JPRI Working Paper No. 98, February 2004
Nonliberal Capitalism in the Information Age: Japan and the Politics of Telecommunications Reform 
by Mark Tilton
 
Overview

Japan has found its economy growing slowly for the past decade, after a century of extraordinarily rapid economic growth.  A primary reason for slow growth was mismanaged macroeconomic policy, which produced first a speculative bubble and then the deflation of a pricked bubble.  But Japan also has problems with microeconomic policy, as the policies Japan designed for industrial catch-up fail to apply to an economy that has now for decades been at the front ranks of the developed economies.  The telecommunications industry illustrates some of Japan’s problems with moving from a developmentalist state model to a more fluid approach to the economy. 
 
Japan’s developmental state used strategies of industrial targeting and managed competition to enable Japan to catch up with more advanced economies.  While these strategies worked well while Japan was behind the most advanced economies, they have not been successful at promoting radical innovation or at lowering domestic prices.  Also, the strategic part of targeting has been lost, as Japan has tended to protect old industries rather than promote new ones.  These problems are clear intelecommunications.  Japan’s cautious approach to subjecting its telephone monopoly, NTT, to competition has meant high telecommunications prices for consumers, which has slowed the spread of use of the internet.  Recognizing this problem, the Japanese government has again used a policy of industrial targeting by mandating low prices for DSL interconnection, at the same time that interconnection rates for standard phone services are kept high.  The resulting low prices have fueled a rapid growth in broadband services.  Japan’s cautious approach to competition in telecommunications means that NTT is in better financial shape than many of the world’s telecommunications firms, and NTT’s deep pockets have funded considerable innovation, most notably in mobile services and the creation of a fiber optic network.  But the cautious high-price approach may mean that Japan misses out on other new technologies that lower overall telecommunications prices could make possible.
 
Nonliberal Capitalism
 
A number of scholars have written about the strengths of “coordinated market economies,” “communitarian capitalism,” or “nonliberal capitalism.”  Though individual approaches vary, in broad terms these scholars argue that a network of long-term relationships between finance and producers, between upstream and downstream firms, between competitors, and between employers and workers, makes possible investment in dedicated production capacity and in skills that in turn result in high-quality goods and well-paid workers.[1]   The prototypes for the model are Germany and Japan.  The problem with the emphasis on long-term relationships is that it can sacrifice the flexibility necessary to speed shifts to new industries.
 
Wolfgang Streeck and Kozo Yamamura use the term, “nonliberal capitalism,” and make clear they mean it in a relative sense.  They argue that Japanese and German capitalism has been less liberal than that of the U.S. or Britain.  The question of whether to make capitalism more liberal is at the heart of the debate over economic policy in both Germany and Japan.  Scholars debate the extent to which various reforms have in fact made German and Japanese capitalism more liberal.  
 
In all countries, telecommunications is an industry in which states must intervene deeply and persistently in order to create competition.  Most states owned telecommunications companies until recently, and those that did not, like the United States, had nationally regulated monopolies.  States have taken away the old telephone monopolies, but have found that in order to create competition they must intervene aggressively.  The problem is that incumbents own a network of wires and switches, and if they are to be challenged in the marketplace they must be forced by the state to share the network with competitors.  At the same time, incumbents must be allowed to make profits from their network, or they will lack the incentive to continue investing.  Finding this balance between requiring competition and allowing incumbents to enjoy the profits of their established positions is difficult, and different states have found different solutions.  While all regulatory authorities wrestle with how much competition to introduce, Japan’s habits of industrial policy lead it to coddle the telecommunications incumbent more than do other advanced capitalist societies.  Japan’s industrial policy approach to economic development included the following elements:
 
* Pursuit of sectoral goals (such as the promotion of a particular industry or technology) rather than general economic growth.

* Limiting (but not eliminating) competition in order to produce higher prices and more stable markets in order to provide funds for investment.[2]

In important ways Japan’s telecommunications policy still fits this pattern.  Regulators have targeted the development of certain technologies rather than emphasizing low prices for consumers.  Prices have tended to be high by international standards.  Regulatory bodies have not pushed competition as aggressively as have either American or German regulatory bodies. 
 
