Internet Engineering Task Force M. McFadden, Ed.
Internet-Draft internet policy advisors, ltd
Intended status: Informational D. Lazanski
Expires: 22 April 2025 Last Press Label
19 October 2024
On the Effects of Internet Consolidation
draft-mcfadden-cnsldtn-effects-04
Abstract
This document contributes to the continuing discussion on Internet
consolidation. Over the last several years there have been many
types of discussions around consolidation at a technical level, an
economic or market level and also at an engineering level. This
document aims to discuss recent areas of Internet consolidation and
provide some suggestions for advancing the discussion.
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Table of Contents
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Acknowledgement of Other Drafts and RFCs on This Topic . . . 4
3. Background to Consolidation Issues and the Role of
Standards . . . . . . . . . . . . . . . . . . . . . . . . 5
4. Overarching Issues Related to Consolidation . . . . . . . . . 6
4.1. Essential Taxonomy of Internet Consolidation . . . . . . 6
4.2. Technical . . . . . . . . . . . . . . . . . . . . . . . . 7
4.3. Economic . . . . . . . . . . . . . . . . . . . . . . . . 7
4.4. Security . . . . . . . . . . . . . . . . . . . . . . . . 9
5. Centralization versus Consolidation . . . . . . . . . . . . . 10
6. Can Consolidation be Measured? . . . . . . . . . . . . . . . 10
6.1. Metrics for Specific Protocols in Relation to
Consolidation . . . . . . . . . . . . . . . . . . . . . . 10
6.2. Metrics for Specific Services in Relation to
Consolidation . . . . . . . . . . . . . . . . . . . . . . 11
7. Implications of Consolidation on Internet Architecture . . . 12
7.1. The Changing Architecture of the Internet . . . . . . . . 12
7.2. The End-to-End Principle Redux . . . . . . . . . . . . . 14
8. Intermediaries and Consolidation . . . . . . . . . . . . . . 15
9. Implications of Consolidation on Protocol Design . . . . . . 16
9.1. Does Protocol Design Really Affect Consolidation? . . . . 16
9.2. Case Studies in Consolidation and Protocol Design . . . . 17
9.2.1. DNS over HTTPS (DoH) . . . . . . . . . . . . . . . . 17
9.2.2. Encrypted Server Name Indication (eSNI) . . . . . . . 18
9.2.3. Oblivious HTTP . . . . . . . . . . . . . . . . . . . 18
10. Potential Technical Risks . . . . . . . . . . . . . . . . . . 19
11. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 19
12. Security Considerations . . . . . . . . . . . . . . . . . . . 19
13. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . 20
14. References . . . . . . . . . . . . . . . . . . . . . . . . . 20
14.1. Informative References . . . . . . . . . . . . . . . . . 20
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . 22
Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . 22
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1. Introduction
The origins of the Internet was and continues to be decentralised.
Resilience, security and best-effort delivery of data and information
on all layers of the Internet works best in a decentralised manner.
But over the last several years there have been discussions on how
the Internet is becoming "centralised" or "consolidated" (see section
2, below).
Internet consolidation is "the process of increasing control over
internet infrastructure and services by a small set of
organizations." [1] Let us consider two general categories of
concentration: "player" and "layer". By player concentration, we
mean the aggregating of a market to a small number of providers for a
particular service. Layer concentration means the combining of
functions within a given layer. An example of "player" concentration
would be a relatively small number of email service providers who
offer billions of users email service. [Litmus] Or the number of web
search providers or even web browser offerings. [Statista] Indeed,
the Internet has changed from being about bits on the wire and
connectivity to the services and content it provides at the
application layer.
As defined in RFC9518 [RFC9518] "centralization" as the ability of a
single entity or a small group of them to exclusively observe,
capture, control, or extract rent from the operation or use of an
Internet function. Furthermore, "centralisation" as noted in the
Internet of Three Protocols is that one or two or three single
protocols are being used for everything rather than one protocol for
one operation as is a guiding principle of protocol design until now.
In this draft we argue that not all consolidation is related to
economics. In fact, the design of specific features of protocols can
lead to consolidation in delivery of services at the application
layer - and sometimes lower layers. We believe that is what RFC9518
argues that protocol designers should avoid. We agree, provide
examples and suggest that not everything in this problem space "is
simply a question of economics."
The Internet is being centralised and, thus, consolidated on all
layers of the Internet and it is essential to recognise the
technical, political and economic reasons for this happening. The
rest of this draft will focus on different aspects of the issue of
consolidation.
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2. Acknowledgement of Other Drafts and RFCs on This Topic
This document recognizes that the topics of protocol design and
centralization have been addressed by several people. In this
section we take a moment to recognize that we are not the first to
come to this topic, nor will we be the last. Our purpose is to
examine the forms of centralization and how protocol design impacts
them.
