Topic - COMPARATIVE STUDY OF ORGANIZED AND UNORGANIZED TAXI

BUSINESS IN UK. STUDY THE CHALLENGES FACED BY UNORGANIZED TAXI

BUSINESS AND DEVELOP A TECHNOLOGY STRATEGY FOR UNORGANIZED
BUSINESS IN UK TO ENSURE LONG TERM MARKET SUSTAINABILITY
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Improvement of information technologies as a factor of competitiveness of firms
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News
Shared Economy: Modality creates new opportunities and ... many controversies,
such as Uber
2
Carolina Cunha
Skein of Communication
14/08 / 201518h36
Print Report error
Niyi Fote / Futura Press / Estado Content
30.jun.2015 - Hundreds of taxi drivers protest in Rio de Janeiro against the mobile
app Uber, which offers rides paid in registered cars. Taxi drivers traveled several city
neighborhoods and concentrated in Flamengo Park, in the southern part of the
capital Rio de Janeiro
30.jun.2015 - Hundreds of taxi drivers protest in Rio de Janeiro against the mobile
app Uber, which offers rides paid in registered cars. Taxi drivers traveled several city
neighborhoods and concentrated in Flamengo Park, in the southern part of the
capital Rio de Janeiro
Have you thought about renting the empty room of your home to a tourist? Have
lunch in the house of a stranger who cook for you or share an office for a few hours
with other people? Or share a shuttle service?
Services such as the controversial Uber, which can connect several passengers to a
particular driver, CouchSurfing, hosting people in homes, or Airbnb, an application
that allows people renting your own home to tourists, are part of the shared
economy, also known as economy collaborative.

This is a new way of consuming and a new economic model with business linked to
the practice of sharing. The consumer does not acquire ownership of the goods, but
their access. This is because the idea is to share, rent or share the use of products
and services with others.
From this model, individuals can have direct relations of purchase and sale of any
type of demand. One consequence is the decentralization of the flow between
customers and businesses, avoiding the role of intermediaries and approaching
customers and suppliers.
The main engine of this economy is the digital technology. Created in 1990, the first
online platform selling products over the Internet began to open the path to the
shared economy, such as eBay, which sells used products, and Craiglists, ranked
page.
technology drives
Currently, most of the shared services are offered by websites and smartphone apps.
The platform is an intermediate operation between a user and the supplier and earn
a percentage of the business. And with the internet, collaboration can happen on a
global scale.
The advantages for the consumer are many. He can spend a little for something that
would only use for a short time and with less bureaucratic access. It can also reduce
the environmental impact and have a closer relationship with the person who is
sharing. But there is an important question: how to trust the person providing a
service?
Two common points on sharing sites are trust and reputation, considered as "new
currency" in this universe. In virtual platforms, service providers users are evaluated
for each other; the receiving good reviews can make more connections, more profit
and tend to boost the quality of services.
The forecast is that the shared economy move billions in the coming years. Today,
for example, the market value of the Airbnb platform is estimated at US $ 13 billion.
The multinational consultancy PricewaterhouseCoopers predicts that the industry
move in 2025, worldwide, something around $ 335 billion. According to a survey by
consultancy Nielsen, in 2013, 70% of people in Latin America would be willing to
participate in sharing services, compared with 52% in North America.
The application of this business model is infinite. In the United States and Europe
there is already crowdbanking, smartphone application where people lend money to
others at a rate equivalent to half of the charged by banks.
Brazil also has start-ups working in the collaborative model. One example is the It
Bag, which connects people interested in products from overseas travelers who
make available to bring them in exchange for a reward. Already the site
descolaai.com invites people to "exchange, buy, sell, teach and learn" with friends
and communities.

