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Re: [gnso-vi-feb10] Revised SRSU text

  • To: Milton L Mueller <mueller@xxxxxxx>
  • Subject: Re: [gnso-vi-feb10] Revised SRSU text
  • From: Stéphane Van Gelder <stephane.vangelder@xxxxxxxxx>
  • Date: Tue, 20 Jul 2010 09:36:42 +0200

I would just shorten that to "SRSU has substantial support" and consider that a 
fair representation of the opinions within this group. But I don't think it's 
useful to make the assertions you make in the rest of the sentence. Whether 
those assertions are true or not helps very little in the context of the final 
report. However, I agree those who oppose the concept of SRSU might want their 
opposition noted in the report.

Stéphane

Le 20 juil. 2010 à 05:22, Milton L Mueller a écrit :

> 
> Tim,
> Your 4-point summary is pretty good, except for #3. 
> 
> The report should note that SRSU has substantial support; in particular, we 
> should point out that representatives from both user Stakeholder Groups are 
> solidly behind it; and that the main opposition to SRSU comes from incumbent 
> registries and registrars who are concerned about its competitive 
> implications. Even so, some prospective registries also support the notion. 
> 
> --MM
> 
>> -----Original Message-----
>> From: owner-gnso-vi-feb10@xxxxxxxxx [mailto:owner-gnso-vi-
>> feb10@xxxxxxxxx] On Behalf Of Tim Ruiz
>> Sent: Monday, July 19, 2010 6:57 PM
>> To: gnso-vi-feb10@xxxxxxxxx
>> Subject: RE: [gnso-vi-feb10] Revised SRSU text
>> 
>> 
>> There's been a lot of discussion about the compliance piece, so I guess
>> if we get more detailed about that, it's fine. But here is what I would
>> prefer to see in the report regarding Exceptions, SRSU, and compliance:
>> 
>> "It is impossible to know or completely understand all potential
>> business models that may be represented by new gTLD applicants. That
>> fact has been an obstacle to finding consensus on policy that defines
>> clear, bright line rules for allowing vertical integration and a
>> compliance framework to support it while ensuring that such policy is
>> practical and beneficial in the public interest. However, there is
>> general acceptance within the Working Group for the following:
>> 
>> 1. Certain new gTLDs likely to be applied for in the first round will be
>> unnecessarily impacted by restrictions on cross-ownership or control
>> between registrar and registry.
>> 
>> 2. The need for a process that would allow applicants to request
>> exceptions and be considered on a case by case basis. The reasons for
>> exceptions and the conditions under which exceptions would be allowed,
>> varied widely in the group.
>> 
>> 3. The concept of Single Registrant Single User should be explored
>> further.
>> 
>> 4. The need for enhanced compliance efforts and the need for a detailed
>> compliance plan in relation to the new gTLD program in general."
>> 
>> All of the details on above are so new that I don't see how consensus
>> can truly be determined, especially when some of it is still be created
>> and edited. Otherwise, I have no doubt that when the report is finally
>> posted there will be edits or other material included that some of us
>> will not have had the chance to even see. If we go with the above we can
>> close those three things off pretty quickly.
>> 
>> 
>> Tim
>> 
>> 
>> -------- Original Message --------
>> Subject: Re: [gnso-vi-feb10] Revised SRSU text
>> From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
>> Date: Mon, July 19, 2010 5:14 pm
>> To: "Rosette, Kristina" <krosette@xxxxxxx>,
>> "Gnso-vi-feb10@xxxxxxxxx" <Gnso-vi-feb10@xxxxxxxxx>
>> 
>> 
>> Kristina,
>> 
>> Comments on the SRSU text. The form is call and response.
>> 
>> Eric
>> 
>> Page 1, Para 1, sentence 3:
>> "Within the VI Working Group, there was a general endorsement of the
>> idea of an SRSU exception."
>> 
>> I suggest qualifying this by observing that advocates for policy
>> choices other than broad continuity included an SRSU exception,
>> explicit in proposals which otherwise contained conditional
>> cross-ownership language, and implicit in proposals which removed
>> cross-ownership restriction, and that in the Brussels meeting period,
>> when compromises were attempted, a limited exception to Recommendation
>> 19 was offered by the advocates for broad policy continuity.
>> 
>> I know it is a lot more words and takes away from the punch of the
>> claim, but it could be more useful to show which policy advocates
>> found common cause with the committed SRSU policy advocates.
>> 
>> Para 2, sentence 2:
>> "... that satisfied additional criteria intended to limit the
>> applicability of the exceptions and to discourage abuse and gaming of
>> the exceptions."
>> 
>> This is advocacy. Please consider cutting it.
>> 
>> Para 2, Types of SRSU exceptions, sentence 3:
>> "Several WG participants who are members of the Non-Commercial
>> Stakeholders Group proposed an SRSU exception for non-governmental
>> organization registries (NGOs) (referred to as .ngo registry) ..."
>> 
>> I have no issue with calling attention to the SG affiliation of any
>> advocate, but implicit in this is something false. The previous
>> sentence has the IPC as a body making a proposal based upon real
>> self-interest. This sentence elevates the association of these WG
>> participants who are members of the NC SG as advocates for NGOs as
>> recipients of a broad cross-ownership and/or Recommendation 19
>> exception, and implicitly their interests, to the same level as the
>> IPC and its membership of brand owners.
>> 
>> This association is false unless there are one or more NGOs which
>> authorized these NC SG members to act on their behalf, as brand owners
>> have authorized their IPC SG members, to pursue indistinguishable ends.
>> 
>> Has any NGO asked for an exception? The Red Cross contacted CORE and
>> it did not, to the best of my knowledge, ask for a SRSU exception. It
>> asked for a fraud solution and brand protection application, which is
>> not a registration policy so narrow as to admit only one registrant.
>> 
>> We are not talking about the interests of imaginary brands. We are not
>> allowing random people to claim "they speak for XYZ Corp and its
>> portfolio of brands". We should not entertain claims so conjectural as
>> a claim that some VI WG volunteer may appropriate the good name of
>> some public interest entity to advance claims that lack any other basis.
>> 
>> The requirement that a policy advocate represents an actual applicant
>> is something that can't be satisfied now, it has to have been
>> demonstrable when the policy was first advocated.
>> 
>> Para 2, Types of SRSU exceptions, sentence 4.
>> 
>> Please consider cutting this. If you and I, who've both been watching
>> this issue like hawks, can't think of the reason, it isn't enough to
>> add to the word count.
>> 
>> Page 2, para 1, sentence 1:
>> 
>> This is advocacy. Please consider cutting it.
>> 
>> Para 1, sentence 2:
>> 
>> This is advocacy. Please consider cutting it.
>> 
>> Para 1, sentence 3:
>> 
>> This is policy. Please don't cut it.
>> 
>> End.
>> 
> 
> 





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