Commercial and geopolitical forces are threatening to fracture the internet into competing regimes, making it harder for companies to operate across borders and potentially limiting their growth. We explore the implications for investors.
John Perry Barlow was a classic American Renaissance man. After growing up on a cattle ranch founded by Mormon pioneers, he became a poet, essayist and political activist. In his spare time, he wrote lyrics for psychedelic rock band The Grateful Dead.
Barlow was also an early proponent of the internet. In 1996, he published a paper called “A Declaration of Independence of Cyberspace”, which summed up the idealistic view of the internet that prevailed as the technology became mainstream.
“Governments of the Industrial World, you weary giants of flesh and steel, I come from Cyberspace, the new home of Mind,” Barlow wrote. “On behalf of the future, I ask you of the past to leave us alone. You are not welcome among us. You have no sovereignty where we gather…Your legal concepts of property, expression, identity, movement and context do not apply to us.”1
A quarter of a century on, Barlow’s words look somewhat quaint. While the coronavirus pandemic has highlighted modern society’s reliance on online tools, it is also clear that the freedoms of the early internet have been sharply curbed. Big tech companies have sectioned off cyberspace into “walled gardens”, where users are corralled, profiled and bombarded with advertisements. Governments have wrested back control of online spaces with firewalls and surveillance technology.
Global companies must adapt their operations to different regulatory regimes
The result is no longer a frictionless platform but an increasingly fractured and fragmented online realm. Global companies must adapt their operations to different regulatory regimes and may even be barred from some countries altogether, due to governments’ efforts to protect their “cyber sovereignty”. These trends bring new challenges and uncertainties for investors.
“Assuming the basic internet plumbing — the domain-name system, the protocols like http, and so on — remains universal, then the key disadvantages are that a company can’t scale as it could in the old days, and companies have to be more answerable to national governments in terms of content, taxation and other sensitive issues,” says Scott Malcomson, director at Strategic Insight Group and the author of Splinternet: How Geopolitics and Commerce are Fragmenting the World Wide Web.
Building the firewall
The infrastructure of the internet was built by Silicon Valley engineers, working with technology inherited from the US government’s military projects.2 But it did not become the global communications system we know today until computer scientist Tim Berners-Lee invented the World Wide Web in 1989, enabling billions of people to access the internet using web browsers and Uniform Resource Locators (URLs).
Berners-Lee wanted the web to be open and free, but before long big companies and states began to reassert control. The Edward Snowden revelations of 2013 showed intelligence agencies in the US and elsewhere had long been working with tech companies to monitor citizens’ online activity.
It is not surprising governments would want to regulate the lawless spaces of the internet and crack down on criminal activity online
It is not surprising governments would want to regulate the lawless spaces of the internet and crack down on criminal activity online. For authoritarian states, the use of online messaging in fomenting civil unrest – as was the case with the Arab Spring protests of 2010-‘12 – posed a direct threat.
China developed its formidable “Great Firewall”, which limits access to websites the Communist Party deems subversive, and other states, including Russia and Iran, have adopted similar methods (see Figure 1). Some governments used the coronavirus crisis as a pretext to expand surveillance powers in 2020, according to research from Freedom House, a non-profit organisation that monitors political freedom and human rights.3
But companies also played a role in the balkanisation of the network. While they benefited from the globalisation of the internet and rising numbers of potential customers, technology firms sought to keep users on their own platforms, limiting the interoperability of software so they could monetise a captive audience using targeted advertising algorithms.
“The walled gardens that social media companies put up have contributed to this, and that’s nothing to do with the Chinese government,” says Jon Crowcroft, Marconi professor of networked systems at Cambridge University’s Computer Laboratory. “There’s no reason why you shouldn’t be able to ‘friend’ somebody on a different platform or send a Weibo message from Facebook; the companies just block it. They don’t want it to be possible.”
Figure 1: Governments impose more restrictions on online freedom
Relatively open internet
- US: Despite recent efforts to block access for some Chinese technology companies, the US retains a largely open internet model. But in creating “walled gardens” to attract users, US tech firms have played their part in the splintering of the internet.
- European Union: The EU is bringing in new laws to protect user privacy and clamp down on hate speech online: social media firms will have to quickly remove illegal content or face the threat of sanctions under a Digital Services Act. This may increase pressure on Big Tech and create regulatory friction with the US.
