We have been given an absurdly short time frame to comment
on an ICANN staff report regarding a very complex issue: review 
of new registry services by ICANN.

In very brief form, the issue (as part of the fallout of Sitefinder)
is whether ICANN should review every attempt of registries
to introduce new services. The GNSO has been asked to make
a policy on this. 

Here is my proposed statement. Please give me your
opinion by today. I apologize for the short time frame.

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NCUC believes that the draft "catalogue of issues" 
on new registry services prepared by ICANN staff is 
acceptable. We are concerned, however, that the 
number and complexity of the issues posed are too
numerous for a single PDP.

NCUC believes that the focus of a process be not be
on prior review of new services, but on improving 
registry contracts to heighten technical and stability 
considerations.

As a user constituency, NCUC believes that contracts 
should be strengthened to prevent registries from 
exploiting user switching costs to make technical 
changes that might affect the service users receive
from a registry. 

We believe that improved contracts and after-the-fact 
challenge and review of services is preferable to a
before-the-fact approval process, which is likely to
be anti-competitive, anti-innovative, and bureaucratic.