Home Page / Reports / Digital platforms / Submissions

AustraliaInquiry into digital platforms:



Submissions made in response to the issues paper were published on the ACCC's inquiry websites on 3 May (a total of 57 submissions). A further seven submissions were published on 11 May as well as a revised submission by the SBS. The ACCC also published a summary of responses to the ACCC's questionnaire (280 responses received)..

The originally published submissions were accompanied my an ACCC media release which stated, in part:

The submissions canvassed a wide range of issues, including the degree of market power held by the digital platforms, the digital advertising supply chain, and the use of news content by digital platforms, including Google and Facebook.

Submissions also detailed the impact of digital platforms on the quality and choice of news in Australia, and the extent to which consumers are aware of how their data is collected and used.

More than 100 submissions were received in response to the preliminary report.


Submissions on preliminary report

Submissions were due 15 February 2019.

86 submissions were published on the ACCC website on 4 March 2019 and a second tranche of 27 submissions was published on 12 March 2019.

For a summary of selected submissions see:

Newsmediaworks, 'ACCC Preliminary report submissions: selected extracts and key points' (14 March 2019)

5Rights Foundation

Ad Standards

American Bar Association Section of Antitrust Law

American Express

Arnold Bloch Leibler

Association for Data-driven Marketing & Advertising

Australian Association of National Advertisers

Australian Broadcasting Corporation

Australian Chamber of Commerce and Industry

Australian Communications and Media Authority

Australian Copyright Council

Australian Council on Children and the Media

Australian Data Privacy Certification Register

Australian Digital Alliance

Australian Film & TV Bodies

Australian Finance Industry Association

Australian Press Council

Australian Privacy Foundation

Australian Publishers Association

Australian Society of Authors

Brad Ellis

Brad Parfitt

BSA The Software Alliance

Carol O'Donnell

Centre for Media Transition

Christine A. McDaniel and Danielle Parks


Clubs Australia

Coalition of Major Professional & Participation Sports

Commercial Radio Australia

Communications Alliance

Computer & Communications Industry Association

Confidential Party #1

Consumer Action Law Centre

Consumer Policy Research Centre

Country Press Australia

Croakey Health Media

David Warr (February 2019)

DIGI (March 2019)

Dr. Kate Mathews Hunt

Dr. Katharine Kemp & Dr. Rob Nicholls


Facebook Australia

Financial Rights Legal Centre

Foundation for Alcohol Research and Education


Free TV

Freedom Publishers Union

Fundraising Institute Australia


Getty Images

Gladwin Legal

Global Antitrust Institute


Guardian Australia

Guillaume Roger

Iconoclast Tech


Innovation Defense Foundation

Insurance Council of Australia

International Center for Law and Economics

Internet of Things Alliance Australia

Intran Australia

Joint Submission 13 Parties

Kayleen Manwaring

Law Council of Australia

McPherson Media Group

Media, Entertainment and Arts Alliance

Michael Hollis



Music Rights Australia

News Corp Australia


Nicolas Suzor


Obesity Policy Coalition

Office of the eSafety Commissioner

Office of the Victorian Information Commissioner


Oracle Corporation

Outdoor Media Association

Professor Jeannie Marie Paterson

Professor Terry Flew and Associate Professor Tim Dwyer

Progressive Policy Institute

Provincial Press Group

Public Health Advocacy Institute of WA

Public Health Association of Australia

Public Interest Journalism Initiative

Queensland Country Press Association

Queensland Law Society

REA Group


Richard Meade

Rod Harris

Screen Producers Australia

Simon Moore

Special Broadcasting Service

Star News Group


Telecommunications Industry Ombudsman

Tania Katsanis

The Australian Industry Group

The Judith Neilson Institute for Journalism and Ideas

The North Western Courier

Tony Healy



UN Special Rapporteur on the Right to Privacy

U.S. Chamber of Commerce

Village Roadshow

Warwick Jones

Worldview Exchange


See also.


On the issues paper

More than fifty seven submissions were made in response to the issues paper (57 were published on 3 May; a further seven were published on 11 May as well as a revised SBS submission). On 11 May the ACCC also published a summary of responses to the ACCC's questionnaire (280 responses received). These can be viewed on the ACCC website.

The following submissions were published on 3 May (unless otherwise noted; submissions published at a later date are dated; most recently published submissions appear with 'new' image).

Descriptions of organisation and individuals (taken from submissions) provided for context.