- Japan: The Japanese government is one of the main advocates of the free flow of information across the internet. In 2019 it led the Data Free Flow with Trust (DFFT) initiative at the G20, pushing for greater openness and regulatory collaboration in managing communication across borders.
Cyber sovereignty model
- Iran: The Iranian government is reportedly developing a country-specific intranet to thwart citizens’ access to the global internet, where they might encounter information critical of the regime.
- China: China’s so-called Great Firewall is a powerful tool of authoritarian control. The system blocks citizens from accessing sites the Communist Party deems subversive. One consequence is that home-grown tech giants such as Baidu, Alibaba and Tencent have been able to flourish at the expense of foreign rivals.
- Russia: The Russian government’s Sovereign Internet Law, introduced in 2019, allows the state to block content and makes it more difficult for foreign websites to operate in the Russian market. This has benefited some domestic firms, including Moscow-based internet giant Mail.Ru.
Source: Aviva Investors, 2020
Mapping the splinternet
A recent report from the Internet and Jurisdiction Policy Network, an international organisation that advocates for greater policy coordination, polled stakeholders from internet companies, technical operators, civil society and academia. Of the respondents, 95 per cent thought legal challenges across different online jurisdictions would become an acute problem in the next three years, while 79 per cent saw insufficient international coordination in policymaking regarding the internet.4 The report concluded small- and medium-sized enterprises in all sectors – not just technology – could find it more difficult to operate across borders as a result.
Major concerns pertain to differences at the level of law and regulation
As these findings suggest, for now the major concerns pertain to differences at the level of law and regulation. But Malcomson points to bipartisan support in the US and elsewhere for a bifurcation that would reach down into the technical standards that govern the global network, splitting the internet at a deeper level.
“That would take a while and be extremely jarring if it were at all extensive,” he says. “One version could operate only for the mobile internet and pivot on alternative standards regimes. Another could dip into the protocol layer of the fixed internet. Another could construct itself around data centres. A fourth might create an alternative domain-naming system, which Russia has been toying with for several years. There are multiple possibilities.”
In a 2019 paper, “The Four Internets: The Geopolitics of Digital Governance”, academics Wendy Lee and Kieran O’Hara laid out a similar argument; in their view, the internet is being carved into four competing systems led by various governments or private entities. First is the “Open Internet” of Silicon Valley, where tech engineers and entrepreneurs retain an idealistic vision of a universal web system. Second is the “Commercial Internet”, associated with policymakers and commercial lawyers based in Washington DC, who emphasise the need to protect corporate interests and intellectual property rights.
The internet is being carved into four competing systems and each is threatened by spoilers
The other two regimes are spearheaded by nations outside the US. “Beijing’s Authoritarian Internet” restricts user freedoms in the interests of political stability, while the big three Chinese tech firms – Baidu, Alibaba and Tencent – take advantage of loose rules over user data collection to create cutting-edge digital platforms. By contrast, the “Bourgeois Internet” of Europe puts greater emphasis on user privacy and looks on corporate monopolies with more suspicion than the other models. Each of the internets is threatened by “spoilers”, such as hackers and Russian state-sponsored propaganda bots.5
As Lee and O’Hara argue, these different visions of the internet are presently “coexisting, and may continue in this way for some time. It is possible, however, that any of these internets may fall by the wayside, and also that any one of them might become dominant – or indeed, that the whole intricate system may collapse from these pressures.”
US vs. China
The most prominent contest is between the US and Chinese models of the internet. Tensions between the two powers escalated in 2017, when the Trump administration slapped tariffs on Chinese goods, ostensibly to rectify a trade imbalance. But technology was also key to the dispute: China stood accused of “forced technology transfer (FTT)”, or the theft of intellectual property from American firms.6
Despite the agreement of a bare bones trade deal in January 2020, under which the US cut some tariffs in exchange for a Chinese pledge to buy more American products and curb FTT, the relationship has soured further during the coronavirus pandemic.
