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the business model for online services includes consumer-facing platforms, platform-based services, and both consumer-facing and platform-based advertising services. on the consumer-facing side, online services include social media platforms like facebook, google, and twitter, as well as platforms that support services like ride-sharing, online retail, online marketplace, streaming media, and other digital services that require an internet connection. these platforms are distinct from other online services in that their primary function is to provide a user-friendly, efficient, and interoperable online service, including the network infrastructure needed to reach users, rather than produce content or run ads. 9

this report proposes a high-level framework for thinking about the universe for regulatory action, the goals for regulation, potential tools to accomplish those goals, and ways to structure them. it envisions many potential pathways to actualizing this visiona combination of new and existing statutes, new rule-making powers, and revived use of existing powers. the report also emphasizes that, given the inherent administrative challenges of regulatory oversight, use of structural separation regimes and clear statutory rules are preferable where appropriate and possible. current ftc chair lina khan and other experts have argued persuasively that structural separation approaches have particular relevance to digital platform competition, especially where platforms play a dual role of marketplace operator and competitor within the marketplace. 28 but this is not always feasible, especially in addressing issues that extend beyond the competitive harms from the largest players. this report conceptualizes a regulatory universe for all online services, encompassing potential structural separations, statutory prohibitions, new rule-making capacities, and increased capacity for oversight. 29




if we are to break the cycle of digital market dominance and prevent natural market conditions from becoming anti-competitive forces, it is time to consider broader and more proactive approaches to digital market regulation. in the new digital gatekeepers, cheney and mooney suggest the following as examples of ideas that might be implemented to reduce the market power of dominant digital platforms and promote competition in the digital economy. initiative online intermediaries: digital platforms should be required to be intermediaries for each of their users. platforms, as media companies, should be prohibited from taking any action that directly competes with the content they create and distribute. this would not only benefit consumers, but may also benefit the platform itself by giving it a strong incentive to put the user first. platforms and platforms plus intermediaries: today, platforms such as google, facebook, and apple are mostly platforms alone. they host user-generated content, but because of their size, they also become oracles and gatekeepers of digital content, and because of their financial incentive to do so, they put in place clear standards and editorial guidelines for what is acceptable. this role for platforms should be expanded. the government should require platforms to become intermediaries that help users find content they want to see. this can be accomplished by requiring platforms to make their editorial decisions transparent and more consistent, as platforms are currently subject to inconsistent practices and inconsistent outcomes. this would have the effect of closing the information gaps that exist across the internet today. 5ec8ef588b


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