Access Now

'Access Now is an international non-governmental organization founded in 2009 to extend and defend the digital rights of users at risk. Access Now provides policy recommendations to leaders in the public and private sectors to ensure the internet’s continued openness and the protection of fundamental rights. We engage with an action focused global community from more than 185 countries, and our Technology Arm operates a 24/7 digital security helpline that provides real time direct technical assistance to users around the world' (Sub p 1)

Ad Standards

'Ad Standards is the central authority in Australia for receiving complaints about advertising content across all forms of media (including online advertising), and in relation to the advertising of any products or services' (Sub p 2)

Australian Associated Press

'AAP has been an integral part of the Australian media landscape for almost 85 years, providing the foundation of news content for newspapers, radio news and talkback programs, television news and more recently the digital versions of all of the above, as well as new digital news arrivals to the national media market' (Sub para 2.1)

'AAP’s primary view is that the introduction of digital search engines, aggregators and social media platforms has changed forever the commercial dynamics of the media industry, having a detrimental impact on AAP, as well as its subscribers (which are also AAP’s primary revenue sources). Ultimately the impact is a poorer information service to Australian news consumers' (Sub para 1.3)

Australian Association of National Advertisers

'The AANA is the peak body for advertisers and has represented national advertising for 90 years. It represents the common interests and obligations of companies across all business sectors involved in the advertising, marketing and media industry.

The AANA has a strong ongoing commitment to self-regulation. The AANA designed and delivered the self-regulatory component of regulation controlling advertising and marketing communication in Australia.' (Sub p 2)

Australian Broadcasting Corporation

'The ABC is internationally recognised as a multi-platform source of Australian conversations, culture and stories—valued and trusted as the national public broadcaster since 1932 while evolving its content and services to meet changing audience behaviours and community needs.' (Sub p 4)

The submission provides a summary of key themes on p 3:

Digital platforms have contributed to an unprecedented level of disruption to Australia’s news media landscape
Australians are increasingly accessing news via a variety of platforms, in effect fragmenting the news media landscape. In this environment, the ABC is delivering quality news and journalism to audiences where they are searching for it and where they are spending significant amounts of time, while adapting to and harnessing the capabilities that digital platforms can offer.

Audiences have moved online, so it is critical that media content creators follow them
The shift away from traditional media delivery methods increases the need for strong, impartial news providers that are focused on the Australian market, like the ABC. The ABC is continually responding to the changing environment and is striving to fulfil its mandate of reaching as many Australians as possible by delivering news and journalistic content on the ABC’s trusted and advertisement-free digital platforms. At the same time, the ABC is engaging with digital platforms in ways that are efficient, effective and convenient for its audiences. This means the ABC’s independent news service can reach more Australians, including those who are not actively seeking news content.

The disruption created by digital platforms has created an
increased demand for trustworthy and reliable news media content

The disruption from digital platforms has led to an increasing demand from audiences for independent, trustworthy, local news and journalistic content. To reflect these audience demands, the ABC suggests a multi-faceted approach to measuring quality and choice of news and journalism. The key characteristics of measuring quality news content include coverage of relevant and publicly important topics, diversity and timeliness, as well as impartiality, accuracy and indepth investigation.

Australian Communications and Media Authority

'The ACMA is an independent statutory authority responsible for the regulation of broadcasting, radiocommunications, telecommunications and some online content.' (sub p 1)

Australian Film & TV Bodies

'The Australian Film & TV Bodies represent a large cross-section of the film and television industry that contributed $5.8 billion to the Australian economy and supported an estimated 46,600 FTE workers in 2012-13.' (Sub p 1)

'The Australian Film & TV Bodies are made up of the Australian Screen Association (ASA), the Australian Home Entertainment Distributors Association (AHEDA), the Motion Picture Distributors Association of Australia (MPDAA), the National Association of Cinema Operators-Australasia (NACO), the Australian Independent Distributors Association (AIDA) and the Independent Cinemas Australia (ICA).' (Sub p 3)

Australian Lottery and Newsagents' Association

'The Australian Lottery and Newsagents’ Association (ALNA) is the peak national industry body representing Lottery Agents, Retail Newsagents’ and Distribution Newsagents who along with affiliated state lottery associations, are small businesses that are found in almost every rural town, regional centre, urban and metropolitan shopping centre in Australia.' (sub p 1)

Australian Press Council

'The objects of the Press Council, as stated in its constitution, include promotion of freedom of speech through responsible and independent print and digital media, and adherence to high journalistic and editorial standards.

