[gnso-vi-feb10] Open Registrar Proposal - condensed version, as requested

[Volker Greimann - Key-Systems GmbH <vgreimann@xxxxxxxxxxxxxxx>]

Hi,

during the discussion of our proposal during yesterdays call, a request was made for a easy to see condensed version. While I believe the proposal is best understood in its long version, I am always willing to comply with reasonable requests: 

Open Registrar Proposal - Main Topics

1) full VI/CO (Ownership: 100CO)
          = no limit on ownership, ability to sell own TLD
          = seen in multiple working models in ccTLDs without harm to consumers 
caused by such setups
          = gaming/abuse of control may occur in small applications and can 
therefore be dealt with after the fact
          = artificial limitations will prevent and/or cripple many potential 
applications
          = many 'fringe' TLDs will benefit greatly from 100CO from the start
          = legacy limit of 15% has no objective basis or justification
         => no limitation of market share/power
         => req'd: full financial seperation between registrar and registry 
entity
         => functional seperation, information firewalls
2) Guaranteeing equal access for all ICANN accredited registrars
          = full implementation of "Recommendation 19"
         = use of registrars (sale only through registrars)

        Equal access is defined as follows:
            - all ICANN accredited registrars must be granted equal access, 
i.e. if one registrar has access, all must have the same basic opportunity:
          = equal connection to registry system for all registrars
                  = first come, first serve amongst registrars for general 
availablility/non-auction phases
                  = no preferential treatment
                  = adequate support levels for all registrars
          = firewalling information from VI/CO registrar entity
                  = no price caps
                  = others?

3) SR models
   SRSU: allowed, even to the exclusion of other registrars (sale of domain 
names does not apply)
   SRMU: allowed, but very restricted to prevent circumvention of the registrar 
system (dotFacebook), allocation through registrars only.

4) Auditing 
	- no to regular audits without cause
                - unnecessary and cost-ineffective
        - yes as part of verification/complaints process
                - will carry stiff penalties for abusers

5) Penalties for abuse:
        make rules/restrictions for minority that abuses system, not for 
majority that will act appropriately
        no rule we implement will be able to prevent abuse 100%, therefore 
penalties are required
        = for abuse of control or gaming in general
        = for abuse of equal access provisions
        = quick and easy system of penalties necessary
        => financial consequences
        => imposition of limitation on new registrations or registrar entity
        => de-accreditation in severe or repeated cases

6)No preliminary Competition Authority approval 
	- it will prove impossible to obtain for practical reasons 
	- would cause further delay
7) Registry Service Providers (Outsourced tech):
     - RSP (back end) can be registrar: yes
         - in "own" TLD: yes
     - RSP (front end) can be registrar: yes
         - in "own" TLD: yes



--

Should you have any further questions, please do not hesitate to contact us.

Best regards,

Volker A. Greimann
- legal department -

Key-Systems GmbH
Prager Ring 4-12
DE-66482 Zweibruecken
Tel.: +49 (0) 6332 - 79 18 85
Fax.: +49 (0) 6332 - 79 18 61
Email: vgreimann@xxxxxxxxxxxxxxx

Web: www.key-systems.net / www.RRPproxy.net
www.domaindiscount24.com / www.BrandShelter.com

Follow us on Twitter or join our fan community on Facebook and stay updated:
www.key-systems.net/facebook
www.twitter.com/key_systems

CEO: Alexander Siffrin
Registration No.: HR B 1861 - Zweibruecken
V.A.T. ID.: DE211006534

This e-mail and its attachments is intended only for the person to whom it is 
addressed. Furthermore it is not permitted to publish any content of this 
email. You must not use, disclose, copy, print or rely on this e-mail. If an 
addressing or transmission error has misdirected this e-mail, kindly notify the 
author by replying to this e-mail or contacting us by telephone.