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telecommunications infrastructure to deploy services such as OTT television (TV360),
digital content platforms, and mobile payment systems (Viettel Money). Viettel’s
advantage lies in infrastructure control, allowing it to integrate network-level
management with content distribution. However, DRM mechanisms are largely
embedded at the service level rather than functioning as a comprehensive ecosystem
governance tool (Bui Quang Tuyen, Le Thi Thu Huong, Phuong Mai Nguyen, 2021).
Meanwhile, FPT Corporation has built an ecosystem around Internet television (FPT Play),
digital education platforms, and broadband-based services. FPT’s model reflects a hybrid
approach, combining proprietary platforms with selective openness, though
interoperability across external ecosystems remains limited (Tran, 2023).
Overall, these cases indicate that while elements of “walled gardens” are emerging,
they are not yet fully institutionalized. DRM practices tend to be fragmented, often
implemented as technical safeguards rather than as strategic instruments for structuring
market relationships.
4.3. Legal framework governing DRM and copyright protection in the digital
environment
Vietnam's legal framework has made significant strides in recognizing and
protecting technological protection measures (TPMs), particularly through the
amendments to the Intellectual Property Law in 2022 and Decree No. 17/2023/NĐ-CP
(Quốc Hội Việt Nam, Luật sở hữu trí tuệ, 2022), (Chính phủ Việt Nam, 2023). However, its
focus primarily centers on copyright protection rather than platform governance (Thong,
2025). First, regarding the scope of protection for technological measures, the amended
2022 Law on Intellectual Property (Vietnam) explicitly acknowledges the importance of
TPMs and Rights Management Information (RMI). These provisions align with
international standards, such as those established by WIPO treaties, and clearly state that
the circumvention of DRM technologies is prohibited. Additionally, the unauthorized
removal or alteration of rights management information is considered unlawful. As a
result, Vietnamese law formally recognizes DRM as a legitimate mechanism for protecting
digital content. Second, in terms of regulated actors and their legal obligations, the legal
framework applies broadly to individuals, content distributors, technology firms, and
intermediary service providers. Under Decree No. 17/2023/NĐ-CP (Chính phủ Việt Nam,
2023), the obligations include the prohibition of bypassing or neutralizing DRM systems,
the prohibition of producing or distributing circumvention tools, and the responsibility of
digital platforms to prevent copyright infringement. This indicates a shift towards shared
responsibility across the digital value chain, including platform operators. Third, there are
sanctions and enforcement mechanisms in place for DRM-related violations. Penalties
include administrative fines, service suspensions, civil liabilities (such as compensation for
damages), and potential criminal liability in serious cases. However, enforcement remains
inconsistent due to the technical complexity of identifying violations, limited institutional
capacity, and challenges associated with cross-border enforcement (Chính phủ Việt Nam,
2025) .
Key Gaps from a Platform-Economy Perspective: Despite these advances, several
structural gaps remain: First, the law treats DRM primarily as a copyright-protection tool
rather than a mechanism of market governance. There is limited recognition of DRM’s
role in shaping competition, interoperability, and platform power. Second, competition-
related implications of “walled gardens” are not explicitly addressed. Issues such as
ecosystem lock-in, data control, and exclusionary technical standards fall largely outside

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