The Press Council is also the principal body with responsibility for setting and promoting high professional standards for publisher members and for dealing with complaints about Australian newspapers, magazines and associated digital outlets. The Press Council plays a pivotal role in promoting and upholding high standards of journalistic practice. This underpins the effective functioning of a free press, which is crucial for the proper functioning of democratic institutions.' (sub p 2)

Australian Publishers Association

'The APA is the peak national body for Australian book, journal and electronic publishers. Established in 1948, the Association is an advocate for all Australian publishers - large and small; commercial and non-profit; academic and popular; locally and overseas owned. The Association has approximately 210 members and, based on turnover, represents over 90% of the industry. Our members include publishers from all sectors of the publishing industry - trade and children’s, schools, tertiary and academic publishing.' (Sub p 1)

Australian Radio Network

'... ARN owns or controls 12 commercial radio stations across Australia ... ARN also operates a number of DAB+ stations ... ARN is owned by HT&E Limited, an ASX listed Australian company' (sub p 1)

'In short, we would like to see a similar regulatory burden on online and traditional media to allow an even playing field' (sub p 1)

Australian Recording Industry Association

'The Australian Recording Industry Association (ARIA) is the peak trade body for the recorded music industry in Australia. ARIA is a not for profit, national industry association that proactively represents the interests of its members.

ARIA has more than 100 members ranging from small "boutique" labels typically run by 1-5 people, to medium sized businesses and very large companies with international affiliates.' (Sub p 2)

Australian Society of Authors

'The Australian Society of Authors (ASA) is the peak national organisation representing Australian writers and illustrators. ...

This Inquiry is most directly relevant to those of our members who are freelance writers and journalists. While the vast majority (87%) of our members publish in print (and mainly under traditional publishing contracts), almost half of our members (45%) have published online. Therefore, while we encourage the ACCC to look to the Media Entertainment and Arts Alliance (MEAA) as the most relevant body to represent journalists, we wish to make a brief submission on behalf of writers and illustrators more generally.' (Sub p 1)

New submission (11 May)Carol O'Donnell (2 October 2018)

Commercial Radio Australia

'Commercial Radio Australia (CRA) is the peak industry body representing the interests of commercial radio broadcasters throughout Australia. CRA has 260 member stations, comprising 99% of the Australian commercial radio industry.' (Sub p 1)

Communications Council

'The Communications Council is the peak industry organisation representing companies in the Australian advertising industry. Our diverse member base spans more than 160 agencies and offices around the country which operate in the areas of creative, digital, strategic planning, promotion, direct marketing, PR, design, production, and healthcare advertising.

Our members are comprised of local offices from all major holding companies (Omnicom, WPP, Dentsu Aegis Network, Havas Worldwide, Publicis Groupe, Interpublic Group, and M&C Saatchi), smaller international networks and a flourishing segment of largely privately-owned Australian independent agencies.' (Sub p 1)

Confidential Party #1
(Confidential submission, partly redacted - focus on Amazon and books)

New submission (11 May)Confidential Party #2 (revised version 28 May 2018)

New submission (11 May)Consumer Policy Research Centre (April 2018)

'CPRC is an independent, not-for-profit consumer research organisation ...'

David Fagan
(Adjunct Professor of Business, QUT and former editorial executive of News Corp in Qld)

New submission (11 May)David Nebe (February 2018; published 11 May 2018)

Brief note - expressing concern about Facebook domination

Digital Industry Group Incorporated

'DIGI includes representatives from Facebook, Google, Twitter and Oath. DIGI members collectively provide various digital services to Australians ranging from Internet search engines, social media platforms and other digital communications platforms. These services and platforms facilitate new distribution, marketing and revenue generating channels for Australian businesses and content creators, including news publishers and journalists. They are also driving fundamental changes to the way that business is conducted, and content is created and distributed. These technological advances are to the overwhelming benefit of Australian consumers and our wider economy' (Sub p 1)

Facebook Australia

'We offer a broad range of products and services that enable Australians and people around the world to connect with each other by sharing ideas and experiences with their friends, families, and other communities. Facebook also helps people discover content that is meaningful to them' (sub p 4 (of 83))

Fairfax Media

'As Australia’s oldest news organisation and the publisher of the country’s leading mastheads, [Fairfax Media] is uniquely positioned to do [respond to this inquiry.' (Sub p 1)

'Fairfax's Austrlaian publications include: The Sydney Morning Herald,...The Age, ... The Australian Financial Review, ... The Canberra Times ... Digital-only news sites Brisbane Times and WAtoday ... Along with 13 major regional dailies including key mastheads the Newcastle Herald and Illawarra Mercury, more than 130 non-daily regional titles, 9 community titles and 10 national specialist agricultural titles including The Land.' (Sub p 1)


Brief submissionf rom Kata Baranyi, Owner AP Baranyi & JK Baranyi, T/A Food4U The Food Factory.

