With Gus Hurwitz.
Executive summary: 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 mischaracterises 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 recognise, 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.