No details, No dice

["Faisal Premji" <faisal@xxxxxxxxxx>]

The proposed changes to the registry services agreement are woefully
bereft of critical implementation information, details that are wholly
necessary to determine the usefulness and legality of the proposed
changes.  No details are given regarding the exact operational mechanism
of the changes; rather, we are implored to simply trust ICANN to implement
this policy in a fair manner.  A critical component of the policy proposal
must be the adoption of clear criteria for determining any increase in
core registration fees for certain domain names.

Several questions arise in attempting to determine the implementation
mechanism of such a policy:

1) How will the registry determine which domain names are subject to a
variable pricing scheme?

2) How will the registry determine the specific increase in price for the
determined names?

These critical implementation questions remain unanswered.  ICANN gives no
details on how the policy is to be implemented, but simply asks for a
carte blanche to arbitrarily raise prices.

Putting aside the lack of a concrete plan of action to implement such a
policy, the concept of variable registration fees at the registry level is
impossible to accord with the substantive principle of equality, a core
precept upon which the United States was founded, and which ICANN, as a
creation of the United States Congress, is bound to in spirit and law.

Until ICANN gives more details on exactly how the policy is to be
implemented, proposed ?variable pricing? changes to the registry agreement
must be rejected.

Yours truly,

Faisal A. Premji
The Semantic Network