Because transparency and accountability are two of the Wikimedia Foundation Guiding Principles, we have issued a statement of operating principles to provide more insight into how Wikipedia Zero operates. The statement is available on our website: https://wikimediafoundation.org/wiki/Wikipedia_Zero_Operating_Principles.

SUBTEL's recent order on April 14, 2014, determined that certain commercial bundles offered by mobile carriers were against domestic Telecommunications legislation. These bundles, which waived data charges for users when using certain social media applications, were discriminative to other content providers of a similar nature, under the Chilean Telecommunications law. Given that Wikipedia Zero is a unique service that does not implicate any of the concerns discussed in SUBTEL's April 14 order, we ask SUBTEL to confirm that the project is indeed not implicated by the order, and that Wikimedia may partner with mobile operators to offer this philanthropic service.

Do not hesitate to contact us in case you require further information about the Wikipedia Zero project. We would love to set up a call with you to discuss this further.

Thank you,

______Erik Möller Eduardo Testart Deputy Director, Wikimedia Foundation President, Wikimedia Chile