RE: [registrars] Further Comments on Final Report of the Transfer Task Force on the WLS proposal

["Ross Wm. Rader" <ross@tucows.com>]

> 
> I believe that provided that WLS is not involved in the 
> process after it is known that a domain name will be deleted 
> for certain, that it would not necessary result in any harm 
> to the consumer in terms of higher prices.  In terms of 
> competition, I still stand by my earlier comments that 
> competition will not be affected by the introduction of WLS 
> at any of the stages I have described above. A phase 
> introduction would initial allow WLS during the first of the 
> stages above, and then consider allowing it after the 
> expiration date of a domain name licence provided that the 
> expiration process is reviewed to ensure that it is 
> consistent across all registrars.
> 


Bruce - I'm not sure that I completely understand your proposal. Are you
advocating that names in a post-expiration grace period are treated
different than those that aren't (and are in a pre-expiry period?).
Would it not make more sense to address the treatment of names in a
post-expiration state through a standardized deletions practice rather
than through the commercial WLS proposition?

Also, I'd like your thought on the Transfers TF including language in
the recommendation that sets the stage for whatever precedent we are
about to set. It concerns me that the TF/DNSO may set a precedent
whereby Registry Services that create an undue benefit for the Registry
Operator due to an existing monopoly (that of control of the TLD) are
treated the same as those that do not. If we play things out a little
bit, I can see a situation whereby an offering like Neulevel's WhoBiz
would get painted with the same policy brush as Verisign's WLS. It would
certainly be my preference if the former was left outside of any ICANN
review (other than a cursory inspection to ensure that it did not fall
into the latter category). Those that fall into the latter category
would necessarily need a higher level of review to uphold ICANN's
mandate to promote competition.

I've reproduced an earlier message of mine on this subject that might
more clearly illustrate my thinking.

Thoughts?

"Its my read that the registry constituency is stuck between a rock and
a hard place.

Neulevel and Afilias have both (or are very close to) introducing a
number of new registry services. And you know what? None of them (that
I'm aware of at least) require access to the monopoly database in order
to be pushed out to the market. The problem with the policy debate thus
far is that it hasn't spent any time considering that there are registry
services that don't require a second look and those that do. My
preference is that the DNSO focus exclusively defining a policy that
strictly deals with the introduction of registry services that provide
the registry operator with undue benefit or preference because of their
monopoly control of the relevant TLD database. Those that don't benefit
from the control of the database should be simply included in the
contract by the staff without a second thought.

Hopefully this idea can get some traction before the board votes on the
subject. I fear that the registry constituency has been forced into an
uncomfortable spot because of this lack of granularity in the policy
examination."


                       -rwr

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