When proposing new dynamics of business, companies shared economy bother

traditional sectors and the formal economy, therefore, to offer reduced costs and less
bureaucracy, this business model can impact consumer demand for the old
companies.
The hotel industry is an example of significant impact. In New York are already 1
million accommodation available on Airbnb. In Rio de Janeiro, Airbnb now has about
80,000 beds, equivalent to almost the same capacity as the traditional hotel chain.
In Rio de Janeiro, the Brazilian Association of Hotels (ABIH) tries to convince the city
that the service can harm the city, as it does not have collection of ISS (Service Tax).
The biggest controversy on the subject in Brazil involves Uber, technology platform
that connects passengers to private drivers who charge to make races. Users say
the service is cheaper and offers more comfort than traditional taxis.
Uber made news
Uber is present in 58 countries and arrived in Brazil in 2014. Fearing competition
with the application, taxi drivers from different cities like So Paulo (SP), Rio de
Janeiro (RJ) and Belo Horizonte (MG) began to protest its use.
In August the situation became a police matter. In So Paulo, a driver's Uber was
kidnapped and beaten by a group of taxi drivers. In Brasilia, taxi drivers attacked
luxury cars that were mistaken for Uber vehicles.
Taxi drivers argue that the app acts erratically and argue that private passenger
transport can only be done by taxis, and claim that the company that owns the
application does not pay taxes mandatory and taxi drivers.
The Brazilian government considers the Uber as an illegal service. The law provides
that the passenger paid should be done only with the permission of the Government.
The Uber dribbled the problem connecting passengers only with professional drivers,
who have their own car or regulated working for transport companies. The
Department of Public Transport (DPT) of the Municipal Transport Secretariat (SMT)
of So Paulo believes that the application falls into an underground taxi service.
A solution to the conflict would be the approval of service by local governments. In
many cities in the world the platform is already accepted. In August, London
recognized the legality of the service.
In Brasilia, the Federal District governor, Rodrigo Rollemberg vetoed a bill approved
by the Legislature wanted to prohibit the company to act in the federal capital.
However, the veto not regularized the application. Until there is a regulation of
services, only drivers authorized by the state to carry out transport of persons may
work legally.
Laws and taxes: still a problem

One of the biggest criticisms companies shared economy is that they provide unfair
competition to traditional businesses for not paying the same taxes.
Besides the lack of tax collection, the state fears that in the future, services like Uber
may impact the labor market and bring unemployment to various categories.
sharing services do not have employment contracts of contract and are not covered
in regulations of labor legislation.
Another issue is lack of resources to protect the buying and selling ratio in the
Consumer Protection Code, which does not regulate activities of individuals.
Defective products, false information and lack of agreement can be some of the
risks. Airbnb, for example, received ratings of some users who reported abuse by
locatrios.
This lack of regulation can contribute to unequal relationships between customer and
supplier or leave the most vulnerable workers and low-income, resulting in the
precariousness of service.
With the growth in the supply of these services, the trend is that there are new types
of regulation that traditional business and shared can live with. But the fact is that
this new economy is here to stay and this model should be increasingly common.
BIBLIOGRAPHY
What's mine is yours - How Collaborative Consumption Will Change Our World,
Rachel Botsman and Roo Rogers (Bookman, 2011)
9999999999999999999999999999999

5. Disruptive Technological Innovations in AVP Service

36. Technological innovations have changed the existing business models.
Economist and American professor Jeremy Rifkin says that the world economy will
be hybrid in the second half of the XXI century. Rifkin predicts that a collaborative
system will be living with an increasingly less aggressive capitalism. To establish his
thesis, Rifkin points out that the three areas - communication, energy and transport on which to support the development models, will be interconnected through the
Internet and it promotes the emergence of a
colaborativa27 economy. Abramovay (2014) 28 points out that the key is not in
power, on the Internet or network notion, but at the junction of the three: not only
energy, but part of growing prosperity of the twenty-first century will come from a
social organization marked by decentralization, for cooperation and sharing.
37. The idea of cooperation comes the concept of collaborative economy, defined as
an economic system of decentralized networks that unlock the value of underutilized
assets, combining certain people have to the needs of others without the use of
intermediaries (botsman, 2014 ) 29. Collaborative economy relies on direct

cooperation ties between individuals - hence the expression in English peer to peer and the use of the idle capacity of certain goods through sharing.
38. On the other hand, the Internet has fast access to a global customer base with
low additional cost of achieving and include new customers, generating new
business by means of "disruptive innovation" 30. According to OECD (2015th) 31,
disruptive innovation can be new products or services; in other cases, innovation can
involve new forms of supply of existing products and services to consumers or new
business models, meeting the needs of consumers unmet or underserved by existing
services.

