Eric, in line with recognizing initiative coming from the grass-roots and since I have noticed support at NARALO level, I have asked At-Large staff to liaise with ICANN policy staff about this, since the deadline for comments was today. I am happy to announce that we have been kindly given the ability to file an ALAC Statement in time for the Board to consider it during their retreat, if we file it by June 18th, even though it is past the public comments deadline. Seth will set-up a Wiki page and will be liaising with you and Beau Brendler in order to get a proposed first draft up for At-Large comment as soon as possible, and we'll have a comment period open until Sunday 15th May. If it gets support, we'll submit an ALAC Statement. Kind regards, Olivier Crépin-Leblond ALAC Chair On 09/05/2011 23:41, Eric Brunner-Williams wrote :

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@icann.org. Forward as you see fit.

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