Thanks for catching those typos/mistakes. 

Milton Mueller
Professor, Syracuse University School of Information Studies
XS4All Professor, Delft University of Technology
------------------------------
Internet Governance Project:
http://internetgovernance.org
 

> -----Original Message-----
> From: Jorge Amodio [mailto:[log in to unmask]] 
> Sent: Wednesday, August 26, 2009 8:34 PM
> To: Milton L Mueller
> Cc: [log in to unmask]
> Subject: Re: Registrar-registry vertical integration
> 
> Two quick comments about the recommendations.
> 
> > 1.      Recommendation 1 was that single organization TLDs 
> (for example, .ibm or .bbc) should be permitted to operate 
> both the registry and the registrar that sells second-level 
> domain name subscriptions.
> > Because single-organization TLDs are basically a new 
> phenomenon, we do not consider this to be a major policy 
> change and thus we favor making this exception and 
> incorporating it into the implementation of the new gTLD 
> round. There might be substantial demand for internalizing a 
> major corporation's or organizations' domain names under a 
> single, self-provided TLD. It is not realistic and serves no 
> public interest to force these organizations to use 
> third-party registrars. Indeed, such a policy might 
> compromise the security of these organizations. There are no 
> competition policy issues raised by this change, as long as 
> the organization's use of the TLD is confined to its own 
> internal departments, employees and units.
> 
> If the use of the TLD is confined within the boundaries of the
> organization the recommendation
> is valid, but on the first sentence you wrote "registrar that sells
> second-level domain..", this
> type of organization should NOT sell second-level domain names, and if
> they wish to do so
> they should open the registrar process to other registries providing
> equal competitive terms.
> 
> > 2.      Second, CRA proposes that a registry may own a 
> registrar so long as the wholly-owned registrar does not sell 
> second-level domain names subscriptions in the TLDs operated 
> by the registrar.
> 
> It should say "operated by the registry"
> 
> > This, in our opinion, is a reasonable recommendation. 
> Nevertheless, it is a policy change (it alters the policy 
> governing the commercial terms and conditions applicable to 
> existing gTLD registries and registrars) and should therefore 
> be part of a new policy proceeding in the GNSO. Thus, action 
> on this should be deferred until the GNSO resolves it.
> 
> While vertical integration in the cases stated above make sense, a
> policy change that
> fundamentally changes the rules of the game should go through the
> GNSO, if not, as I
> said in my previous message ICANN will be violating several of its
> core values as
> stated in the bylaws.
> 
> My .02
> 
> Warm Regards
> Jorge
>