RE: [gnso-vi-feb10] Not so Innovative Proposal

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

Milton,

It is great when your posts focus on constructive feedback and counterpoint.
But when you throw in disconected thoughts, the value of the post is lost.
You should restrict these comments to your blog and twittering and keep them
out of this working group.

Tom




-----Original Message-----
From: owner-gnso-vi-feb10@xxxxxxxxx [mailto:owner-gnso-vi-feb10@xxxxxxxxx]
On Behalf Of Milton L Mueller
Sent: Thursday, April 15, 2010 12:28 AM
To: Gnso-vi-feb10@xxxxxxxxx
Subject: [gnso-vi-feb10] Not so Innovative Proposal 


> 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."