CRTC rules against Usage Based Billing

The CRTC has made a very important, and surprising, ruling on the state of usage based billing on wholesale ISP's in Canada.  While this actually won't affect most people reading this, it is a pretty important and precedent setting ruling.  The most surprising thing about the ruling? The fact that it is actually pro-consumer, not pro-big business.

UPDATED: see the bottom of the post for an update

To keep it simple, the CRTC has ruled that Bell cannot charge wholesale ISP's based on how much data moves through the network.  Bell can, however, charge based on speed of the connection.  As a quick reminder, wholesale ISP's are smaller, often local ISPs that do not have their own network.  They lease space from large ISP's such as Bell, and resell that service to consumers.  So while this ruling does not affect the consumer directly, this will have an impact in the long run.

I made the point months ago that charging wholesale ISP's, or even regular users, on a usage based billing system that puts a limit on how much data a user can download each month makes zero sense.  I won't go back into it, but you can find the previous posts from January 2011 and on on this site that will explain all of it.  The nuts and bolts are that the true cost to the ISP is not how much data moves through a connection, but how fast the connection actually is.  Data is a nearly infinite resource; I'm creating data typing this post right now.  But how fast you can get that data is limited, and it does cost ISP's more to offer faster connections.

In a nutshell, with this ruling are that the CRTC has seen the truth to this argument, and has said that Bell can charge wholesale ISP's more for a bigger, faster connection, but not for how much data moves through.  This is a very fair ruling as it does reflect the true cost of internet service.  Wholesale ISP's should be charged more to lease more bandwidth (the actually term for the speed of the connection) from Bell, as that really is where the cost is.  I don't think you'll find many rational arguments against that, as it is fair for everyone.

Why this is important is that it is precedent setting.  Since Bell can't do it, It will be nearly impossible for Rogers, Telus or Shaw to charge wholesale ISP's on usage based billing now as well.  It also means that there is a stronger argument for the general consumer should not be subject to usage based billing.  If large ISP's can't do it for their wholesale customers, why should the general consumer face that type of restriction.  I have always been a proponent of this, and this does give another bullet in the chamber for the groups that are lobbying for it.

The last thing I will say is that I'm very surprised at the ruling, in a good way.  The CRTC very rarely makes consumer friendly rulings of this magnitude.  Traditionally it has catered to larger businesses.  This ruling helps small businesses the most, but will have a long term positive impact on the state of internet and content delivery in Canada.  There are many CRTC rules which I think are so anti-consumer they hurt more than they help (simulcasting sports broadcasting is my favourite example), but this ruling is a surprising breath of fresh air, and a very welcome one.

UPDATE: Since the posting of this article some new news and clarifications have come out.  I have also included links to the original article, as well as the two new articles for this update below.

The Canadian Association of Internet Providers (can no one come up with better names for these types of organizations?) has come out against the ruling, saying that it will drive up costs for consumers who subscribe to those wholesale ISP's, since those who want faster connections will likely have to pay more.  Now, this actually may be true, but then that will make those ISP's and customers of those ISP's on a similar playing field that customers on Bell, Rogers, Telus and Shaw are.   They may even be in a better position because there does not have to be a data limit on their plans, like the larger ISP's have chosen to impliment.

The rhetoric is quite funny.  The large ISP's are unhappy because they wanted to implement usage based billing on the smaller ISP's in an effort to make more money.  Small ISP's are unhappy because they don't like the prospect of having to pay more to the larger ISP's in any way.  Usually, when both sides of the business are unhappy, that is generally a good thing for the consumer.  I know that there is a possibility that a consumer using a small ISP will have to pay a bit more, however the deal remains fair to all sides, and does accurately reflect the real cost of delivering internet.

There has also been an update on exactly how the wholesale ISP's will have to pay for their connection speed.  According to Ars Technica, the Large ISP's will have two methods to charge the wholesale providers.  They can either charge a flat rate, or force the small ISP to pay up front at the beginning of the month for however much capacity they want/need for that month.  That is something I personally don't like, because having to pay ahead of time will lead to guess work.  If the ISP pays for too much capacity, they will pay for more than what they need and end up paying more than they need to.  If they buy too little, it will cause congestion for their customers and slow down their internet.  this is not a good situation for the wholesale ISP's and one that they are likely going to have a difficult time handling.  You will likely see them having to pay for far more than what they usually need on a given month, especially in the beginning, to ensure there is no drop off in capacity.  what I would have liked to have seen is for the wholesale ISP's use what they need in a given month, and then pay the large ISP's the appropriate amount. No more, no less.  This would have been a much more fair deal for those small wholesale ISPs.