Marie Anchordoguy writes that industrial policy worked well for telecommunications when the task was to reverse-engineer foreign technology and when citizens didn’t mind paying high prices for reliable service.[3]  Japanese industrial policy still does a marvelous job at fulfilling the communitarian goal of supporting well-paid workers at NTT and the developmental goal of funding ambitious investments in a national fiber optic network and sophisticated 3G mobile technology.  The problem is that the high-price approach inhibits downstream uses of telecommunications services and because of this Japan has been slow to develop technologies that rely on inexpensive telecommunications service, notably the internet.
 
Struggle between Nonliberal and Liberal Visions of the Telecommunications Market
 
The world of telecommunications regulation changed in important ways in response to the 1984 U.S. breakup of AT&T.  In 1985 Japan privatized NTT, although the Japanese government kept most of the shares in the company and competitors complained it was difficult to compete in areas, such as long distance, that were opened to them because of NTT’s monopoly in local telephone service.  A much bigger change came with the split-up of NTT in 1999.  Local service was split between NTT East and West, mobile phone service given to NTT DoCoMo, and NTT has ceded market share to a number of competitors, though it still dominates most branches of the telecommunications market.[4]  When NTT was broken up, it was only with the important concession that Japan’s 52-year-old ban on holding companies be lifted.  The ban on holding companies had been imposed by the United States occupation because of suspicion that the zaibatsu, all held together by holding companies, was responsible for Japan’s embarking on military expansion in Asia.[5]
 
There has been rapid change in the telecommunications market, combined with controversy and political struggle.  The policymaking process is deeply politicized, with NTT exerting significant pressure on regulators.  Important liberalization and price drops have occurred, but at crucial times regulators lean in favor of protecting NTT, a powerful firm with over 200,000 employees.  The NTT labor union is politically active and a number of dietmembers are former employees of NTT.  NTT is effective at mobilizing both the ruling LDP and the Democratic Party to fight against regulations disadvantageous to its interests.
 
NTT has political clout partly because its labor union mobilizes politicians to intervene in the policy process to protect NTT jobs.  The NTT labor union (All NTT Workers Union of Japan, or NTT Rodo Kumiai) plays a direct and active role in pressuring politicians to intervene in policymaking and makes specific recommendations about regulations that expose NTT to competition.  In July 2003 the union invited Democratic Party leader Kan Naoto and other politicians to its annual meeting, where union leader Onodera Ryo declared that, “The nation should abolish the requirement that NTT share its fiber network.”  The union was opposing KDDI’s drive to offer broadband service via fiber optic cable. The union has good reason to campaign against more competition for NTT.   NTT is under great pressure to cut jobs, and has only forestalled this by introducing wage cuts.  NTT cut salaries of workers over fifty by thirty percent in 2002.  In some sense, this is unremarkable.  Even in the U.S., where unions are weaker than in any other major industrialized country, labor unions can successfully help producers win economic policy concessions such as trade protection.  What is remarkable about the Japanese telecommunications case is that the NTT union helps win concessions on domestic pricing and competition policy.  This works because union pressure resonates with broadly held suspicions of the market, and because regulatory authorities lack the autonomy of U.S. or German authorities.
 
Despite NTT pressure, regulatory reform has created considerable opportunities for competitors.  The challengers to NTT, the new common carriers (NCCs), have taken large market share in all of the areas of telecommunications service, with the exception of local service.  But their workforces are small; the largest, KDDI, has only 10,000 workers.  Their pockets are also shallower and their political power is correspondingly less than that of NTT.  The new common carriers have little support in the Diet, although NTT Softbank, which is behind Yahoo BB’s huge expansion of ADSL service, apparently has some pull.[6]  Softbank President Son Masayoshi is said to have influence with several politicians, including Iwaya Takeshi, an LDP Upper House Dietmember from Oita prefecture.[7]
 
MPHPT lacks the independence of either the U.S. Federal Communications Commission (FCC) or Germany’s Regulierungsbehörde für Telekommunikation (RegTP).  At the time of privatization in 1985, NTT came under the formal jurisdiction of the Ministry of Posts and Telecommunications (MPT, folded in 2000 into the Ministry of Public Management, Home Affairs, Posts and Telecommunications, or MPHPT).   MPHPT can’t match NTT’s expertise, budget, or political clout with dietmembers.   MPHPT has supported increased competition in telecommunications, but it is sensitive to political pressure from the LDP and pulls its punches at crucial junctures.  In making its policies MPHPT consults with the Telecommunications Council, which includes representatives from telecommunications firms, consumers, and academics.  Big changes have come through the council, although the power of NTT and the dominant conservative mainstream of the LDP acts as a brake on pro-competitive reforms.
 
