RE: [bc-gnso] BC Position Statement on Vertical Integration (VI) -- single registrant TLDs
- To: bc-gnso@xxxxxxxxx
- Subject: RE: [bc-gnso] BC Position Statement on Vertical Integration (VI) -- single registrant TLDs
- From: berrycobb@xxxxxxxxxxxxxxxxxxx
- Date: Sun, 16 May 2010 17:04:40 -0400
I tend to agree with Jon's comments below. For sure, registration
caps should not be required for internal registrations. In relation
to Case #1, I feel confident we will see strong consensus develop from
the VI WG on single-registrant TLDs.
WRT to Jon's point on cases 2 & 3, Registrations to third parties not
only can open the door to gaming, but IMO also begin to impede fair
competition. For example, in case #3 Facebook offers a free or super
cheap 2nd level domain (berrycobb.facebook) to it's customer that
would have otherwise purchased a 2nd level domain (berrycobb.social)
from the dot_social TLD at the going market rate. Would this not
threaten the dot_social's business model?
My example may not be the best here, but I invite CBUC members to
review VI responses from Richard Tindal about threats to competition.
He has some good insight in to this issue.
Another variation to consider will be the not-for-profit
organizations. The NCUC has mentioned several examples where business
models will supply 2nd level domains as a value added service. Will
this have potential to threat competition.
As an FYI, I do believe the CBUC will need to set aside specific
conference calls to build our consensus position. This will be a very
complex topic to bring everyone up to speed on the concepts and issues
in addition to any consensus that comes from the VI WG.
Infinity Portals LLC
From: owner-bc-gnso@xxxxxxxxx [mailto:owner-bc-gnso@xxxxxxxxx] On
Behalf Of Jon Nevett
Sent: Friday, May 14, 2010 10:56 AM
To: Steve DelBianco
Cc: berrycobb@xxxxxxxxxxxxxxxxxxx; bc-gnso@xxxxxxxxx
Subject: Re: [bc-gnso] BC Position Statement on Vertical Integration
(VI) -- single registrant TLDs
I support you on Case 1, but not Case 2 or Case 3. Once you start
distributing the names to third parties outside of the company, it
should follow the applicable restrictions. In case 2, why just bank
customers, why not telecom customers or retail customers, etc.? It's
a slippery slope. Similarly, in case 3, could a registry set up as a
social media site and get around restrictions that we set-up. The
thing about all exceptions is that they are subject to gaming. If the
exception is limited to just that entity -- no third parties -- it
would be cleaner, implementable, and more likely to be approved. It's
not like Facebook wouldn't be able to give away names to its
subscribers, it would just have to be done with whatever
restrictions/protections that ICANN sets up.
On May 14, 2010, at 1:19 PM, Steve DelBianco wrote:
Thanks to Berry and the other BC members on the VI working group for keeping
us apprised of your work there.
As we form our constituency position on the proposed VI models, I wanted to
focus briefly on one issue: single registrant TLDs.
Most of the 9 proposed VI models mentions single registrant TLDs and most
would allow the TLD to manage its registrations -- but with caps of 30,000
or 50,000. Let me offer a few examples that show how companies (even some
BC members) would want more control over their own TLD registrations:
Case 1: employees of a company. This is the example cited most often, as
in, IBM might want to create 2nd level registrations for all its employees,
for HR functions, scheduling, or even "mail@xxxxxxxxxxxxxxxxxxx". If a
company were to do this, they would rightfully insist upon total control
over 2nd level registrations, and would not want to let all registrars have
equal access to sell names. The employer might create its own accredited
registrar, in which case 100% cross ownership and self-distribution would
need to be allowed under the new VI policy. For this case, there is no
justification to impose an arbitrary cap of 50,000 on the number of
registrations that could be done before opening it up to all registrars.
IBM, for instance, has 400,000 worldwide employees, according to its 2009
Annual Report. Case 2: bank customers. A global consumer bank
might pursue its own TLD,
hoping to give each of its customers their own 2nd level registration to
enable secure access to a DNSSEC-signed online banking page. An arbitrary
limit of 50,000 registrations would not be sufficient for even medium-sized
regional banks. When a bank reaches the registration cap, it will not want
to be forced to compensate and cooperate with all ICANN registrars to
enroll, authenticate, or remove banking customer registrations.
Case 3: social network services. A global social network platform might
want to operate its own TLD in order to give each of its users their own 2nd
level web address. (e.g. SteveDelbianco.facebook ) Even sites like Flickr,
dropBox, and Twitter might want to offer this service to enrolled customers.
An arbitrary limit of 50,000 registrations would be too low a threshold, and
no service would want to lose total control over the privacy and security of
its users' data. These services would not want to be forced to compensate
and cooperate with all ICANN registrars to enroll, authenticate, or remove
I am not aware of any BC member (or NetChoice member) who's planning to
apply for their own TLD, but I doubt any would want to operate their own TLD
if arbitrary caps were placed on self-managed registrations.
I believe the BC is in the best position to argue for potential needs of
single registrant TLDs like those described in these examples.
Let's acknowledge that single-registrant TLDs would need to conform with
ICANN's contract and consensus policies. It's also acceptable to require
the use of a single accredited registrar, as long as this registrar can be
wholly-owned and controlled by the single registrant company. But let's
argue against arbitrary registration caps that would force single-registrant
TLDs to use all ICANN registrars once those caps were reached.
http://www.NetChoice.org and http://blog.netchoice.org
+1.202.420.7482 <berrycobb@xxxxxxxxxxxxxxxxxxx> wrote:
Attached is the CBUC position statement from Aug 2009 regarding the
issue of Vertical Integration. While several CBUC members participate
on the VI WG, no substantial change has occurred requiring
modification to our consensus. The CBUC reserves a change to our
consensus position, if any, when the VI WG creates its final report
and opens the final community comment period.
In summary, Our present consensus position basically aligns to the
ICANN board resolution in Nairobi and we are pleased with the
substantial and adequate discussion with respect to VI/CO & also
Single Registrant TLDs. The CBUC looks forward to the analysis of
proposals by the VI WG and we are optimistic a solution will be
created to match the expansion of gTLDs.
Any specific questions to the CBUC can be filed through Berry Cobb.
Infinity Portals LLC