[read] - CRTC offers compromise on usage based billing (CBC)

[read] - CRTC ruling may boost prices (CBC)

[read] - Canadian regulators ditch usage based billing for independent ISP's

The Vancouver Riots

I am embarrased and ashamed.

After Boston won the Stanley Cup, chaos erupted in downtown Vancouver. I'm sure you've seen the pictures, and watched the video.  It was something that we shouldn't be seeing in a country like Canada. Just 16 months ago, Vancouver hosted the Olympics in what many can agree was one of the most unifying moments this country has ever seen.  The world watched Vancouver celebrate the winter olympics, and watched Vancouver, and the country, celebrate our game.  Last night and today the world again has been watching, watching a city burn.  They watched looters destroy businesses, and violent fights.  Exact numbers aren't yet known, but there have been several stabbings, and all we can hope for is that no one died in the riots.

I don't remember the riots of 1994. I was 7 when they happened, and didn't really care what was happening in the world.  But I, like many others, have seen the videos of it, and were appauled at how Vancouver acted in 1994.  After the Olympics of 2010, many thought that Vancouver was past that. Clearly, they were not.

Now, lets be clear.  The people who rioted for hours were *not* the majority.  There were over 100,000 people in downtown Vancouver last night for the game.  Only a few thousand were really involved in the riots, with only several hundred likely doing the most damage.  The type of people that will do something like this are the type of people who would have done the same had Vancouver won.  They were a group of people who were just looking for an excuse to incite a riot, and having 100,000 people in a (relatively) small area to basically serve as cover for them was an easy setup.  Many of the worst rioters covered their faces with bandannas to try to hid their identity.  The people who would do this are the type of people who were prepared to do this.  Not many people who would "spontaneously" join a riot would even think of doing something like that.  Those people knew exactly what they were doing, and they were there for one reason, and one reason alone.

I stayed up very late last night watching live coverage of the events, and it sickened me to watch people causing that much damage.  I am almost afraid to look at the pictures that will come out this morning, of the charred vehciles, glass and garbage in the streets.  This riot will cost millions of dollars, and the people who will be hurt the most are the small business owners.  It is disgraceful.

It is shameful that a small group of people have put a black eye on the most beautiful metropolitan area in the country.  Here we are, the morning after Game 7 of the Stanley Cup Finals, and the game almost seems like a distant memory right now.  At a time when we should be celebrating our sport, we now have this to deal with.  Instead of talking about hockey, the playoffs, or the final, we have to try to defend our country's image and our reputation to the world.  There are many countries in the world where hockey is a sport that they barely know the name of, but this morning they are talking about Vancouver, for all the wrong reasons.

The worst part of this is that Vancouver, Canada's olympic city, has now list the wonderful respect and reputation it garnered worldwide in February 2010 during the Olympics.  The years of planning for that event, and the wonderful 2 weeks that the world witnessed have been erased, replaced with pictures of cars on fire and people looting businesses.  A small group of people have done this, and destroyed Vancouver's reputation to the world.

MAny efforts are already being made to work to clean the city up.  The Vancouver Police are asking everyone who was downtown last night to submit their video and photos so the police can identify those who caused damage, and bring them to justice.  Facebook groups are being organized to help clean up the streets of downtown Vancouver, as well as posting pictures of those who did take part in the riots. While I don't necessarily recommend putting the pictures directly onto Facebook, I hope that the Police get everything they need.

I'd also like to say that CTV had by far the best coverage of the riots last night.  While other news organizations stopped their coverage for part of the night, CTV pre-empted everything, and continued to cover the riots, even after I finally went to bed.  Their reporter on the ground, Rob Brown, did a simply sensational job covering this, along with his camera man.  They put themselves in danger to bring what were by far the best pictures and video I could find last night.  Last night CTV provided an example of journalism at it's best, and I thank them for that.  On a similar note, all of that coverage was streaming live on CTV's website, which is where I was watching it.  that was also a great example of how "traditional" journalism can use new media to provide news, and I wish it happened more often. I've been saying for years that news should be streamed live to the internet, and this only cemented that.

