[gnso-vi-feb10] Comment on Vertical Integration

["Roberto Gaetano" <roberto@xxxxxxxxx>]

Peter,

As you know, we co-chair the Vertical Integration WG.

Our aim, as co-chairs, has been to reach consensus on a document that could
be useful input for the Board's imminent decisions on the deployment of new
TLDs. However, the report that will conclude Phase 1 of the process is still
being reworked, and the working group will not be able to send it to the
GNSO Council in time for the Council to make a decision (and formulate a
timely recommendation for the Board) in compliance with the GNSO PDP
process.

Thus, we would like to submit a few broad points to the attention of the
Board in our personal capacity.  We believe that the WG has worked hard and
has reached some agreement (although no consensus call has been made yet) on
the following points:

*       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, reasonable goals, appropriate levels of
staffing, risk informed processes and resources in place to enforce them;

*       There is no consensus on full vertical integration, complete
vertical separation, or any hybrid proposal to date;

*       The working group has 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, there is a general
feeling that some exceptions could be granted.

To the best of our knowledge, two Directors have been subscribing to the WG
list.   They can provide you and the rest of the Board with more details on
the process followed and the results achieved.

Please let us know if there is anything else that could be useful from our
side.

Best regards,

Roberto Gaetano
Mike O'Connor