comments to lac dns mkt report

[Carlos Neira <carlos@xxxxxxxxx>]

Dear Icann, pls find below my comments.

With respect to the "chapter" on  The Sales Channel...

Not sure if the report is losing sight that, other than the interest in 
developing their domestic markets,  registrars are incorporated in 
countries such as Panama, or Belize, taking advantage of tax benefits 
offered by those countries.
Although the evidence presented shows that RAA is a probable cause of 
the weakening of the channel,  I believe it is only one  of several 
factors that has contributed to this.
I believe the biggest inhibitor to growing the channel is reluctance of 
the ccTLDs to open up their operation to the sales channel, even for 
their domestic market.   As you mention in your report, most of them 
sell direct to customers.  Other than the investment to be able to offer 
an EPP connection, opening up to the sales channel will mean giving up 
direct sales, and also "sacrificing"  margin to give room to the 
Registrar to operate,  something they are not used to or willing to do.
Thanks for the interest in the Latin American market and for the chance 
to comment.
Regards,

Carlos Neira