[gnso-vi-feb10] Not so Innovative Proposal

[Milton L Mueller <mueller@xxxxxxx>]

> What might we lose by changing to a system
> of full vertical integration?

Both the Eckhaus proposal and the MMA proposal do not propose a system of "full 
vertical integration." They both retain equivalent access for competing 
registrars, and simply allow a registry to own its own registrar and sell its 
own TLD, just as Apple has its own stores. 
So this question leads nowhere, unless one likes to spend time knocking down 
straw men. The key consumer protection question revolves around switching 
costs. The consumer switching cost problem is solved as long as you retain 
equivalent access. From a user standpoint, therefore, I see no reason to be 
concerned. Only with SRs do we get into full VI. 

>A)      Customer detail for all registrants: we are a thick registry and [snip]
>
>B)      EPP data: This data of the Extensive Provisioning Protocol
>provides a stunning overview of activities and interest in the TLD [snip]
>
>C)      Dropped Names Data: We know before anyone else before anyone
> else, other than the dropping registrar. We also know in what order the

The MMA proposed a series of audits and checks to prevent any abuse of this in 
cases where a cross-owned entity was involved. I don't see anything in your 
arguments that addresses those. It is almost as if you assume they don't exist. 

> In a vertically integrated situation, with a shared data center, shared
> operational personnel, and/or shared offices, the ability to pass on,
> observe or overhear information about technologies, systems, operations,

Again, you persistently elide the fact that we will be talking about _new_ TLDs 
- i.e., domains with 0% of the market. We are not talking about .com, or even 
.org. 
The biggest problem facing the suppliers of these new services is not the 
registry interface, it's .com, .net, .org, and other incumbent TLDs such as the 
major ccTLDs. Who will promote these new ones? How will they convince consumers 
to take a chance on an unknown, untested name and service? How can they survive 
when they will have fewer economies of scale and will probably have to offer 
lower prices to gain a foothold in the market? 

The PIR position is just completely out of touch with these new market 
realities. I know that you speak for .org, Kathy, and .org has very llittle to 
worry about. It is an established TLD. It has a growing base of nearly 8 
million subscribers now, and its millions of users, like my own 
Internetgovernance.org, are going to keep renting those domains as long as our 
organizations survive because our whole identity revolves around the domain. 
This parade of horribles regarding data sharing describes a situation that is 
only relevant to registrars competing for hte right to sell names in a 
cartelized market for well-established, well-known TLDs. 

And please, please, stop with the financial collapse analogies. Financial 
over-leveraging involving trillions of dollars, breakdowns of regulation and 
certification with respect to derivatives, pushing subprime loans on people who 
cant afford them, Ponzi schemes, zero- interest rates, a gigantic global real 
estate bubble, stock market dips of 60%, these things are just orders of 
magnitude away, they are in a different universe in terms of social impact. 
Don't trivialize that painful experience by comparing it to minor changes in 
DNS registration practices. 

Granted, there may be some issues related to data-sharing between Rrs and Rys, 
but: 
 a) they may affect consumers and competitors but they have absolutely nothing 
to do with the technical stability or security of the DNS.  
 b) start-ups with no installed base are unlikely to treat all other registrars 
badly - they need the business, and most of the money they make will hinge on 
the success of the TLD, not on fending off competing registrars 
 c) those who do want to carefully discriminate among registrars, e.g., impose 
highly selective conditions on them for legitimate reasons, ought to be able to 
and without those innovative business models we may as well just stay where we 
are and do nothing. 

And indeed, the more I look at the PIR proposal, the  more it looks like the 
status quo. It's ok to argue for the status quo. Just don't call it 
"innovation."