RE: [gnso-vi-feb10] Agenda item offer

["Neuman, Jeff" <Jeff.Neuman@xxxxxxxxxx>]

I have no objection to adding proposals to the agenda, but I fail to see how 
this reflects vertical integration of a REGISTRY and REGISTRAR.  It is merely 
the innerworkings of a registry which may or may not choose to outrource some 
of all of the registry functions to an RSP?  

Eric, are you saying that all registries from here on out must outsource and 
must outsource not just to one RSP, but to all entities wanting to be an RSP?  
Can you please explain how that notion would not violate some of the principles 
espoused by ICP-3 (http://www.icann.org/en/icp/icp-3.htm).  The corollary to 
your proposal by the way would then require CORE as a registrar to outsource 
all of its functions on equal non-discriminatory basis, and by extension would 
require any registrar that uses resellers to treat all resellers on an equal 
non-discriminatory basis. 

Personally, I do not think anyone believes we should go there.

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 Eric Brunner-Williams
Sent: Monday, May 10, 2010 10:04 AM
To: Gnso-vi-feb10@xxxxxxxxx
Subject: [gnso-vi-feb10] Agenda item offer


Co-Chairs,

As the portion of CORE's proposal for introducing competition in the
provider<->operator space, that is, removing vertical integration
constraints, first envisioned before ICANN was formed, hasn't gotten
any voice time (or showed up on any of the matrix efforts), I offer to
spend some few minutes doing advocate monologue and some more minutes
taking questions and comments.

Two items of mail to the list are excerpted below for convenience.

Quoting from my mail of the 2nd, which summarized the proposal in
"Zupke Matrix Form":

"65 Registry Operator (RO) to allow two or more Registry Back-End
Service Providers (RSP) to service provisioning.        

66 RO to provide equal access to RSP(s) from all registrars

67 RO to provide equal access to RSP(s) from all registrants, proxy
and direct

68 RO to provide equal access to RSP(s) for all Registry Services.

69 RO to allow two or more RSP(s) to publish on ports 41 and 80

70 RO to allow two or more RSP(s) to publish on port 53

71 RO to allow transfers of provisioned data between RSP(s) upon
request by the registrar of record.

72 RO to allow transfers of provisioned data between RSP(s) upon
request by the registrant."


Quoting from my mail of the 30th, which proposed this in narrative
form with some examples:

"I propose that registry back-end operators, current and prospective,
upon meeting some reasonable criteria for safety and security, be
allowed to offer registry back-end service for current, and
prospective, registries.

Roberto, you may recognize this as the original, IHAC period SRS
proposal, which then proposed to create the locus of competition in
the registry function, rather than in the registrar function.

This would mean, that to pick numbers arbitrarily, that a registry
operator would be able to offer .com registry service, through the
.com registry operator, in competition with the existing, monopoly
back end registry services operator for .com, to registrars, for $1
per domain year, in competition with the current pricing of $6 per
domain year.

The Vertical Integration policy recommendation is to require registry
operators to provide equal access to competitive registry back-end
operators, and to provide neutral pass-through pricing to registrars.

This proposal is distinct from all other current proposals, which
leave the registry function an unfied, monopoly held by the merged
back-end services provider and the registry operator.

As an example, CORE could provide registry back-end services for names
in .com, .net and .name, which the registrars could select, for
whatever reasons they, their resellers, the registrants or their
proxies, choose, price included.

Thank you for asking what was missing, we've focused on the registrar
and the consumer interest, and overlooked the registry and the
consumer interest."

This ends the two excerpts.

Eric