These geopolitical tensions have caused trouble for Chinese companies with global aspirations
These geopolitical tensions have caused trouble for Chinese companies with global aspirations, such as smartphone maker Huawei. The US has long sought to curtail Huawei’s influence and sees the company’s supremacy in 5G telecommunications infrastructure as a security risk. Recent sanctions that limit Huawei’s access to American-made semiconductors have severely harmed the company’s ability to develop competitive handsets, and it has already started to lose its domestic market share.7 In January 2021, the US imposed new sanctions on another smartphone maker, Xiaomi.
Political concerns have also obstructed the international ambitions of two innovative Chinese mobile platforms: Tencent’s WeChat and TikTok, a video streaming service developed by Beijing-based ByteDance. In August 2020, Trump signed an executive order that put commercial restrictions on both apps and ordered ByteDance to sell TikTok’s US operations. ByteDance appealed the decision and TikTok remains available in the US. For its part, the Chinese government says it will not approve a sale; the state-owned China Daily newspaper has branded the TikTok situation a case of “bullying and extortion”.8
“TikTok created a genuinely innovative artificial intelligence-driven platform and became the first emerging market internet company to make substantial inroads in developed markets. But this arguably happened at the wrong time given the geopolitical situation and the extra level of scrutiny now on this sort of business model,” says Alistair Way, head of emerging market equities at Aviva Investors.
“TikTok does push the boundaries in terms of data collection from users, so it is no real surprise it has faced restrictions in the US, especially as it was taking market share from American firms as well. We may see more of this trend, with internet companies having to create local subsidiaries or sell off foreign operations, given the differences across jurisdictions and the growing resistance to data collection on privacy grounds,” adds Way.
Proxy battles and national champions
With Chinese firms blocked from doing business in the US, they are increasingly looking for opportunities elsewhere. China’s Digital Silk Road initiative offers cheap loan financing for poorer countries, many of them in Africa, to develop their internet infrastructure using loans from Chinese banks and hardware provided by Chinese companies such as Huawei.9
Huawei has also teamed up with Chinese state-owned organisations to press for a fresh technical standard for the internet, known as “New IP”, at the United Nations’ International Telecommunication Union (ITU). Huawei says this model for the internet’s architecture would allow for faster internet speeds; critics say it is a more centralised, top-down system that would give nation states like China a more granular level of control over citizens’ access to the network.10
Both US and Chinese firms are looking to make up for their lack of access to each other’s markets by vying for customers in third countries
Meanwhile, both US and Chinese firms are looking to make up for their lack of access to each other’s markets by vying for customers in third countries such as Indonesia, Thailand and Vietnam, whether through partnerships with local companies or by directly offering their own services. But in these markets, too, the splintering of the internet into national regimes is apparent, and domestic firms have been able to fend off competition by leveraging their local expertise in some sectors.
“In e-commerce retailing and logistics, local expertise is absolutely key; these are areas where local players have a decent chance of fighting off Amazon or Alibaba,” says Way. “To a lesser extent, this is also true of other sectors such as gaming. Companies such as Singapore-based Sea Limited for example, which customise games for lower-spec mobile phones and tailor the software for local cultural preferences, have done well.”
In social media, Western brands have retained an advantage due to global economies of scale, although there are exceptions. In Russia, Moscow-based Mail.Ru has benefited from government efforts to create a “sovereign internet” by imposing barriers to foreign companies. Mail.Ru’s social networking platforms are holding their own against Facebook.
“Facebook has always been present in Russia but struggled with domestic regulation and competition from the Mail.Ru-owned social network companies OK and VK,” says Way. “These two platforms merged at an opportune time and have managed to hold off Facebook, which remains more of a way for Russians to connect with international friends rather than others in the country. Instagram has taken more share, but Mail.Ru remains pretty popular with users there.”
The mobile internet and verticalization
The mobile-led internet model in emerging markets has powered a trend for “verticalization”, which deepens the splintering effect. Rather than access an all-purpose search engine on a web browser, people in emerging markets increasingly seek out products and services using dedicated apps. This can create barriers for other tech companies hoping to generate advertising revenue, argues Mikhail Zverev, head of global equities at Aviva Investors.
