[gnso-vi-feb10] Demand Media support of Neustar position

[Jeff Eckhaus <eckhaus@xxxxxxxxxxxxxxx>]

I would like to thank Jeff Neuman and Neustar for advocating a position that is 
a compromise and a position that Demand Media supports and most others can get 
behind. Neustar could have easily have taken the anti-competitive position that 
Afilias and their spokespeople have taken and started making claims of harms by 
using terms like EPP commands and DNS queries, but they actually studied the 
issue and the implications of allowing a type of cross-ownership. Rather than 
assume that a single class of potential applicants (registrars) will willfully 
violate ICANN rules, Neustar looks at actual potential harms and who could 
commit them. 

The reason why I trust Neustar' s perspective on the concerns of registry data 
is that they are not only a registry provider for TLDs such as .biz and the 
United States  .us, but they also own Ultra DNS,  a leading managed DNS 
provider. On top of that Neustar is the authorative database for telephone 
number resources in North America.  I do not believe they take the issues of 
data sharing and security lightly and have truly studied the issue before 
stating  their position. As for the others who are claiming harms it is as Jeff 
Neuman stated "we have not seen any evidence of potential harms cross TLDs nor 
have we heard a justification for it" .  

I believe that the Neustar position as stated below is a true compromise 
between proposals and a way forward, as it allows for the introduction of real 
competition and innovation while maintaining consumer protections, security and 
stability. 



Regards,

Jeff Eckhaus


On Fri, Jun 4, 2010 at 11:01 AM, Neuman, Jeff <Jeff.Neuman@xxxxxxxxxx> wrote:
> All,
>
>
>
> I just wanted to go on the record with Neustar’s concerns over a 
> strict interpretation of the “Afilias/PIR/Go-Daddy/Some ALAC members” 
> proposal.  As you know from the beginning, Neustar has opposed the 
> complete vertical integration of registries and registrars because of 
> all of the harms to registrants that have been previously expressed in 
> letters we have helped co-author as well as the damaging effect on 
> ensuring a level-competitive playing field amongst registries, registrars, 
> back-end operators, etc.
> However, our concerns have been confined to the vertical 
> integration/cross-ownership within a TLD as opposed to a general 
> notion of cross ownership.  What I mean is that we have never 
> supported the notion that a registry or back-end registry operator 
> could not distribute domain names in a TLD for which it was not the 
> registry or back-end operator.  This is not necessarily because 
> Neustar wants to be a registrar, reseller or distributor for .com, 
> .net or any new TLDs, but rather that we do not see any justification 
> or any potential harms that would occur cross TLDs.  In fact, we 
> believe that Afilias’ proposal would have the effect of preventing any 
> existing registrar or reseller from becoming a registry or back-end operator 
> in any TLD even if they agree not to distribute names in that TLD.
>
>
>
> To us, that is by definition anti-competitive and would unnecessarily 
> restrict new entrants into the registry/back-end registry service 
> provider market without any justification.  Similarly, it would 
> restrict new entrants into the registrar market as well simply because 
> they serve as a registry in a separate TLD.    Preventing a Demand 
> Media, Network Solutions, GoDaddy, Tucows, GMO or any registrar from 
> being in the registry business completely is not what Neustar had in 
> mind and is not something we can or should get behind.  Similarly, 
> preventing an existing or future registry/registry service provider 
> from becoming a registrar or reseller in other TLDs is not what we have 
> advocated.
>
>
>
> To summarize, I do believe strongly in strict limits to vertical 
> integration and cross ownership within a TLD and believe that without 
> such limits and protections, consumers and registrants will be harmed.  
> I know there are others that dispute that and that is something we 
> will work in the long term.  But we have not seen any evidence of 
> potential harms cross TLDs nor have we heard a justification for it.  
> I prefer the JN2 Proposal because it contemplates this scenario.  The 
> only way we could support another proposal like the Afilias one, is to 
> address the cross TLD issue.
>
>
>
> P.S. – we know the ICANN proposal is similar to the Afilias one in 
> this respect and therefore will probably be making the same comments to the 
> DAG.
>
>
>
> Jeffrey J. Neuman
> Neustar, Inc. / Vice President, Law & Policy
> 46000 Center Oak Plaza Sterling, VA 20166
> Office: +1.571.434.5772  Mobile: +1.202.549.5079  Fax: +1.703.738.7965 
> / jeff.neuman@xxxxxxxxxxx  / www.neustar.biz
>
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