[NA-Discuss] Public Comment on the .NET auto-renew, proposed contract extension for multiple technical providers
Eric Brunner-Williams
ebw at abenaki.wabanaki.net
Mon May 9 21:41:01 UTC 2011
Colleagues,
I'm submitting two comments, the SECOND of which follows, proposing
contract extension for multiple technical providers.
The public announcement is here:
http://icann.org/en/announcements/announcement-11apr11-en.htm
If anyone wants to co-sign, you'll have to explicitly let me know.
I'll be submitting the comment around 9am EDT tomorrow.
Begin:
The proposed changes to the .NET agreement, while of some utility, do
not address the core problem of monopoly power by the registry
operator. This is a hold-over from the May 1999 decision to create a
locus of competition in a separate registrar function, a decision
reversed in November 2010.
The contract should be changed to include language which separates the
formal Registry Operator (RO) functions (zone file signing, zone file
production from one or more distinct data sources, pointer data to
registrar held "thin registry" registrant data, registrar transfer
processing, registrar invoicing, ICANN reporting and transactional fee
processing and payment), from the Data Base Operator (DBO) (aka
"registry technical services") set of functions, allowing registrants,
through their registrars, to select the underlying competitive DBO for
a given domain.
The means to allow the .NET contract to be modified, allowing a
second, and subsequent Data Base Operators to provide database service
to the Registry Operator, is now necessary, in light of the removal of
structural separation requirement for legacy contracts.
No specific set-aside for ROOT-SERVERS.NET is necessary under a
stability and security theory, as the root server operators are
capable of designating whether they seek to use a DBO other than the
current unique DBO.
An additional extension to EPP will be necessary, to allow registrants
to select, through the registrar function, their choice of DBO to have
custody of their data.
It is possible that the registrars with a large number of domains, or
other mature database operators, including the operators of other
registries, also currently contractually constrained as monopolies,
will seek to become Competitive Data Base Operators (CDBOs) for the
.NET registry, transforming over 10% of the gTLD domain market from
monopoly to competition.
The default choice of many users may remain Verisign, the legacy
monopoly registry entity. However, where competition is possible, and
competition among back-end registry service providers within a single
name space is possible, it must be allowed if the competition policy
goal is to be achieved in the current decade.
End
To be sent to net-agreement-renewal at icann.org. Forward as you see fit.
Eric
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