IEC Newsletter

VoIP: Forcing Changes in the Telecom Market and Its Regulation - An Update

Ronald Cowles
Research Vice President, Communications - Network Services, Regulatory and Public Policy Matters
Gartner

Wm. L. Hahn
Principal Analyst, Carrier Operations and Strategies Worldwide
Gartner

Abstract

Voice over Internet protocol (VoIP) will change the marketplace and force broader regulatory changes in the process. In the United States, the Federal Communications Commission's (FCC's) VoIP proceeding is addressing this issue; the rest of the world is likely to take notes.

Introduction: Internet Protocol Is a Major Market Change Factor

Internet protocol (IP) is an agent of market change for data and voice services. Not only does IP affect the pricing of voice services, but IP telephony is starting to engender market behavioral changes with surprising implications. Voice services and communication needs will become individually customized and independent of geography and carriers. Eventually, this will change how voice services and features are ordered, provisioned and delivered, marketed, priced, and regulated. This will impact more than traditional telephone companies, cable companies, telecommunications outsourcers, systems integrators, and Internet service providers (ISPs). In fact, it will create a new group of service providers and will affect application services, back-office and front-office operations, and the entire IT industry.

Why Regulation Is the Lynchpin for IP Telephony Adoption
Regulation of voice communications originated early in the 20th century, in the United States and elsewhere, when telecom technology was simpler and universal access to the telephone was a national priority. This goal has largely been accomplished in the developed world. However, during the past 30 years, as technology has changed to a connectionless, logical, and software-based environment, regulation has not kept pace. Regulation now chokes rather than promoting innovation in telecom.

The Internet and developments in voice communications using IP have been catalysts for numerous challenges to both national and local voice regulations during the past three years. While these challenges were narrow in terms of scope and impact, because of the limited network deployment and adoption of VoIP services, IP investment and telephony solutions are now mainstream. Leading carriers continue to invest a significant portion of their non-mandated capital expenditures and operating expenditures in IP technology and telephony services. Some of the most conservative worldwide carriers claim to have developed competitive portfolios of network-based IP telephony services.

Governments React
Regulators are being pressured by market realities, legislators, businesses, and carriers alike to address VoIP regulation. Importantly, by their nature, VoIP services are disruptive to legacy voice services and policy goals. In fact, because of this disruption, some countries-especially those with government-owned telephone companies-have either regulated or outlawed the service in order to constrain its development. These are drastic measures that cannot and will not be sustained.

The U.S. Example: Likely to Sway Others
In 2004, the FCC issued and proposed a number of rulings that would ultimately regulate VoIP and other IP-enabled services, including: exerting jurisdiction over Internet services to avoid any conflicting policies being enacted at the state level; imposing requirements that non peer-to-peer VoIP providers provide access to E-911 emergency services by November 28, 2005 or cease offering services in those unserved areas (surprisingly most providers met this date); and enacting rules requiring both broadband Internet and interconnected VoIP service providers to comply with Communications Assistance for Law Enforcement Act (CALEA) provisions to meet national security and law enforcement surveillance requirements by May 2007. At the same time, the FCC-after an extensive legal battle leading up to the U.S. Supreme Court-deregulated cable modem, DSL, and other broadband Internet access services thereby relinquishing its authority over the Internet. The FCC in its place adopted a policy statement outlining four principles of equal access which will be incorporated into its ongoing policy-making activities. (Due to a major initiative underway in the U.S. Congress to rewrite communications law in 2006, these principles have unfortunately become the underpinning of network neutrality, one of the most heavily debated telecom policy issue,).

These federal proceedings will set the tone and direction of voice communications in the United States and, to some extent, the rest of the world. These proceedings will be messy but are on a fast track. A lot is at stake here; voice telephony is being redefined. Literally hundreds of carriers, ISPs, equipment vendors, software providers, state regulators, along with consumer groups and associations have participated in these proceedings. Similar proceedings are taking place in Canada, as well as in Western Europe, and will most likely follow in Asia Pacific where the technological underpinnings of IP-enabled voice services are actually more advanced than in the United States.

