Opportunities and Challenges in Southeast Asia, 2019 (Bangkok, Thailand) 15 As the area of digital rights remains nebulous, some studies on the topic anchor their work on existing frameworks or guidelines instead, mostly in the form of Internet/digital bills of rights or charters, which provide sets of norms and principles agreed upon by various constituencies through stakeholder consultations (Gill, Redeker, & Gasser, 2015; Dheere, 2017; Daskal, 2018; Redeker, Gill, & Gasser, 2018). For example, the Charter of Human Rights and Principles for the Internet by the Internet Rights & Principles Coalition (IRPC) outlines ten general Internet rights and principles and provides a breakdown of these rights in 21 articles, using the Universal Declaration of Human Rights (UDHR) as a framework (Internet Rights & Principles Coalition, 2018). Another framework that is oft-mentioned is the APC Internet Rights Charter by the Association of Progressive Communication (APC), which organises 31 rights by seven themes.3 There are many such charters and attempts to create “magna cartas” of sorts of Internet rights. In a comparative study of principles for governing the Internet, UNESCO (2015) identified more than 50 Internet-specific declarations and frameworks. In another attempt on analysing “digital constitutionalism” or initiatives that “seek to articulate a set of political rights, governance norms, and limitations on the exercise of power on the Internet”, Gill et al. (2015) identified 30 such initiatives and collected a list of 42 rights which they categorised into seven themes4. Gill et al. (2015) found that freedom of expression, privacy rights, and the right of access to the Internet were the three most featured out of the 30 digital constitutions studied (27, 26, and 24 times out of 30). Freedom of information, as well as transparency, and openness (of Internet governance processes and of networks), were other focal points which were covered by more than two thirds of the documents analysed (22 times out of 30). Indeed, some studies or documents have found it expedient to narrow down their scope to the top two to three rights and to move along with their analytical work or practical advocacy (Daskal, 2018; Global Network Initiative, 2017; Hope, 2011; Kumar, Prasad & Maréchal, 2017). This may be sufficient if the purpose of the authors is to look specifically at freedom of expression and privacy rights, however, most discussions do identify these choices as main or representative foci of digital rights or human rights in the online space. The challenge then seems to be the lack of a theoretical or conceptual framework to define the boundaries of digital rights, compelling researchers and advocates to choose the rights that are most representative and forgoing some other rights that are deemed less central. The concepts of digital rights and Internet freedom have been operationalised for the purposes of ranking corporations and countries on their performance of upholding rights in the digital or online space. The Corporate Accountability Index, produced yearly by Ranking Digital Rights, for example, ranks a selection of the most influential Internet, 3 4 Accessible at https://www.apc.org/sites/default/files/APC_charter_EN_0_1_2.pdf 1) Basic or fundamental rights and freedoms, 2) General limits on state power, 3) Internet governance and civic participation, 4) Privacy rights and surveillance, 5) Access and education, 6) Openness and stability of networks, 7) Economic rights and responsibilities.