Re: [ALAC] Comment on proposal for the removal of existing gTLD-Registrar cross-ownership .
In light of Evan's comment, have made a change to the statement. Not exactly what he suggested, but I think in the same direction. I note that if a comment is to be submited by the ALAC, even a preliminary one, it must be done in the next 22 hours. 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. However, the ALAC does have one major concern with the proposal. The option for existing gTLD operators to transition to the new gTLD agreement would remove cross-ownership constraints, but it would also have a very significant other effect that has not been the subject of virtually any public discussion. Specifically, it would remove the price caps in the existing agreements, and that is not something that should quietly be slipped in without careful analysis. 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.
Dear Alan, thank you for your kind follow-up on this. I understand that this was a short comment period but have so far only see positive feedback about the text. With today being the deadline for submitting comments and with only positive feedback received both on the ALAC but also the wider At-Large list, I have given the green light for staff proceed as follows TODAY: - submit this final version to the public comment process, with a note that the statement is currently undergoing ALAC ratification, - create a wiki page for the comment with the first draft of your text and the final version, as submitted, - cut/paste all comments received on the ALAC and the At-Large lists and display them as a comment on this Wiki page. This process ensures a better transparency and archiving of the discussion for future reference, if needed. Kind regards, Olivier On 06/06/2012 04:15, Alan Greenberg wrote :
In light of Evan's comment, have made a change to the statement. Not exactly what he suggested, but I think in the same direction.
I note that if a comment is to be submited by the ALAC, even a preliminary one, it must be done in the next 22 hours.
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.
However, the ALAC does have one major concern with the proposal. The option for existing gTLD operators to transition to the new gTLD agreement would remove cross-ownership constraints, but it would also have a very significant other effect that has not been the subject of virtually any public discussion. Specifically, it would remove the price caps in the existing agreements, and that is not something that should quietly be slipped in without careful analysis.
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.
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
-- Olivier MJ Crépin-Leblond, PhD http://www.gih.com/ocl.html
On 6 June 2012 03:53, Olivier MJ Crepin-Leblond <ocl@gih.com> wrote:
thank you for your kind follow-up on this. I understand that this was a short comment period but have so far only see positive feedback about the text.
That said, I'm still ambiguous about the wording. Apparently, we're concerned about the price cap, but not enough to affect our approval of the policy. Tacking on "major" is IMO pointless. Either the issue is significant enough for ALAC to make support conditional on maintaining price controls, or it isn't. The wording of the statement allows our advice to be comfortably accepted as "support" and the trailer concern ignored. The policy can be revisited after the gTLD rollout and we can determine if monopoly power still exists. It's not likely I would vote in favour of the statement as worded. But I'm just one vote. - Evan
With today being the deadline for submitting comments and with only positive feedback received both on the ALAC but also the wider At-Large list, I have given the green light for staff proceed as follows TODAY:
- submit this final version to the public comment process, with a note that the statement is currently undergoing ALAC ratification, - create a wiki page for the comment with the first draft of your text and the final version, as submitted, - cut/paste all comments received on the ALAC and the At-Large lists and display them as a comment on this Wiki page.
This process ensures a better transparency and archiving of the discussion for future reference, if needed.
Kind regards,
Olivier
On 06/06/2012 04:15, Alan Greenberg wrote :
In light of Evan's comment, have made a change to the statement. Not exactly what he suggested, but I think in the same direction.
I note that if a comment is to be submited by the ALAC, even a preliminary one, it must be done in the next 22 hours.
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.
However, the ALAC does have one major concern with the proposal. The option for existing gTLD operators to transition to the new gTLD agreement would remove cross-ownership constraints, but it would also have a very significant other effect that has not been the subject of virtually any public discussion. Specifically, it would remove the price caps in the existing agreements, and that is not something that should quietly be slipped in without careful analysis.
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.
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
-- Olivier MJ Crépin-Leblond, PhD http://www.gih.com/ocl.html
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
-- Evan Leibovitch Toronto Canada Em: evan at telly dot org Sk: evanleibovitch Tw: el56
*Evan just brought out an aspect I had not noticed. So I too would request the change he is suggesting.* *Jean-Jacques. * 2012/6/6 Evan Leibovitch <evan@telly.org>
On 6 June 2012 03:53, Olivier MJ Crepin-Leblond <ocl@gih.com> wrote:
thank you for your kind follow-up on this. I understand that this was a short comment period but have so far only see positive feedback about the text.
That said, I'm still ambiguous about the wording.
Apparently, we're concerned about the price cap, but not enough to affect our approval of the policy. Tacking on "major" is IMO pointless. Either the issue is significant enough for ALAC to make support conditional on maintaining price controls, or it isn't. The wording of the statement allows our advice to be comfortably accepted as "support" and the trailer concern ignored.
The policy can be revisited after the gTLD rollout and we can determine if monopoly power still exists.
It's not likely I would vote in favour of the statement as worded. But I'm just one vote.
- Evan
With today being the deadline for submitting comments and with only positive feedback received both on the ALAC but also the wider At-Large list, I have given the green light for staff proceed as follows TODAY:
- submit this final version to the public comment process, with a note that the statement is currently undergoing ALAC ratification, - create a wiki page for the comment with the first draft of your text and the final version, as submitted, - cut/paste all comments received on the ALAC and the At-Large lists and display them as a comment on this Wiki page.
This process ensures a better transparency and archiving of the discussion for future reference, if needed.
Kind regards,
Olivier
On 06/06/2012 04:15, Alan Greenberg wrote :
In light of Evan's comment, have made a change to the statement. Not exactly what he suggested, but I think in the same direction.
I note that if a comment is to be submited by the ALAC, even a preliminary one, it must be done in the next 22 hours.
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.
However, the ALAC does have one major concern with the proposal. The option for existing gTLD operators to transition to the new gTLD agreement would remove cross-ownership constraints, but it would also have a very significant other effect that has not been the subject of virtually any public discussion. Specifically, it would remove the price caps in the existing agreements, and that is not something that should quietly be slipped in without careful analysis.
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.
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:
https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
-- Olivier MJ Crépin-Leblond, PhD http://www.gih.com/ocl.html
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:
https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
-- Evan Leibovitch Toronto Canada
Em: evan at telly dot org Sk: evanleibovitch Tw: el56 _______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
participants (4)
-
Alan Greenberg -
Evan Leibovitch -
JJS -
Olivier MJ Crepin-Leblond