In section 1 above we cited the RFC that discusses centralization in
Internet protocols and relates it to consolidation of power.[RFC9518]
The draft goes on to identify possible reactions to centralization
and specifically what Internet protocols should do to limit or
mitigate centralization.
Another draft (now expired) explored a slightly different angle. In
draft-arkko-iab-internet-consolidation-02, the authors consider the
topic from the perspective of how available technology and Internet
architecture drives different market directions.[Arrko1] This draft
ends with a call to action that emphasizes open interfaces, specific
standardization choices and the benefits of open source development
and the need for further research.
Another important contribution to the discussion is a paper
"Centrality and the Internet" published by Geoff Huston on his
blog.[Huston] The paper explores the historical precedents for
consolidation and the consequences of having large organizations
control important parts of specific sectors of the economy. It
finishes with a look at the role of regulation in ensuring that the
market functions properly and the impact of advertiser funding in
creating a small number of dominating incumbents.
Another recent paper, by a team from The Netherlands and Brazil,
examines consolidation in the hosting industry.[Zembruzski] The paper
focuses on that industry and shows how it is heavily concentrated: 10
hosting providers account for most of the hosting for all TLDs
considered. While European ccTLDs have a strong hosting industry,
US-based providers have been continuously conquering the market,
especially in the high end of it - the popular domain names, which
poses challenges for the European Union's goals of digital
sovereignty.
Both the Internet Society and participants of the IETF have published
on the subject of consolidation in 2019. At the IAB's Design
Expectations vs. Deployment Reality in Protocol Development Workshop
2019 a handful of the participants discussed concentration and
consolidation. Jari Arkko discussed the impacts of consolidation on
the Internet infrastructure in a document for the IETF[Arrko2], with
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the document identifying issues including loss of resilience and
increased risk of surveillance. It goes on to note that "it seems
prudent to recommend that whenever it comes to Internet
infrastructure services, centralised designs should be avoided where
possible".[Arrko2] From networks to applications, the overarching
theme was that consolidation is taking place from one end of the
Internet to the other.
Additionally, the Journal of Cyber Policy published a special edition
on Consolidation of the Internet. Topics in this special issue
included market concentration and security, DNS consolidation, supply
chains, interoperability and Internet architecture. However, much is
still yet to be discussed on consolidation at most layers of the
Internet stack. [Lazanski]
The discussion of consolidation primarily focuses on Internet
services and data. However, it is important to draw attention to the
issues and risks of consolidation at other layers of the Internet
beyond just the application layer. The application layer is directly
user-facing and, as a result, is what users experience. But the
underlying infrastructure and protocols are also going through
consolidation as they develop. The complete end-to-end encryption
model forces data into endpoints which consolidates data into and
handful of companies. Furthermore, protocol standards are
facilitating this consolidation.
3. Background to Consolidation Issues and the Role of Standards
The Internet is being consolidated at all layers, from the
application layer to the network layer. In the context of search
online Google has 84% of all searches online.[Statista] But market
consolidation is not limited to the Internet. It happens when
economies of scale provide highly aggregated firms an advantage. For
the last three decades, we have witnessed concentration occurring not
only in telecommunications, but in the financial sector as well.
Concern is growing over the fact that financial institutions are only
using cloud services from a handful of cloud service
providers.[Bankingdive] The acceleration of consolidation has been
assisted by cloud technologies, such as occurred with email. Thanks
to ease of use enabled by cloud hosting, services like email and
online payments can be accessed via a web browser.
General purpose, more broadly capable platforms will increasingly
have an advantage. Specialized players must not only be better than
their general purpose competitors to survive, they must be
significantly better. One theoretical advantage of general-purpose
platforms is their streamlined user experience. For instance, users
do not need multiple logins or to navigate various user interfaces,
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reducing cognitive load. Given the current market's preference for
and emphasis on user experience, specialized players must prioritize
the user experience in their offerings. They may also need to form
partnerships to address some of their perceived weaknesses.
In other market consolidation cases, fewer Internet standards are in
play. In the case of home assistant tools such as the Amazon Echo or
Google Home Assistant, communication from these devices to their
respective clouds is largely proprietary in nature. In particular,
the information models and schemas they use are not exposed to the
outside world. This is because the bulk of the service is performed
by the cloud, with relatively little processing occurring in the
home. This two-sided model eliminates the lengthy standards
development process, thereby permitting faster service improvements.
On the Internet over previous decades, numerous Internet Service
Provider (ISP) markets were subject to deregulation, disaggregation
of customers by regulatory requirement, consolidation, and to some
extent, re-regulation.
In years past, standards have been viewed as a means to prevent
barriers to entry. During the 1980s, ATT was required to abide by
standards as part of the consent decree that resolved antitrust
litigation, leading to the ability of anyone to connect a telephone
to its network. By 1994 standards were recognized as a means to
prevent technical barriers to trade (TBT) during the Uruguay Round of
the World Trade Organization.
