Tuesday, June 2, 2015

Competition Issues in Credit Card, Debit Card Swipe Machines in India: Atos Worldline India Private Ltd v. Verifone India



Atos Worldline India Private Ltd v. Verifone India
Parties
1. Atos Worldline India Private Limited
Atos Worldline India Private Ltd provides end-to-end services for electronic transactions in India. It focuses on electronic payment services for banks, merchants, and government institutions. The company offers acquiring managed services including merchant signup and activation; point-of-sale (PoS) terminal procurement, supply, and installation; and merchant training. Additionally, it provides credit, debit, and prepaid cards application, issuance, and transaction processing; currency conversion, fraud and risk management, and Internet and mobile payment services. The company caters to banking, financial services, energy, utilities, retail, hospitality, transport, and healthcare sectors.
VeriFone India
2. VeriFone India is subsidiary of Verifone US. VeriFone is an American multinational corporation headquartered in San Jose, California that provides technology for electronic payment transactions and value-added services at the point-of-sale. VeriFone sells merchant-operated, consumer-facing and self-service payment systems to the financial, retail, hospitality, petroleum, government and healthcare industries. The company’s system solutions consist of POS electronic payment devices that run its own operating systems, security and encryption software, and certified payment software, and that are designed for both consumer-facing and unattended environments.
POS Machine
A point of sale (POS) terminal is credit card or debit card swipe machine. A merchant can use to perform transactions with a bank card.
Software Development Kits (SDKs) are used to enable the basic functionality of the POS Terminals.
For the provision of VAS, it is extremely important for the Atos Worldline to have access to the core POS Terminal applications and their crucial enhancements/updates along with SDKs.
Withholding of such enhancements/updates and SDKs by the POS Terminal manufacturers will negatively impact the growth of the TPP and VAS markets.
As per standard industry practice, core POS Terminal applications and SDKs are provided along with the POS Terminals and the costs of the same are built into the price paid for the POS Terminals.
Between September, 2010 and December 2011, the Verifone India continued to provide SDKs to the Atos Worldline along with the POS Terminals and core terminal applications without any restrictions on the use of SDKs.
The Verifone India also used to provide training to the Informants engineers to enable the Atos Worldline to render VAS to its customers.
Atos Worldline in September, 2010 alleging breach of Source Code License Agreement (SCLA) which was signed between them in July, 2009 for a particular model of a POS Terminal.
As per the Informant, despite issue of the said termination letter, the Verifone India continued to supply POS Terminals along with its core applications, SDKs and training to its engineers for the use of SDKs.
In January 2012, the Verifone India sent a proposed draft SDK agreement to the Atos Worldline stating that the same is not open to any negotiations, amendments or changes and that the Atos Worldline has to insert certain details in the said draft SDK agreement and to counter-sign it.

Citing Reserve Bank of India’s Payment System Vision Document, 2012-15, the Atos Worldline stated that in the POS Terminal manufacturing industry in India, Verifone and Ingenico are the two prominent players.

By virtue of being almost an exclusive supplier of POS Terminals in India, the Verifone India exercises significant control over the supply of hardware and software solutions.

The Atos Worldline has also stated that there appears to be no objective justification for imposing unreasonable and unfair terms in the draft SDK agreement.

These terms would effectively eliminate the Atos Worldline from the downstream market and would support the Verifone Indias interests by eliminating competition in the market.

The Atos Worldline has alleged that Verifone India, by imposing restrictions in the draft SDK agreement, is aiming to strengthen its position in the VAS market.

Relevant Market
The market for POS Terminals as the relevant product market.
DG has found that the clauses of the SDK license agreements are unfair. The DG noted that the Purpose Clause under which the licensee can develop VAS and use the same only on the licensors products and the restrictive clauses prohibiting TPP to assist or develop the applications were found to be in violation of section 4(2)(a)(i), 4(2)(b)(i), 4(2)(b)(ii) and 4(2)(e) of the Act.
Alternative Technologies
MPOS such as Ezetap and Mswipe achieve the same end result

CCI is of the view that DG has segregated the upstream market for POS Terminals which also includes core applications such as Kernel, Operating System, Source Code and SDK and the downstream market like TPP (terminal management services), VAS (application development services) and after sales services (repairs and maintenance), etc.
The Commission is of the same view as that of the DG in this regard that upstream market for POS Terminals as stated above is different from the downstream market of VAS and after sales services. It is so because POS Terminals require services such as terminal management, application development, repairs and maintenance, etc.
CCI found Verifone dominant abusing its dominance in the relevant market.

Having regard to the above, the Commission decides to impose a penalty on the Verifone India at the rate of 5% of its turnover based on the financial statements filed by the Verifone India.

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