Divide and conquer?

["Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxxx>]

Dear Sir / Madam

I am submitting these comments on behalf of Blacknight, Ireland's only ICANN 
accredited registrar. They do not reflect the formal views of any stakeholder 
group, but those of our company.

While we may submit comments on other aspects of the "Public Interest 
Commitments Specification" at this juncture we wish to address section 1:

"1.     Registry Operator will use only ICANN accredited registrars that are 
party to the Registrar Accreditation Agreement approved by the ICANN Board of 
Directors on _____________ ___, 2013(or any subsequent form of Registrar 
Accreditation Agreement approved by the ICANN Board of Directors) in 
registering domain names.  A list of such registrars shall be maintained by 
ICANN on ICANN’s website."


What is ICANN's rationale for this criterion?

While it would be expected that ICANN accredited registrars party to an RAA 
would be used, this document specifies a version of the RAA that currently does 
not exist.

Does this mean that ICANN wants to drive a "wedge" between registrars and new 
TLD applicants?

Or does this mean that ICANN does not trust those of us who are on the 2009 RAA?

The RAA negotiations are currently ongoing and while they may be concluded 
shortly any agreement that comes out of the negotiations should be agreed to on 
its own merits ie. without this form of external pressure.

Or is it ICANN's intention to use any delay with the RAA as an excuse for 
delaying the launch of new TLDs?

A rational explanation for this specific clause would be appreciated.

Regards

Michele

Mr Michele Neylon
Blacknight Solutions ♞
Hosting & Domains
ICANN Accredited Registrar
http://www.blacknight.co
http://blog.blacknight.com/
Intl. +353 (0) 59  9183072
US: 213-233-1612 
Locall: 1850 929 929
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