The QUIC protocol[RFC9000] is an example of the consolidation between
layers of the Internet - and not at the application layer. Designed
and deployed as a transport layer protocol, it effectively replaces
TCP at the network layer while also adding improved security. The
result is the merging or consolidation of three layers. QUIC should
improve efficiency and delivery of applications, but also forces all
data to be managed at the endpoint, which in this case is a browser,
making it more difficult to manage traffic at the network layer.
4. Overarching Issues Related to Consolidation
4.1. Essential Taxonomy of Internet Consolidation
Discussions at the IETF (and elsewhere) have shown that different
people have different views of how consolidation expresses itself.
While there is little argument that the increasing control of
Internet infrastructure and services is being coalesced into the
hands of a small number of organizations. However, that
consolidation expresses itself in a variety of ways.
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Another draft suggests a potential taxonomy of consolidation and
proposes four main categories: [McFadden]
* Economic consolidation
* Traffic and infrastructure consolidation
* Architectural consolidation
* Service and Application Consolidation
4.2. Technical
Consolidation has led to the development of a few, large Internet
companies which consumers are using by way of platform consolidation,
as mentioned above. But consolidation also has led to the
development of protocols which are developed and used by these few,
large Internet companies to control traffic flow and data capture as
well.
Overarching technical issues related to consolidation include an
over-reliance on one or two entities and a handful of protocols.
Certain stakeholders who have developed and implemented these
protocols manage the updated and upgraded versions of the protocols.
"Did the IETF create a better internet when it approved DoH?"
There's a lot of disagreement about that, but what has upset many is
that DoH was a surprise - the IETF standardised it without consulting
some who it was likely to affect," it says in RFC 8890 [RFC8890]
However, there was little multistakeholder consultation and
discussion prior to the adoption of DoH. This was more of a rapid
development and deployment process, without the market driving the
use cases and uptake. By forcing the concentration of the data at
the endpoint, the data is consolidated into the service provider at
that endpoint.
4.3. Economic
According to the Internet Society's 2019 report Consolidation In the
Internet Economy the Internet economy is broadly defined as,
"economic activities that either support the Internet or are
fundamentally dependent on the Internet's existence."[ISOC] Internet
applications, service infrastructure and access provision are the
primary three areas of economic activities on the Internet.
One focus of consolidation is around the concentration of power -
consumer, technical and financial - into a handful of large Internet
companies. The first point of engagement with any of these
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companies, including Facebook and Google, is through consumer
applications. The ability to easily understand consolidation at an
application layer, because of the widespread and common use of
Facebook and Google, has caused the focus of consolidation and anti-
competitive issues from policymakers and politicians to be at the
application layer.
However, consolidation doesn't always have its downsides.
Consolidation allows for economies of scale, investment in
infrastructure and the ability for small and medium enterprises to
buy and use services, like cloud storage, content distribution
networks and security technology, without having to build them from
the ground up every time. However, the lack of market diversity
means a lack of competition which, in turn means a lack of innovation
and a lack of consumer choice.
Amazon offers affordable cloud services and Cloudflare is one of only
a handful of companies that are content delivery networks at a large
scale. So large, in fact, that a substantial amount of Internet
traffic transits through Cloudflare's servers, though there are many
thousands of small CDNs. Rather than each and every Internet
application company create their own storage and content delivery
network, it is easier and more affordable to outsource both to other
companies. Because of the cost of CDNs at scale, few companies offer
these services.
Economic analysis of these dominant players often focuses on the
network effects they exploit. While this draft does not intend to
explore the broader question of what, precisely, a network effect
actually is, one definition could be the negative relationship
between product/service price and network/service delivery size.
There has been past research into finding evidence of network effects
in markets such as home computers, ATMs, and spreadsheet programs.
In these studies there is plausible evidence that network effects are
in play, however the problem is to determine whether a given change
in the relationship between price and the market is the result of
network effects or some other underlying economy of scale in the
particular market in question. In light of this, one researcher hass
said that "if future empirical work were to show that network effects
are merely theoretical concepts, then government antitrust
authorities should treat Internet-related markets like any other sort
of product market or distribution channel in determining the presence
(or lack) of viable competition."
Indeed, the same research led to the following conclusion: "even if a
case can be made that market power follows from network effects, it
may be difficult to identify how a firm's market dominance followed
from its conscious exploitation of existing network effects through
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some sort of "attempt at monopolization". Establishing this latter
condition will likely raise a host of other, relatively messy,
questions. For example, what constitutes predatory or exclusionary
conduct, and how should entry barriers be evaluated in a market
characterized by network effects?"
The market should be a primary regulating factor in consolidation.