What Issues Are the Industry Facing and the FCC Addressing?
The industry still faces uncertainty, and the FCC owes final orders to the industry on some very critical items, including:

Whether the FCC's ruling that IP-enabled services or deregulated Information Services will withstand court challenges and how rulings will take place based on that determination.
What regulations are required to address the converging telecom, media, and Internet markets.
How IP-enabled service providers will pay into the Universal Service Fund (USF), and how-and whether-access charges should apply.
Whether compensation parity should be required for calls using the public switched telephone network (PSTN), irrespective of whether the traffic originates on the PSTN or an IP network.
Whether IP-enabled services are technically and operationally capable of complying with the commission's enhanced 911 (E911) emergency service rules concerning nomadic services and what requirements it should impose.
How other important operational and customer-centric issues are to be addressed, such as security and privacy.

A Crucial Issue Yet to Be Addressed: Numbering
The next big contentious issue (beyond intercarrier compensation and all the other issues that have been teed up) for regulators to wrestle with is telephone numbering vis-à-vis VoIP. Customers, and therefore providers, want to use telephone numbers as aliases for users' names. The rub is that IP-enabled services are immune to geographic limitations, whereas existing numbering schemes, rate structures, and so forth are strictly tied to geographies. VoIP services enable numbers to be universal and be assigned anywhere in the world, thus eliminating long-distance call charges and changing the structure of national and international telecom markets to the detriment of incumbent carriers. Indeed, the ability to make international calls at local rates poses new challenges for the telecom industry.

Numbering has been addressed to some degree (for example, the U.K., Irish, and Japanese regulators have created the option of "non-geographic" area codes which cause VoIP customers to change telephone numbers). However, there are now extensive issues that involve existing numbering plans, settlement rates, existing number porting schemes, existing local, long-distance, and international rate plans, and so forth, that will have to be dealt with in some fashion. But, technology is moving too fast and the issues will not go away, they have to be dealt with and the rules will have to change.

Gartner Perspective

Regulators Compelled to Act on VoIP
Historically, most regulators and legislators view IP and the Internet as an enabling technology for cheaper next-generation data and information services and as a vehicle for market entry via this alternative to traditional voice. Thus, most regulators have no appetite to regulate this technology because they are concerned that doing so might stifle both its deployment and adoption. In fact, the FCC has attempted to deregulate cable modem services, but has been halted in court. This is also the case with Ofcom, the United Kingdom's regulator, the Canadian Radio Television and Telecommunications Commission, and Germany's Regulatory Authority for Telecommunications and Post.

VoIP Will Be a Catalyst to Bring Voice Regulation into the 21st Century
Regulators and legislators find themselves in a difficult situation because voice is now being delivered over unregulated IP networks. IP telephony could be the long sought after mechanism to achieve true local voice services competition and unprecedented innovation in the mass market. However, it also has the potential to thoroughly disrupt the funding mechanism for federal and state social policy goals, along with the financials of the carriers of last resort, such as the incumbent local exchange carriers. Many other thorny issues must be considered, such as consumer protection, personal security and privacy issues, E911, equitable treatment for different call types, and carrier types. In addition, the carefully crafted web of federal, state, and local taxes will be undermined unless regulations are overhauled to balance all these competing interests.

The regulatory debate will be difficult. It has started in the United States at many levels, including federal and state regulatory and legislative bodies. The FCC commissioners are split on how to govern VoIP services and certain states (for example, Michigan, New York, and California) are appealing for strongly regulating VoIP service providers. Other countries will see similar debates.

Regulatory and public policy decisions made now will determine how successful IP-based services will be and how it will shape future voice and data services. Too much regulation will stymie the services and will create artificial markets. Too little regulation will undermine certain universal service, emergency services, security, and other public policy goals. Therefore, it is imperative that the regulators develop well-reasoned national VoIP regulations and not multiple frameworks, which could take effect in the United States, that is, if the states were allowed to regulate VoIP.

VoIP's Future: Impacts of the FCC Decisions

The FCC, a leading telecoms regulator, has taken the following actions:

Proposed that IP-enabled services will be governed at the national, not local, level
Announced its intention to lightly regulate the sector, likely in a fashion similar to cable-modem or mobile service
Indicated that it will consider whether to impose certain obligations and restrictions on VoIP providers, including:
- Contributions to the Universal Service Fund
- The obligation to provide 911 and E911 capability
- The ability to comply with national laws regarding security as requested by law enforcement agencies

Among the major issues not yet explicitly considered:

Even though the FCC has implemented data-base-driven intermodal local number portability to enable VoIP customers to keep their telephone numbers, there are myriad numbering issues that need to be resolved once the service becomes mainstream
The question of where and how much, if at all, the present access and interconnection fees apply to calls originated or terminated over packet-based networks

Global Regulation: a Ripple Effect?
It is likely that global telecom regulators will take on several aspects of the FCC's actions. Some moves have been imitative, while others have motivated independent invention, and much of the global response will move in different directions altogether.