The Ministry of Economy, Trade and Industry (METI, which was MITI before the 2000 reshuffling and name-switching) expresses its opinions about telecommunications policy, but has no direct influence over policy.  It complains from the sidelines that there should be more competition in the telecommunications industry and that high telecommunications prices are a drag on the Japanese economy. 
 
In contrast to the situation in the United States, Japan’s competition policy authority has never had significant influence on telecommunications.  While in the United States the Department of Justice played a key role in breaking up AT&T and the courts have regularly intervened, the corresponding antitrust authority in Japan, the Japan Fair Trade Commission (JFTC), has had little to do with telecommunications.  In principle there is a process in place for the JFTC to advise the MPHPT on telecommunications policy, but MPHPT keeps JFTC’s role limited.[8]  The JFTC lacks the staff, expertise and, most importantly, political power to influence telecommunications policy.
 
Foreign pressure has played an important role in shaping Japanese telecommunications policy.  U.S. pressure has been especially important, although in recent years the European Union has also made suggestions for changes in telecommunications policy.  Currently, the U.S. is playing a reduced role with regard to telecommunications policy.  In part, this reflects considerable progress that has already been achieved in reforming telecommunications policy and the existence now of major telecommunications firms within Japan that can exert some pressure on their own.  It undoubtedly also reflects the Bush administration’s current emphasis on securing Japan’s cooperation with its Iraq policy rather than pushing for further economic reforms in Japan.  For instance, although the U.S. protested Japan’s hike in interconnection rates in April 2003, it has not followed up and continued to put pressure on Japan.  The E.U. as well criticizes Japan’s telecommunications regulatory process as lacking either “principles” or an independent regulator.[9] 
 
The weakness of Japan’s telecommunications regulators in the face of NTT pressure is illustrated in their inability to lower interconnection rates, the rates charged to competitors of NTT to hook up to its network, to internationally prevailing levels.  In 2000 the interconnection rate was lowered by 20 percent, to 4.5 yen per three minutes, which made it possible for Japan Telecom, KDDI and others to break into the local phone market by charging rates of 8.5 yen per three minutes.  Yet even the newly reduced rate was still double the rate charged in the U.S. and Europe.  In August 2002 the Telecommunications Council recommended that the interconnection fee be cut by up to 51 percent, down to 2.2 yen.  The basic monthly phone charge paid by consumers would be raised from 1,750 yen to 2,272 yen.  The MPHPT suggested instead a cut of just 8 percent to 4.1 yen.  NTT East and West were strongly opposed, because they feared losing large revenues from interconnection fees and strengthening their competitors.  NTT East and West received 693 billion yen (roughly $6 billion) in interconnection fees in Fiscal Year 2001.[10]
 
In April 2003, MPHPT reversed itself and decided to raise interconnection rates by 5 percent.  An MPHPT official said the reason was that it wanted to “avoid repeating the U.S.’s failures in telecommunications,” that is the strong price competition which lead to the bankruptcy of Worldcom.[11]  But according to the business journal Zaikai, the real reason was that NTT exerted strong political pressure through NTT-related dietmembers.   As Zaikai put it, “MPHPT had tried to tame NTT, but got bit.”[12]  This rate increase invited protest from competing firms, from the U.S. and from the European Union.  These argued that the formulas used to justify the high interconnection rates were based on estimates of costs that were unreasonably high and gave NTT too much reward for its inefficient management of its infrastructure.
 
Telecommunications policymaking took a surprising twist in July 2003, when five telecommunications carriers sued MPHPT for raising interconnection rates.[13]  Observers suggest it is unlikely the suit will succeed, but it was a striking way for the new competitors to voice their objections to Japan’s conservative anti-competitive policies.  However, the generally gloomy prognoses of the suit’s chances highlight a contrast between Japan’s telecommunications regulatory process and that of the U.S. or Germany, where courts have routinely played an important role. 
 