Here I am, about 12 hours after the Stanley Cup was awarded to Boston, and I've written nearly a thousand words. Not about the game, or anything to do with the game.  I've written a thousand words about the shameful act of a few thousand people who decided that last night, they were going to do everything they could to destroy a city.  I know that the majority of the people in the lower mainland were not involved with this riot, but that does not change the fact that the morning after, we are not talking about what we should be talking about.  We are talking about one of the most shameful things I have ever seen in my life.  It is very unfortunate because 10 years from now we will not remember the amazing run by the Boston Bruins to win the Stanley Cup. We will not remember some of the truly fantastic hockey games along the way in the playoffs, and we will not remember how Boston was able to celebrate their first win in 39 years.  We will remember Vancouver, and the night the city was set on fire.

I am embarrassed and ashamed.

Shaw presents new Internet packages

On January 7th, 2011 I wrote this article which detailed Shaw’s plans to begin enforcing data caps on their internet plans in what was said was an effort to combat congestion on the network. over 11 subsequent posts (this will be number 13), I’ve detailed a lot more in those posts here if you would like to read further about them.  In a nutshell, Shaw was going to put very low caps into place, coupled that with lowering those caps right before the announcement, and did fall into a bit of bad luck in regards to other internet issues in the CRTC that did not even affect them.  But, this is not about the last 5 months, this post is about today, and I’m pleased to say that the news is good.  Very good.

So, what’s the deal?

I’m going to just get this out of the way and say that, in my opinion, Shaw has just become the industry leader in Canada when it comes to internet pricing. This is a statement that I can make without hesitation, but am shocked to say.  Going into the second round of customer consultations tonight, didn’t know what to expect, but did have some ideas.  My personal belief was that Shaw was going to offer internet packages that separated speed from data limits, letting users pick both their speed, and the amount of data per month.  This would not have been a terrible solution, but would have still resulted in capped internet, and possibly high costs for high amounts of data.  What came out of the meeting surprised me, and in almost the best way possible.

Quite The Statement. Now Get To The Details.

Shaw High Speed Lite, High Speed, and High Speed Extreme will remain, with the exception of the data limits, which are being increased by a factor of 2 or 2.5.  This will mean that for Shaw High Speed Extreme, users will get 25Mbps download speeds and 250GB limits for the same price they are paying now.  I think that this plan should be the minimum now for most users, as it provides a good balance of speed, data, and price, and will be good for most users today.  When compared to the new plans I will detail, I personally do not believe that High Speed does not offer a good price/performance value anymore.

The new plans.  Ah, the new plans.  I will say up front that most of them do have data caps, and the pricing is a bit higher, but the value in them is something that has never been seen in Canada to this point.  For the vast majority of customers who run what Shaw now calls “legacy TV” for $59 + the cost of your TV package, you get a data plan of 50Mbps download speed (6.25 Megabytes/second), 3Mbps upload speed (375 KiloBytes/second), and a data cap of 400GB.  400GB is now the starting point for the new plans.  In the short term, the plans will run all the way up to 100Mbps download speed with unlimited data for $120 + the cost of TV.  This compares to the current cost of Warp speed internet which has 50Mbps download speed and a 175GB data cap for $97 when bundled with TV.  Shaw plans to add 250Mbps download speeds with unlimited data for that same $120/month to all markets within the next 16 months, shifting the 100Mbps plan down to a cheaper price point.

To be frank, these new plans are fantastic.  High speed Extreme remains, but with higher data caps, at current prices.  that alone will be enough for most users today.  However, the value of the Broadband 50 plan (50Mbps, 400GB) at $59 is simply out of this world. The closest plan today is Warp Speed, which is the same speed, lower cap, and $30 more expensive.  Compared to today’s High speed extreme, Broadband 50 has 3.2x the data and 2x the speed for $10 more. The value there is hard to ignore.  The new plans go into place June 7, 2011, you will be able to order them then.  You can find a link to the full list of plans at the bottom of this article.

But There Are Still Caps…

Yes, on most plans there are still caps, which means the ability of users to go over the caps.  In the short term, nothing is going to change from the way it is today.  Shaw continues to have an “acceptable use policy” which, translated into English, means that users can go over the cap, but only users who abuse it the most will be contacted and warned.  That is a bit vague, and that was brought up during our meeting, but essentially if you’ve never had a problem to this point you won’t have a problem now.

