Melbourne IT comments on the CRAI report

["Bruce Tonkin" <Bruce.Tonkin@xxxxxxxxxxxxxxxxxx>]

Hello All,

Melbourne IT offers the following comments on the CRAI report:

(1) single organisation - registry/registrar separation
=======================================================

- Melbourne IT supports allowing a single organisation operating a
"closed" gTLD to perform both the registry and registrar functions.
"Closed" gTLD - only allows registrations at the second level by the
applicant, and the applicant takes full responsibility for use of the
domain name at the second level.   This type of gTLD could be used by
corporates wanting to create their own hierarchy of domain names under a
new top level domain.

Recommendation
==============
- to avoid gaming - limit this situation to "closed" gTLDs, when the
single organisation is the "registrant" for all second level domains -
ie second level domains are not able to be licensed to third parties


(2) hybrid model - proposal to allow a registry to own a registrar as
long as not for its gTLD
========================================================================
==============

- there are no real clear benefits in this proposal for new start-up
registries and there is room for abuse, where a registry can have access
to domain name check availability searches and contact information to
give it an unfair advantage in other gTLDs.

- the rules for registry-registrar separation are also not clear when a
registrar provides back-end registry services for an applicant (and
hence may not be designated as the "registry operator")

- small start-up registries will want the option to operate their own
registrars to help with the direct marketing and sales of names to get
the TLD started


Recommendation
==============
- where a registry offers registrations to third parties, allow the
registry to operate its own registrar up to a cap of 50,000 names in
total, as well as allowing other ICANN registrars to offer names on the
same commercial terms .  Once that cap is hit the registry would no
longer be able to perform registrar services for new registrations but
could support their existing base.   A registry would not be able to
operate a registrar for other gTLDs in this model.  This assists a small
registry to get started, but ensures that if the registry is dealing
with large numbers of registrants (e.g above 50,000), that registrants
have the option to choose registrars in a competitive market.