RE: [gnso-dow123] NCUC Procedural Proposal - recirculated

["Bret Fausett" <bfausett@xxxxxxxxxxxxxxxx>]

> my question is whether it is consistent with the RAA. 

My assumption is that either (a) the practice is consistent with the RAA or
(b) the provision is an unlawful restraint on trade. From my perspective, it
would not be consistent with ICANN's mission and core value to prevent
registrars from offering services to the public for "free" (for any value of
"free"). And, in the unlikely event that ICANN were to read the provision as
restricting registrars to a particular pricing model, the provision would be
unenforceable as a matter of law. 

          -- Bret

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