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Magazines are not synchrnozied though.

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Re: Licensing of Mobile Services on Expiry of Existing Licences for Second
  Generation Mobile Services – Analysis of Comments Received, Preliminary
Conclusions and Further Consultation

  I am writing to express my opinion on the consultation paper issued on 19th
    March, 2004 on “Licensing of Mobile Services on Expiry of Existing Licences
    for Second Generation Mobile Services – Analysis of Comments Received, Preliminary
    Conclusions and Further Consultation” (the “Consultation”) in my capacity
      as a content provider of wireless data service, a view which has not been
      adequately
    represented in the first consultation.
 

Company Background
  Established in Hong Kong in 1999, LoverLover.com Limited (“LoverLover”) is
    one of the pioneers in providing anonymous matchmaking and dating services
    in Hong Kong via the Internet. GameEast.com Limited (“GameEast”), a sister
    company of LoverLover, was established in Hong Kong in 2000 as a free gaming
    services provider. GameEast had operated one of the most successful consumer
    online gaming services (www.GameEast.com) in Hong Kong. According to an independent
    survey conducted by NetValue, an internationally renowned Internet measurement
    company, GameEast was Hong Kong’s stickiest games site, as well as one of
    the most visited games sites in July 2001.
 

Both companies have also been pioneers in their respective sectors of expanding
    their popular services to wireless. GameEast was among the first batch of
    Java developers which had supplied games to Motorola during its launch of
    the first
    Java-enabled handset in Hong Kong back in 2001. LoverLover is the first in
    Hong Kong that offers full featured matchmaking services via WAP on operators’
    platforms.

  Against the above background, I offer my opinion on the Consultation. I would
      like to share my experience in content development in Hong Kong to illustrate
      that the success of mobile data is dependent on a number of factors. While
      there is a lot that the Government can do to promote mobile data, issuing
      a fifth 3G license certainly does not help.

Hong Kong’s early wireless mobile market
  Both LoverLover and GameEast had decided to enter the wireless market in late
    2001 after substantial efforts spent on transforming their original business
    models of offering free services supported by advertising to that of subscription-based
    had proved futile for both companies. There were simply too many competitors
    offering free services over the Internet.

The two companies, however, have taken different approaches to implementing
  their wireless strategies. Harnessing its strength as a game developer, GameEast
  had translated games that were popular on the web to Java for Motorola’s handsets.
  Motorola acted as an aggregator of applications and then marketed them to end
  users. Revenue collected by Motorola was then shared between Motorola and the
  respective content providers. Unfortunately, at a time when Motorola was the
  only supplier of Java handsets, adoption of this new breed of smart phone never
  reached a critical mass at the pace I had anticipated. To prevent further loss,
  GameEast had to suspend its operation. Java, of course, is now the most popular
  platform for running applications on handsets. I never doubted the prospects
  of Java. It was just an untimely decision.

LoverLover, on the other hand, was able to continue pursuing its wireless strategy
  because the nature of its product is fundamentally different from GameEast
  – the games of GameEast had to be developed and customized for each device.
  The main product feature of LoverLover is providing users the ability to create
  profiles on our database, which is then made available for other registered
  users to search and “find” their matches. The service is informational in nature.
  Having learnt the lesson from GameEast, I have decided it was necessary to
  make available our service through a “medium” that is not device specific,
  and look for distribution partners who have billing capability.

At that time, I noticed WAP browser was a built-in function in the majority
  of handsets being sold, with CSD still being the only choice of data connection.
  But GPRS had begun to appear on an increasing number of handsets. Although
  WAP had never quite caught on in Hong Kong, it was the only means to deliver
  interactive informational content to handsets. Similar matchmaking services
  had been available through IVRS and SMS. But the respective nature of listen-and-respond
  and respond-in-turn interaction modes of the two systems makes them not ideal
  for accessing information in a true interactive manner. The fact that neither
  of them offers the ability to display picture is another factor which had led
  us to go with WAP. WAP, however, had already shown at that time it was a transitional
  technology. What lies further down the road, xHTML, was really what I have
been betting on.

