Dear All,

The Registries Stakeholder Group [RySG] would like to propose a friendly amendment to the Vertical Integration Charter circulated by Stéphane.

For purposes of accuracy and consistency, we believe that Objective #4 should be revised to read: “To identify and clearly articulate the differences between the current restrictions and practices concerning registry-registrar separation and equivalent access, on the one hand, and the options described in the most recent version of the DAG and supporting documents^[1] and changes considered by staff, on the other hand.”

The words “equivalent access” in yellow would replace the words “equal access” that are in the current version of Objective #4. We understand that the Charter Group has recognized the difference between “equal access” and “equivalent access” in its deliberations and has adopted “equivalent access” in other parts of the Charter.

More generally, the RySG notes that the proposed working definitions in the Charter are neither accurate nor complete and, in certain cases, they represent policy statements.  The RySG underscores the importance of developing standalone definitions for each element of vertical integration.  However, these definitions should be developed by experts in competition and antitrust matters and derived from, where possible, language in ICANN contracts and ICANN documentation that uses the relevant terms.     

Many thanks.

Kind regards,

Caroline.

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^[1] The working group understands that the DAG is a fluid document.  As a result, the working group will conduct its activities based upon the version of the document available.