Re: [gnso-vi-feb10] refined version of Roberto's bullet-points -- pls review/comment within 24 hours
- To: "Mike O'Connor" <mike@xxxxxxxxxx>
- Subject: Re: [gnso-vi-feb10] refined version of Roberto's bullet-points -- pls review/comment within 24 hours
- From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
- Date: Mon, 25 Oct 2010 18:36:05 -0400
On 10/25/10 2:33 PM, Mike O'Connor wrote:
• Compliance is key (the working group spent a considerable amount of
time discussing the issue). Whatever the rules established for the new TLDs, we need
adequate leadership, processes and resources in place to enforce them;
Please note that we do not have consensus on this point.
We have approached the issue of how to prevent abuse, as argued to
exist, either by Staff (Kurt's note to CRAI, Kurt via voca on several
occasions, Corporate General and Deputy Counsel on one occasion,
External Counsel (Joe Sims) on one occasion), or by the Board, or by
end user advocates, competing contractual parties, and non-contractual
parties) from the perspective that any registrar and any (within some
broad "types") registry and compliance over the transactions between
the "any registrar" and the "some registry".
We have not approached the issue of whether abuse equally exists
across all registrars, Brett's point, and mine, and possibly that of
other registrars, that what I'll call "prudent registrars" have a
record that calls for less "compliance" than what I'll call "imprudent
We've been arguing for "types" of registries: standard,
community-based, SRSU(s), linguistic and cultural, orphan, ...
We've been arguing for a typeless registrars, so eNom's Nth shell
registrar is the same as GoDaddy is the same as ...
Transactional compliance is a big burden, and failing to distinguish
between registrar risk and business models may not be the lowest
overall cost and complexity path to careful integration of registrar
function and registry functions.
So I'd like to see "adequate leadership, processes and resources"
changed to "reasonable goals, adequate staffing, risk informed
processes and resources"
• There is no consensus on either full vertical integration or full
• We have compiled a list of potential harms that may be associated with
either complete separation or complete integration. We have not finalized the list, we
have not focused on potential harms associated with partial integration or separation,
and we do not have consensus on the list we do have.
• While the WG has not identified exact examples (although some cases
like cultural TLDs or brand TLDs have been discussed), there is a general feeling that
some exceptions could be granted.
The advocates for brands really need to start the process to get their
application type clearly defined and proposed through process so that
community comment is available.