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 >