Verticalization can create barriers for other tech companies hoping to generate advertising revenue
“Take Baidu, which runs China’s biggest search engine. Many investors have been disappointed with Baidu’s performance in recent years, because they expected it to replicate Google’s rate of growth. As it turned out, a lot of the pools of value Google accessed in the West weren’t open to Baidu, as product advertising – the most lucrative form of advertising – had already been verticalized on the dominant e-commerce platform, Alibaba,” Zverev says.
There could be opportunities for investors who are able to spot verticalization in its early stages in different sectors.
“One of India’s leading online travel agencies (OTA) claims 70-80 per cent of traffic to its site is ‘organic’, because users tend to go straight to the product platform itself; by contrast, Western OTAs tend to have around 40 per cent organic traffic, and need to pay Google or other companies to attract the remainder of their customers. We are seeing similar trends for verticalization in sectors such as restaurant bookings, food delivery and financial services in emerging markets,” adds Zverev.
Younger generations in Europe and America, who access the internet almost exclusively using mobile phones, may start to act more like emerging-market consumers, migrating to vertically integrated apps and thereby cutting off advertising revenue streams from tech giants that operate more universal platforms.
The Bourgeois Internet
In what Lee and O’Hara call the “Bourgeois Internet” regime in Europe, regulators have shown more willingness to crack down on Big Tech, notably in the area of content moderation, where US regulators have been wary of interfering due to concerns over freedom of speech. Social media companies have become notorious for allowing hate speech and disinformation to thrive on their platforms and European governments have introduced new laws to tackle the problem.
From hate speech to bullying, extremism to misinformation, there is a lot of content that damages communities
“The 24/7 nature of social media and the amplification of content through sharing clearly exacerbates the impact of these kinds of messages on wider society,” says Louise Piffaut, ESG analyst at Aviva Investors. “From hate speech to bullying, extremism to misinformation, there is a lot of content here that damages communities.”
The European Commission is drawing up legislation that will force tech giants to remove illegal content or face the threat of sanctions under a comprehensive Digital Services Act, due to be unveiled at the end of 2021. Germany has introduced the Network Enforcement Act (NetzDG), which forces large social media companies to review complaints and remove any content that is clearly illegal within 24 hours. In July 2020, Facebook was fined €2 million for under-reporting illegal activity on its platforms in Germany.18
“A tougher regulatory environment is long overdue,” says Jennifer Cobbe, coordinator of the Trust and Technology Initiative at Cambridge University, an interdisciplinary research project that explores the dynamics of trust and distrust in relation to Internet technologies, society and power. “We are now acknowledging the reality: these platforms play such an outsized role in society that they need to have some kind of responsibility, and need to be brought under some degree of control.”
Tighter regulations may force tech companies to spend more on technology or human labour to moderate content on their platforms. As operating expenses among tech companies tend to be high even before these added outlays – 40 per cent of total revenue in 2019, in Facebook’s case – any increase in R&D and labour costs may have a material impact on the company’s profit margins, says Piffaut.
Figure 2: What Big Tech knows about you
Source: Angela Moscaritolo, ‘What does big tech know about you? Basically everything’, PC Magazine, October 30, 2019
A digital advertising bubble?
The European Union also looks likely to introduce new laws to protect individuals’ data ownership and privacy, building on the General Data Protection Regulation (GDPR) of 2018. Pending regulation may compel big technology firms to allow interoperability, enabling users to shift their data easily between platforms, potentially punching holes in the “walled gardens” that contribute to the splintering of the internet.19
Past regulation has made it more difficult for companies to track customers’ online behaviour using cookies
Past regulation has made it more difficult for companies to track customers’ online behaviour using cookies. The new Digital Services Act will require further transparency from technology firms over why users are being targeted with adverts.
Previous legislation has actually favoured the biggest technology firms; the laws tended to apply to surreptitious, third-party tracking and data-gathering methods rather than those favoured by “logged-in” platforms such as Google and Facebook (these two companies increased their online advertising market share in Europe in the wake of GDPR).