A lesson from i-mode
  Parallels can be drawn between xHTML with i-mode in Japan.
  i-mode was introduced in Japan in 1999. Usage of i-mode had been so popular
  that it had spawned the birth of over 79,000 i-mode sites, most of them were
  information and database in nature like what LoverLover has been offering.
  The stellar growth in popularity and acceptance of i-mode had occurred at a
  time when the infrastructure of data capability and handsets’ functionalities
  in Japan were far behind that of what Hong Kong is now having. It is out of
  i-mode that a wireless data-centric generation had born.

The success of i-mode is largely a result of DoCoMo’s adoption of iHTML. WAP
  was born earlier than i-mode outside Japan out of the well-conceived idea to
  devise a set of protocols there were secure and specifically built for handsets.
  Unfortunately, the first version of WAP offered very limited functionalities
  and had to force developers of HTML websites to strip away a lot of features
  in order to comply with it. iHTML, on the other hand, being a subset of HTML,
  makes it easy to convert any existing website written in HTML into i-mode content,
  since iHTML requires only minor changes to the HTML. Because conversion is
  so simple, more and more sites have joined and continue to join i-mode. It
  wasn’t the advanced or superior technology that had driven the growth of i-mode
  sites in Japan, which in turn attracted users who were already familiar with
  the “wired” websites of their wireless counterparts to embrace the wireless
  versions.

The World Wide Web Consortium had realized the shortcomings of WAP and moved
  on with developing the standard of xHTML, which like iHTML, is also a subset
  of HTML. It has become much easier to develop xHTML compliant websites that
  can be viewed across different handsets with mark-up functionalities similar
  to normal HTML websites. An xHTML-enabled handset coupled with GPRS is already
  more powerful and provides a much faster surfing experience than what Netscape
  and the then websites offered that were first introduced to the public almost
  a decade ago. They had captured the hearts of millions and changed the way
  those millions lived and socialized in the following years. I dare to say that
  the necessary technologies to create wireless phenomenon are already in place
  here in Hong Kong and it is up to the developers to harness their creative
  minds to capture the hearts of the 7.3 million mobile subscribers in Hong Kong.
  They should not be distracted by the anticipation of another new standard that
  promises what existing standards
are more than capable of providing.

Experience with Hong Kong’s mobile network operators
  The decision to construct a WAP version from scratch was an easy one to make.
    The construction was relatively easy compared with our Java experience. Our
    backend database had been in place for over 3 years then and we had built
    up one of the largest databases in Hong Kong for matchmaking purposes. The
    fact that WAP then offered little formatting options had helped us not to
    be over-ambitious with our design. Having said that, the present xHTML standard
    is even easier to construct and offers a lot more capabilities and formatting
    options. Our WAP interface essentially served as a thin-client to our database.

With the product built, we needed to look for a distribution partner.
  This proved to be the most difficult and daunting task of the whole process.
  The
    task that I have set out to complete in late 2001 is still an ongoing one
  for me. The task has remained the same all along – to exhort each operator
  to offer
    on its platform our ready database of over 80,000 members on the Internet
  that can interact with their subscribers via handsets in return for a share
  of the
    value-added service fees collected from the subscribers. The barrier to enter
    a seemingly highly-competitive industry, where its operators have openly
  discussed and criticized the local market for lack of suppliers of mobile content,
  is
    so high that it is beyond my comprehension. Because of confidentiality arrangements,
    I cannot disclose the terms and arrangements that I have had with any of
  them. Suffice to say, of those who have agreed to offer our service, the period
  taken
    from the first introductory meeting to the execution of contract ranges from 5
    months to 30 months. And I wasn’t even pitching them for vapourware. Except
    for the first operator who had signed up, the rest had the benefits of experiencing
    the real service in production. In fact, some of them had taken the initiative
    to approach me after using the service on competing operators. I never demanded
    to be paid for anything – neither for setting up the service nor for opening
    up my database.
 

