[Japan] Our Submission to the Japan Digital Market Competition Headquarters (DMCH)

On August 18th, 2023, ATTIA provided its submission on mobile app ecosystem competition to Japan’s Digital Market Competition Headquarters (DMCH), under the Cabinet Secretariat.  We thank the DMCH for the subsequent consultation meeting held with ATTIA on September 28th 2023.

Download our submission here.

ATTIA is committed to fostering innovation, promoting fair competition, and ensuring a diverse range of travel options for users within the Mobile Ecosystem. We firmly support the DMCH’s efforts to establish a fair and equitable competition environment in this rapidly evolving landscape.

As ever more consumers use their mobile to book trips, a competitive market in the Mobile Ecosystem is essential for OTAs and metasearch platforms to offer users a wider array of travel choices, enhancing their overall travel experiences.

To this end, we have provided our detailed recommendations and comments in a document accompanying this letter. We invite the DMCH to carefully review these recommendations and consider them in their ongoing consultation. These insights have been gathered through extensive industry analysis and collaboration with our Members.

We express broad support for the DMCH’s recommendations in the draft Final Report under consultation, particularly those targeting large platforms like Google, which aim to address self-preferencing concerns. By advocating for measures that prevent self-preferencing by platform operators, we ensure fair visibility and rankings for travel-related services. Additionally, we emphasize the importance of data portability and interoperability, which will empower travel technology players to enhance user experience and choice.

ATTIA acknowledges the pivotal role played by the DMCH in evaluating the digital market and its objectives of promoting competition and innovation while ensuring security, privacy, and preserving users’ freedom of choice within the Mobile Ecosystem. We believe that conventional competition law approaches are insufficient to address the unique challenges posed by the Mobile Ecosystem, necessitating a fresh approach.