[At-Large] Fwd: Comment on proposal for the removal of existing gTLD-Registrar cross-ownership.

Christopher Wilkinson cw at christopherwilkinson.eu
Mon Jun 4 07:53:20 UTC 2012

Dear Alan:

I share your concerns. There should be an ALAC comment.
If the removal of gTLD Registry/Registrar cross-ownership restrictions  
is applied retroactively to existing operators, that radically changes  
the DNS business model.
Including aspects of competition policy for which ICANN is responsible.

Thanks and Regards


On 04 Jun 2012, at 01:06, Alan Greenberg wrote:

> Note the following note sent to the ALAC list.
> Alan
>> To: ALAC Working List <alac at atlarge-lists.icann.org>
>> From: Alan Greenberg <alan.greenberg at mcgill.ca>
>> Subject: Comment on proposal for the removal of existing
>> gTLD-Registrar cross-ownership .
>> 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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