As if “joining” an operator is not hard enough, some of the operators
  engage in business behaviour that is in direct competition with us after we
  have
      been in service on their platform. They ignore notions such as mutual-trust
      and
      respect. One of the senior managers of an operator told me point-blank
  in a meeting last October that my request for adding MMS and location-based
      services
      would not be considered because it was their company policy not to provide
      such capabilities to content providers. It turned out that this operator
      was building a service similar to what we have been offering on their platform
      but with the added capabilities they denied me. They have also set up unrealistically
      high entry and setup cost, compared to what I have been getting from the
      revenue
      derived from them, to deny me connecting to their SMS service. Inevitably,
      individual content providers rely very much on the operators opening up
  connectivity
      in relation to a lot of service “enhancement” features like MMS, SMS and
      location-based
      services. Without their “blessings”, we cannot implement them. Other operators
      have waived all such charges in view of the risks that we are taking to
      promote advanced data usage in a market segment which has just started
      to grow.

Conclusion
  To sum up the experience that I have learnt as manager of a developer – the
    underlying technology of how data (e.g. GPRS, EDGE, CDMA) is delivered to
    the handsets has never entered into our business decision making process.
    On the other hand, we are concerned how hardware manufacturers and makers
    of enabling technologies (e.g. Java, BREW and WIPI) together had made the
    process of designing and implementing application for handsets, which now
    come in every imaginable form factor, functionality and navigation design,
    as efficient as possible. The problems that we had faced during the infancy
    period of Java have now mostly been fixed. Java as a platform has matured
    and its wide-spread adoption and implementation by major handsets manufacturers
    mean it is the time that I get prepared to expand our present products to
    take advantage of its advanced capabilities to provide a more engaging and
    feature-rich experience for our customers. It also means it is time to develop
    games again for Java.

Sometimes, the simplest solution like i-mode turns out to be the most efficient
  one and generating the biggest returns to everyone involved. The xHTML standard,
  which arguably has been evolved out of WAP, has become the de facto standard
  on handsets released in the last 6 months or so. Increasing efforts spent by
  operators to promote advanced handsets and their own portals building around
  xHTML also promises increasing awareness from end users of the data and web
  browsing capabilities of their new handsets. This trend is reflected in the
  increasing number of subscribers to the service of LoverLover.

Introducing another standard with a view to “stimulate the development of an
  advanced mobile market in Hong Kong” is not needed. It is because Hong Kong
  already has an advanced mobile market. Our present data capability and handsets
  far exceed that of Japan had experienced at the time when i-mode was first
  introduced in 1999. Our six operators have shown their commitment to promote
  the availability of such advanced mobile capabilities to each of their respective
  subscriber bases but yet the approaches taken by some of them in sourcing content
  to feature on their platforms were restrictive and un-professional. Unfortunately,
  content providers have to rely on the operators to bill their customers. Instead
  of spending substantial resources on introducing another standard, the government
  should focus on how to make full use of Hong Kong’s already advanced mobile
  technologies and lay down best practice guidelines for the operators to follow
  to nurture the industry.

The mobile market place in Hong Kong is too fragmented with no single operator
  commanding a majority of the subscriber base. As a content provider, the decision
  to invest in and develop a product is justified only if such product has some
  prospects of being offered across at least the majority of operators. Although
  I am now very close to achieving that with my current product, I have hesitation
  about developing further new products because the mere anticipation of going
  through the whole process again holds me back. The fact that I have established
  relationships with the majority of operators certainly eases the process. But
  my experience is that they deal with each product on an ad hoc basis and changes
  in personnel aggravate uncertainty.

There are just too many non-technology related issues that need to be dealt
  with in bringing a finished product to end users via their respective operators.
  And certainly bringing in another data transmission standard is not the answer
  to “stimulate the development of an advanced mobile market in Hong Kong”. The
  market is made up of demand for and supply of mobile applications. Introduction
  of a new standard doesn’t add supply or enhance the applications being supplied.
  On the other hand, developers will be motivated to increase supply and/or enhance
their products if the non-technology issues identified above are resolved.