Regulatory
39. From a regulatory point of view, disruptive innovations can give rise to legitimate
public policy concerns, such as security and privacy issues, and thus create demand
for regulation. In most cases, however, the established providers (incumbents) lobby
for the existing regulations be applied to new providers, in order to reduce the
competitive advantage of the latter, claiming to or wrongly that this advantage stems
from the non-application "unfair" regulatory standards (OECD, 2015b) 32. In this
context, the competition authorities can play an important role in shaping the
inevitable transitions caused by disruptive innovation with regulatory responses that
do not unduly restrict competition or imposing competition rules to ensure that
incumbents do not prevent new rivals in the market. They can also promote studies
and research methods to promote a greater understanding of new technologies and
business models (OECD, 2015c) 33.
40. According to OECD (2015c), applications in general are more sensitive to
consumer demand, and promote a more efficient allocation of resources and reduce
transaction costs. At a minimum, provide new alternatives for consumers. Currently,
the most visible examples of disruptive innovations are the "compartilhamento34 of
services" that are impacting conventional markets taxi and hotels, such as those
offered by Uber and Airbnb companies.
41. Despite the introduction of Radiotaxi services have been a major disruptive
innovation in the way taxi services are accessed by customers, currently the

Objective 2
emergence of innovations through smartphones
has produced new competitive environment in the
individual transport service market passengers. As a highlight, the
Uber company puts in touch two distinct groups, the drivers of the AVP service and
passageiros35. Drivers glimpse extra income by taking advantage of the idle
capacity of their own vehicles and the flexible working hours. Already passengers
wishing to travel the cities through a safe, efficient, quality and transparent as the
rate charged.

42. Described in this way, Uber is a company that manages the application that
connects passengers to private drivers. The company's know-how is not employ
drivers and have vehicles, but to reveal the potential of existing transport
infrastructure and meet the individual transport of pent-up demand, which is not well
served by public transport or conventional taxis.
43. As the company's response to the Uber questionamento36 of SEAE as the
requirements for the application user registration, the company states that "the
plaintiffs provided by the partner service drivers can be any user, over 18 years,
which have mobile devices the most current version of the application, have valid
credit card whose limit will be checked, and have no prior record, and sealed more
than one registration per person. "
44. Since the drivers of AVP service, to be registered in the Uber app, must have
driver's license for professional drivers with the observation that conducting
exercises remunerated activity, have insurance with protection for passengers and
pass criminal background check of both the federal and the state. In verbis:
"People interested in offering shared through the Uber app transport services must
have a driver's license with the observation that the driver exercises remunerated
activity EAR, ie which has professional performance. Furthermore, it requires that
these stakeholders hire insurance in the form Personal Accident Passenger (APP) in
order to protect the insured vehicle passengers of any damage resulting from
accidents. still it should be noted that all partners registered drivers in the application
undergo a criminal background check both the federal and the state, through
documents provided by the competent authorities and independent research
conducted by partner company Uber. "
45. Thus, the partners drivers are not employees of the company, as the business
model is not a transport company, but technology, which enables to efficiently
meeting between passengers and motoristas37.
46. Once you sign the application, to request a race, users must enter the current
location to the application to notify the nearest registered drivers informed of the
location. Once designated driver accepts that race, receives the location and
customer information. On the other hand, the client receives an image of the driver,
his name, a description of the vehicle and an estimate of the final value minimum
and maximum of the race, provided that the consumer has informed the final
destination of the race. When the race is finished, the value is charged to the credit
card previously registered in the application by the client.
47. The application offers different types of services, such as UberBlack, UberLux,
UberSuv, UberX, UberPool and UberTaxi. The UberBlack and UberLux are the most
sophisticated services and using black cars in the sedan model, which should have a
maximum number of years of use. According to information provided by the
company, the UberSuv is a UberBlack category based on car type Sport Utility
Vehicle (SUV) and serve so
to carry greater numbers of people. The UberX is the cheapest - is also known as
UberPop in Europe - because it uses more simples38 vehicles. The UberPool39 is
the service that allows two or more people share the same race and divide the value
in the end. According to Uber, this type of service allows not only that the trip be up