Submission claims '... we were squeezed out of the digital platforms by larger or a proliferation of companies ... Whilst these digital platforms may be affordable to many companies, it is the small business owners (companies employing under 20 or 30 staff) that cannot even afford to compete on any equal playing field or search engine with the exception of social media. ...' (Sub p 1)

Foxtel & Fox Sports

'Foxtel is one of Australia’s most innovative and dynamic media companies and home to award winning local drama plus the widest choice in live sport, hit international TV and movies and a host of complete TV seasons.' (sub p 3)

'FOX SPORTS Australia Pty Limited ... is Australia’s leading producer of sports coverage and is home to Australia’s favourite subscription television sports channels as well as Australia’s number one multi-sports website and app.' (sub p 3)

Argue (in part): 'The free (but unauthorised) availability of Foxtel and Fox Sports’ content on digital platforms is undermining subscription revenue, contributing to churn and threatening the economics of content production' (Sub p 2)

Free TV Australia

Submission also published by Free TV here: Free TV, Submission by Free TV Australia, Digital Platforms Inquiry, Australian Competition and Consumer Commission (April 2018)

'Free TV represents all of Australia’s commercial television networks, covering metropolitan, regional and remote areas.' (sub p 5)

Executive summary (p 3)

Google and Facebook have become virtual monopolies in search and social media and have become seemingly essential to our personal lives and in business. However, despite the influence and power they enjoy, these platforms have achieved this position with very little oversight from Government or regulators.

The rise of Facebook and Google has had a significant and irreversible effect on traditional media companies. The diversion of advertising revenue to these dominant digital titans away from newspapers, radio and television directly impacts the delivery of local, trusted, fair, accurate and impartial news content that is vital to our democracy. It also impacts the local entertainment, sport and drama programs that contribute so much to our sense of national identity.

Digital advertising, driven by Google and Facebook, has captured more than half of all Australian advertising revenue in a little over a decade. ... Google and Facebook have in part been able to achieve this outcome based on unsubstantiated and exaggerated claims around reach, viewability and effectiveness. They write their own standards and force advertisers to use their vertically integrated products to get access to their platforms.


The top priority for this inquiry must be to address the absence of independently verifiable metrics to provide reliable information on the true reach and viewability of advertising on the Facebook and Google platforms. The ACCC should require Facebook and Google to implement third-party Software Development Kits (SDK) and transparent measurement of web traffic to allow robust and reliable measurement and verification. It is not acceptable for these dominant platforms to set and supposedly verify their own measurement tools.

Facebook and Google have also been able to take advantage of their almost completely unregulated status in competing with commercial television broadcasters, who remain the most heavily regulated media platform in Australia. ...

Google and Facebook are not merely platforms, they are also media companies. They monetise content. However, unlike commercial television broadcasters that invest in the creation of content, Google and Facebook monetise content created by others, without meaningfully investing in its creation or licensing its use. To add insult to injury, these platforms earn significant revenue by facilitating access to illegal pirated content. ...

The scale of personal data collected and stored by Facebook and Google is now a significant barrier to entry. It has also given rise to serious concerns around privacy and misuse of that data. The ACCC must seriously consider the need for greater transparency and controls around data collection and use.

New submission (11 May)Free TV Australia Submission 2 (Sept 2018)


New submission (11 May)Free TV Australia Submission 3 (November 2018)


Freedom Publishers Union

From Freedom Publishers Union website (about us): 'Opening the gates of freedom of information and transparency. Making the internet and open-source software more accessible. We publish articles, documents and files on topics of interest related to, but not limited to: Freedom of information, Digital Privacy Violations, Mass-surveillance ... At Freedom Publishers Union, our political view is largely libertarian, who believe in fairness and democracy.'

Getty Images

'Getty Images was founded 22 years ago. It has an award-winning image and video collection of over 250 million assets, of which over 170 million are digitized, encompassing the latest global news, sports, celebrity, music and fashion coverage; exclusive conceptual creative images; and the world’s largest commercial archive. New content is added daily, with more than 6 million highly edited and curated new assets added each quarter.' (Sub p 1)


Submission also published by Google: Google, Submission of Google Australia Pty Ltd to the ACCC Digital Platforms Inquiry (20 April 2018)

New submission (11 May)Google Submission 2 (26 October 2018)


Harley Comrie

Submission comprises reproduction of blog piece published in The Stragegist (blog of the Australian Strategic Policy Institute) on 18 January 2018 under the title 'Misinformation for profit'. Focus is on fake news.

Internet Australia

'Internet Australia is the not-for-profit organisation representing all users of the Internet. Our mission – “Helping Shape Our Internet Future” – is to promote Internet developments for the benefit of the whole Australian community, including business, educational, government and private Internet users. Our leaders and members are experts who hold significant roles in Internet-related organisations and enable us to provide education and high level policy and technical information to Internet user groups, governments and regulatory authorities. We are the Australian chapter of the global Internet Society, where we contribute to the development of international Internet policy, governance, regulation and technical development for the global benefit' (Sub p 1)

Intran Australia

No corporate blurb provided, not notes that for 'some time, Intran Australia Pty Ltd has been pursuing a venture to see established in Australia a National Internet Platform' (sub p 1)

James Meese

Executive summary: '... The digital market is changing and growing at a rapid rate, such that perhaps the only current certainty is uncertainty. Moreover, digital platforms intervene in multiple markets, which are often interrelated. This makes it difficult to assess the power of digital platforms in light of current competition law frameworks. Nonetheless, there are dominant platforms and trends towards market concentration in Australia. I recommend a range of reforms around the use, handling and transfer of data. However, at this stage, I suggest the market remains too underdeveloped to engage in substantive intervention around competition ...'