An area that has been off limits for regulatory reform is the large deposits consumers must pay to start telephone service.  If these were abolished, patrons that paid them in the past would demand the return of their four trillion yen (roughly $40 billon).  Also not addressed have been the fixed monthly service fee, which the consumer group on the Telecommunications Council has suggested should be reduced.[14]
 
Restrictions on competition in telecommunications have indeed resulted in high prices.  According to the OECD, Japanese residential telephone charges in 2002 were 46 percent higher than German charges and 24 percent higher than U.S. charges.  Japanese business charges were 54 percent higher than German charges and 51 percent higher than U.S. charges (see Table 1).  METI complains that the high telecommunications prices that result from limiting competition stunt the growth of downstream uses of telecommunications, such as the use of the internet.   High telecommunications prices have meant that dial-up internet access in Japan has been expensive.  Using the internet for forty hours in 2000 cost $78 in Japan, $49 in Germany, and $23 in the U.S.  Twenty hours cost $59 in Japan, $33 in Germany and $22 in the U.S.  By September 2002 these figures had dropped, though Japan was still higher than the U.S. and Germany (See Table 2).
 
Table 1: OECD Composite Basket of Residential and Business Telephone Charges, August 2002 (includes mobile and international calls,
excludes VAT, $U.S)



Source: Based on data in OECD, "OECD Communications Outlook," 2003.
 
Table 2: OECD Internet Access Basket at Daytime Discounted PSTN Rates



Source: Based on data in OECD, "OECD Communications Outlook," 2003, and OECD, OECD Internet Access Price Comparison 2000 [accessed October 17 2000], available from http://www.oecd.org/dsti/sti/it/cm/stats/isp-40hrs.htm.
 

Recent Industrial Policy Response to Backwardness in Internet Development
 
On July 7, 2000, the Japanese cabinet attempted to get around NTT’s lack of initiative in promoting internet access and around MPT ineffectiveness by establishing an IT Strategy Headquarters “in order to promote comprehensive measures for the creation of an internationally competitive ‘IT nation.’”  The government also established an IT Strategy Council, with 20 members.  At its sixth meeting, the Council put forth a “Basic IT Strategy.”  On January 6, 2001, a new law came into force, the Basic Law on the Formation of an Advanced Information and Telecommunications Network Society (The IT Basic Law).[15]
 
The e-Japan Strategy follows the pattern of traditional industrial policy in important respects.  First, the policy is clearly oriented to industrial catch-up, as expressed in a 2001 report by the IT Headquarters:
 
…as for penetration rate [sic] of the Internet, which other nations identify as the core of IT policies, Japan is still at a low level among major industrialized nations.…
 
…[T]he swift action of a nation in creating an environment necessary for realizing an advanced information and telecommunications network society determines the nation’s world competitive leadership in the 21st century.  As nations in the Americas, Europe and Asia are intensively promoting efforts to create such environments, the delay in the world arena for socioeconomic structural changes at a high speed will result in irrecoverable competitiveness gap [sic] in the future.[16]
 
This sounds a bit like a report from the Meiji period, and in fact, the report explicitly notes the parallels to Japan’s earlier drive to catch up with the first Industrial Revolution:
 
Just as a nation’s response to the Industrial Revolution later determined its economic prosperity, the same will hold true with the IT revolution.
 
The report makes clear that the problem to be fixed is the high prices which are preventing Japanese from using the internet:
 
[T]he low rate of access to the internet] is caused by high communications tariffs under the usage-sensitive rate, stemming from what is in reality a monopoly of the local telecommunications market. …. [17] 
 
The report then sets forward the goal of providing high speed internet access. 
 
Based on this new initiative from the Cabinet Japan’s telecommunications policy changed quickly.  On August 31, 2000, the Telecommunication Council issued a report to the MPHPT Minister recommending an amendment to Ministerial Ordinances to introduce local loop unbundling for copper cables, and the new amendment came into force in October 2000.  Based on the amendment new carriers were able to connect their networks to NTT East and West networks and to put their equipment in NTT buildings (co-location).  MPT also lowered the charge for using  lines from 800 yen to 187 yen per month.[18]  Based on this change, NTT East and West and several new carriers began offering DSL services in December 2000.[19]
 
This selection of DSL service as strategic and the regulatory decision to force NTT to cut access charges for DSL service is in the tradition of earlier industrial policy in that it led to differential pricing.  Since broadband internet access was identified as the key problem, regulators required NTT to sharply cut its interconnection charges for the purpose of DSL access, inspiring Yahoo BB to take the aggressive and risky strategy of selling broadband access at the world’s lowest price (at a loss of a billion dollars a year).  Interconnection rates for nonstrategic fixed line phone services were actually raised, even though they were already twice or more the rates of other advanced countries.
 
