RE: [gnso-vi-feb10] Innovative Proposal

["Thomas Barrett - EnCirca" <tbarrett@xxxxxxxxxxx>]

Dear Kathy,
 
It is nice to see another proposal being added to the possible options.  The
introduction of new gtld's is an opportunity not only for new registry
operators but also for new registrars willing to focus their efforts on
promoting a new gtld.  Let's make sure that we do not disadvantage possible
new or existing registrars with respect to re-selling new gtlds.
 
The whole concept of even having a threshold cap before registrars are
required is one that clearly disadvantages new registrars and smaller
registrars. (see anti-trust and competition memo sent out earlier today:
...the WG participants should avoid engaging in discussions that could be
construed as an effort to exclude, disadvantage or boycott any particular
competitors, suppliers or customers. )
 
In this regard, your "innovation" idea becomes less viable by allowing
registries a threshold of 50,000 names before they need to use a registrar.
Experience already tells us that there can be viable stld's with far less
than 50,000 names.  Although some TLDs have complained about the lack of
registrars carrying their product, this implies that if they did, then more
registrations would magically accrue.  There are often other reasons why a
tld does does not meet expectations.
 
Aside from internal registry use, the threshold cap for not using a
registrar should INITIALLY be zero. Your idea to prevent "gaming" provides
an avenue for registries to first try the "Main Model" before they petition
ICANN to bypass the registrar channel.
 
The proposal has several areas which have a clear bias against new and small
registrars.  including these statements:
 
1. Community-Based TLDs: "lest this TLD not be of interest to top-tier
registrars"
 
2. Orphan TLDs: "has not been picked up for distribution by the top three
tiers of registrars"
 
Why are we only concerned with top-tier registrars?   Has ICANN decided not
to accredit any new registrars?   Are there any registries planning to drop
registrars and only serve the top-tiers? (all rhetorical questions).  How
will low-tier registrars ever become top-tier registrars if the system
excludes them from participating in launch of new tlds?
 
As you say, now is not the time to tamper with a tried and true system.
 
Creating a system that favors large registrars over new entrants and smaller
registrars will actually reduce consumer choice and harm competition.
 
Best regards,
 
tom barrett
encirca, inc
 


  _____  

From: owner-gnso-vi-feb10@xxxxxxxxx [mailto:owner-gnso-vi-feb10@xxxxxxxxx]
On Behalf Of Kathy Kleiman
Sent: Monday, April 12, 2010 12:22 PM
To: Gnso-vi-feb10@xxxxxxxxx
Subject: [gnso-vi-feb10] Innovative Proposal



Dear VI WG,

 

Now is the time to rollout new competition and new gTLDs that will service
the growth and future of the Net.  Now is not the time to tamper with tried
and true systems. 

 

The subprime mortgage crisis in the United States was led by cries for
innovation and unwinding of the regulations that had long held a steady hand
in the financial markets. Few relatively small experiments ultimately had
the unintended, unanticipated and domino-like effect of the collapse of
multiple financial institutions.  As one failure precipitated another, it
soon became evident that the damage could not be constrained, or easily
reversed.  In the end, the public trust was lost in not only in the
institutions themselves but also in the regulatory bodies which had heard
but not heeded the call for restraint.    

 

With stakes high for serving the public interest, and preserving the
security and stability of the Internet, tampering with a proven model is not
an option - not for us, nor for the millions of registrants, websites,
listserves and other systems which depend on the domain names we offer.  It
is far easier to determine the right structure to drive behavior, than to
police conduct after the fact.

 

PIR hereby submits a proposal which relies on the most basic of principles,
as well as some innovative ideas.  In the interest of delivering this
proposal to the Working Group by today's deadline, we provide a framework
here, and will follow with further details and explanations. We look forward
to the discussion today, and in the days and weeks ahead. Please find our
new proposal for our discussion attached. 

 

Best, 

Kathy Kleiman

Director of Policy, PIR

 

 

Kathy Kleiman

Director of Policy

.ORG The Public Interest Registry

Direct: +1 703 889-5756  Mobile: +1 703 371-6846

 

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From: owner-gnso-vi-feb10@xxxxxxxxx [mailto:owner-gnso-vi-feb10@xxxxxxxxx]
On Behalf Of Margie Milam
Sent: Sunday, April 11, 2010 11:53 PM
To: Gnso-vi-feb10@xxxxxxxxx
Subject: [gnso-vi-feb10] Vertical Integration Antitrust and Competition
Memorandum

 

Dear All,

 

In preparation for tomorrow's call, please review the attached Antitrust
Memorandum.    Amy Stathos will be available to participate on the VI-WG
call to discuss this document.

 

Best Regards,

 

Margie 

 

______________

 

Margie Milam

Senior Policy Counselor

ICANN

______________