Some Will Do Nothing ("Let the Market Handle It")
Many remote and developing regimes have ignored the existence of VoIP altogether; in others, a straight ban has been imposed, but no other proceedings or announcements have been made. In these cases, the following effects are to be expected:

A substantial black/grey market in VoIP used for international bypass, to avoid high interconnection fees.
Incumbent carrier(s) will be slow to introduce IP-enabled services.
Eventually the regulators will have to address the issues because of the disruption caused by the black/grey markets.

Some Will Impose Restrictions ("Let the Incumbent Handle It")
Some regulatory regimes are imposing rules and restrictions on VoIP services, which essentially seek to slow entry or to support the existing rate scheme in place. This position has the ancillary effect of reinforcing the incumbent's position or role in the evolution of the market. Most prominent among these are rules designed to make VoIP providers pay most or all of the same access and interconnection fees as circuit-switched carriers. Cofetel, Mexico's telecoms regulator, just announced plans to crack down on companies that skirt rules to complete long distance calls using VoIP. But, another significant effect derives from the requirement of non-geographic numbers for VoIP service. This can serve many other important goals and can even have a positive effect overall. Some nations, such as Ireland and the UK, have provided for both the porting of existing numbers to VoIP services and the creation of separate area codes for new service lines. However, both of these solutions have drawbacks and eventually have to change. It is important to consider that:

Ported numbers using remote call-forwarding from the incumbent carrier enables the incumbent to be involved with the switching and transport of nearly every call.
Ported numbers using remote call-forwarding from the incumbent carrier many times causes unacceptable delays in the completion of a call and introduces potential spots for trouble to occur, by introducing multiple carriers into the completion of calls.
Separate area codes for VoIP services forces number changes, which places the nascent service at a competitive disadvantage.

In such regimes, the following effects should be expected:

Slowed market entry for VoIP players
Short-term prop for the revenue streams and market-share of the incumbent
A "mid-life crisis," as these issues over VoIP numbering and access charges have to be resolved in later years, detracting from market growth and investment opportunity

What Needs Doing - Gartner Advice
While national regimes will vary widely according to needs and the relative development of the market, Gartner advises the following:

Take charge at the national level; do not leave the playing field cut up into a maze of local variations.
Make service obligations transparent to end-users: help to resolve any outstanding technical issues and make it clear if any provider of telephony service, regardless of technology, needs to live up to the obligations presently imposed on circuit-switched carriers (namely, 911 and law enforcement requirements).
Let social policy dictate your approach to charging: the access and interconnection regime, which supported circuit-switched telephony, is becoming rapidly outdated. A new charging regime needs to be implemented that is non-discriminatory and still meets the remaining social needs of the national market.
If the penetration goals mandated by Universal Service have been met, phase in a reduction in these charges.
Work to bring down artificially high international connection fees (or suffer a more drastic shock as VoIP's cost avoidance advantage remains high).
Recognize that domestic long distance, and possibly international long distance, will disappear as separate retail service offerings; adjust the interconnection and access fee regime accordingly.

Worldwide telecom regulators must approach the difficult task of adjusting interconnection and access charges with an eye toward technology-neutral, forward-looking, and fair arrangements that do not promote fruitless warfare over customer ownership. This type of regulatory regime, rather than a patchwork remedy to existing rules and processes, is essential to make telecoms, as well as the national economy at large, very successful. Regulators must foresee that, unlike other evolutionary changes that have occurred, the changes brought on by VoIP and other IP-enabled services will be swift and sweeping.

Copyright © 2006 Gartner, Inc. and/or its Affiliates. All rights reserved. Reproduction of this publication in any form without prior written permission is forbidden. The information contained herein has been obtained from sources believed to be reliable. Gartner disclaims all warranties as to the accuracy, completeness or adequacy of such information. Gartner shall have no liability for errors, omissions or inadequacies in the information contained herein or for interpretations thereof. The reader assumes sole responsibility for the selection of these materials to achieve its intended results. The opinions expressed herein are subject to change without notice.

