Re: .CAT Cross-Ownership Removal Request

[ebw@xxxxxxxxxxxxxxxxxxxx]

Karla, Jordi,

I did not support reduction of the cross-ownership restriction from 15%, as
registries can benefit from the cooperation necessary to form a registrar
owned by seven or more independent registries, and the variation across the
EPP implementation space is necessarily reduced by an order of magnitude.

Observing the existing applications it is clear thatthe number of technically
independent registries ("facilities based operations"), hence the number of
potential variant EPP implementations, will not be significantly greater than
the number of currently contracted registries.

Therefore no compelling rational now exists to restrict cross-ownership, at
least where, as the EC Competition Authority and US DoJ Antitrust Division
note, the registry (or regsitry platform operator) lacks market power.

Consequently, I recommend that the request made by Fundacio puntCAT be
approved.

Please note that my name appeared on the 2004 application by Fundacio puntCAT,
and that I'd some policy responsibilities for CORE, which provides registry
services for the .CAT registry, in 2008-2010, e.g., its DNSSEC funnel request.
I've no other material connection with Fundacio puntCAT, and this comment is
made as an otherwise disinterested observer familiar with the Vertical
Integration issue set, and the opertion of the party making the request for
a restriction removal.

Eric Brunner-Williams
Eugene, Oregon