.wed Introduction of Third Level Domain Sales

[Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>]

I am submitting these comments on my own behalf.

Several things about this request strike me as odd.

Why did it take from October 2013 to June 2014 before this was open to comment? 
If the request was non-contentious surely it would have been presented to the 
community sooner?

However the timeline of the request isn't a substantive issue.
The request itself, however, is.

At time of writing the .wed registry is already advertising domain names at the 
3rd level via the only registrar they are listing on their site.
See: http://www.101domains.wed/

If the change in contract is required in order for .wed to start offering these 
3rd levels, why are they already offering them for registration?
I would have thought that this would not be permitted until ICANN had approved 
the contract change permitting their sale / registration?

With respect to the actual request that has been submitted.

Under normal circumstances a registry operator is expected to show ICANN that 
they have consulted with registrars. I suspect that most people would interpret 
"registrars" to mean a representative number of registrars that reflect a 
variety of business models.
That appears to not be the case.
Atgron's request only makes reference to them consulting with two registrars. 
Considering the amount of time between the original request being submitted to 
ICANN and the opening of this comment period why didn't the registry operator 
engage with a broader cross-section of the registrar community?

With respect to the 3rd levels themselves.
While it is not uncommon for ccTLDs to offer 3rd level registrations generally 
speaking the number of 3rd levels that are made available is usually limited in 
number ie. fewer than 10
In this instance Atgron wish to create 11 thousand.
That means that effectively the registry operator will have registered 11 
thousand domain names to themselves in order to create 11 thousand new 
namespaces.
This appears, to me at least, to be an attempt to circumvent established 
policies within the new TLD program.

Regards

Michele

--
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Domains
http://www.blacknight.co/
http://blog.blacknight.com/
http://www.technology.ie/
Intl. +353 (0) 59  9183072
Twitter: http://twitter.com/mneylon
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