.moi comment

["Konstantinos Zournas" <blue@xxxxxxxxxxxxx>]

(Please disregard my previous comment. It was sent by the wrong email
address.)



Amazon attempts to make one, but ultimately all, of its new extensions
restricted despite
<http://domainincite.com/18804-icann-bans-closed-generic-gtlds-for-now>
ICANN's ban on closed generic TLDs.

Amazon Registry Services, Inc., the Registry Operator of .MOI TLD, has filed
to ICANN a proposed amendment to the .MOI Registry Agreement.

More or less the amendment states that Amazon will be deciding who gets a
.moi domain name and most certainly the only ones approved will be the ones
that buy other products and services from Amazon before they are allowed to
register a domain.

A closed generic TLD is one where the registry doesn't allow anyone to
register a domain name except maybe a few selected partners. The extension
is solely operated by the registry and only the registry can register domain
names for its company use.

ICANN has opened a
<https://www.icann.org/public-comments/moi-registration-auth-2016-03-02-en>
Public Comment period about this issue that has a closing date in 2 days, 24
Apr 2016.

The title of the public comment "Launch of Registration Authentication
Platform for .MOI TLD" is rather misleading. The whole proposal is not about
authenticating domain registrants but rather NOT allowing anyone that Amazon
does not approve to register a .moi. The qualifications for approval are not
yet known.

The amendment requires the Registry Operator to provide, receive, and
validate authentication tokens from registrars via EPP. As part of this
Registry Service, the Registry Operator would also be permitted to offer
optional customer value products and/or services. As described in the
<https://www.icann.org/en/system/files/files/rsep-2014162-moi-request-21dec1
5-en.pdf> RSEP request:

The  Technology  Tools  can  be  acquired  from  hundreds  of  sources
other  than  the  Registry.    Indeed,  hundreds  (if  not thousands) of
companies that do not operate under contract with ICANN provide one or more
of the Technology Tools.  Similarly,  the  offering  of  ancillary  products
or  services  (other  than  Technology  Tools)  to  further  complement  the
customer's use  of  the  to-be-purchased  item  already  occurs  thousands
of  times  daily  on  a  wide-variety  of  third-party  sites  operated  by
entities that are not under contract with ICANN.

Amazon provides absolutely no explanation as to why it wants to perform
pre-registration policy verification for customers that wish to register
.MOI domain names.

.MOI is an open New gTLD and Amazon tries to circumvent this fact by
introducing questionable authentication tokens required for the registration
of domain names in the TLD.

Amazon says that the .MOI registration eligibility requirements will be
posted publicly before the .MOI Sunrise Period begins. This is simply not
acceptable as people and companies participating in the ICANN public comment
need to know the registration eligibility requirements to decide if this
proposed amendment to .MOI Registry Agreement is warranted or not. The fact
is that very few, if any, extensions would warrant such an amendment.

Amazon will only accept as registrants of .MOI domains the individuals or
companies that will first purchase products or services offered by Amazon.
Amazon says this is not a requirement but if it is not a requirement why is
it even mentioned in the ICANN proposed amendment?

Amazon  Registry  reached  out  to  several  registrars  to  have  general
discussions  about  their  experience  with  pre-registration policy
verification and how that experience (including customer experience) could
be improved.  Any consultations that may have  occurred  regarding  the
Technology  Tools  and  the  ancillary  products  and  services  would  have
occurred  subject  to  a Mutual Non-Disclosure Agreement and cannot be
disclosed.

If Amazon can't disclose anything, why even mention these discussions? This
only creates a lot of questions about Amazon's intentions.

What is so important about .MOI that makes it a different extension that all
the other hundreds extensions? Amazon offers no explanation as to what is so
special about .moi. What is it going to be used for?

.Moi doesn't seem to fall under the .bank or .pharmacy category. Most people
were opposed to any TLD being restricted and asking for .moi to be a closed
TLD is far reached.

Probably this request for .moi is simply a test to see how ICANN is going to
respond, so that Amazon can adjust accordingly its future request for more
important TLDs in Amazon's portfolio. Amazon that operated several new
extension will most surely ask ICANN for the same amendment for some of its
better TLDs such as .book, .buy, and .like.

All of Amazon's New gTLDs were supposed to be open for anyone to register a
domain name. Any attempt to close, restrict and limit any of those is
opposed to the NEW gTLD ICANN registry agreement.

Amazon is looking at a policy change that will be a workaround of the
closed-generic ban imposed by ICANN and could lead to other registries
asking for the same privilege.

Konstantinos Zournas

OnlineDomain.com





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