And even with the caps in place, they are high, very high.  Consider that Shaw claims only 10% of users go over the current caps today, and those caps have been raised at least 2x.  These limits are significantly higher than anything offered by any other ISP in Canada at similar price points.  In Alberta Telus offers 25Mbps with a 250GB limit for $52/month. Shaw will offer double the speed and 1.6x the data for $9 more. In Eastern Canada, Bell offers a similar 25Mbps plan with only 75GB of data for $56/month. Shaw offers double the speed and  5.3x the data for $3 more.  And do not forget that the top tier plan does feature unlimited internet, so if 750GB or 1TB of internet is truly not enough for you, an unlimited option is available.  These limits will be what they should be, a way only to punish users who truly abuse the system the most.

There will be a new system in the future, however this is one piece that has yet to be fully fleshed out. It is tentatively called the bump up plan, which will be some kind of provision that if a person reaches their data limit, they will be bumped up to the next plan instead of having a per GB charge.  I will again stress that Shaw did say there is much work to do with this, and that a plan will be put into place in the coming months of exactly how this will work (warning customers ahead of time, pro-rating costs, etc), and that this plan will not be put into place until 2012. There will be more details on this in the months to come.

Do You Have Anything Bad To Say?

Sure, these plans aren’t perfect. There are a few oddities, and things that could use some tweaking.  For example, the High Speed Lite plan is 1Mbps with a 30GB data cap, at a cost of $27/month when bundled with TV. A new plan called Unlimited Lite will also be offered that has a 1Mbps speed but with unlimited data.  The cost of this plan will be $59/month when bundled with TV.  That cost is the exact same as the Broadband 50 plan, which offers 50x the speed and 400GB data. Now, the 1Mbps may be unlimited, the average user of such a slow speed plan will be hard pressed to use anywhere near 100GB of data simply because the speed is not fast enough to get that kind of data in a month.  The pricing on Lite unlimited is very awkward, and I would argue that the plan itself is unnecessary.

My only other real complaint is the fact that the new broadband plans all require TV bundled in with them.  There is no option to buy those packaged stand alone.  You will still be able to buy High Speed Lite, High Speed, and High Speed Extreme stand alone, but not the new Broadband plans.  Now, that being said, a customer can get the Broadband 50 plan, and the lowest cost TV package offered will bring the cost to $84.90/month.  This package is less expensive than buying Warp Speed stand alone for $107/month. The user gets more data, the same speed, and TV for $22/month less, and if you really do not want TV, you do not have to plug in the cable box.

that being said, it would be nice if those plans would be offered stand alone. Some users truly do not want a TV package, and under this new plan they will be forced to pay for TV to get a new plan. This is clearly a business decision by Shaw to ensure as many people as possible subscribe to their TV services, and I understand the reasoning behind it.  It is just not a decision I personally agree with.

How Is Shaw Actually Going To Make This Work?

I almost feel like I’ve buried the lead here, because how Shaw is going to accomplish this is a pretty significant step for them.  Over the coming months, Shaw is going to transition most of their analog cable offerings to digital only.  The significance of this shift cannot be understated.  Right now, Shaw has 4 levels of analog cable.  Basic, and tiers 1, 2, and 3.  This transition will leave Basic cable on Analog, but the three tiers will be moving to digital only.  This will mean that a user in a major market will only be able to get approximately 40 channels without a cable box.  Anything more will require a digital cable box.  Shaw says doing this will triple the amount of bandwidth available on their current network infrastructure, which will allow them to offer the speeds shown in the new Broadband plans.

Again, the scale of this transition is quite large, and was the biggest surprise for me.  This type of transition was inevitable, and was going to need to be done eventually, but this plan has accelerated any plans.  Shaw currently has over 300,000 subscribers that have at least Tier 1 level of service and are analog only.  Every single one of those customers will need to be contacted and Shaw is going to work with them on this change.  Final plans are not in place yet, options are being explored including giving each user a free digital box, lowering the cost of the box for the users, and making basic cable cheaper and having them drop down to that. Shaw will be doing this transition beginning in August and will be done region by region, city by city, and neighborhood by neighborhood. it is expected that it will take up to a year to complete.  Once the transition is complete in the area you live, the Broadband 250 plans, which offer the 250Mbit download speeds.

