Hi,

Personally I am hoping that they do not get exception from the RCC.  While I approve of a ICANN Staff decision that Registries could register as many names for their own use as possible, I don't expect this.  By and large I am against exceptions.

Another question I have is user/consumer rights.  If there is no RAA, will the users of these closed TLDs have any recourse?  I do not know the answer, but most user's issue resolution seems to stem from the RAA and not the Registry agreement.  Maybe the existence of PICS with their access for 3rd party complaint will be significant, but I don't know if the closed are offering PICs.  Should check.

So what will be the recourse for the user/consumer complaint on a closed TLD?  I think until that is well understood, care should be taken in abrogating the requirements for a registrar.

avri


On 12 Mar 2013, at 23:59, David Cake wrote:

> I think the official position is that if they have a registrar, they are required to communicate with their registrar by EPP, but I think the assumption is also that closed generics have no registrar and are claiming the exemption to the RCC to that effect. The RCC does say that if you have a registrar, you have to actually use them for the majority of registrations, even if it is the registry themselves that is the registrant. 
> 
> I have no heard yet of anyone who intends to have a separate registrar, but make the registration conditions so tight as to be effectively a single registrant domain. 
> 
> So, as far as I am aware, closed for the purposes of this discussion is the same as 'registry with no registrar', even though that might not be a close fit to the more general use of closed. 
> 
> Regards
> 	David
> 
> On 13/03/2013, at 11:47 AM, Avri Doria <[log in to unmask]> wrote:
> 
>> Hi,
>> 
>> They would need to have an interface to any outside registrar who wanted to meet their constraints and conditions because the Registry Code of Conduct requirements say they need to be.   Unless of course they get an exceptions, which it looks like ICANN will at least consider.  
>> 
>> 
>> And of course there are probably lots of ways to do it, including Timothe's pigeons, but the easiest and cleanest way of doing it as far as I know is EPP.  Since I beleive they are required to use EPP anyway.
>> 
>> I know rules rules rules.  But this is ICANN, if you incant the words to the right entity, there is always an exception or extra privilege to be had.
>> 
>> avri
>> 
>> 
>> 
>> On 12 Mar 2013, at 22:17, Horacio T. Cadiz wrote:
>> 
>>> On 03/12/2013 01:56 AM, Avri Doria wrote:
>>>> Hi,
>>>> 
>>>> As a mental exercise, what are the technical implications and risks of private/restricted TLDs other than the addition of EPP functionality for confirming when a registration is allowed?
>>> 
>>> For closed TLDs (brand or generic), why would they need EPP if they themselves
>>> plan to run their own registrars?
>>> 
>>> I see no logic why a dotBrand, say .IBM, would need to go through an outside
>>> registrar for the company to register domains for its own use.
>>> 
>>> For closed generics, if one agrees with the premise that registration is restricted to those approved by the registry, why would the registry
>>> need an external registrar at all?
>>> 
>>> 
>>> 
>>> -- 
>>> Bombim Cadiz
>>> *****************************************
>>> *  Free/Open Source Software (FOSS) --  *
>>> * No windows. No gates. It is open.     *
>>> * No Bill. It is Free.                  *
>>> *****************************************
>>> 
>