Educational content provided by Gartner, Inc.


June 2006, Volume 1 back to index
VoIP: Forcing Changes in the Telecom Market and Its Regulation - An Update Ronald Cowles Research Vice President, Communications - Network Services, Regulatory and Public Policy Matters Gartner Wm. L. Hahn Principal Analyst, Carrier Operations and Strategies Worldwide Gartner Abstract Voice over Internet protocol (VoIP) will change the marketplace and force broader regulatory changes in the process. In the United States, the Federal Communications Commission's (FCC's) VoIP proceeding is addressing this issue; the rest of the world is likely to take notes. Introduction: Internet Protocol Is a Major Market Change Factor Internet protocol (IP) is an agent of market change for data and voice services. Not only does IP affect the pricing of voice services, but IP telephony is starting to engender market behavioral changes with surprising implications. Voice services and communication needs will become individually customized and independent of geography and carriers. Eventually, this will change how voice services and features are ordered, provisioned and delivered, marketed, priced, and regulated. This will impact more than traditional telephone companies, cable companies, telecommunications outsourcers, systems integrators, and Internet service providers (ISPs). In fact, it will create a new group of service providers and will affect application services, back-office and front-office operations, and the entire IT industry. Why Regulation Is the Lynchpin for IP Telephony Adoption Regulation of voice communications originated early in the 20th century, in the United States and elsewhere, when telecom technology was simpler and universal access to the telephone was a national priority. This goal has largely been accomplished in the developed world. However, during the past 30 years, as technology has changed to a connectionless, logical, and software-based environment, regulation has not kept pace. Regulation now chokes rather than promoting innovation in telecom. The Internet and developments in voice communications using IP have been catalysts for numerous challenges to both national and local voice regulations during the past three years. While these challenges were narrow in terms of scope and impact, because of the limited network deployment and adoption of VoIP services, IP investment and telephony solutions are now mainstream. Leading carriers continue to invest a significant portion of their non-mandated capital expenditures and operating expenditures in IP technology and telephony services. Some of the most conservative worldwide carriers claim to have developed competitive portfolios of network-based IP telephony services. Governments React Regulators are being pressured by market realities, legislators, businesses, and carriers alike to address VoIP regulation. Importantly, by their nature, VoIP services are disruptive to legacy voice services and policy goals. In fact, because of this disruption, some countries-especially those with government-owned telephone companies-have either regulated or outlawed the service in order to constrain its development. These are drastic measures that cannot and will not be sustained. The U.S. Example: Likely to Sway Others In 2004, the FCC issued and proposed a number of rulings that would ultimately regulate VoIP and other IP-enabled services, including: exerting jurisdiction over Internet services to avoid any conflicting policies being enacted at the state level; imposing requirements that non peer-to-peer VoIP providers provide access to E-911 emergency services by November 28, 2005 or cease offering services in those unserved areas (surprisingly most providers met this date); and enacting rules requiring both broadband Internet and interconnected VoIP service providers to comply with Communications Assistance for Law Enforcement Act (CALEA) provisions to meet national security and law enforcement surveillance requirements by May 2007. At the same time, the FCC-after an extensive legal battle leading up to the U.S. Supreme Court-deregulated cable modem, DSL, and other broadband Internet access services thereby relinquishing its authority over the Internet. The FCC in its place adopted a policy statement outlining four principles of equal access which will be incorporated into its ongoing policy-making activities. (Due to a major initiative underway in the U.S. Congress to rewrite communications law in 2006, these principles have unfortunately become the underpinning of network neutrality, one of the most heavily debated telecom policy issue,). These federal proceedings will set the tone and direction of voice communications in the United States and, to some extent, the rest of the world. These proceedings will be messy but are on a fast track. A lot is at stake here; voice telephony is being redefined. Literally hundreds of carriers, ISPs, equipment vendors, software providers, state regulators, along with consumer groups and associations have participated in these proceedings. Similar proceedings are taking place in Canada, as well as in Western Europe, and will most likely follow in Asia Pacific where the technological underpinnings of IP-enabled voice services are actually more advanced than in the United States. What Issues Are the Industry Facing and the FCC Addressing? The industry still faces uncertainty, and the FCC owes final orders to the industry on some very critical items, including: Whether the FCC's ruling that IP-enabled services or deregulated Information Services will withstand court challenges and how rulings will take place based on that determination. What regulations are required