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-restrict.... 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.
Hi Alan Thanks for this comment. It does pick up the one concern that was raised and I"d support it being used. Holly On 04/06/2012, at 9:05 AM, Alan Greenberg wrote:
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-restrict....
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.
_______________________________________________ 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...)
*Alan, Holly, +1.* *Jean-Jacques. * 2012/6/4 Holly Raiche <h.raiche@internode.on.net>
Hi Alan
Thanks for this comment. It does pick up the one concern that was raised and I"d support it being used.
Holly On 04/06/2012, at 9:05 AM, Alan Greenberg wrote:
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-restrict... .
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.
_______________________________________________ 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...)
_______________________________________________ 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...)
I will support this Statement. - Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Sun, Jun 3, 2012 at 6:05 PM, Alan Greenberg <alan.greenberg@mcgill.ca>wrote:
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-restrict... .
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.
_______________________________________________ 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...)
Hi Alan, Thanks for doing this. I agree with your rationale ... so much so, in fact, that I would strengthen the ALAC comment in line with it. So, instead of saying "the ALAC supports the removal of cross-ownership constraints for existing
gTLD operators. Nevertheless, [we don't like the prospect of removal of price caps]"
I would suggest "the ALAC supports the removal of cross-ownership constraints for existing
gTLD operators, on the condition that existing regulations related to price caps are left unchanged."
(or something like that). In other words, I would link our support to the promise to leave the price caps untouched. - Evan On 3 June 2012 19:05, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
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-restrict... .
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.
_______________________________________________ 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
+1 this has my support in particular the caveat that price caps be not removed. We have enough hurdles without creating even more of one for developing economies playing catch up on the issues of Internet real estate. TT On Mon, Jun 4, 2012 at 6:36 AM, Evan Leibovitch <evan@telly.org> wrote:
Hi Alan,
Thanks for doing this. I agree with your rationale ... so much so, in fact, that I would strengthen the ALAC comment in line with it.
So, instead of saying
"the ALAC supports the removal of cross-ownership constraints for existing
gTLD operators. Nevertheless, [we don't like the prospect of removal of price caps]"
I would suggest
"the ALAC supports the removal of cross-ownership constraints for existing
gTLD operators, on the condition that existing regulations related to price caps are left unchanged."
(or something like that).
In other words, I would link our support to the promise to leave the price caps untouched.
- Evan
On 3 June 2012 19:05, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
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-restrict...
.
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.
_______________________________________________ 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...)
-- Mrs. Titi Akinsanmi Consultant/Researcher Mobile: +27 83 300 7105 titi.akinsanmi@gmail.com Impacting My Generation
participants (6)
-
Alan Greenberg -
Carlton Samuels -
Evan Leibovitch -
Holly Raiche -
JJS -
Titi Akinsanmi