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Re: [soac-newgtldapsup-wg] On the continuity instrument
- To: Alan Greenberg <alan.greenberg@xxxxxxxxx>
- Subject: Re: [soac-newgtldapsup-wg] On the continuity instrument
- From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
- Date: Mon, 13 Dec 2010 20:10:01 -0500
The DAG requirement puzzles me.
A community-based registry has no obvious alternative for registrants
to re-brand to, Richard Tindale's hypothesis for the three year goal.
A registry contemplating entering "continuity operations" could
voluntarily transfer its good will and registry contract and related
assets (sell, a la Geir's sale of .name to VGRS), and if so, what is
the point, or the fate of, the significant cash value of the deposit
(in either of the two forms described in the addenda to Module 2)?
The DAG requirement clearly envision the continued operation of all of
the registry functions, not necessarily with no new registrations, but
with no continued operations by the operational staff, or within the
operational facilities, of the "continued registry". It is a
performance bond for no-cost-to-acquire transfer of the registry
assets, less its physical infrastructure and labor contracts, left
intentionally breached, to the acquiring operator.
If a registry is located in Reston, as .biz was, and fails, as .biz
would have had the NANPA revenues not been available, we don't have an
issue if the continuity plan moves all the .biz assets from one part
of Reston to another and VGRS provides continuity operations.
However, our applicants are outside of Reston and it is not consistent
with the diversity interest if "continuity" becomes the means by which
millions of dollars raised from, or on behalf of, developing
economies, are placed in escrow in US banks, and together with all
good will and registration assets, given to registry operators in the
highly developed economies. Stealing from the poor shouldn't be so
convoluted if that is the policy goal to be realized.
Eric
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