to 50% cheaper to users, but also gives the driver the possibility to earn more
revenue, because it involves the transport of more than one passenger. UberTaxi40
is the service that helps connect passengers to regular taxis drivers, then working as
a taxi rides request application.
48. In response to questioning from SEAE with respect to the locations where the
operation of the Uber app was authorized or not, considering that it is available in
330 cities of 63 countries, Uber said that "only the city of Berlin was decided by the
highest judicial authority in favor of the prohibition of service through UberX
categories UberBlack and UberPop, only being released UberTaxi service. It is
noteworthy that, in addition to Germany, UberPop category is suspended also in
Italy, Spain and Belgium. In France, the Parliament adopted in October 2014, a new
law of transport which now requires that all providers drivers paid passenger
transport service have special license, and the European Union evaluates currently
possible impacts competitive this legislation. "
49. According to the company, "the leading significant change in the existing
regulatory framework in order to regulate the operation of technology companies like
Uber and the provision of a registered drivers transport services on platforms offered
by such companies occurred in the State American California, in September 2013,
with the creation of the model Transportation Network Company (TNC) that has
certain basic features especficas41. The TNC models are characterized by not
define prices
minimum or maximum for passenger service, unlike what happens with the taxi
service. However, in some jurisdictions, such as in Washington (DC) set up a legal
ceiling on the variable price multiplier in cases of natural disasters. "
50. With regard to taxation, in jurisdictions where specific regulations have been
approved for the operation of the Uber under the scope of the TNC model were
created different taxation mechanisms, such as the possibility of charging an annual
fee by the technology company in return the authorization by the government, an
annual fee charged by the driver who provides private individual transport service
using technology platform or an annual rate per vehicle registered in plataforma42.
51. In Brazil, the Uber app currently works in the cities of Belo Horizonte, Brasilia,
Sao Paulo, Rio de Janeiro, Porto Alegre, Campinas and Goinia. Currently, Uber
offers in Brazil, three types of service, namely (i) UberBlack; (Ii) UberX; (Iii)
UberBike; and
(Iv) UberBag43, the latter two offered only in the city of So Paulo. According to Uber
company, "the UberTaxi services, UberSUV and UberLux are not offered in Brazil to
date and there are no plans to provide such services in national territory."
52. The operation of the application was not regulated in any of the Brazilian cities
where the Uber operates. In Brasilia and Belo Horizonte are in progress projects of
laws in the Legislative Chambers and Municipal respectively, which address the
issue, but have not yet votados44,45. In Rio de Janeiro, although the City Council
has approved in August 2015 the project prohibiting the movement of drivers who
make private transport of passengers, the Court granted the Uber an injunction that
prevents the government from fining drivers application. The Court of Justice of Rio
de Janeiro, the decision follows mantida46. In Porto Alegre, after the start of

operation of Uber, the city created a working group that aims to discuss new
alternatives to transport passengers in the city. Among the measures that can be
adopted is the regulation of an executive taxi service that may or may not cover the
aplicativo47.
53. In the city of So Paulo, in a second tentativa48 to regularize the operation of the
application, the mayor launched in December 2015 a public consultation to receive
people's suggestions and improvements in order to consolidate the regulation of
economic exploitation of the use of mesh urban road. In this model, we propose the
creation of the category of Accredited Transport Operators (OTCs), which are the
technology providers responsible for intermediation between service providers and
their drivers usurios49.
54. According to the company's own information, in all categories of services offered
by Uber, the price charged follows the same pricing structure defined by Uber,
namely a fixed initial value and a variable value consists of: (i) elapsed travel minute
and (ii) by mileage round.
55. It is important to note that, in addition to this price structure, the Uber makes use
of a mechanism known as dynamic price at which adjusts the variable portion of its
pricing structure to balance supply and demand for transport service private
individual provided by its partners drivers. The idea is that the float rate to bring the
balance between supply and demand. So when there are not enough drivers to meet
demand, the rates go up to attract more drivers and reduce the demand for travel;
when supply exceeds demand drivers, the price of fares decreases.
56. This pricing model is different from what occurs in the regulated taxi service,
whose rate is fixed, why can form long customer queues at taxi ranks waiting for
service at peak times or long queues waiting for taxi drivers customers at certain
times of day or days of the month (OECD, 2015th).
57. According to Hall, Kendrick & Nosko (2015) 50, the Uber app uses an algorithm
to multiply the rate in times of elevada51 demand. Once application operates in a
market with large fluctuations in demand and a varied range of drivers who are free
to work when they want, the method of dynamic price encourages drivers to provide
their services at specific times - for example, rainy days, holidays, after closing of
bars and restaurants on Saturday night, among others - and thus ensure a stable
supply of such services. The multiplier is presented to the customer at the time of
application access. The client must acknowledge that the price is high before making
the request and only then confirm. Therefore, the client can choose to use the
application at the time that the higher rate is being charged or wait until the price
decrease.
58. With respect to compensation, a percentage of 20% to 25% depending on the
service used, go to the application and the remainder comprises the driver's partner
remuneration. At the end of the race, the driver and the passenger are evaluated in
the application itself. The score on this assessment ensures the application driver's
residence. The passenger feedback to the driver is done anonymously.
59. The company Uber says "that in the case of passengers at the end of each trip, it
requires them to assign a note to the driver, which ranges from 1 to 5 stars, there is

