Danny, I saw your note last night on the NA-Discuss list and thought about it over night. The subject came up at the December 2008 meeting in Washington, held at the offices of Wilmer Hale (courtesy Becky Burr). At that meeting a proposal was first made in response to the then hot-off-the-press report from Charles River Associates -- the CRAI Report -- and its recommendations that later resulted in the Vertical Integration PDP. The proposal was a new registry could have an exception from Recommendation 19 (use of accredited registrars, equal access) for the first 100,000 units of inventory. Immediately the participants, representing registries and registrars, as well as non-contractual parties, realized that proposals of this form would be likely result in "bulk premium names" exploits. Because of the language in ICP-1, and RFC 1591, I don't think that it is necessarily the case that public interest, even if the public is the public which uses Cyrillic script and has a reliance, one the IANA, and then ICANN have fostered for 15 years, may be ignored. Because RU-Center (IANA #439) is a contracted party, it is reasonable to ask how the RAA, or the current or proposed Registry Agreements, bear on the conduct of contracted party also engaged in ccTLD registrations. I would like to see much more detail, and will make a point of meeting with persons likely to be helpful for information gathering purposes next week in Cartagena. I suspect that the outcome of the VI PDP is relevant, that is, as the Board adopted the position that structural separation is no longer necessary, if some monitoring is present, that a similar outcome will result. I don't regard the VI result as good policy outcome, but it may be controlling on questions of pricing behavior by integrated entities. However, I don't want to spend time on a process issue before we have an incident report. Eric