New entrants and competition in a market creates options for
consumers that potentially pulls them away from popular websites and
applications. When a market is not competitive or viable, regulation
and anti-trust measures can intervene to remedy a consolidated market
which is tending towards or has achieved monopoly status. Legal and
regulatory intervention, however, tends to create its own set of
issues as seen through several decades of EU intervention in big tech
starting with Microsoft in 2004. Unintended consequences with
regulatory or legal intervention may skew the market even further.
Economics is driving protocol design in a couple of different ways.
First, participation in standardization is open and free, at least in
one sense and for the IETF. However, attending the IETF in person
requires a financial commitment - not just for registration, but the
travel, hotel and expenses are costly. The very organizations that
can afford to attend in person are the ones facilitating
consolidation.
4.4. Security
Consolidation of protocol development which has facilitated the
secure, end-to-end encryption of information going over networks in
recent years. New technologies such as DNS-over-HTTPS (DoH) and DNS-
over-TLS (DoT) standardised through the IETF process allow for
confidential look-up of DNS queries. However, it has required
updates to many DNS servers and operating systems. The
implementation of this protocol enables circumvention of DNS
filtering which ISPs offer for protection from malicious websites and
software on the network.
This is a form of market consolidation based on development choices
by several large companies. These development choices are often
technically opaque without transparency of what happens when updates
take place, resulting in more difficulty when trying to troubleshoot
security issues.
The development of these protocols, while providing increased privacy
and addressing issues concerning government surveillance, have for
another unintended consequences which is promoting consolidation.
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Consequences of the security of the global Internet are evident. On
June 8, 2021, a global outage of Fastly, a content delivery network
(CDN), was caused by a software update which included an undiscovered
bug. [Fastly] While this was resolved within a working day, one of
the main causes of the outage was a dependency on the limited number
of CDNs running services in the cloud. Other CDNs, which resolved
traffic via Fastly for redundancy, were also taken down as a result
of the Fastly outage. This dependency is caused by consolidation and
a concentration of infrastructure. A highly consolidated CDN network
facilitates a less secure environment because of the weakening of
resilience. [CircleID]
5. Centralization versus Consolidation
The words "centralization" and "consolidation" are often used
interchangeably when discussing the idea of concentration within the
internet. However, centralization and consolidation are, in fact,
different. Consolidation is an economic choice one that is driven by
economies of scale and efficiencies of work. Consolidation through
economic choices causes the outcome to be a centralized way of
building Internet architecture and, thus, a centralized market with
limited choices of technical and service options.
Another draft [Arrko2] carefully considers the distinction between
centralization and consolidation and concludes that decentralized
technology - by itself - does not guarantee decentralized outcomes.
That same draft describes consolidation as "the ability of a single
entity or a small group of them to exclusively observe, capture,
control, or extract rent from the operation or use of an Internet
function." That draft is careful to identify "Centralization" as the
source of consolidation.
6. Can Consolidation be Measured?
While it is possible to describe the effects of Internet
Consolidation, is it possible to measure them? Several researchers
have tried to establish metrics and then identify datasets that can
be used as the source for measurements.
6.1. Metrics for Specific Protocols in Relation to Consolidation
One approach is to concentrate on a specific protocol and then
identify metrics associated with that protocol. In research
published in 2022, one metric was the embedded page resources
measured by DNS A records in HTTP pages. The researchers then
identified datasets covering longitudinal measurements of DNS records
for 166.5 million Web domains over five years and measurements of DNS
records for Alexa Top 1 million over a month. In addition, source
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datasets of measurements of page loads and renders for 4.3 million
webpages, which include data on 392.3 million requested resources
were identified.
The researchers then define "CDI penetration" as the ratio of CDI-
hosted objects to all measured objects, which is a metric used to
quantify consolidation around CDIs.
In the period covered by the datasets, the researchers found that a
set of six CDIs delivered the majority of content across all
datasets, with these six CDIs being responsible for more than 80% of
all 221.9 million CDI-delivered resources (56.6% of all resources in
total).
The researchers noted both good and bad outcomes from this
measurement, pointing in particular to the ability of a small number
of CDIs to deploy new technologies like TLS 1.3 more quickly. In
summary, the researchers said, "Overall, these observations indicate
a potential oligopoly, which brings both benefits but also risks to
the future of the Web."
6.2. Metrics for Specific Services in Relation to Consolidation
Another research result is to merge three separate metrics in a
combined score to represent the level of consolidation on a country-
by-country basis.
The first of these metrics starts by labeling all nameservers a
website uses as private or third-party. This methodology begins by
issuing NS queries to all the nameservers the website uses without
resolving those names. Initially, the nameserver is categorized as
"unknown." Then, if the second-level domain is matched to the
website's domain, it is classified as "private." Finally, a set of
heuristics are used to examine cases where a website's domain differs
from the DNS server's domain. For example, the SOA record for
imdb.com is amazon.com, and its nameservers are Dynet and UltraDNS.
In these cases, the website is labelled as using two third-party DNS
providers.
