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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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