[At-Large] Request to have a Fast Track PDP initiated

Eric Brunner-Williams ebw at abenaki.wabanaki.net
Tue Nov 30 12:59:49 UTC 2010


I saw your note last night on the NA-Discuss list and thought about it 
over night.

The subject came up at the December 2008 meeting in Washington, held 
at the offices of Wilmer Hale (courtesy Becky Burr). At that meeting a 
proposal was first made in response to the then hot-off-the-press 
report from Charles River Associates -- the CRAI Report -- and its 
recommendations that later resulted in the Vertical Integration PDP.

The proposal was a new registry could have an exception from 
Recommendation 19 (use of accredited registrars, equal access) for the 
first 100,000 units of inventory.

Immediately the participants, representing registries and registrars, 
as well as non-contractual parties, realized that proposals of this 
form would be likely result in "bulk premium names" exploits.

Because of the language in ICP-1, and RFC 1591, I don't think that it 
is necessarily the case that public interest, even if the public is 
the public which uses Cyrillic script and has a reliance, one the 
IANA, and then ICANN have fostered for 15 years, may be ignored.

Because RU-Center (IANA #439) is a contracted party, it is reasonable 
to ask how the RAA, or the current or proposed Registry Agreements, 
bear on the conduct of contracted party also engaged in ccTLD 

I would like to see much more detail, and will make a point of meeting 
with persons likely to be helpful for information gathering purposes 
next week in Cartagena.

I suspect that the outcome of the VI PDP is relevant, that is, as the 
Board adopted the position that structural separation is no longer 
necessary, if some monitoring is present, that a similar outcome will 
result. I don't regard the VI result as good policy outcome, but it 
may be controlling on questions of pricing behavior by integrated 
entities. However, I don't want to spend time on a process issue 
before we have an incident report.


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