With lower prices for DSL, but continued high prices for other phone services, Japan quickly moved to the front ranks of the major industrialized countries in broadband, while at the same time keeping NTT revenues up (See Table 3 and Figure 1). Japan is now ahead of other large economies in diffusion of broadband use.
 
Table 3: Broadband subscribers/100 population



Source: OECD. "OECD Communications Outlook." 2003.
 
Figure 1.  Japan’s Broadband Service Subscriptions



Source: JECC, Kompyûta Nôto 2003, p. 123.[20]
 
Some American critics have argued the U.S. has been wrong to press Japan to make NTT unbundle access to its network.[21]  And indeed, the FCC recently voted to phase out the low prices for unbundled access to the local loop that had been required under the 1996 Telecommunications Act.  The argument against unbundling is that local providers need a monopoly over the use of their new investments in network capacity in order to encourage them to carry out new investment in infrastructure, especially fiber to the home.  The U.S. ruling allows incumbents to close off access to their fiber networks, although they must continue to sell discounted access to their copper wire networks.  
 
In the long run, Japan may well benefit from less competition, higher prices, and more security for NTT.  But in the short run, Japan has gotten a slow start to developing the internet.  A survey by Ipsos-Reid found that Japan is well behind the U.S., although roughly on a par with the U.K. and Germany, in terms of diffusion of internet use (See Table 4).  An OECD survey finds that Japan is far behind Germany, the U.S., and other major countries in the development of websites, a measure of depth of use of the internet.  Thus, while Japan has jumped ahead in broadband penetration, it lags behind the U.S. in the diffusion of internet use throughout society and the intensity with which it is used.
 
Table 4: Percentage of Adults Who Went Online At Least Once in Last 30 Days



Source: Ipsos-Reid, “Internet Use Continues to Climb in Most Markets,” December 10, 2002.  Accessed at http://stat.nca.or.kr/news/files/ipsos-raid2.pdf, October 20, 2003.
 
Table 5: Websites (servers) per 1000 inhabitants



Source: OECD. "OECD Communications Outlook." 2003.

Conclusions
 
The result of Japan’s use of high prices for telecommunications is that NTT has had a good source of funding for developing mobile telephony.  According to MPHPT’s assessment, Japan is a leader in wireless technology (see Figure 2), although some American observers dispute this position, noting that much of Japan’s wireless system is based on American technology.   NTT’s deep pockets have also funded the creation of an extensive national fiber optic network, though some critics argue NTT has wasted the money on obsolete technology.  In any case, the high telecommunications fees that have funded Japan’s wireless and fiber optic development have at the same time prevented consumers from using the internet as quickly as have consumers in other countries.  Japan’s nonliberal or “less liberal” approach to telecommunications policy has slowed Japan’s use of the internet and made it again a follower nation relying on industrial policy to play catch-up with the United States.
 
Figure 2.  International Comparison of Superiority in Information and Communications Technologies



Source: MPHPT, Information and Communication in Japan, White Paper 2003, p.10.
 
 
MARK TILTON is Associate Professor of Political Science at Purdue University and Luce Fellow, Woodrow Wilson Center/Sigur Center for Asian Studies, George Washington University, Washington, DC. He is the author of Restrained Trade: Cartels in Japan’s Basic Materials Industries (Ithaca, NY: Cornell University Press, 1996); “Informal Market Governance in Japan,” International Organization 48:4 (Autumn 1994); and many other works. He can be reached at tilton@polsci.purdue.edu.  This paper was first presented at the Washington and Southeast Regional Japan Seminar, George Washington University, November 15, 2003.
 