New submission (11 May)Karl Goiser (published 11 May)

Brief submission with focus on Facebook and Google. Argues effect of Facebook and Google buying out competition (referencing YouTube, Instagram and WhatsApp) 'is anti-competitive behaviour because it destroys competition when small and not allowing it to grow'.

New submission (11 May)Margaret Simons (published 11 May)
Associate Professor, School of Media, Film and Journalism, Monash University

Includes timeline of relevant inquiries into journalism and media regulation.

Media, Entertainment and Arts Alliance

Also published by MEAA here: MEAA, MEAA submission to the ACCC inquiry into digital platforms (April 2018)

No corporate blurb provided in submission. From MEAA website: 'Built on integrity and powered by creativity, MEAA is the largest and most established union and industry advocate for Australia’s creative professionals.'

New submission (11 May)MediaScope (published 11 May)
Submission by Denise Shrivell, MediaScope

MediaScope 'is a solo-run business which launched in early 2010 and now creates and curates a unique range of resources, services, independent advice and industry commentary for the media, advertising and marketing sectors ...' (from 'About Us' page on website

Submission takes the form of PowerPoint presentation (20 pages)


No corporate blurb provided in submission, although submission notes that the response reflects view of the Medibank Group, including its private health insurance subsidiary, amh, and that data used in the submission relates to Medibank Private Limited.

Corporate website: 'Medibank is a leading private health insurer, with 40 years of experience delivering better health to Australians. We look after the health cover needs of more than 3.7 million customers through our Medibank and ahm brands, and distribute travel, life and pet insurance.'

Mitchell Watt & Hubert Wu

Submission details findings of reserach project conducted at Harvard Kennedy School into regulatory appropriate regulatory responses to online platforms; project was conducted for Office of Policy Planning at US Federal Trade Commission - that full report is also available here: Mitchell Watt and Hubert We, 'Trust mechanisms and online platforms: a regulatory reponse' (Policy Analysis Exercise for the Federal Trade Commission, 27 March 2018)

National Association for the Visual Arts

'The National Association for the Visual Arts is the peak body representing the professional interests of the Australian visual and media arts, craft and design sector, comprising of 20,000 practitioners, galleries and other art organisations. Since its establishment in 1983, NAVA has been influential in bringing about policy and legislative change to encourage the growth and development of the visual arts sector and to increase professionalism within the industry.

NAVA sets industry standards through the Code of Practice for the Professional Australian Visual Arts, Craft and Design Sector. We have long been committed to ensuring copyright entitlements for visual creators and, in 1995, were responsible for the establishment of Viscopy, Australia’s visual arts copyright collecting agency, now part of Copyright Agency. NAVA has long been a vigorous advocate for the introduction of both moral rights and resale royalty rights legislation.' (sub p 1)

New submission (11 May)Netflix (June 2018)


Network Ten

'Ten is one of Australia's leading entertainment and news content companies, with assets across free-to-air television, online and digital platforms. It is owned by CBS Corporation, one of the world's leading media organisations.' (Sub p 1)

In addition to making its own brief submission, Ten notes that it was 'directly engaged in and strongly supports the detailed submission made by Free TV Australia ...' (Sub p 1)

News & Media Research Centre

'The News and Media Research Centre (N&MRC) at the University of Canberra (http://www.canberra.edu.au/nmrc) investigates the evolution of media, content and communication and the impact of online and mobile systems on the way citizens consume information.

Since 2015, the Centre has published the Digital News Report: Australia, a national annual online survey of more than 2,000 adult Australians which monitors changes in news consumption over time, particularly within the digital space. The Australian survey forms part of a global study of 36 news markets by the Reuters Institute for the Study of Journalism at the University of Oxford' (Sub p 1)

New submission (11 May)News and Media Research Centre (June 2018)


News Corp Australia

News Corp Australia's 144 page submission does not include a corporate blurb. The corporate website describes it as 'Australia's No.1 media company' offering 'advertisers greater reach of audiences than any other Australian media company across all platforms - print, web, broadcast, mobile & tablet.' Brands include The Australian, Daily Telegraph, Herald Sun, Courer Mail, Mergury, WSJ, Vogue Australia, GQ AUstralia, Kidspot and many more.

