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

[Milton L Mueller <mueller@xxxxxxx>]

I don't know what's disconnected about a point by point rebuttal of the claims 
made for a specific proposal. 

 
> 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."
>