Sounds Like a Big Change For Shaw.

It is, and moves them firmly into the 21st century.  Eventually the Basic Analog will have to be eliminated, but this is a significant step for them.  A move like this really begins to transition Shaw away from a Cable company with internet, to a content distribution company.  TV will still remain a very big part of their business, but this type of move really puts the internet where it should be, equal or higher than TV on their priority list.  Cable TV as we know it will eventually go away. It won’t be next year, or 10 years from now, but it will eventually make way for an entirely internet driven system of content delivery, and this is the biggest step Shaw has made in this direction to date.

I said it at the beginning, and I will say it again. The plans that Shaw unveiled today moves them firmly into the lead in internet pricing in this country.  Shaw will now offer plans that the competition quite frankly cannot compare to.  The bar has been raised, and it has been set very high.  This type of innovation is something that frankly is not seen in this industry.  Shaw has taken a leap forward while others are standing still. Even Telus, who has improved the most in the past 2-3 years, is left behind by this offering. For all of the bad press and attention Shaw has received in the last 5-6 months, Shaw deserves to be applauded, for they got this one right. It’s that simple.

[Read] – New Shaw Internet Packages

Bandwidth and Data - Clearing up the confusion

There has been a lot of confusion over Usage Based Billing over the past few weeks.  There has been much debate on both sides of this issue.   Unfortunately, much of this debate is being had by people who do not understand the technology behind the concept.  I do not claim to be an expert, but I do believe that I can help clarify some of the confusion that has been so clear over the past few weeks.  Once again, I will mainly use Shaw as my example.  This is only because I personally have Shaw as my provider, and I have the most experience with them.  I am not trying to single Shaw out, as what I am going to talk about here is true for all Internet Service Providers. First off, nearly everyone who has talked about this story has been using the term “bandwidth cap.”  I myself am included in this.  Many people have been doing this because it makes it easier for most people to understand, and keeps some confusing terms and technology out of the discussion.  I need to clarify two things to make the rest of what I’m saying make a little more sense.

The term “bandwidth” does not actually have anything to do with the limits being put in place by the ISP’s such as Shaw.  Bandwidth is the term used to describe how fast your internet connection is.  Shaw’s high speed plan provides a bandwidth of 7.5 megabits per second (Mbps).  This means that a user can download files, videos, music, etc, at a maximum speed of 937 KiloBytes (KB) per second; or just under 1 MegaByte per second.  The High Speed Extreme plan is twice that speed.  The bandwidth that Shaw provides allows for faster downloads.

What I, and many others, have been calling the “bandwidth cap” until this point is actually a data transfer limit.  This limit governs how much data you can transfer, not how fast you can download it.  The limit on Shaw High Speed is 60GB per billing cycle, while for High Speed Extreme allows for 100GB per billing cycle.  This data transfer limit has no bearing at all on how fast you can download that data, which is your Bandwidth.

Wait, what?

To put it simply, data limits are how much you can download, and your available bandwidth is how fast you can download it.  At the end it’s pretty simple, but it’s been misrepresented to this point.  This should hopefully make my next explanation a little easier to understand.

Networks that have been built by ISP’s are very complex.  Much too complex for me to really talk about in detail here.  Shaw, Bell, Telus, Rogers all spend considerable amounts of money to build out and upgrade their networks.  This point is fact, and it can’t be disputed.  I won’t even try, because that they do spend that money for the upgrades is, in the long run, better for Canadians.  This is good, and something that we want to continue.

This brings us back to the bandwidth vs. data limits discussion.  What the ISP’s spend money on to upgrade their networks is mostly about the ability to increase available bandwidth.  The infrastructure is upgraded to allow for faster data transfers.  Now, this doesn’t mean just for you.  Part of the investment is for the “backbone” network, which is where the bulk of data is carried.  When you load a website based in Europe, the BBC for example, that website comes through a cable that literally runs through the bottom of the Atlantic Ocean, and then runs across North America to its destination.  The upgrades that ISP’s, as well as the major “backbone” providers that most of the public has never heard of, to allow for faster transfers.   Again, this is good for consumers, and is something that we want to continue to further expand what users can do on the internet.  The investment that the ISP’s make have allowed for improved speed on our internet in the past 10 years.

