Re: [gnso-vi-feb10] Joint Proposal - MMA

[Richard Tindal <richardtindal@xxxxxx>]

MMA,

Thanks for the briefing last night.

The more I think about the 'competition referral' portion of your proposal the 
more difficulties I'm having with it   (this is the piece where applicants who 
want more than 15% cross ownership submit a written request -- which is then 
subject to public comment and competition authority analysis) .      I 
understand the concept behind it,  but I'm struggling with the practicality of 
implementing it.

To give new TLD applicants predictability in the process (Implementation 
Guideline 1) this competition referral would have to happen before the TLD 
application window opens.  I think we agreed that last night.

The public and the competition authority will not be able to make informed 
comments or judgements unless the applicant's written request contains a 
reasonable amount of detail.  I think the request would have to include the 
applicant's full ownership details, business plan and intended string.    
Without that information I don't think the public or the competition authority 
could make a meaningful analysis.

Given that, we would be putting applicants in the position of revealing 
sensitive data prior to the application window opening.  For example,  another 
party could see the request and decide to also apply for the string.

Was it your intention that applicants would have to prematurely reveal their 
plans?  Or do you see a way around this problem?

RT



On Apr 12, 2010, at 2:18 AM, Michael D. Palage wrote:

> Hello All,
>  
> Attached is the proposal which is being jointly submitted by Avri, Milton and 
> myself to the working group for consideration.  We look forward to formally 
> presenting this concept to the group on tomorrow’s call, and answering any 
> questions that you may have.
>  
> Best regards,
>  
> Michael Palage (on behalf of Team MMA)
> <Vertical Integration Co-Ownership Joint Proposal.pdf>