As noted last Friday, the BC executive committee drafted clarifications to the Sep-209 BC position on vertical integration. Below I’ve summarized comments from members that influenced the clarifications that were filed by the BC today: - Philip Sheppard agreed with the clarifications. (significant, since he was Rapporteur for Sep-2009 position) - John Berard has larger concerns, but ended saying the “status quo position is acceptable” - Ron Andruff offered several in-line edits. ‘Therefore, the BC position should be interpreted as opposing changes to any separation safeguards, including not more than 15% financial investments between any two structural entities.’ This implies that the BC assumed registrars should not own more than 15% of registries. - Ron Andruff also noted that the WG would resist our clarification about single registrant with multiple users. Mike Rodenbaugh and Fred Felman replied that the BC should nonetheless press our case. - Marilyn Cade noted that this comment is just for clarification of our Sep-2009 position, so it cannot be expanded to cover additional topics. That discsussion should, however, be part of ongoing BC policy position development. - Mike, Ron, and John had further exchange regarding SRSU/SRMU, all of which can be useful in further work, but would not be a clarification of our Sep-2009 positions. - Konstantin Kladouras (ETNO) supported the draft clarifications, but noted that we did not allow enough time for trade associations to react to draft comments. - Marilyn Cade asked for documentation for my assertion that a dot-brand should be able to manage domains for its “business partners, agents, and subcontractors”. Since I could not locate written documentation for this, we struck this from our clarification. Attached is the comment that the BC Executive Committee filed today. The cover note is shown below: The Business Constituency (BC) already has an approved position on Vertical Integration (VI), which was posted in Sep-2009. However, The executive committee of the BC believes that the BC needs to add clarifications of our Sep-2009 position in order to make it more relevant the VI Working Group’s initial draft report: 1. clarify what the BC meant by “status quo” in our statement “the BC opposes any change to the status quo for all TLDs intended for sale to third parties” 2. clarify what the BC meant by “internal use” in our statement “The BC believes that uniquely for domain names intended for internal use, the principle of registry-registrar vertical separation should be waived.” 3. encourage continued work to define eligibility and scope for dot-brand (single registrant) exceptions. We drafted a comment along these lines and have posted it here. Steve DelBianco Vice chair for policy coordination ICANN Business Constituency