Keep Calm and Fight on: A Comparative Study of Network Neutrality in the United States, South Korea and Israel

10 Pages Posted: 16 Mar 2018 Last revised: 17 Aug 2018

See all articles by Sangyong Han

Sangyong Han

University of Pennsylvania Law School

Amit M. Schejter

Ben-Gurion University of the Negev; Pennsylvania State University

Date Written: March 16, 2018


Historical, political and ideological frameworks of different countries create the context for telecommunications policy, context that is required in order to understand its reasoning and logic. One method that helps uncover these frameworks is comparative research. Indeed, comparing policy initiatives undertaken by others in order to learn from them is commonly seen as a justification for conducting comparative research (Livingstone, 2003) and national policy makers not only study reforms in other countries, but they also often adopt similar policies as a result (Bauer 2003). One recent policy issue that has been the focus of public attention but has not been fully studied in a comparative form, is that of regulating network neutrality. There are different approaches to the regulation of network neutrality in different countries as they are deeply rooted in conceptually distinctive ideological, political assumptions regarding the role of government in telecommunications. Differences in institutional frameworks need to be taken into account so that our understanding of policy will be more systematic than anecdotal. While it may be easy to downplay the significance of comparisons and argue that certain things defy comparison. In the case of policies geared toward liberalizing telecommunications markets these comparisons can and should be undertaken, because of the very basic similarities that stem from the common elements that characterize telecommunication networks. The debate over net neutrality picked up most recently in the United States, when the Federal Communications Commission voted on December 14, 2017 to repeal the rules established as recently as 2015 that prohibited broadband service providers from discriminating among different types of services and traffic over the Internet As such, network neutrality, emerged as one of the most discussed topics of telecommunications policy by the public in the United States. At the same time, in South Korea, where government has been playing a key role in shaping the structure of the telecommunications environment, the network neutrality debate has not been as heated, but rather the opposite. The South Korean government has been deeply involved in facilitating broadband deployment, promoting competition and fostering innovation. To ensure competition and innovation in telecommunications, South Korea has promoted a policy actively protecting network neutrality (Shin and Han, 2012). The Ministry of Science and ICT of South Korea confirmed that it is unlikely to alter the network neutrality policy even in light the repeal of the rules in the United States. Meanwhile, Israel enacted a network neutrality law in 2011 for mobile broadband and the requirements have been extended to fixed broadband in 2014 . This law was passed with no public debate whatsoever. Recent revelations that had led to a police investigation involving the prime minister, senior bureaucrats and the top brass of the national telco, Bezeq, indicated that the main concern of the telco was not network neutrality, but rather unbundling rules, in particular in the wholesale market. This study will compare and contrast network neutrality rules in the United States, Israel and South Korea in order to utilize comparison, similarities and differences (Shin, 2014) as the tool serving a better understanding of the rules in each national context. References Bauer, J. (2003). ‘Prospects and Limits of Comparative Research in Communications Policy-Making’, paper presented at the 31st Telecommunications Policy Research Conference (Arlington, VA), September 2003. Livingstone, S. (2003). On the challenges of cross national comparative research. European Journal of Communication, 18, 477–500. Shin, D. (2014). A Comparative analysis of net neutrality: Insights gained by juxtaposing the U.S. and Korea. Telecommunications Policy, 38, 1117-1133. Shin, D., Han, E. (2012). How will net neutrality be played out in Korea? Government Information Quarterly, 29, 243-251.

Keywords: Network Neutrality, Net Neutrality, Comparative Study, South Korea, Israel, the United States

Suggested Citation

Han, Sangyong and Schejter, Amit M., Keep Calm and Fight on: A Comparative Study of Network Neutrality in the United States, South Korea and Israel (March 16, 2018). TPRC 46: The 46th Research Conference on Communication, Information and Internet Policy 2018. Available at SSRN:

Sangyong Han (Contact Author)

University of Pennsylvania Law School ( email )

3501 Sansom Street
Philadelphia, PA 19104
United States
2155739356 (Phone)

Amit M. Schejter

Ben-Gurion University of the Negev ( email )

Beer--Sheva, 84105

Pennsylvania State University ( email )

106 Carnegie
College of Communications
University Park, PA 16802
United States
814-865-3717 (Phone)


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