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

[Olivier MJ Crepin-Leblond]

Dear Alan,

thank you for your kind follow-up on this. I understand that this was a
short comment period but have so far only see positive feedback about
the text.  With today being the deadline for submitting comments and
with only positive feedback received both on the ALAC but also the wider
At-Large list, I have given the green light for staff proceed as follows
TODAY:

- submit this final version to the public comment process, with a note
that the statement is currently undergoing ALAC ratification,
- create a wiki page for the comment with the first draft of your text
and the final version, as submitted,
- cut/paste all comments received on the ALAC and the At-Large lists and
display them as a comment on this Wiki page.

This process ensures a better transparency and archiving of the
discussion for future reference, if needed.

Kind regards,

Olivier

On 06/06/2012 04:15, Alan Greenberg wrote :
> In light of Evan's comment, have made a change to the statement. Not 
> exactly what he suggested, but I think in the same direction.
>
> I note that if a comment is to be submited by the ALAC, even a 
> preliminary one, it must be done in the next 22 hours.
>
> 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.
>
> However, the ALAC does have one major concern with the proposal. The 
> option for existing gTLD operators to transition to the new gTLD 
> agreement would remove cross-ownership constraints, but it would also 
> have a very significant other effect that has not been the subject of 
> virtually any public discussion. Specifically, it would remove the 
> price caps in the existing agreements, and that is not something that 
> should quietly be slipped in without careful analysis.
>
> 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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>

-- 
Olivier MJ Crépin-Leblond, PhD
http://www.gih.com/ocl.html