If you have read the print version that appeared today on Techpost, you may want to read the unabridged version below.

Print version:
Download 3g.pdf

Unabridged version:

I am writing in response to Deep Batra’s letter about his frustrations with
3G and the concerns about the NEC c616 raised by Neil Taylor in his column. In
my opinion, the overall “bad” experience that has bugged so many early adopters
is largely the result of handset glitches rather than the overall 3G service.
I bought two NEC c616 handsets a week after its official launch for myself and
my wife. After almost two months of use, my conclusion is that the combination
of video call functionality and high-speed Internet access have proved 3G is
more than hype.

I did experience, to a lesser extent, the problems Mr. Batra identified
  during my first month of use. Fortunately, they didn’t occur to me at the rate
  of “up to 10 times a day”. And they surely weren’t serious enough to keep me
  from recommending that my father, sister and other close friends get on board
  with 3G. Indeed, early adopters of the 1G and 2G mobiles phones would have
  experienced similar teething problems when they first used their handsets.

The problem that I have found the most annoying is the phone itself. Automatic
  reboots and hangs in the operating system reminded me of my early experiences
  with Ericsson’s T68 (one of the first colour “smart phones”). By the end of
  my first month with 3, I had my fourth upgrade of software for my c616. But
  at least, Hutchison has acted responsibly by adopting a policy of upgrading
  software whenever “newer” software becomes available. Most of the phone manufacturers
  sell their phones “as they are” and won’t perform software upgrades for users
  who bought early versions. My fourth c616 software upgrade is now almost a
  month old and the occurrence of problems has been less than a handful so far,
  which I find very acceptable considering this is a very sophisticated mobile
  device and a new technology.

I don’t have information about the batteries used by Mr. Batra or his
  usage patterns. But I managed to make 1,246 minutes of voice calls and 432
  minutes of video calls, and consume in excess of 600 multimedia content units
  (a lot of them were video clips) and 400 text content units during the first
  month (my detailed invoice is attached) using mainly the medium-sized battery
  (1,360mAh). I also used my phone to listen to music I had recorded on my memory
  stick duo. I keep a separate charger at the office to keep the battery fully
  charged while there. But this is a habit developed over the years with 2G phones.
  I also keep a slim battery in my pocket while out of the office for extended
  periods of time. I have yet to try the new i-Tech 1,800mAh battery which is
  known to have much longer battery life but a lesser size.

My daily MTR commuting covers Causeway Bay to Central and the handover
  from 3G to 2G has improved a lot in the past two months. Very occasionally,
  the handover will result in a complete loss of signal from a few seconds to
  up to a minute at worst. After a successful handover, the phone will act just
  like a 2G phone.

As for dropping lines, I find this a problem with voice calls rather than
  video calls. I have been able to conduct video calls of more than 30 minutes
  on a few occasions. For voice calls, I do experience occasional cut-off in
  the middle of a call but the problem has improved a lot with my fourth software
  upgrade. So I suspect this is another handset rather than network problem.

Although the hardware problems seem to be a thing of the past for me,
  the following “problems” prevent me from making full use of the current capabilities
  of 3G:

• lack of roaming support in Japan, the country that has the most 3G users,
  and more importantly, where my wife roams regularly, but I hear that 2G roaming
  will be available from 19 April.

  • WebCall is not easy to setup especially for elderly who reside overseas and
  only know how to turn on a computer.

  • limitation of 100kb per video message

  • Internet-access pricing (i.e. surfing out of the 3 portal and using the phone
  as a modem) too expensive to make full use of it as a WiFi alternative

  • none of the current handsets is powerful and small enough to replace my XDA
  II

  • should be more transparent in releasing details of upcoming phones that are
  expected to be available soon (which Nokia is very good at)

I hope the above problems can be addressed sooner rather than later, so
  that I can make the best use of my 3G device.

Roderick Kar

  CEO

  LoverLover.com