News Corp Australia argues (in part) : 'A number of digital platforms possess substantial market pwoer and are engaging in anti-competitive practices that prevent publishers such as News Corp Australia from competing on the merits. These practices have the potential to profoundly damage the creation, distribution and consumption of news and journalism in Australia ...' (p 2)

New submission (11 May)News Corp Australia Submission 2 (7 September 2018)



'Nine Entertainment Co. (ASX: NEC) is a leading Australian media and entertainment company. Its main business activities involve its free-to-air television business; digital publishing assets including its news and lifestyle verticals 9news.com.au and 9Honey; digital on-demand services including 9Now and Stan (50% JV); and television content production and distribution. In 2016/17 Nine turned over $1.28 billion, consisting of $1.1 billion in television revenue and $150 million in digital revenue.

Nine has more than 3500 employees across seven main offices, of which a significant proportion are involved in content production and distribution: as journalists, camerapersons, producers and editors. Journalism remains a key anchor of Nine’s business. While traditional news and current affairs journalism remains a key component of Nine’s content offering, the other content pillars of sport, entertainment and lifestyle journalism also have strong cultural value for Australians, and are necessarily a part of Nine’s content mix.

Each of Nine’s business activities involves content at its core, with a particular focus on distribution of premium content across multiple platforms to reach and engage a broader audience. Nine has a unique combination of assets: linear television, on-demand (both subscription and advertiser-based), as well as a broadening range of digital publishing properties. Nine is no longer just a traditional linear television broadcast business. Our success in the future will depend on our ability to transform to a cross-platform business model.' (Sub Appendix A, p 45)

NSW Business Chamber

'... the NSW Business Chamber (“the Chamber”) is one of Australia’s largest business support groups, with a direct membership of more than 20,000 businesses, providing services to over 30,000 businesses each year.

Tracing its heritage back to the Sydney Chamber of Commerce established in 1825, the Chamber works with thousands of businesses ranging in size from owner operators to large corporations, and spanning all industry sectors from product-based manufacturers to service provider enterprises.' (Sub p 2)

NSW Young Lawyers

'NSW Young Lawyers is a division of The Law Society of New South Wales. NSW Young Lawyers supports practitioners in their professional and career development in numerous ways, including by encouraging active participation in its 15 separate committees, each dedicated to particular areas of practice. Membership is automatic for all NSW lawyers (solicitors and barristers) under 36 years and/or in their first five years of practice, as well as law students. NSW Young Lawyers currently has over 15,000 members.

The Communications, Entertainment and Technology Law Committee (CET Committee) of NSW Young Lawyers aims to serve the interests of lawyers, law students and other members of the community concerned with areas of law relating to information and communication technology (including technology affecting legal practice), intellectual property; advertising and consumer protection; confidential information and privacy; entertainment; and the media. As innovation inevitably challenges custom, the CET Committee promotes forward thinking, particularly about the shape of the law and the legal profession as a whole.' (Sub p 1)

Obesity Policy Coalition

'The Obesity Policy Coalition (OPC) is a partnership between the Cancer Council of Victoria, Diabetes Victoria and the Global Obesity Centre at Deakin University, a World Health Organization Collaborating Centre for Obesity, with support from VicHealth. The OPC advocates for evidencebased policy interventions and research to address the high rates of overweight, obesity and unhealthy diets in Australia, particularly in children.' (Sub p 2)

Office of the Australian Information Commissioner

Submission also available from OAIC website

'The OAIC is a key advisory body on privacy and information management, drawing on our domestic and international networks to shape how organisations and Australian government agencies (APP entities) harness emerging technologies and data practices to improve the lives of Australians. Central themes in the Privacy Act—such as transparency, choice and control for individuals and accountability for APP entities—are intended to support individuals in making decisions about their personal information, and to ensure APP entities protect personal information and are accountable for how it is handled.' (sub p 1)


'oOh! is one of the leading operators in Australia and New Zealand’s fast-growing Out Of Home advertising industry. We create deep engagement between people and brands through Unmissable location-based media solutions. We have a diverse portfolio of classic and digital signs, across roadside, retail, airport and place based media, in CBD office towers, cafés, fitness venues, bars and universities'.

'oOh! owns Junkee Media Australia (Junkee Media), a leading youth publication network, which employs 20 fulltime writers, journalists, editors and videographers, and uses 150 freelance contributors.'

