Registrar-registry vertical integration

[Jorge Amodio]

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