Now we talk about data transfer.  I’ll just get this out of the way first.  Data transfer over that network is not free. However, it is much closer to free than most know.  All large ISP’s have contracts or agreements with each other to allow traffic to flow from one ISP’s network to another.  This is how someone on a Shaw or Bell computer can read this website, which is hosted by a provider in the United States.  These agreements are called peering agreements, which is actually at its core a very simple thing.  Taking the example of Shaw and Bell, a peering agreement is where they build a connection between their two networks that allows data to be transferred between them.  If the overall data transfer is anywhere close to equal between both sides, most times no money changes hands, since the cost would end up being equal for both sides anyway.  In cases where the data transfer is not equal, the party with lesser traffic may have to pay for that connectivity.  However, the sheer scale of traffic that is transferred between ISP’s means that in most cases, no money does change hands.

Where money often does change hands is in an IP transit agreement.  This type of agreement is where a provider such as Shaw does not have direct access to another provider’s network, i.e. one in the United Kingdom.  In this case, Shaw would have to pay an IP Transit provider so traffic can get from Shaw’s network to the United Kingdom and vice-versa.

My understanding from communicating with people who do have direct knowledge on this is that the cost to deliver 1GB of data to a customer is 1-3 cents.  This means that at most, on a 60GB/month plan the actual cost to deliver 60GB to the user is at most $1.80.

There is a fantastic write up that goes into more detail about peering agreements and how much it costs for data transfer here.  I encourage you to read it to get a more detailed grasp on this concept.

Now, the 1-3 cents/GB does not include costs like network maintenance, labour, etc.  There is a cost to that of course, and that will increase the cost per GB overall.  However, this is why Shaw charges $37 or $47/month for the High Speed plan.  Those costs, as well as others, are built into that price that you pay per month.

However, the simple fact that Shaw would like to charge an overage fee of $2/GB when in fact it costs them 1-3 cents is a markup of approximately 6600%.  This is why they can offer the “data packs” which can give you up to 250GB for $50, which is 20 cents/GB.  Even this is a significant markup (600%) on something that is as close to free as a gigabyte of data.

So If All This Data Is Free, Why Do They Want to Charge So Much For It?

I’ve heard many arguments for UBB that bandwidth is limited, and that charging for data is a way to solve that.  Frankly, that is not true.  Bandwidth, by its definition of being how fast a provider can serve that data to you, is limited.  This is why Shaw has plans of 1, 7.5, 15, 50, and in some areas 100Mbps.  That is the physical size of the “pipe” that Shaw is providing to you, and that is what is scarce.  There is no scarcity on the actual amount of data that can be transferred to you.  The only limiting factor is how fast you can actually get it.  The cost for an ISP to provide you with 5GB of data is, in the grand scheme of things, virtually identical to how much it would cost them to provide you with 500GB of data.  It doesn’t matter whether it takes a 1 hour, 1 week, or 1 month to transfer that data to you; the actual cost of the data is the same.  The real cost is in how fast they can actually get that data to you.

Shaw, and many other providers would have the general public believe that the internet should be treated like utilities such as water.  They say that it costs money to build the pipe to deliver the product to the user, but also for the actual product they deliver.  If an area needs more water, they have to build a bigger pipe to carry more water, and there is a cost to that.  This makes sense, since water is a scarce resource, and there is a finite amount of it in the world.  However, this argument does not quite work for the internet.  While actually building the “pipe” and expanding it from time to time does cost money, the cost of actually moving data through that pipe over time is negligible.  Data, or “bits” as I like to call them, is not a finite resource, and cannot be treated as such.

The actual data transfer, which is what Bell, Shaw, and Rogers seek to limit and charge overage fees for, is actually the cheapest part of the entire equation on the internet.  This is simply another way for these companies to make money where they do not have to raise their basic rates.  They don’t even need the majority of their customers to go over the limits, since the current overages that they are charging are so inflated that the profit margin on those 10% of users is massive.

So when many ISP’s tell you that bandwidth is limited, remember two things.  First, bandwidth actually is limited.  However, in the discussion of UBB, bandwidth has absolutely nothing to do with what your ISP is charging you for overages.  While an ISP would like to have you believe that they are the same, in reality, they are trying to take the most plentiful and cheapest part of their ecosystem and pass it off as a much higher cost and limited part.