Go Daddy Comments

[Tim Ruiz <tim@xxxxxxxxxxx>]

Appendix S allows for the Sponsor to register 5,000 names directly with
the Registry Operator. We believe it is inappropriate to allow MuseDoma
to circumvent its contractual requirement to use ICANN Accredited
Registrars.

Recent events have made it crystal clear that serious problems can arise
when Registrars are not held to their obligations under their
accreditation agreement with ICANN, and that better enforcement
mechanisms need to be put in place. Given the recent comments on this
topic posted by ICANN's President and CEO, Paul Twomey, it amazes us
that ICANN would even consider the use of non-accredited organizations
for domain name registration, organizations that are not obligated to
abide by the same rules as accredited registrars.

ICANN must maintain the ability to formulate and enforce policy and
standards regarding the registration system for all TLDs under its
purview. If the Sponsor feels the need for additional distribution
channels, it can well be accomplished within the established registrar
accreditation framework.

If any exception is to made, we suggest that the Sponsor be allowed to
establish its own registrar accreditation through which it can provide
the services and support it feels is missing from its current Registrar
partners. This can be done and still maintain established principles of
non-discriminatory conduct and confidentiality.

Tim Ruiz
Vice President
Corp. Development & Policy
GoDaddy.com