If I could just add a word of explanation on the positive support, just to set the context. It seems to me that quite your remit is quite rightly focused on the areas we've discussed so far. More generally though, if we are interested in news plurality, it is ...

But here there may be some levers that can be pulled. For instance, the Internet service providers would be one way of getting at whether these organisations have wide access to consumers or not. You can look at the extent to which UK advertisers can advertise on compliant or non-compliant ...

Really, this would be the threat of more draconian regulation. And I don't for a moment suggest that we would want to go down this route, but other countries do find ways of controlling the activities of big international search engines and other digital companies --

I can think of a number of sticks as opposed to carrots, which would be --

I think that's absolutely right. I think the second line of attack, if you like, is then probably not at UK level but on an EU basis, rather along the lines of the Audiovisual Media Services Directive or the E-commerce Directive, because these are organisations which operate across the ...

I think that is absolutely right and indeed, it's one of the factors behind my suggestion that in the first instance, we, in effect, try and bring them into the fold, wherever they may be located. I think Google and Facebook have registered in Ireland, I believe, and as ...

It's a very good question and I think I would like to step back from that, if you don't mind, to say that first of all, in my Reuters paper, I suggest that we shouldn't leap to this sort of regulation in any event, because although it ...

Yes. The issue is that new digital intermediaries like Google, a powerful search engine, Facebook as a social network, Apple as a mechanism for getting newspaper apps, all place themselves between the news provider and the consumer. So one concern would be if any one of those, or perhaps a ...

No, indeed, and the behavioural interventions may be undertakings in lieu, so there's some crossover between the two. The only other set of interventions, as I come onto later, are those which apply specifically to digital gateways -- so access interventions -- and then, of course, public support, which is another ...

Yes, and I think from the point of view of a situation in which we have organic growth, then perhaps this behavioural remedy list is likely to be more useful or more valuable than telling people to shut down or sell off a newspaper or close down a television channel ...

Absolutely. Let me just be clear in case I've created the wrong impression. I wouldn't rule out those, as you describe them, draconian measures of divestment, spin-off. They should still be kept in the toolkit. The point I'm trying to make is we should need to make ...

I've lost it on my screen so I'll read it on my notes. This is about requiring the content investment commitments. In practice, there are precedents in place, as I mentioned earlier, in broadcasting in the UK. In other counties -- for instance I think in the US, where ...

And, I suppose, strengthened the wall a bit.

I absolutely agree and I guess what makes me veer towards the Ofcom/other regulator solution is that this is then strength in numbers, in process, in the institutional framework for that regulator, whether it be Ofcom or not, which may be better placed to withstand the sort of pressures ...

And some commentators have noted the risks, too, which I think I should acknowledge, which are that the regulator could become the subject of a huge amount of expensive lobbying and influence from powerful media companies if it had this sort of responsibility.

There isn't accountability in the sense that you can vote Ofcom out, I know, and that, for many, is the big issue. The accountability, I think, has to be built in, as I suggest, in the way in which Parliament sets out the approach that Ofcom can take and ...

Well, I guess so. I do recall, though, from my time at Ofcom that it's quite difficult to have your own agenda when there are some very clear processes in place for carrying out duties and responsibilities, and in a way, personally, I would have more confidence that a ...

That's correct; whether it's the Enterprise Act or the Communications Act or one of the two. It was designed to try and address the concern that quite clearly exists about political involvement at a detailed level on a case-by-case basis, which at least leads to the perception of ...

Mm. So what I was -- trying to square that circle, I was suggesting that there is an important role for political discretion and decision-taking that could be accommodated at the start of the process in any new legislation in setting out the parameters which Ofcom should apply, but then the ...

Sure.

Sure. So the first step is to get the metrics in place, but then -- I absolutely agree that you have to take a view based on accumulated expertise of the extent to which these different types of online news providers do have an impact on plurality of supply. So, for ...

Not -- well, the objective part is measuring the consumption --

Yes. The recommendation is that new online news providers should be part of a consideration of news plurality in the UK. They do quite clearly provide alternative sources of news and debate. The interesting and difficult question is working out how important they actually are, because they do cover all ...

