Divide and conquer?
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 Facebook: http://fb.me/blacknight Twitter: http://twitter.com/mneylon ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845