still the possibility of the passenger write a message with a suggestion or criticism of
the rated driver. This review is of fundamental importance for the company to assess
the quality of service provided by the platform's partners and service drivers,
therefore, decide to keep the contract with them. It should be noted at this point that
the minimum threshold for Uber with partners drivers is 4.6 stars, and the current
average of the grades given by passengers to these agents is 4.85 stars. Likewise,
Uber application requires drivers to assess the passengers at the end of each trip. In
this context, passengers who have low grades and / or descumpram the terms of
use of the application can be disconnected from the platform, or not be met by Uber
partners drivers. "
60. Finally, we point out that the model Uber application business aims to use the
idle capacity of durable goods, in this case, the private car as it aims to establish an
efficient offset option, safe and to be transparent in question tariff collection. The
application also encourages some people to leave their cars at home and want to
positively impact urban mobility, for example, in reducing the demand for private car
parks, the daily traffic jams, and consequently the air pollution. It argues, however,
that it would be premature to conclude that Uber has positive impacts on urban
mobility by uncertainties related to externalities. Also it should be noted that the
traditional taxi service produces the same externalities on urban mobility, since, in
theory, can reduce the circulation of private cars on the streets.
61. The following section will bring the definition of the relevant market and the
competitive impact of the introduction of technological innovations in the individual
transport service.
6. Definition of Relevant Market and Antitrust Impacts of Applications Introduction in
Passenger Single Shuttle
62. The definition of the relevant market is one of the most important stages of
competitive analysis, given its relevance in the synthesis of information that the
delimitation brings about the competitive aspects. The concept of relevant market is
crucial to the analysis of the potential anticompetitive effects of transactions involving
market concentration and / or conduct

practiced by companies that are supposed to be in possession of market power,

whose abusive exercise lies with the legislation and antitrust agencies (antitrust), as
key objectives, to prevent and restrain, it is at this locus (the relevant market) properly delimited - that happens, actually or potentially, such exerccio52.
63. symmetrically, delimitation requires a thorough analysis of the context and the
competitive market reality analysis. Regarding the promotion or competition
advocacy, information obtained from the definition of the market help guide actions
aimed at stimulating competition in the industry.

64. Regarding the geographical scope, it is assumed that the relevant market is
local. It is unlikely that a taxi service provider or AVP that offer services in a particular
location is a suitable replacement for another location, which unconfigures a regional
or national boundaries. This alternative is not suitable or the driver (offerer) and not
to the user (applicant). Thus, it is assumed that the size is local and may include
more than one city in the case of metropolitan areas. It proviso, however, that the
driving distance of the relevant market may be smaller and is related to a time scale
that is given by the offset time of the service provider to the consumer. Thus, in some
areas of large cities with high population density, AVP service can not be a good
substitute for the taxi service.
65. In relation to the size of individual transport service, one of the claims
ABRACOMTAXI the representation made by the MPF refers to the fact that the
registered drivers in the Uber application does not meet any of the requirements of
Brazilian law to provide the individual transport services passengers. Therefore,
according to the association of taxi drivers, the service offered by the application
should be submitted to the Brazilian legislation on the taxi service, because they are
identical services.
66. However, this understanding does not coincide with the company's vision Uber,
in verbis:
"The service offered by the partners drivers is distinct from that provided by taxi
drivers because the service provided by Uber partners drivers qualifies as an
individual private shuttle service (mode permitted by Law No. 12.587 / 2012), since
the taxi service is on an individual public transport service. The consequence of this
distinction is that, unlike the taxi services, private individual transport service offered
by Uber partners drivers is not subject to regulatory requirements set out in
legislation and regulations applicable to taxi services. While the taxi service there by
professionals who exercise the obligation of universal service - that is, anyone who
interpele a taxi driver on the street has the right to be transported by it - the driver's
Uber can always choose who will provide its services, evaluating previously
registered people the platform to meet specific requirements. "
67. On the other hand, the supply of UberX service, because it is cheaper and held
in simpler vehicles, has similarities, in the question quality, the provision of the
conventional taxi service. According to the answer given to the question raised by
Uber SEAE, "the differences between the demand for services offered by UberX
category and the demand for conventional taxi service relate mainly to the merits of
the plaintiffs. This is because, not infrequently, Uber partners drivers who work in
service
UberX meet fully unattended locations for taxis, especially peripheral neighborhoods
that show not profitable for taxi drivers. " This would, in theory, more relevant
geographic market.
68. Regarding the question of SEAE about how the company itself defines the
services provided by the application, the Uber argues that there is complementarity
between the services provided by partners registered drivers in the application and
the services provided by taxistas53. In Verbis:

