Although this amount is around 12% lower than the average monthly licence fee paid by the other MNOs to R3CPS, that amount is already 17% higher than the average monthly licence fee paid by HKT to other private tunnel operators. Since the monthly licence fees paid by HKT to other private tunnel operators were agreed after commercial negotiation, they could be reasonably used as a benchmark for measuring the reasonableness of the level of fees for 2G and 3G systems involved in the Application.