'We combine this reach with location data, research insights and world leading digital innovation, integrating our physical inventory with experiential, social and mobile online channels, to provide clients with greater connections with consumers.' (Sub p 1)

New submission (11 May)Oracle (June2018)


New submission (11 May)Oracle Submission 2 (Sept 2018)


Outdoor Media Association

'The Outdoor Media Association (OMA) is the peak national industry body representing the majority of Australia’s Out of Home (OOH) media display and media production companies, as well as some media display asset owners. The OMA advocates for reasonable, evidence-based regulation.' (Sub p 1)

Post Newspapers

Post Newspapers Pty Ltd is 'a group of suburban newspapers operating between the cities of Perth and Fremantle.' (Sub p 1)

Post Newspapers argues that 'The problem is simple: Journalists are being paid by their employers to provide original news coverage. Yet the platforms pay nothing to re-use it, and to add insult to injury, make enormous profits by selling advising content that accompanies the cost-free (to them) journalism they publish. At the same time the big digital platforms are hollowing-out the advertising content of conventional publishers, the advertising revenue used to pay journalists. The end result could well be that independent journalism is so diminished that real, verified information the public needs for our democracy to function will dangerously diminish in both quantity and quality, if it has not already done so.' (Sub p 1)

REA Group Ltd

REA operates an Austarlian digital property listings platform.

'REA is a Melbourne-based, multinational digital advertising company specialising in property. REA's core business involves advertising properties on behalf of real estate agents and providing a platform for property seekers to search for properties by reference to criteria such as listing type, property type, price, location and features.' (sub p 5)

Rosa Walden

Private submission - based on expereinces as consumer and digital tutor with community agencies. Expresses some concern that scope of inquiry is too limited (concerned about lost opportunity to assess consumer impacts, especially those of 'less digitally literate consumers')

Screen Producers Australia

'Screen Producers Australia was formed by the screen industry to represent large and small enterprises across a diverse production slate of feature film, television and interactive content.

As the peak industry and trade body, we consult with a membership of more than 450 production businesses in the preparation of our submissions. This consultation is augmented by ongoing discussions with our elected Council and appointed Policy Working Group representatives. Our members employ over 17,000 Australians and drive more than $1.7 billion worth of annual production activity from the independent sector. ...'

Seven West Media

'2.1 Seven West Media is one of Australia’s leading integrated media companies, with a portfolio of world class television, publishing and digital properties.

2.2 The Seven Network is Australia’s most-watched television network, with five broadcast channels (7, 7TWO, 7Mate, 7flix and racing.com) in Sydney, Melbourne, Brisbane, Adelaide, Perth and regional Queensland. It is home to many of Australia’s most popular programs including My Kitchen Rules, House Rules, Home and Away, Better Homes and Gardens and Sunrise, along with key sporting events including the AFL, the Olympic and Commonwealth Games. Regional affiliates broadcast Seven content across New South Wales, Victoria, Western Australia, the Northern Territory and Tasmania

2.3 Our TV production business, Seven Studios, is one of the country’s largest producers of Australian content, and one of the only significant producers of Australian content that is Australian owned. Seven commissions, creates and produces around 700 hours of programming a year.

2.4 Seven News is the highest rating TV news service in Australia. ...

2.5 The West Australian and The Sunday Times are the number one news brands in WA.

2.6 Pacific Magazines is Australia’s best performing magazine publisher and home to three of the top six highest reaching magazines in the country - Better Homes and Gardens, New Idea and that’s life!.

2.7 Seven West Media has a strong online presence for each of its television, newspaper and magazine brands, as well as stand alone digital properties such as Perthnow.com.au, thegame.com.au and beautycrew.com.au. Seven recently ended its joint venture with Yahoo!7 after 11 years to pursue its own digital strategy, including the launch of online streaming platform 7Plus.' (sub p 4)

Submission argues: 'It is SWM's submission that both Google and Facebook enjoy significant market power in the markets for search services and social media platforms respectively. Unconstrained by competitors; countervailing customer/buyer power; and regulation, Google and Facebook use their market power in their respective markets to engage in conduct which negatively impacts traditional media, and which harm consumers.' (Sub para 1.4)

New submission (11 May)Simon M (published 11 May)

Submission takes the form of a series of communications reported to the GG's Cyber Emergency Response Team in 2017.

Simon Thompson

Australian Lawyer and qualified solicitor in England and Wales. Worked at tech and internet focussed startups in Europe and completing masters thesis on 'the effective regulation of data centric online platforms'.

Southern Cross Austereo

'SCA is a leading Australian media and entertainment company, with the ability to reach more than 95% of the Australian population through its audio (radio, radio-related websites and podcasts) and television businesses.' (sub p 1)

Special Broadcasting Service

'... as Australia’s multicultural and Indigenous public broadcaster, SBS is more critical now than ever to building understanding and cohesion in our society. ...