to address the converging telecom, media, and Internet markets. How IP-enabled service providers will pay into the Universal Service Fund (USF), and how-and whether-access charges should apply. Whether compensation parity should be required for calls using the public switched telephone network (PSTN), irrespective of whether the traffic originates on the PSTN or an IP network. Whether IP-enabled services are technically and operationally capable of complying with the commission's enhanced 911 (E911) emergency service rules concerning nomadic services and what requirements it should impose. How other important operational and customer-centric issues are to be addressed, such as security and privacy. A Crucial Issue Yet to Be Addressed: Numbering The next big contentious issue (beyond intercarrier compensation and all the other issues that have been teed up) for regulators to wrestle with is telephone numbering vis-à-vis VoIP. Customers, and therefore providers, want to use telephone numbers as aliases for users' names. The rub is that IP-enabled services are immune to geographic limitations, whereas existing numbering schemes, rate structures, and so forth are strictly tied to geographies. VoIP services enable numbers to be universal and be assigned anywhere in the world, thus eliminating long-distance call charges and changing the structure of national and international telecom markets to the detriment of incumbent carriers. Indeed, the ability to make international calls at local rates poses new challenges for the telecom industry. Numbering has been addressed to some degree (for example, the U.K., Irish, and Japanese regulators have created the option of "non-geographic" area codes which cause VoIP customers to change telephone numbers). However, there are now extensive issues that involve existing numbering plans, settlement rates, existing number porting schemes, existing local, long-distance, and international rate plans, and so forth, that will have to be dealt with in some fashion. But, technology is moving too fast and the issues will not go away, they have to be dealt with and the rules will have to change. Gartner Perspective Regulators Compelled to Act on VoIP Historically, most regulators and legislators view IP and the Internet as an enabling technology for cheaper next-generation data and information services and as a vehicle for market entry via this alternative to traditional voice. Thus, most regulators have no appetite to regulate this technology because they are concerned that doing so might stifle both its deployment and adoption. In fact, the FCC has attempted to deregulate cable modem services, but has been halted in court. This is also the case with Ofcom, the United Kingdom's regulator, the Canadian Radio Television and Telecommunications Commission, and Germany's Regulatory Authority for Telecommunications and Post. VoIP Will Be a Catalyst to Bring Voice Regulation into the 21st Century Regulators and legislators find themselves in a difficult situation because voice is now being delivered over unregulated IP networks. IP telephony could be the long sought after mechanism to achieve true local voice services competition and unprecedented innovation in the mass market. However, it also has the potential to thoroughly disrupt the funding mechanism for federal and state social policy goals, along with the financials of the carriers of last resort, such as the incumbent local exchange carriers. Many other thorny issues must be considered, such as consumer protection, personal security and privacy issues, E911, equitable treatment for different call types, and carrier types. In addition, the carefully crafted web of federal, state, and local taxes will be undermined unless regulations are overhauled to balance all these competing interests. The regulatory debate will be difficult. It has started in the United States at many levels, including federal and state regulatory and legislative bodies. The FCC commissioners are split on how to govern VoIP services and certain states (for example, Michigan, New York, and California) are appealing for strongly regulating VoIP service providers. Other countries will see similar debates. Regulatory and public policy decisions made now will determine how successful IP-based services will be and how it will shape future voice and data services. Too much regulation will stymie the services and will create artificial markets. Too little regulation will undermine certain universal service, emergency services, security, and other public policy goals. Therefore, it is imperative that the regulators develop well-reasoned national VoIP regulations and not multiple frameworks, which could take effect in the United States, that is, if the states were allowed to regulate VoIP. VoIP's Future: Impacts of the FCC Decisions The FCC, a leading telecoms regulator, has taken the following actions: Proposed that IP-enabled services will be governed at the national, not local, level Announced its intention to lightly regulate the sector, likely in a fashion similar to cable-modem or mobile service Indicated that it will consider whether to impose certain obligations and restrictions on VoIP providers, including: Contributions to the Universal Service Fund The obligation to provide 911 and E911 capability The ability to comply with national laws regarding security as requested by law enforcement agencies Among the major issues not yet explicitly considered: Even though the FCC has implemented data-base-driven intermodal local number portability to enable VoIP customers to keep their telephone numbers, there are myriad numbering issues that need to be resolved once the service becomes