Re: [gnso-vi-feb10] RE: Proposed draft message to ICANN staff

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

Hello,

I wholeheartedly agree to the statement of Jeff E.

Full integration and X-ownership is possible provided appropriate 
penalties as well as checks are in place. It will make no economic sense 
for a new gTLD registry to violate their obligations if it will cost 
them their TLD at the end of the day. Preventing full integration and 
X-ownership as a model entirely _will_ restrict certain applicants from 
applying and therefore be contrary to the interest of promoting 
competition. It makes no sense to treat round 1 differently from round 
2, as round 1 will be the decicive round for many applications and by 
excluding certain applicants in the first round, we effectively exclude 
them altogether. Yes, we will have more experience after one round, but 
by that time, the damage to free competition and innovation will already 
have been done in favor of the incumbent providers and against the 
newcomers.
> While I understand you want to move forward, I do not think that we 
> can throw our hands up and say we are not going to get it perfect so 
> lets not deal with it.  By not addressing this issue, I strongly 
> believe there will be harm to applicants and more important their 
> intended users, the consumers.  
>
> If this WG decides to restrict competition and put in a model that is 
> currently in place for a majority of TLDs (com, net) it will keep out 
> many applicants because they will be restricted from applying. This 
> will limit the innovation and options that consumers will have to 
> choose from and not the best outcome for end users.
> What if there are four Registry applicants for .charity, but three of 
> them have co-ownership with a Registrar so they are now restricted 
> from applying for this string. What if the three have innovative 
> solutions with giveback programs and support from large charitable 
> groups and the independent TLD applicant is only in it for the 
> revenue.  Are we best serving the community by letting the 
> unaffiliated applicant sail through ?  
>
> I do agree with you that we will not solve every single issue, but I 
> think the issue of VI/CO is a major issue and is directly linked to 
> the initiation of new applications.  It is really a decision on 
> whether or not to let a whole class of applicants compete for TLDs in 
> this first round and it  must be solved before we can open the round 
> since there will only be one .web , one .blog and we cannot start 
> applications before we figure this out. 
>
> I think this should motivate us further to come to a compromise as 
> soon as possible so that we can launch new gTLDs ASAP.  Look forward 
> to working towards an agreeable resolution on this
--

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

Best regards,

Volker A. Greimann

Key-Systems GmbH