Yes. That's a very good way of putting it. I think then you can have a debate about what those factors should be, how specific they could be, given the background of uncertainty which we've discussed, but I think that would go some way towards providing a degree ...

I think that is correct, but I think we have to think about how a regulator is going to be able to work effectively against that sort of background. I mean, thinking back to my experience at Ofcom and the work I used to do there, it was always very ...

Yes. Consumption is a very good starting point and I agree absolutely with what Ofcom says there in terms of the need to look at share of consumption, the reach of news media and the multiple sourcing. I think, though, the problem we have with all of these metrics is ...

I didn't hear their evidence this morning, but I have read the paper which Ofcom prepared and I would say that is a fair assessment.

It may be worth just saying what lies behind that, because this is all about, it seems to me, whether you can have a ...

Yes. I think there are trade-offs to be made here. It becomes harder with organic growth, I think, than with the case of mergers and acquisitions. With organic growth, I guess -- let's imagine we're talking about a world in which it has been suggested or that has -- a ...

No.

I think it would be intuitively.

I think it does, and you're correct to point that out. The linkage, I guess, would be that -- and this may be a point I make only in my main Reuters report, rather than in my witness statement, but the linkage may be this: that the larger and more ...

Yes, exactly so. That may well be the case.

That might be --

I guess one can envisage an outcome in which the plurality rules have -- formulated have managed to secure, say, half a dozen different news suppliers in the market, but then there is no particular guarantee that those news suppliers will provide a range and diversity of news. They'll be ...

Absolutely. I think, as I was saying, it seems to me the minimum step as far as these digital intermediaries is concerned is to make sure that Ofcom has the ability to include them in a market review of plurality and to properly assess both their positive and potentially negative ...

Yes.

I would, because it seems to me that at the very least, if Ofcom is asked, as it has, I think, proposed -- if it is asked to carry out a periodic review of plurality in the news market in the UK, then the influence of these digital intermediaries, how they ...

Well, they could be. It's one of the things which I talk about in the report which I've written for the Reuters Institute. As you say, there are different categories of digital intermediary which I've tried to identify, they're not all the same and they have ...

Mm.

Absolutely. I was going on to say that it's not clear to me that that is any worse than the position we had in the past, although you could argue that even the partisan newspapers did tend to include a sort of range of different commentators and views which ...

Yes. This, I suppose, is the counter to the benefits which I've just talked about of sharing and creating news, that for various reasons digital media has been accused of limiting the range of news and views which people over time have access to, the reason being because if ...

Yes, I think it is encouraging and Ofcom are right to start to include this when they think about plurality, because clearly if you have a world in which large numbers of people consume half a dozen sources of news that's different from one where we relied on one ...

I don't think I have a huge amount more to say that I have in my witness statement. The point is that although we tend to think of the important aspects of news as being focused around original journalism, investigative reporting and possibly high-cost correspondents around the world, in ...

I wouldn't like to go that far, no. I think this is one of the big issues that we really don't know the answer to are.

What I would say, though, is that I don't think we should assume that the game is up for established news ...

I'm sure that's part of the reason. I'm also sure it's because -- also part of the reason is that none of this looks particularly economically attractive to new entrants, so the business models don't add up. So we've identified one of the causes of ...

I don't think I know the answer to that. I think the point that I was trying to make is that given those uncertainties, we have to be very careful in introducing regulation which makes it even tougher for the newspapers to make a living, and as -- I go ...

Yes, and certainly the newspapers which have found it easiest to start to monetise their product are those which have something of special or unique value which their target audience is prepared to pay for. It's harder for general interest newspapers to persuade consumers that it's worth paying ...

I think that's been one of the big problems, that in the rush to get involved with the early stages of digital media, newspapers took the view that it was important to get readers rather than income. I think now those strategies are starting to change and the uncertainty ...

So far some progress is being made. The prospects offered by the new newspaper apps for smartphones and tablets offer greater prospect of future revenue, but you're quite correct; at the moment, I don't think any newspaper firm really knows whether if they're going to be able ...

Yes. To an extent, that is linked to the previous bullet points and the different trends which you can observe in the market. What's happening to the providers of packages of news, the established media brands, is that they are facing more competition, they are, to an extent, losing ...