Re: [gnso-vi-feb10] RE: A Call to Harms

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

Dear Jeff,

thank you for the clarification.

I agree with the assessment that there is no inherent harm or automatic 
benefit to consumers in CO/VI. We propose to not include a limitation as 
long as the necessary controls and correctives are in place in order to 
allow for a multitude of new gTLD options, paired with sanctions against 
abuse. Controlled freedom over restrictions, in effect.
A - if not the - principal control instrument in my view is the use of 
registrars with guaranteed equal access as expressed in our proposal. 
The implementation of recommendation 19 is an easily verifyable 
condition that will allow VI/CO registries to be a viable option with 
the interests of consumers.
If I take as an example the current .SE regime, where IIS (the registry) 
owns and operates SE-Direct (a registrar in all effects), and sells the 
domains in the TLD at little over wholesale prices to registrants, yet 
we are able to market .SE successfully to our customers by providing 
easier access, better service or just the convenience of purchasing a 
multitude of TLDs in one place. We do not see any harm to consumers or 
even ourselves caused by this VI-model. This would however be different 
if registrar access were limited or barred. Equal access to the TLD 
allows us to serve our customers better.
I agree that VI/CO models without registrar access may be possible, but 
they will be much harder to monitor against abuse. It makes sense to me 
to maintain the equal access provision as the best and strongest 
corrective. In many cases of DotObscure, the registry will remain the 
only registrar selling the domain even though others are theoretically 
able to do so as well.
> Nothing in and of itself is harmful just the same as nothing in and of itself 
> is beneficial.  All of it involves possibilities.  For example, allowing VI/CO 
> does not automatically mean there will be innovation or consumer benefits.  
> Similarly, allowing VI/CO does not automatically mean there will be harms.
>
> And as the economists said yesterday (and many times before that), the use of registrars in general does not automatically have consumer benefits.  In fact, in many cases, absent market power, there are a number of detrimental effects of requiring equal access among registrars for consumers.  
>
> So, I understand your desire as a registrar to be allowed to own both a 
> registry and registrar, but are you also willing to do away with the equal 
> access requirements as well as the requirement to have to use ICANN-accredited 
> registrars in the first place.
>
> If you are truly willing to do this, then I would be happy to discuss your 
> proposal for open VI/CO on a serious basis.  If you are only willing to open up 
> the registry side, but not touch the registrar side, then I think we have some 
> more work to do.
>
> Thanks.
>
> Jeffrey J. Neuman 
> Neustar, Inc. / Vice President, Law & Policy
>
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> -----Original Message-----
> From: owner-gnso-vi-feb10@xxxxxxxxx [mailto:owner-gnso-vi-feb10@xxxxxxxxx] On 
> Behalf Of Volker Greimann - Key-Systems GmbH
> Sent: Friday, April 30, 2010 8:26 AM
> To: gn >> "'Gnso-vi-feb10@xxxxxxxxx'"
> Subject: Re: [gnso-vi-feb10] RE: A Call to Harms
>
>
> Hi Jeff,
>
> just for clarification:
>
> Do you feel, as you write, that VI/CO _does_ have harmful effects, or 
> just that it _can_ have harmful effects?
> If it is the latter, would you not agree that instead of limiting every 
> new registry inrterested in VI/CO models it would be much more sensible 
> to just prevent those harmful effects?
>   
> > I did not want this group to delve into these issues because frankly 
> > some of us feel like VI/CO does have harmful effects, some do not.  We 
> > are not going to change minds here in this group.  We are trying to 
> > find compromise.  Simply bringing up these old arguments about the 
> > harms and benefits of integration is in my mind not a useful exercise 
> > until we can actually have real studies done by non-interested parties 
> > (which is a long term objective).
> > Jeffrey J. Neuman
> >
> > Neustar, Inc. / Vice President, Law & Policy
> >
> >     
> --
>
> Best regards,
>
> Volker A. Greimann
>
> Key-Systems GmbH
>
>
>   

--


Best regards,

Volker A. Greimann

Key-Systems GmbH