[1] Oliver E. Williamson, The Economic Institutions of Capitalism: Firms, Markets, Relational Contracting (New York, London: Free Press, Collier Macmillan, 1985); Peter A. Hall and David W. Soskice, Varieties of Capitalism: The Institutional Foundations of Comparative Advantage (Oxford [England], New York: Oxford University Press, 2001); Ronald Philip Dore, Stock Market Capitalism: Welfare Capitalism: Japan and Germany Versus the Anglo-Saxons (Oxford [UK] and New York: Oxford University Press, 2000); Michel Albert, Capitalism vs. Capitalism: How America's Obsession with Individual Achievement and Short-term Profit Has Led It to the Brink of Collapse (New York: Four Walls Eight Windows, 1993); Wolfgang Streeck and Kozo Yamamura, The Origins of Nonliberal Capitalism: Germany and Japan in Comparison, Cornell Studies in Political Economy (Ithaca, NY: Cornell University Press, 2001); Kozo Yamamura and Wolfgang Streeck, The End of Diversity?: Prospects for German and Japanese Capitalism, Cornell Studies in Political Economy (Ithaca, NY: Cornell University Press, 2003).

[2] Chalmers Johnson, MITI and the Japanese miracle: The Growth of Industrial Policy, 1925-1975 (Stanford, Calif.: Stanford University Press, 1982).

[3] Marie Anchordoguy, "Whatever Happened to the Japanese Miracle?," Japan Policy Research Institute Working Paper, no. 80 (2001).

[4] Steven Kent Vogel, Freer Markets, More Rules: Regulatory Reform in Advanced Industrial Countries, Cornell studies in political economy (Ithaca, NY: Cornell University Press, 1996); Seifu Kisei Nado To Kyoso Seisaku ni Kansuru Kenkyukai (Study Group on Government Regulations and Competition Policy), "Denkitsushin bunya no seido kaikaku oyobi kyoso seisaku no arikata" (Competition policy and systemic reform in the field of telecommunications), (Tokyo: 2002).

[5] John Owen Haley, Antitrust in Germany and Japan: The First Fifty Years, 1947-1998, vol. 16, Asian Law Series (Seattle: University of Washington Press, 2001).

[6] Interview with official at NCC, July 2003.

[7] "'Kaiho' meguri seijiryoku sodoin (burodobando daikyoso)" (General mobilization of political power around sharing fiber optic cable (The great competition over broadband)), Nikkei Sangyo Shimbun, July 8 2003.

[8] Interview with JFTC official, July 2003.

[9] European Commission, "EU Priority Proposals for Regulatory Reform in Japan," (2002).

[10] "Telecom Council Devises Radical Way of Throwing Open Local-Call Markets," Nikkei Weekly, August 5, 2002.

[11] "NTT setsuzokuryo age, shindenden hampatsu, giron wa konsen, jotsushin 28 nichi kettei, beio mo 'kyoso sogai'" (In response to the increase in the NTT interconnection rate, the New Common Carriers are opposed, discussion is in confusion, the Telecommunications Council is to decide on the 28th, and Europe and America claim 'obstruction of competition'), NihonKeizaiShimbun, March 25 2003.

[12] "KDDI nado shin denden go sha ga 'NTT no setsuzoku ryo o sagero' to somusho o teisho" (KDDI and four other new common carriers sue MPHPT to get it to lower NTT's interconnection rates), Zaikai, August 2003.

[13] "Telecoms to Sue Government over NTT's Fee Hike," Japan Times, July 11 2003.

[14] "NTT kihon ryokin, suijun minaoshi konsen moyo-hikisage kitai tsuyoku, rongi shidai de neagemo (Confusion over reevaluating the NTT basic charge-strong expectations for reduction, but possibility of an increase depending on discussions)," Nihon Keizai Shimbun, June 24 2003.

[15] IT Strategy Headquarters, "E-Japan Priority Policy Program," (2001), available from http://www.kantei.go.jp/foreign/it/network/priority-all/index.html.

[16] Ibid.

[17] Ibid.

[18] Point.topic.com, Japan: Broadband Overview (2003 [accessed April 8 2003]); available from www.point.topic.com.

[19] Home Affairs Ministry of Public Management, Posts and Telecommunications, "Recent Regulatory and Policy Development in Japan," (APEC Telecommunications and Information Working Group, 2001), available from http://www.apectelwg.org/apecdata/telwg/23tel/plenary/plen_28.htm.

[20] Thanks to Hyeonjung Choi for sharing these two figures with me, and for invaluable advice and assistance with this paper.

[21] Jeffrey H. Rohlfs and J. Gregory Sidak, "Exporting Telecommunications Regulation: The U.S.-Japan Negotiations on Interconnection Pricing," Harvard International Law Journal 43 (2002).

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