But the sustainability of these firms’ business models has been questioned on other grounds. In a recent book, Subprime Attention Crisis, author and former Google executive Tim Hwang draws an analogy between the risky collateralised mortgages that sparked the global financial crisis and today’s market for digital advertising. Hwang assembles evidence to show microtargeted digital advertising often doesn’t work, is subject to widespread fraud, and will be further curtailed by future regulation. He argues that once companies grasp the worthlessness of digital ads, they will withdraw their custom en masse, much as the bottom abruptly fell out of the subprime loan market.20
“While I don’t think that we are looking at a subprime-level problem, investors should monitor this potential risk to technology firms,” Zverev says. “One could argue that with the decline of television and the lack of alternatives, advertisers have nowhere else to go, and will continue to use the large internet firms to market their products and services. But they may start to spend less money on ads if their effectiveness is called into question.”
Decentralisation and the Internet of Things
US tech companies active in Europe may have to work on localising their offering as a result of the new regulation – a potentially costly and time-consuming process. And the divergence between the US and other Western regimes may go farther still.
Some European governments, alongside those in Australia and Canada, have begun to look at new methods of digital citizenship designed to put data firmly back in the hands of individuals. Estonia has already implemented a model whereby citizens can access a range of services using mobile apps, retaining complete control of their personal data in the process. An online dashboard shows them a log of everyone who has accessed information such as their medical records; they can report any intrusions to a data ombudsman.21
One of the leading ways of building trustworthy digital citizenship is the decentralised model
“One of the leading ways of building trustworthy digital citizenship is this decentralised model,” says Crowcroft. “These projects are interesting because they create a world where the government and private sector are obliged to think much harder about what users’ data is worth, because the user controls access to their data. Sometimes these projects are just distributed, highly federated, rather than fully decentralised, but the idea is gaining traction.”
Crowcroft argues the debate over privacy may shape the next stage in the development of the internet: the so-called Internet of Things (IoT), which enables devices from refrigerators to industrial manufacturing equipment to communicate autonomously. If the IoT has user privacy “built in”, this could improve standards for the internet as a whole; if not, the corporate surveillance of our everyday lives could reach another level altogether.
“I’ve worked on a study that tests privacy around the IoT, which has a bad reputation in that regard. I was cynical about it, but there are some interesting approaches to managing privacy and security in the ‘cyber-physical’ world,” says Crowcroft.
“Because it is ‘greenfield’, building the systems to connect these devices together could be a place where you see these decentralised approaches take off. The research community is looking at this and making headway. Some of the platforms, such as those being developed by Microsoft and [UK semiconductor company] Arm, are secure systems to ensure data privacy and security. There’s a chance those standards could be adopted by the rest of the industry in things like tablets and wearable gadgets,” he adds.
A diverse ecosystem
From a commercial perspective, much depends on how far these different models of the internet continue to diverge. While few experts expect the deep technology of the internet to shift in such a way as to make regional networks incompatible, each regime is likely to continue to become more distinct in legal and regulatory terms.
Each regime is likely to continue to become more distinct in legal and regulatory terms
In the US and especially Europe, Big Tech firms will need to tread more carefully as concerns over content and data ownership grow, potentially opening up opportunities for platforms that offer better security and data-privacy protections. Some of these alternatives, and communications apps built on the decentralised Matrix communications protocol, have already gained traction in European countries.22
These same concerns over privacy will limit the overseas growth of China’s internet behemoths in the West. But behind the Great Firewall, they will continue to develop innovative systems and may outstrip Western firms in areas such as artificial intelligence thanks to their access to vast swathes of user data. In other emerging markets, companies that can attract mobile users to vertically integrated platforms will be able to resist incursions from global internet firms, whether they hail from the US or China. This could create a more diverse internet ecosystem globally, although the distinctions between the regimes are not always clear-cut (for example, Chinese regulators have started getting tougher on their own tech firms, announcing an antitrust investigation into Alibaba’s e-commerce operation in December 2020).
Whether these trends are positive or negative in the aggregate largely depends on your point of view, argues Malcomson. Provided the underlying network remains global, the splinternet could bring benefits; while different markets are likely to offer different versions of the same platform, that could be advantageous to communities who receive a more tailored and localised service that suits their preferences. Such a system may look very different from the limitless universal space that John Perry Barlow envisaged – but that may be no bad thing.
“The key advantages of this fracturing, as compared to the universal system once imagined by Silicon Valley pioneers, are that local innovation can grow, and local content can flourish, in what amount to relatively protected virtual markets,” says Malcomson. “A fractured internet, in aggregate, could be much richer, in every sense, than a universal one”