[gnso-vi-feb10] Open Registrar Proposal
Years of experience in the ccTLDs space abundantly show that models with cross ownership (“CO”) or vertical integration (“VI”) between registries and registrars *do not cause consumer harm by themselves *and therefore should not be automatically prohibited in the new gTLD (“nTLD”) process. To the contrary, we believe (along with DM and MMA) that too strict limitations of such models will end up crippling or worse discourage many potential nTLD applications, directly against ICANN goal of stimulating innovation and growth for nTLDs. At the core of the vertical integration debate is ensuring competition, i.e. making sure that an organization that holds a monopoly or, more correct from a competition law point of view, an "essential facility" (the TLD), ensures access to such resource under fair, reasonable, and non-discriminatory terms (the "FRAND" standard). The choice made in order to ensure such access is to disentangle two roles: the registry (managing the infrastructure) and a registrar (reseller network) providing access to the infrastructure. What’s interesting is that although we are talking about “new” gTLDs, the debate is nothing new: we have seen similar issues in telecommunications, the railroad network, energy and mining, and so on. However, the Vertical Integration Working Group (“VI WG”) is still one of a kind: 62 members, 1500 emails on the mailing list and several extremely good and diverse proposals. Having attended all conference calls, read each and every e-mail and examining all documents, we (a group of independent mid-size European Registrars) respectfully submit the attached proposal. We apologize for the lateness of this proposal, but we felt a new proposal was necessary to address the issues we feel strongly about based on our experience. Jean-Christophe Vignes, /EuroDNS/ Michele Neylon, /Blacknight Solutions/ Stéphane Van Gelder, /INDOM/ Volker Greimann, /Key-Systems/ Attachment:
Open Registrar proposal.pdf |