In addition, the researchers also measured the percentage of websites
that are served by a single DNS provider (in other words, critically
dependent on that provider) or served by multiple third-party DNS
providers and the percentage of websites that are served by private
and third-party DNS providers.
The second of the three metrics used in this study uses a complicated
methodology of analyzing the CNAMEs of all internal resources used on
the website. This also allows the categorization of CDNs as
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"private" or "third-party." It is also possible to use the
methodology to study websites redundantly provisioned by multiple
CDNs. Once again, by analyzing the CNAME records of internal
resources for the website, it is possible to identify whether a
"private" CND is in use, or if one or more "third-party" CDNs are in
use.
The final metric relates to websites that support HTTPS. Using a
similar approach as above, the methodology identifies whether the
certificate authority in use is a "third-party" (for instance,
DigiCert) or a private CA (for instance, a CA run by the company
associated with the website).
By combining these metrics, it is possible to answer empirical
questions. The researchers posed three distinct questions:
* How common is the third-party dependency of websites around the
world?
* How much of this dependency is critical, dependent on a single
third-party DNS or CDN provider?
* How concentrated is the market of third-party service providers
within a country, region, and globally?
While this study is a snapshot in time (the research was published in
2023), what is undeniable is that you can identify metrics, study
those metrics over time, and then draw conclusions about trends in
consolidation in the market. Both studies also show that it is
possible to identify individual metrics associated with individual
protocols and assess the extent and rate of change for the
consolidation of individual protocols and technologies.
7. Implications of Consolidation on Internet Architecture
7.1. The Changing Architecture of the Internet
The phenomenon of consolidation may be in the eyes of the beholder.
A government may see market failure or a need for
regulation.[Economist] A civil society advocate may see it from the
point of view of privacy or free speech . For the purposes of this
draft we view it from the perspective of the underlying architecture
of the public Internet.
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Consolidation in the Internet's architecture is not a new
development. The approach of providing intermediaries to deliver
service or content rather than the more traditional end-to-end
approach has been in place for more than a decade. However, it is
possible to argue that the architecture of the Internet has changed
dramatically in the last decade.
The architecture of the Internet is always changing. New services,
applications and content mean that the market creates new ways to
deliver them. Consolidation clearly has economic, social and policy
issues, but it is important to understand how consolidation affects
the underlying architecture of the Internet. The impact of
intermediaries on architecture is often not obvious.
The use of intermediaries in the Internet's architecture may include
the use of third parties to provide services, applications or
content. In the early days of the Web, this was evident when
rendering a web page that included content from multiple sources. In
today's Internet the intermediaries are not so obvious.
Authentication servers, content distribution networks, certificate
authorities, malicious content protection and DNS resolution services
are all examples of tools provided to the Internet by intermediaries
- often without the knowledge or approval of both endpoints.
Having intermediaries embedded in the architecture is a different
effect from having them embedded in the service structure. The
domination by a few companies of the content and application layer is
largely an economic effect of scale. On the other hand, there is a
prevalent belief that the Internet puts intelligence at the edge.
While that may have been true in the past, it is hard to argue that
this is a feature of the contemporary Internet.
There is a suggestion that the network simply provides for the
transport of data. There are almost no network connections like that
in today's Internet. A consumer's view of the Internet is limited by
unseen intermediaries of many types - some delivering positive
services, others not. In either case, a consumer on the Internet
seldom makes choices about those intermediaries: they are simply part
of the fabric that makes up the Internet.
It is into just consolidation from the perspective of a consumer.
Almost all important parts of the architecture have been affected by
consolidation: DNS resolution, access service, transit provision,
content distribution and authorization. Consolidation in these areas
has a direct effect on engineering and protocol design.
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7.2. The End-to-End Principle Redux
The end-to-end principle is the idea that reliability and
trustworthiness reside at the end nodes of networks rather than in
the network itself. In other words, the idea was that the network
itself was dumb and intelligence was at the edge or end. However,
Internet architecture is evolving in such a way that this principle
is changing.
Networks and the devices on the networks are acting as access
consolidators. While, in the past, the network was a simple
transporter of bits, today's networks see intermediaries
consolidating both access and the delivery of information (e.g.
streaming media). For example, 5G will allow for different services,
systems and use cases at a very specific level. Network slicing in
5G will concentrate services like video on demand into concentrated -
and consolidation - areas on a network. In other words, as specific
types of services are relegated to a segregated part of a network,
the availability and access of that service is limited to accessing a
specific network. Depending on the type of device or maturity of the
network infrastructure available at the point of the attempted
access, options for access might be limited. If a network slice on
5G is where a specific service is located, for example, but it is
only possible to use a 3G mobile network, then the service is
unavailable. Thus, the service is only available on a consolidated
part of the mobile network. Another change is how the layers of the
Internet, as discussed in the QUIC example, are consolidating.