SBS reaches almost 100 per cent of the population through its six free-to-air TV channels (SBS, SBS HD, SBS VICELAND, SBS VICELAND HD, Food Network and National Indigenous Television (NITV)) and eight radio stations (SBS Radio 1, 2 3 and 4, SBS Arabic24, SBS PopDesi, SBS Chill and SBS PopAsia). Engagement is being significantly extended through SBS’s digital services, including SBS On Demand and portals which make online audio programming and information available in nearly 70 languages other than English.' (sub p 2)

New submission (11 May)Special Broadcasting Service (revised) (published 11 May)

Revised submission May 2018. Submission itself still dated April and on quick run-through I could not identify the change; file size is different though and this version replaces the original posted version rather than appearing as a separate file.


'Stan is the country’s leading local SVOD service and is at the forefront of changing how Australians consume video content. Stan’s interest in the Australian Competition & Consumer Commission’s Digital Platforms Inquiry revolves around the issue of content piracy. Stan invests significant amounts of money in original productions and licensed content, for which we either own or license the intellectual property. This content forms the basis of Stan’s business model. Stan is also owned by two of Australia’s biggest content creators in Nine Entertainment and Fairfax Media. We have a first-hand view of how harmful piracy is to the content industry and, therefore, to the quality of content itself.' (sub p 1 of 1)

New submission (11 May)Teresa K (published 11 May)

Brief submission relating to Oasis dating website

New submission (11 May)Tony Healy (published 11 May)
Software engineer (no further information published)

Brief submission addressing questions 1.2 (other platforms), 3.5 (market power) and 3.36 (new laws for digital platforms). Suggests 'explicit bans on deliberate data-driven manipulation of users', development of 'standard privacy schema' and 'holding digital platforms accountable for complying with data laws, at the board level, with financial sanctions'.


'As a public, real-time platform, Twitter is where people can see every side of a topic, discover news, share their perspectives, and engage in conversation. Twitter was founded upon a set of core values that continue to guide us as we develop as a company. Among those values are defending and respecting the user’s voice and a two-part commitment to freedom of expression and privacy.

Twitter’s purpose is to keep the world informed by serving the public conversation and supporting a free and independent media as a matter of public interest. We celebrate journalism and believe strongly in the importance of a rich media ecosystem where consumers have variety, quality, and choice in news.' (Sub p 2 of 7)

Victoria Fielding

PhD candidate in Political Communications and Media at University of South Australia

Vision Australia

'Vision Australia is the largest national provider of services to people who are blind, deaf blind, or have low vision in Australia. We are formed through the merger of several of Australia’s most respected and experienced blindness and low vision agencies, celebrating our 150th year of operation in 2017.

Our vision is that people who are blind, deafblind, or have low vision will increasingly be able to choose to participate fully in every facet of community life. To help realise this goal, we provide high-quality services to the community of people who are blind, have low vision, are deafblind or have a print disability, and their families.' (Sub p 5 of 5)

Walkley Foundation

'The Walkley Foundation is at the heart of the Australian media. We recognise and promote excellence in our craft. We advocate for great journalism. The Walkleys is a well-regarded and respected brand within both the industry and the public mind....

The Walkley Foundation now partners with not only traditional media industry players but also the start-ups, both global and local, that have entered the Australian journalism field over the last 10 years. The Foundation remains an independent umbrella industry body that works with all media organisations including Fairfax, News Corp, Sky, Channel Ten, Nine Network, SBS, Seven West Media, the ABC, The Conversation, The Guardian, The New York Times Australia, BuzzFeed Australia, Crikey, Mamamia, Schwartz Media, Junkee, Vice, Pedestrian TV, Mumbrella, Broadsheet, Griffith Review, The Newcastle Herald, the Community Broadcasters Association of Australia, The Weekly Times and more' (Sub pp 2-3)

Consumer questionnarie

On 11 May the ACCC also published 170 pages of responses to submissions in relation to their consumer questionnaire (this appears in the list of other submissions in alphabetical order under the file name 'Consumer Questionnaire Responses (February - April 2018)'

280 reponses were received. Where responses were provided directly in relation to questions 2-8 the answers are set out in the ACCC's collated document (with some editing to remove identification or which the ACCC regarded as 'potentially defamatory or libellous'. Other responses were collated in the summary report, which includes a series of bar charts - for example:

Source: 'ACCC, Consumer Questionnaire Responses (February - April 2018), published and accessed on 11 May 2018 (reproduced under CC BY 3.0 AU licence, (c) Commonwealth of Australia)


On the Final Report (2019)

The Government invited submissions on the final report between 1 August - 12 September 2019.

See Final Report review page.


Public forums (2018)

On 3 May the ACCC announced that the following public forums would be held:

  • For consumers: Tuesday 29 May (Melbourne)
  • For business (including advertisers): Wednesday 30 May (Melbourne)
  • For journalists: August (date TBC) (Sydney)