Facebook says some recommendations of the ACCC's inquiry into digital platforms come to unfounded conclusions based on "misunderstandings" about the competitive dynamics of the industry and "mischaracterisation" of aspects of its services.
The company, in a 141-page reply to the 23 recommendations by the consumer watchdog, says proposed privacy reform would actually reduce consumer welfare and the significant efficiencies that targeted advertising has created for Australian advertisers and small businesses.
The social media platform notes that the report made no finding of anti-competitive conduct by Facebook.
"Despite an 18-month long inquiry and no clear finding of anti-competitive conduct, the final report’s overall conclusion is that Facebook possesses market power and is a threat to competition, privacy and consumer rights in Australia," says Facebook.
"We disagree.
"The final report’s analysis does not rest on a sound evidence base. It draws unfounded conclusions based on a selective and incomplete view of the spaces in which we compete, including subscribing to outmoded distinctions between different advertising services.
"It also departs from established competition law principles in proposing recommendations to address potential future conduct that is entirely speculative and/or hypothetical in nature."
Facebook supports 15 of the 29 recommendations and sub-parts, supports in principle five of the recommendations, opposes five and notes four.
"Of the recommendations we support or support in principle, the devil is in the detail in how these are implemented," says Facebook.
Facebook says the finding that there is an imbalance in bargaining power -- and Facebook has substantial bargaining power in dealings with news media businesses -- is not consistent with the commercial environment.
"Our submission proposes a new policy solution - a Digital News Distributor Code - that we believe will effectively address concerns about potential adverse effects of algorithms and digital distribution services on news in Australia.
"We do not agree, however, that a 'bargaining code' between Facebook and some of the most influential and powerful media companies in Australia will promote public interest journalism.
"It is hard to imagine that such influential companies require the assistance of the Australian Government to negotiate commercial terms with Facebook, especially in light of the lack of evidence or findings of unfair trading on our part.
"The analysis does not reflect our experience and is not supported by evidence of our daily commercial interactions, feedback or engagement with Australian publishers."
Facebook sasy it is concerned that some recommendations have potential to adversely impact Australia’s economy.
"For example, the recommendations that make targeted advertising practically unworkable in Australia," it says.
"A cross-border study found that Australian businesses using Facebook’s targeted advertising tools are more likely to export than businesses in general. These findings support an emerging pattern in the data showing that digital platforms can facilitate cross-border trade, especially for smaller businesses."
Facebook says targeted advertising has contributed to economic and employment growth, especially in small businesses.
The use of online services such as Facebook and Instagram by Australian small business owners has allowed them to hire 120,000 more people, generating $16.8 billion, with 34,800 of those new employees and $4 billion in additional economic value in regional Australia.
"Targeted advertising has also reduced the cost of advertising, opening up advertising opportunities for small businesses across the country that were historically unavailable or unaffordable," says Facebook.
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