Differentiation among layers is fading fast with the development of
applications which require network access and control.
Rapidly, the end-to-end principle is becoming the edge-to-edge
principle. The layers of the internet are morphing into several
consolidated layers and it is becoming difficult to differentiate
between the end or edge, and also nearly impossible to ensure the
reliability of the internet because of it. But the important part of
this is the network is not dumb. Data processing, storage and highly
evolved services (including custom data and metadata processing at
the edge) means that the 'dumb' network is no longer dumb.
If the number of organizations that provide those "network services"
that we rely upon is small, our dependence is higher. In extreme
cases of engineering, we put ourselves at risk of engineering a
single point of failure. But also if organisations can't and won't
enter the market, the market is left with very few options and
choices.
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The trend toward highly specific and concentrated processing, as well
as the drive for highly customised applications and services will
drive the Internet away from an end-to-end principle. This will
create not a network of networks, but a mesh. If the mesh is
dependent on a small number of very large providers through
consolidation, we will have engineered a single source of failure
into the Internet.
8. Intermediaries and Consolidation
Internet privacy concerns have encouraged protocol designers to take
a more aggressive approach to ensuring privacy in communications. In
the past, a secure channel using technologies such as TLS or IPsec
provided a way to ensure that point-to-point communications was
protected while information was in transit. Providing privacy (and
authentication of the data stream) occurred between the endpoints of
communication.
However, it became widely recognized that this was insufficient. In
particular, a secure channel between two endpoints does not guarantee
that the information will remain private at the endpoints. As the
importance of privacy increased, so too did the attempt to fashion
protocols that increased the protection of the data a the endpoints.
A draft from the IAB describes the technique for separating the data
and metadata visible to diverse parties in network communication as
"privacy partitioning."[IABPartitioning] It notes that a group of
IETF working groups are using this intermediary strategy as a
protocol-based, technical approach to improving privacy at the ends
of network connections. The working groups involved include OHAI,
MASQUE, Privacy Pass and PPM. All four have in common a general
strategy of using an intermediary to provide a higher level of
privacy for endpoints.
The use of intermediaries is nothing new: we have had HTTP proxy
services in the Internet almost since the advent of the Web. What has
changed is the dominance of privacy preservation in protocol design.
The intermediaries that provide the privacy partitions are in a
special and notable place in a network connection. The former end-
to-end principle drops away and in its place are two connections: one
between an end user and the intermediary and the other between the
intermediary and the requested service or application.
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The risk of consolidation to the is approach would mean that a
dominant set of large companies provide the intermediary services.
That would lead to the possibility of collusion with the consequence
that no privacy was actually provided. A centralized service
providing the "privacy partitioning" could log requests and share
information about patterns of use or actual, specific user
information.
The result is that "privacy partitioning" needs to be considered as
part of the consolidation landscape. The result of having a very
small number of dominant providers acting as the intermediaries would
lead to some of the same risks as economic or traffic consolidation
already exhibit.
9. Implications of Consolidation on Protocol Design
9.1. Does Protocol Design Really Affect Consolidation?
As noted in "Internet of Three Protocols" draft, "One of the guiding
principles of designing a protocol in the original Internet community
was "the protocol is not complete when everything possible has been
added, but rather when everything possible has been removed." This
is so that security, scalability, resilience and observability can be
ensured. However, the recent trend has been towards having a few
protocols, but having those protocols do all things.
Though Internet protocol development should be multistakeholder, but
standards development is subject to vested interests, personal
approaches and commercial realities.[IABProDevWkSshp] Developing
protocols, and standards more generally, takes time, much discussion
and a bottom-up approach. However, commercial organizations have
different goals in the process of trying to standardize protocols.
Larger organizations have more resources dedicated to protocol and
standards development. Larger organizations with staff specifically
dedicated to standards tend to have the ability to push for their
proposals and their protocols. There is no coincidence that these
companies are the ones that have facilitated consolidation on a
commercial level and are facilitating consolidation on a protocol
level.
There is clear evidence that concentration in the marketplace
redistributes risk. In fact concentration can change who is the
target of attacks or malware. Large operating systems, platforms,
protocols and organizations often act as magnets for malicious
activity. In addition, some organizations attempt to reduce their
risk by transferring their security requirements to larger
organizations (for instance, CDNs or cloud service providers).
However, that transfer can lead to the redistribution of the attacks:
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for instance, a smaller organization that was once "under the radar"
is now subject to all the attacks on the larger infrastructure
provider. This is an example of the fact that when major providers
of infrastructure fall victim to attacks, the impact can be far more
significant than when the systems are highly distributed.
