Bayern Connect comments on Vertical Integration & Economic Studies

[Caspar von Veltheim <caspar.veltheim@xxxxxxxxxxxxxxxx>]

Dear ICANN Board,

First of all I like to thank ICANN for the opportunity to comment on the 
Proposed Final Applicant Guidebook. 

1) We are satisfied with the Cross-Ownership decision. ICANN had many good 
reasons to do so.
First of all, the community did not come to a consensus and it was time for 
ICANN to make a decision. The decision that was made is a natural one as the 
restrictions on cross-ownership are from an old era that helped to give some 
entities in the market place monopolist power. But with the growth of smaller 
registries and their need to market their TLDs directly to the desired 
community, the termination of this restriction will help to create a new and 
fair ecosystem of TLDs. Registries will be in fact not dependent on big 
registrars who have no real interest on promoting a TLD for a special 
community. The new rules will make it possible that a regsitry can navigate 
their customers to a registrar-site that actually deals with the desired TLD 
and its potential customers. Hence, this new system will be beneficial for the 
global internet community.

Additionally, the decision will benefit new gTLD applicants to make their TLD a 
success. This will support the whole progarm and reduce registry failure risk. 
In addition, potential trademark owners who like to apply (and we know there 
are going to be several) will not have to go to another company in order to 
register their own domain name that they just want for their own use anyway. 
Naturally, registrars will be able to apply for Top Level Domains by 
themselves. This decision on vertical integration is a natural one and ICANN 
has positioned itself as a globally orientated organisation that is willing to 
adapt with time and to enhance competition. 

2) Furthermore we want to support the view that many have argued before. 
Several economic studies have been made and a lot of financial resources have 
been spent. Economic studies will not help to figure out what exactly the 
benefits and costs are. Nobody can predict such thing. However, competition and 
consumer choice will be generated. In fact, the whole process has enhanced 
competition already among potential applicants. This is the best indication 
that there is an existing demand for new TLDs. 
Rather to analyse TLDs launched years ago, which was done in the last economic 
study, ICANN and the community should look at the recent success and launch of 
the IDN TLD for .ru and the .co TLD. The outcome has surprised all and even the 
registries behind these great projects.


Sincerely,



Caspar Veltheim


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Bayern Connect GmbH
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tel: +49 (0) 89 360 351 04
fax: +49 (0) 89 360 351 07
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mail: caspar.veltheim@xxxxxxxxxxxxxxxx


Geschäftsführer: Caspar von Veltheim  
HRB 177369 Amtsgericht München