RE: [gnso-vi-feb10] SRSU
- To: Jeff Eckhaus <eckhaus@xxxxxxxxxxxxxxx>, "Gnso-vi-feb10@xxxxxxxxx" <Gnso-vi-feb10@xxxxxxxxx>
- Subject: RE: [gnso-vi-feb10] SRSU
- From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
- Date: Sat, 03 Jul 2010 16:52:46 -0400
Jeff, your description of resellers is once possibility, but there
are others. A "captive reseller" is my term for a reseller
substantially owned by a registrar or both owned by the same parent.
For an example of what I was referring to, see scenario b) in
I do not at this time favour any level of integration above the
nominal 15%, but that message proposed one possible set of
constraints (not yet fully fleshed out) that should be mandatory if
integration is ultimately allowed.
At 03/07/2010 03:23 PM, Jeff Eckhaus wrote:
I cannot seem to find the captive reseller example, but think it may
be worth explaining to the group how the reseller model works so
that there is clarity on the issue.
A domain reseller is an entity such as Google, Yahoo, Intuit, or
maybe a mom and pop hosting company that has an existing business
but would like to sell domains as a complementary part of their
business. They do not want to become ICANN accredited and do not
want to build a registrar system since that is not their core
competency. Some offer free domains as a loss leader for their main
business line and that is their business choice and allows consumers
a choice on how they acquire their domain name.
Any domain that a reseller registers lists the Registrar in the
whois record. So if XYZ hosting is a reseller of Network Solutions
than Netsol will come up in the whois record.
If in the proposed JN2 model a Registry owns Registrar X and applies
for .TLD, then Registrar X or any of its resellers cannot offer .TLD
through Registrar X. This is easy to monitor as I mentioned
previously since Registrar X would show up as the registrar of
record in the whois.
Now I know everyone can think real hard and think of an edge case
where there could be some secret agreements, but, do these
agreements have anything to do with cross ownership? If the co-owned
registrar and its affiliated registrars (if any) are restricted from
offering that TLD and can be verified in the whois, wouldn't any
harms from co-ownership be mitigated and be put into the same
situation if there was no co-ownership?
Right now it seems to me that we are willing to block out new
competition, market entrants and possible innovation even though we
have mitigated harms due to the minor possibility that an entity can
possibly think of a way around the normal process. Is this the best
decision for new TLDs? For consumers? That is what we really need to decide
Have a great weekend
From: Alan Greenberg [alan.greenberg@xxxxxxxxx]
Sent: Friday, July 02, 2010 1:54 PM
To: Jeff Eckhaus; Gnso-vi-feb10@xxxxxxxxx
Subject: RE: [gnso-vi-feb10] SRSU
See comments embedded. Alan
At 02/07/2010 02:34 PM, Jeff Eckhaus wrote:
>I also like the idea of exploring exceptions including the SRSU
>model as described below, but I have a more fundamental question on
>Why is there no question or discussion on compliance abilities with
>regard to SRSU or other exceptions but arms start flying when other
>types of co-ownership are brought up
I thought that Eric's message timestamped 2 Jul 2010 06:15:20 -0400
didjust raised just that issue.
>? When I look at the idea of a Registry being able to own a
>Registrar but not be able to sell the TLD it owns it is actually
>simple to monitor, since the Registrar and affiliates could not be
>accredited in that TLD. If it is not accredited it cannot register
>any names. With mandatory thick whois, the Registrar of record is
>displayed. All very easy to monitor.
And easy to circumvent. See my earlier example of how through the use
a captive resellers.
>The SRSU model (which I said is worth exploring) has an incredible
>number of moving parts that need to be monitored and by many
>estimates there are expected to be over 200 .brand TLDs, yet the
>compliance issues and harms are not brought up.
>What is it about .brand SRSU TLDs that make it easier to monitor and
>protect than another TLD that allows cross-ownership?