9.2. Case Studies in Consolidation and Protocol Design
9.2.1. DNS over HTTPS (DoH)
The development of encrypted DNS, specifically DNS-over-HTTPS (DoH),
has been driven by a desire to show full end-to-end encryption of
network connections. The protocol was completed and the DoH working
group wound up in March 2020 despite the absence of both resolver
discovery and selection mechanisms. This may be addressed in the
future.[RFC8484]
Client software is developing with interim discovery solutions which
almost always favour the large, cloud-based resolver operators. This
is leading to a situation where users are being presented with a very
small number of pre-configured resolver options irrespective of their
location - in some client software as few as three or four options
may be presented. [Arrko2] Currently, there are many thousands of
servers operating without DoH.
It is likely that most of the DNS traffic will be consolidated onto a
handful of global operators, if multiple options for discovery
mechanisms are not developed. The impact that such a loss of
diversity of providers may have on the long-term resilience of DNS
should not be underestimated. [Bates] Nor should the attractiveness
of these potential network chokepoints to attack be overlooked either
to access consolidated data or launch an attack from. One danger is
that if DNS traffic is concentrated onto a small handful of global
operators and turned 'automatically-on' the result would be default
adoption by the vast majority of the Internet's clients. The
suggestion that there were mechanisms for users to opt-out would not
matter in the face of statistics that regularly show that users
almost never change default settings. Currently, the deployment
approach for DoH is opt-in. For CDNs, DoH default-on would disrupt
and render CDN geolocation designed to manage traffic flows more
efficient closer to the desired delivery location. Thus, protocol
design decisions that are enshrined in default settings will become
the norm. In this case, default on, which facilitates consolidation,
will become standard.
By routing the DNS over HTTPS, it becomes much easier to track user
activity through the use of cookies. Therefore, a protocol that was
developed to enhance user privacy and security could actually
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undermine both: privacy through the use of cookies and security by
consolidating DNS traffic onto far fewer resolver operators that are
far more attractive targets for malicious actors of various types.
9.2.2. Encrypted Server Name Indication (eSNI)
Options to encrypt the Server Name Indication (SNI) have been
explored in the TLS working group but to date it has not been
possible to develop a solution without shortcomings. This flaw in
the encrypted SNI (eSNI) options under evaluation required a rethink
in the approach being taken.
The solution now proposed, Encrypted Client Hello (ECH, previously
called ECHO) assumes that private origins will co-locate with or hide
behind a provider (CDN, application server etc.) which can protect
SNIs for all of the domains that it hosts.[ECH] Whilst there is logic
in this approach, the consequence is that the would-be standard
encourages further consolidation of data to aid privacy. What it
does not appear to consider is the attractiveness of this larger data
pool to an attacker, compared with more dispersed solutions.
9.2.3. Oblivious HTTP
Oblivious HTTP (OHTTP)[OHTTP] is a relay based intermediary system
that attempts to provide an extra layer of privacy by incorporating
per-message encryption in the relay exchange. A client sends a
request to an Oblivious Relay which is not allowed to read its
contents. The request is forwarded to an Oblivious Gateway which is
able to decrypt the messages but does not know the identity of the
client or any metadata (for instance, source IP address) related to
the client.
The key to OHTTP's privacy features is that the client metadata and
request data are separated into separate contexts: the goal is that
no entity (other than the client) can see both contexts.
The major risk in OHTTP is collusion across those contexts. If a
small number of providers of the OHTTP services dominated, the risks
of collusion might be expanded - specifically, protections against
collusion and the exposure of user identifying information would be
greater in a marketplace without a variety of servers to provide the
service.
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10. Potential Technical Risks
There are a number of potential risks to the security, stability and
performance of the Internet and many of them are well articulated in
draft-livingood-doh-implementation-risks-issues-04 [Arrko3], but some
notable ones are:
1. Significant operational shift of the global Internet from a
highly distributed to a centralised system. This would impact
both security and resilience.
2. Decreased stability due to the fact that a centralised system
will have higher fragility, fewer points of failure and greater
impact on the system when it does fail.
3. Increased security issues caused by the reduction of number of
recursive DNS operators. [see https://hbswk.hbs.edu/item/
evidence-of-decreasing-internet-entropy-the-lack-of-redundancy-
in-dns-resolution-by-major-websites-and-services][Bates] Lack of
distributed and recursive DNS creates a lack of redundancy for
when security attacks hit parts of the Internet.
4. Loss of security threat visibility due to degraded ability to use
DNS blocklists and overall network management for malware,
phishing, spam, DDoS and etc if DNS management is consolidated
into a few operators.
5. Reduced diversity in the Internet ecosystem. Diversity creates
greater redundancy, resilience and agility to respond to attacks,
outages and network issues.
11. IANA Considerations
This memo includes no request to IANA.
12. Security Considerations
While this document does not describe a specific protocol, it does
discuss the evolving architecture of the Internet. Changes to the
Internet's architecture have direct and indirect implications for the
Internet's threat model.
Specifically, the changes to the end-to-end model (see section 4.2
above) have inserted new interfaces which must be reflected in
security considerations for new protocols.
