Re: [gnso-vi-feb10] Innovative Proposal

[Richard Tindal <richardtindal@xxxxxx>]

Hi Kathy,

Your proposal uses language from existing contracts,  e.g.  'Registry Operator 
shall not act as a registrar with respect to their TLD'.   However as others 
(Jon N and Jeff N) have noted,  this language contains some ambiguity.    

You're saying a registry can cross-own up to 15% of a registrar.  That's clear.

You're saying the registry entity itself (the registry corporation) cannot act 
as a registrar in its own TLD.  That's also clear.

What's not clear is whether a registrar that is 14% (say) cross owned by the 
registry can operate as a registrar in that TLD.      Do you intend that (1) 
cross-owned registrars below the 15% threshold CAN sell names in the TLD in 
question,   or are you taking a stricter approach that says (2)  no cross-owned 
registrar of any ownership percentage can sell names in the registry's TLD?

I'm assuming it's (1) -  but wanted to be 100% clear.

Richard