[ALAC] Comment on proposal for the removal of existing gTLD-Registrar cross-ownership .

[JJS]

*Alan, Holly, +1.*
*Jean-Jacques.
*
2012/6/4 Holly Raiche <h.raiche at internode.on.net>

> Hi Alan
>
> Thanks for this comment.  It does pick up the one concern that was raised
> and I"d support it being used.
>
> Holly
> On 04/06/2012, at 9:05 AM, Alan Greenberg wrote:
>
> > I was asked to evaluate whether a comment of the Proposed Revised
> > Process for Handling Requests for Removal of Cross-Ownership
> > Restrictions on Operators of Existing gTLDs warrants ALAC comment,
> > and if so to draft such a comment. Following consultation with
> > selected ALAC and At-Large members, I believe that a comment is
> warranted.
> >
> > Unfortunately other commitments have prevented me from submitting
> > such a comment until today, and the first stage of the comment period
> > ends on June 6th.
> >
> > I would suggest that if there is no substantive ALAC request to not
> > submit this comment, that it be submitted prior to the deadline with
> > the stated proviso that it is undergoing ALAC comment and approval.
> > That would allow the ALAC to revise it if needed, and accept or
> > reject it prior to the conclusion of the 2nd phase of the comment period.
> >
> > The details of the proposal and comment period are at
> >
> http://www.icann.org/en/news/public-comment/revised-cross-ownership-restrictions-16may12-en.htm
> .
> >
> > My concern is that one of the options provided is that existing
> > registry operators (and specifically .com, .net and .org) can either
> > request amendment of their agreements to remove cross-ownership
> > restrictions, or can transition  to the agreement to be used by all
> > new gTLD operators. If they chose the latter path, along with the
> > removal  of the restrictions on cross ownership, they would also
> > remove the price caps that are in existing agreements. This I feel
> > could be of great detriment to Internet users.
> >
> > My proposed comment follows.
> >
> > Alan
> > ==========================
> >
> > The ALAC and At-Large have multiple opinions on whether the removal
> > of Cross-Ownership Restrictions for gTLD Operators will be to the
> > benefit or detriment of users, or in fact, the domain ecosystem.
> > There is, however, a unified position that whatever the environment
> > is, with certain constraints, there should be a level playing field
> > for all gTLD operators.
> >
> > As such, the ALAC supports the removal of cross-ownership constraints
> > for existing gTLD operators.
> >
> > Nevertheless, the ALAC does have one concern with the proposal, and
> > that is the option for existing gTLD operators to transition to the
> > new gTLD agreement. That transition would be subject to limits
> > related to competition issues raised by the removal of the
> > cross-ownership restrictions. The document is silent on other results
> > of such a transition, and particularly the removal of price caps on
> > existing operators.
> >
> > The ALAC does not believe that there is sufficient proof at this time
> > to indicate that the new gTLD environment will so significantly
> > change the gTLD market so that price caps are no longer required for
> > the dominant gTLDs. As such, no change driven by the removal of
> > cross-ownership restrictions should at the same time remove the price
> > caps in the current agreements for dominant gTLDs without substantive
> > community involvement.
> >
> > _______________________________________________
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> >
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>
>
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