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13. Conclusions
This document seeks to rekindle and restart the discussion on
consolidation. As argued above, Internet consolidation is happening
at different places and different layers of the Internet. Though
there has been interest in the Internet consolidation in the past,
now is the time to start the discussions again.
14. References
14.1. Informative References
[Arrko1] Arrko, J., "Considerations on Internet Consolidation and
the Internet Architecture [draft-arkko-iab-internet-
consolidation-02] (Expired)", 2019.
[Arrko2] Arrko, J., "Centralised Architecture in Internet
Infrastructure [draft-arkko-arch-infrastructure-
centralisation-00] (Exxpired)", 2020.
[Arrko3] Livingood, J., "Centralized DNS over HTTPS (DoH)
Implementation Issues and Risks,
[https://datatracker.ietf.org/doc/draft-livingood-doh-
implementation-risks-issues/] (Expired)", 2020.
[Bankingdive]
Industry Dive, Informa, "Cloud providers pose potential
risk to banking sector: Treasury report", 2023,
.
[Bates] Bates, S., Bowers, J., Greenstein, S., Weinstock, J., and
J. Zittrain, "Evidence of Decreasing Internet Entropy: The
Lack of Redundancy in DNS Resolution by Major Websites and
Services [https://hbswk.hbs.edu/item/evidence-of-
decreasing-internet-entropy-the-lack-of-redundancy-in-dns-
resolution-by-major-websites-and-services]", 2018.
[CircleID] CircleID, "The Deeper Root Cause of the Fastly and Akamai
Outages", 2021, .
[ECH] Rescorla, E., Oku, K., Sullivan, N., and C. Wood, "TLS
Encrypted Client Hello
[https://datatracker.ietf.org/doc/draft-ietf-tls-esni/]",
2023.
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[Economist]
The Economist, "Google, antitrust and how to best regulate
big tech", 2020,
.
[Fastly] Fastly Blog, "Target of the June 8th Outage", 2021,
.
[Huston] Huston, G., "Centrality and the Internet
[https://www.potaroo.net/ispcol/2021-06/centrality.html]",
2021.
[IABPartitioning]
Internet Architecture Board, "Partitioning as an
Architecture for Privacy", 2023,
.
[IABProDevWkSshp]
Internet Architecture Board, "Design Expectations vs.
Deployment Reality in Protocol Development Workshop",
2019, .
[ISOC] The Internet Society, "Consolidation In the Internet
Economy", 2019, .
[Lazanski] D. Lazanski, Journal of Cyber Policy, "Governance in
international technical standards-making: a tripartite
model, Journal of Cyber Policy", 2019,
.
[Litmus] Litmus Software, Inc., "Email Market Share", 2022,
.
[McFadden] McFadden, M., "A Taxonomy of Internet Consolidation
[https://datatracker.ietf.org/doc/draft-mcfadden-
consolidation-taxonomy/]", 2024.
[OHTTP] Thomson, M. and C. Wood, "Oblivious HTTP
[https://www.ietf.org/archive/id/draft-thomson-http-
oblivious-01.html]", 2023.
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[RFC8484] Hoffman, P. and P. McManus, "DNS Queries over HTTPS
(DoH)", RFC 8484, DOI 10.17487/RFC8484, October 2018,
.
[RFC8890] Nottingham, M., "The Internet is for End Users", RFC 8990,
DOI 10.17487/RFC8990, August 2020,
.
[RFC9000] Iyengar, L. and M. Thomson, "QUIC: A UDP-Based Multiplexed
and Secure Transport", RFC 9000, DOI 10.17487/RFC9000, May
2021, .
[RFC9518] Nottingham, M., "Internet Centralization: What Can
Standards Do? [RFC9518]", 2023.
[Statista] Statista, "Search Engine Market Share Market Share", 2022,
.
[Techcrunch]
TechCrunch, "Cloudflare DNS goes down taking a large piece
of the Internet with it", 2020,
.
[W3Counter]
Awio Web Services LLC, "Browser and Platform Market Share
January 2021", 2021,
.
[Zembruzski]
Zembruzski, L., Sommese, R., Granville, L.Z., Selle
Jacobs, A., and M. Jonker, "Hosting Industry
Centralization and Consolidation
[https://ieeexplore.ieee.org/abstract/document/9789881/]",
2021.
Acknowledgements
Many thanks to all who discussed this with us, especially Jason
Livingood, Geoff Huston and Jari Arkko.
Many thanks to all who discussed this with us in DINRG in 2021, 2022,
2023, and 2024.
Authors' Addresses
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Mark McFadden (editor)
internet policy advisors, ltd
6 Bridge Street
Chepstow
NP16 5EY
United Kingdom
Phone: +1 608 504 7776
Email: mark@internetpolicyadvisors.com
Dominique Lazanski
Last Press Label
London
United Kingdom
Email: dml@lastpresslabel.com
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