"The services provided by partners drivers, in principle, are complementary to the

services provided by taxi drivers. This is because, in many situations, there is no
substitution between the services of the partners Uber drivers and taxi drivers
services. Just as an example, there is, based on Uber's travel records in cities like
Chicago and Mexico City, which not infrequently partners drivers meet totally
neglected by taxis locations in major cities, such as the peripheral neighborhoods,
since these locations are not shown profitable for taxi drivers. Similarly, there are
individuals who choose Uber to shifts in special situations (eg going to an event or a
party). Such situations are also observed in Brazil. "
69. However, the Uber company claims that "it is possible that in some situations,
identify any overlap between the services provided by its partners drivers and those
offered by taxi drivers, even if such services have some significant differences. This
is the case of intended travel to specific locations such as airports, where there is
some rivalry Uber drivers and taxi drivers ".
70. For purposes of this analysis, the relevant market in the dimension of the product
or service is defined as the "individual passenger transport services market", which
includes all passenger transport services by light rental vehicles with driver (service
provider) 54 in order to meet the individual demands (custom) 55.
71. From this definition of relevant market, two categories would be covered in this
market: (i) the traditional taxi service (taxi drivers); (Ii) the rental service of private
vehicles - AVP56. Both categories refer to individual services paid for passenger
travel as provided by individual drivers. Drivers AVP category are potential suppliers
of individual transport services through the Uber app and the like.
72. Described in this way, the services provided by AVP drivers using the Uber app
to be interpreted as close substitutes for services provided by taxi drivers and
therefore have the potential to compete consumers from one location at a given time.
73. It is noteworthy, however, that the fact that services are close substitutes does
not mean that they are identical, differing in the way they are accessed by applicants
and bidders. Among the features that distinguish the two services include the
provision of AVP service through the Uber app requires that the contractor has: (i)
prior registration in the application, ie, the service is not public and the taxi service ;
(Ii) smartphone data plan valid to access the service; and (iii) credit card for
payment. They would therefore be heterogeneous or differentiated services, but
there is no monopoly in the provision of service. Ie, taxi services and AVP are not
entirely homogeneous, which means that no substitute
perfeitos57 but near, considering that there is considerable degree of substitutability
between them to allow competition.
74. It is noted also the existence of a mercado58 segmentation strategy by the
aplicativos59, based on differences between the users that make up the individual
transport service passenger market. Thus, the demand side, the requirements of
applications for hiring the service not only differentiates services but also segments
the market by distinguishing consumers, which reinforces the perception of
competition within the same relevant market.

75. From a competitive point of view, the

availability of AVP services through
Uber60 application produces
microeconomic effects that were not
possible without the presence of
smartphones. This is because the use of a
technological platform (application) that
connects passengers and drivers of
individual transport offerors private service
has expanded the market for AVP service
beyond the niche to which the service was
previously restricted. Thus, technological
innovations in the individual transport
service
passengers allowed increased supply of
AVP services in very competitive
conditions, which have rivaled the taxi
segment in several Brazilian cities.
76. In this context, the services AVP services using the Uber app are not identical to
the traditional taxi service, as alleged by ABRACOMTAXI. One implication of this is
that the taxi service legislation may be appropriate for drivers of txi61, but certainly
not for drivers of AVP service. Nor can
accept that they are completely different and complementary services, as claimed by
Uber.