Roberto:
Let me begin by stating our points of agreement. As I stated
in my last
email, I believe there should be a presumption of using the
current
registrar distribution model for all registries. I believe
in reading
your comments, you might find a "stronger"
presumption in favor of using
the current registrar distribution. The reason I submitted
my comments
with regard to Recommendation #19 was that there was no
latitude/flexibility to discuss varying levels of
presumption just a
simple black and white rule. As we saw during our time on
the Board in
connection with the 2004 sTLD round, black and white
analysis rarely
works. That is why the original sTLD evaluation committees
only approved
2 out of the 10 applicants (.POST and .CAT) and why the
ICANN Board had
to intervene in connection with (.TRAVEL. .JOBS, .MOBI,
.ASIA, and
.TEL).
I fully agree that registries which have strict verification
criteria
are generally more suitable to potentially overcome the
presumption that
I have discussed. That is because the heightened levels of
verification
generally discourage registrars from investing the time and
money to
build systems to interface with these registries, and these
heightened
levels of verification also generally result in lower
numbers of
registrations. In fact according to my quick back of the
napkin
calculations, the only sTLD with over 50,000 registrations
is .MOBI. In
fact most of the sTLDs are under 10,000, numbers that I
believe are
comparable to the .EDU, .GOV, .MIL and .INT TLDs that I
referenced.
As I previously stated, my initial thinking was to look
toward a black
and white numerical threshold by which registries could seek
an
exemption. While this would work for most of the current
registries in
today's marketplace (i.e. .MUSEUM) it would not scale to
address every
possible scenario. That is why I have been an advocate of
the rebuttable
presumption. It sends a clear message to potential
applicants that there
is a presumption in favor of the existing registrar/registry
dichotomy.
In fact I am even personally open to dialog about wording
along the
lines of a strong presumption. I just know that the absolute
black and
white rule contained in Recommendation #19 will not scale
and will fail
in the next round. That is why I am trying to socialize this
idea of
taking a different look at the situation.
I agree that registrars have done a lot within the existing
.COM, .ORG
and .NET gTLDs to decrease costs and spur innovation, that
is why in my
answer to Elliot I do not see any justification in today's
market to
allow a registry such as VeriSign to go direct.
As Eric said on the list, I think there is a lot of common
ground shared
by most of the people intelligently discussing this topic
and hopefully
this dialog will help encourage potential alternative
solutions to
maximize the common ground, and help provide for the best
criteria for
the next round of sTLDs.
Roberto, I hope this email provides some additional
clarification to my
original posting and finds some additional points of
commonality in our
thinking.
Best regards,
Michael
P.S. In the interst of continuing a positive dialog I
changed the
subject line to this thread
-----Original Message-----
From: owner-ga gnso.icann.org [mailto:owner-ga gnso.icann.org] On Behalf
Of Roberto Gaetano
Sent: Wednesday, September 05, 2007 3:41 AM
To: 'Michael D. Palage'; 'Nevett, Jonathon'; 'Danny
Younger';
ga gnso.icann.org
Subject: RE: [ga] GNSO Council: Taking 21 months to arrive
at bad
decisions
I am mostly a listener on this topic, and I am very
interested in
hearing the different opinions. Incidentally, it is
refreshing to read
something on this list that is related to DNS issues.
I have a comment related to Mike's post below:
> Obviously if a registry goes direct there is the need
for
> scrutiny to make sure that a registry does not abuse
its
> position as a sole source provider. However, as has
been
> demonstrated in the case of .EDU, .GOV, .MIL and .INT,
> consumers are not being harmed even though they are I
some
> cases paying higher per domain name registrant costs
than
> equivalent registrants in the .COM space.
There are striking differences to me between .EDU, .GOV,
.MIL, .INT, and
.COM. The first one is that everybody qualifies for the
latter, and very
few for the former. This is because there are strict rules
for the
former, and none for the latter. Connected with this, is the
fact that
the business model is quite different. I am not a registrar,
but if I
were one I would doubt that I would rely too much on
registrations under
.INT to ensure income for the company ;>). This simply
means that in
some cases the registry-registrar model would make, IMHO,
little sense.
And maybe .MUSEUM is, among the ICANN-introduced TLDs,
another example.
However, I think that we have to be extremely careful in
dropping the
model in the general case. For general purpose TLDs, or
generally
speaking for TLDs that do not have a market niche but are in
competition
among themselves (I am talking about cases like .COM, .ORG,
.NET, .INFO,
etc.) it would be extremely dangerous, IMHO, to have some of
them bound
by current contracts to the use of registrars, while others
would have
free hand.
Again, I am eager to listen, mine is not a position carved
in stone,
just food for thought.
Cheers,
Roberto
|
In keeping with the topic of alternative domain name
distribution models, I would like to put forth a
probable scenario.
Let's assume for a moment that Nii Quaynor is
passionate about launching the new gTLD .africa and
has managed to convince the UNDP to underwrite the
program on a non-profit basis so as to reduce as much
as possible for African registrants the financial
barriers to entry. Perhaps Nii seeks to utilize an
innovative DNAMES approach and plans to initially roll
out registration interfaces and customer service in
Swahili, Hausa, Yoruba, Wolof, Ibo, Fulani, and
Isizulu.
In keeping with the approach utilized by .asia
regarding the selection of registrars, he chooses to
set the requirement (1) "Demonstrated ability to
provide Eligibility and Name-Selection Services (ENS
Services) and demonstrated familiarity with the needs
of the TLD Community in the language and region(s)
served by the registrar, and established modes for
reflecting these needs in the ENS Services processes;"
and (2) that all such registrars be non-profit
entities so that registration costs will be kept at a
bare minimum.
The proposed requirement that all registries must use
only ICANN-accredited registrars will result in
.africa never being launched as no current
ICANN-accredited registrars would ever meet the
.africa registrar selection criteria.
On the other hand, Nii could certainly find local
registrars (not accredited by ICANN and that don't
have US$70,000 in reserve) that could readily serve
the needs of his community.
So, do we wish to stifle access and innovation by
denying Nii this opportunity (just to comply with a
poorly considered recommendation) or are we prepared
to admit that alternative models may indeed be viable?
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