We wish to make a comment regarding the interlocking issues of the portion of the .net fee that goes to ICANN and the issue of registry equivalence.
While Section 4 of the .net RFP talks of a $0.75 fee payable to ICANN for each registration year it does not identify whether this is an absolute number or merely a minimum.
We would expect some bidders to wish to submit bids with fees to ICANN well in excess of $0.75. Our concern with this would be the unclear concept of "registry equivalency".
In our view "registry equivalency", while desirable, is made very difficult due to the different histories of each of the various tlds. We believe that any submission for the .net registry should be explicitly encouraged to provide amounts in excess of $0.75 per registration year. This could be accomplished by simply changing the wording in the relevant section(s) to read "no less than $0.75".
Elliot Noss CEO, Tucows Inc.