mainstream The question of where and how much, if at all, the present access and interconnection fees apply to calls originated or terminated over packet-based networks Global Regulation: a Ripple Effect? It is likely that global telecom regulators will take on several aspects of the FCC's actions. Some moves have been imitative, while others have motivated independent invention, and much of the global response will move in different directions altogether. Some Will Do Nothing ("Let the Market Handle It") Many remote and developing regimes have ignored the existence of VoIP altogether; in others, a straight ban has been imposed, but no other proceedings or announcements have been made. In these cases, the following effects are to be expected: A substantial black/grey market in VoIP used for international bypass, to avoid high interconnection fees. Incumbent carrier(s) will be slow to introduce IP-enabled services. Eventually the regulators will have to address the issues because of the disruption caused by the black/grey markets. Some Will Impose Restrictions ("Let the Incumbent Handle It") Some regulatory regimes are imposing rules and restrictions on VoIP services, which essentially seek to slow entry or to support the existing rate scheme in place. This position has the ancillary effect of reinforcing the incumbent's position or role in the evolution of the market. Most prominent among these are rules designed to make VoIP providers pay most or all of the same access and interconnection fees as circuit-switched carriers. Cofetel, Mexico's telecoms regulator, just announced plans to crack down on companies that skirt rules to complete long distance calls using VoIP. But, another significant effect derives from the requirement of non-geographic numbers for VoIP service. This can serve many other important goals and can even have a positive effect overall. Some nations, such as Ireland and the UK, have provided for both the porting of existing numbers to VoIP services and the creation of separate area codes for new service lines. However, both of these solutions have drawbacks and eventually have to change. It is important to consider that: Ported numbers using remote call-forwarding from the incumbent carrier enables the incumbent to be involved with the switching and transport of nearly every call. Ported numbers using remote call-forwarding from the incumbent carrier many times causes unacceptable delays in the completion of a call and introduces potential spots for trouble to occur, by introducing multiple carriers into the completion of calls. Separate area codes for VoIP services forces number changes, which places the nascent service at a competitive disadvantage. In such regimes, the following effects should be expected: Slowed market entry for VoIP players Short-term prop for the revenue streams and market-share of the incumbent A "mid-life crisis," as these issues over VoIP numbering and access charges have to be resolved in later years, detracting from market growth and investment opportunity What Needs Doing - Gartner Advice While national regimes will vary widely according to needs and the relative development of the market, Gartner advises the following: Take charge at the national level; do not leave the playing field cut up into a maze of local variations. Make service obligations transparent to end-users: help to resolve any outstanding technical issues and make it clear if any provider of telephony service, regardless of technology, needs to live up to the obligations presently imposed on circuit-switched carriers (namely, 911 and law enforcement requirements). Let social policy dictate your approach to charging: the access and interconnection regime, which supported circuit-switched telephony, is becoming rapidly outdated. A new charging regime needs to be implemented that is non-discriminatory and still meets the remaining social needs of the national market. If the penetration goals mandated by Universal Service have been met, phase in a reduction in these charges. Work to bring down artificially high international connection fees (or suffer a more drastic shock as VoIP's cost avoidance advantage remains high). Recognize that domestic long distance, and possibly international long distance, will disappear as separate retail service offerings; adjust the interconnection and access fee regime accordingly. Worldwide telecom regulators must approach the difficult task of adjusting interconnection and access charges with an eye toward technology-neutral, forward-looking, and fair arrangements that do not promote fruitless warfare over customer ownership. This type of regulatory regime, rather than a patchwork remedy to existing rules and processes, is essential to make telecoms, as well as the national economy at large, very successful. Regulators must foresee that, unlike other evolutionary changes that have occurred, the changes brought on by VoIP and other IP-enabled services will be swift and sweeping. Copyright © 2006 Gartner, Inc. and/or its Affiliates. All rights reserved. Reproduction of this publication in any form without prior written permission is forbidden. The information contained herein has been obtained from sources believed to be reliable. Gartner disclaims all warranties as to the accuracy, completeness or adequacy of such information. Gartner shall have no liability for errors, omissions or inadequacies in the information contained herein or for interpretations thereof. The reader assumes sole responsibility for the selection of these materials to achieve its intended results. The opinions expressed herein are subject to change without notice. Educational content provided by Gartner, Inc.