On 06/03/2013, at 1:12 AM, Milton L Mueller <[log in to unmask]> wrote:

> Ron:
> 
>> -----Original Message-----
>> 
>> i am not diametrically opposed to many of the points raised, but am
>> conflicted on details outside the scope of the statement such as the
>> extreme cost for registry qualifications that are uncompetitive since they
>> constrain applicants to large organizations where i have felt that the
>> running of a gtld could be handled by a reasonably technically copentent
>> small group (or even individual) and if they fail, i don't see how the
> 
> We are in violent agreement on that, but that issue is orthogonal to the closed generic issue. It is true that some of the critics of closed generics, who typically want to impose ever-higher obligations and requirements on TLD registries, whether in the name of "public interest" or "security" or "stability," have created and are continuing to create a situation where registry operation is needlessly limited to a small number of very large (and very politically well-connected) providers.

	I am in thorough agreement that this argument is largely orthogonal to the closed generics argument. The arguments against closed generics are all focussed on the issue of who gets to be a registrant (though admittedly, registrars are not making that argument without an obvious interest). ICANN is supposed to be more than an industry competition regulatory body, and arguments based only on entry to market of new registry service providers are weak on their own, when compared to arguments regarding potential registrants. 

	And even regarding technical restrictions on registrants it is largely a side issue in any case. Requirements on potential registrants to .bank that they implement DNSSEC etc are nothing compared to policies requiring that the registrants prove that they are a bank, for example. For open registries, the requirements to provide trademark related services are a FAR bigger burden than any of the technical requirements.
	Personally, while I have some sympathy for the argument that the various restrictions on becoming a newGTLD are much, much higher and more prescriptive than they should be (while acknowledging that those debates have already been have), I think focussing on the security and stability requirements as the problem rather than trademark and financial compliance etc would be a grievous tactical error, greatly broadening the opposition to the argument while easily amenable to mischaracterisation ("Milton wants to make the internet less secure"). 

	FWIW, though - there are a few operators attempting to use the newGTLD process to break the cosy registry services oligopoly up somewhat. It can be done by small teams. Cloud Registry in Sydney, for example, are a small, new, operation. I wish them much luck. Being a registry should be a relatively simple process from a technical point of view, without compromising security or stability in any significant way. Now, operating a new GTLD registry in a way that will satisfy the IPC, that is a different story. 

	Cheers
		David