Subject: Re: [CPWG] DNS Abuse PDP – Structural & Economic Considerations

Dear Mike, Alan, and Claire,

Thank you for the thoughtful interventions. Allow me to respond to each point directly and practically.

1. On the alignment (or misalignment) between Registries and Registrars (Alan’s point)

You are correct—Registries and Registrars were structurally separated because their incentives are fundamentally different.

The obvious implication is this:
If policy development begins treating them as aligned or interchangeable, the system risks losing its built-in checks and balances.

Proper handling:

Policy discussions must explicitly acknowledge these divergent incentives
Impact assessments should be conducted separately for Registries and Registrars
Any consensus claims should clearly distinguish whether alignment is real or assumed

Blurring these roles doesn’t simplify governance—it weakens it.

2. On ICANN’s lack of comprehensive economic analysis (Mike’s point)

The concern here is straightforward: decisions affecting a global naming monopoly are being made without a transparent economic baseline.

That’s not just a gap—it’s a governance risk.

Proper handling:

A formal, independent economic study should be commissioned covering:
- Pricing structures across Registries and Registrars
- Market entry barriers for new gTLD applicants
- Downstream cost impacts on end users
Findings should be publicly available and used as a reference point for future PDPs

You cannot regulate what you have not properly measured.

3. On vertical integration and unilateral Board decisions

The issue isn’t just the decision—it’s the absence of a documented, transparent justification.

When structural changes are made without economic and legal analysis, trust erodes.

Proper handling:

Any future structural changes should require:
- Published economic impact assessments
- Legal review summaries
- Community consultation before implementation
Retrospectively, it would be appropriate to review the outcomes of vertical integration with actual data

If decisions shape the market, they must be accountable to it.

4. On registrar-imposed listing/marketing fees (“silent tax”)

This is a classic case of cost shifting within the value chain—often invisible to new entrants.

The reality is simple:
If fees are not transparent, they distort competition.

Proper handling:

Introduce transparency requirements for all registry–registrar commercial terms that materially affect market access
Consider standardized disclosure frameworks for TLD applicants
Evaluate whether such fees create anti-competitive effects

If it impacts entry, it must be visible.

5. On “do not enrage the channel” and innovation constraints

If innovation is being informally discouraged to maintain operational convenience, that’s a systemic issue—not just a cultural one.

Especially when, as noted, some TLDs demonstrate zero DNS abuse, this should be a signal for differentiation—not suppression.

Proper handling:

Recognize and reward high-performing TLDs (e.g., low or zero abuse rates)
Allow differentiated registry models rather than enforcing uniformity
Encourage registrar participation in innovation instead of passive resistance

A system that penalizes excellence eventually standardizes mediocrity.

6. On the proposal for an economic fact-finding effort

This is probably the most actionable point raised.

The need is clear:
Without evidence, discussions remain theoretical.

Proper handling:

Establish a structured, community-supported fact-finding initiative
Define scope clearly (pricing, abuse mitigation costs, integration effects, market barriers)
Ensure outputs are documented, verifiable, and usable in PDP processes

If there are insights to uncover, they should be formalized—not anecdotal.

Closing Thought

At its core, this discussion highlights a recurring issue:
Policy is moving faster than structured evidence and institutional accountability.

The fix is not complicated—
Measure properly, disclose transparently, and decide collectively.

Everything else is noise.

Kind regards,

Chubasco Maximus Diranga
AMOC Stratum Tech Solutions

“Simple, genuine goodness is the best capital to found the business of this life upon. It lasts when fame and money fail, and is the only riches we can take out of this world with us.”

On Thu, Apr 9, 2026 at 10:28 AM mike palage.com via CPWG <cpwg@icann.org> wrote:

Alan,

This is one of the reasons I have repeatedly been beating the drum about ICANN’s failure to undertake a comprehensive economic study of the unique identifiers that ICANN holds a monopoly over through the IANA function.

On the issue of vertical integration, the ICANN Board acted unilaterally in approving the change and has never undertaken a proper economic or legal analysis of its decision. The listing/marketing fees that Registrars are imposing on Registry Operators are a silent tax on prospective TLD applicants that most do not fully appreciate.

Reading between the lines of the CPH Summit session on "do not enrage the channel" basically discourages innovation at the Registry Level. Instead of applauding the ZERO instances of DNS abuse in fTLDs TLDs, most Registrars do not want to be bothered. They just want all Registries to be the same cookie-cutter business model.

Anyone up for an economic fact-finding excursion? I know where the bodies are buried. I just need some help digging them up and documenting them.

Best regards,

Michael

From: Alan Greenberg <greenberg.alan@gmail.com>
Date: Wednesday, April 8, 2026 at 4:19 PM
To: mike palage.com <mike@palage.com>
Cc: ICANN At-Large Staff via CPWG <cpwg@icann.org>
Subject: Re: [CPWG] DNS Abuse PDP

Sadly, I tend to agree with Mike. Eons ago when the GNSO Council was reorganized, one of the rationales for two SG (Rr and Ry) was that their interests were different. Vertical integration reduced that, but the overriding consideration that Registries do not want to go against their customers was and has been largely ignored. It takes something VERY important to Registries to disagree with Registrars. Generally, they either agree, or simply stay quiet.

That results in a pretty impenetrable barrier.

Alan

On Wed, Apr 8, 2026 at 12:29 PM mike palage.com via CPWG <cpwg@icann.org> wrote:

Hello Claire,

I just wanted to document my Zoom intervention on today’s CPWG call here via the mailing list to hopefully spur additional discussion.

Claire I will document my concerns here and in the CPWG mailing list. Louie Touton’s original General Counsel had a saying that ICANN’s mission is to protect competition, not individual competitors’ business models. All too often in ICANN’s current PDP, Registrars and Registrars flex their de facto veto authority at the GNSO to impede real, meaningful change. Why this is BAD for ICANN is that it demonstrates that certain aspects of ICANN’s multistakeholder model have been captured, thus leaving disenfranchised members to resort to national laws, see NIS2, Chinese Real Name Verification, India litigation, etc.

Sadly, one can see the handwriting on the wall on how this PDP will end, and one needs to look no further back in history than the transfer PDP. The registrars will get almost everything they want, and ALAC will get some consolation footnote about addressing their concerns in future work.

Registrars will be out in force in this PDP as they are the tip of the Abuse spear since most Registries have now gone thin. Registries will largely remain silent because they do not want to alienate their channel or incur higher listing/placement fees. In fact, the importance of Registries NOT upsetting their Registrar channel is a topic of an upcoming session at the ICANN Contractual Party Summit, see https://cpsummit2026.sched.com/event/2GbE1/how-to-engage-and-not-enrage-the-channel

Thoughts? Comments?

Best regards,

Michael

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