Beau, The exploit has already begun, and will continue until at least the early operators transition through the Sunrise/Landrush/General-Availability set of phases and the "you can get ..." buzz fades due to either ease of true registration or the demand fades due to unforeseen consequences such as a large, simultanious set of registration choices. So the utility runs from not too long ago, through at least mid-2013. The harms are: o to ordinary registrants, that of capture by the "facilitating" registrar, akin to frontrunning, only it is the registrant, not the domain, which is subject to some degree of enticement or coersion, o to ordinary registrars, that of capturing by the "facilitating" regisrars, of future transactions with the captive registrants, o to policy-based applicants, that their policies are fictional and some third-party is capable of binding them to its "pre-sales" committments, or that pay-per-click, or porn, or latin script labels in an IDN name space are policy-consistenent, o to all applicants, that their fundraising, investment offers, and marketing are all dependent upon the actions of "facilitating" registrars. So there is consumer fraud, and it doesn't go away by observing, correctly, that some of the defrauded consumers are ad word buyers, who are utterly indifferent to who wins any contention, or what policy applies to a name space, so long as the ad word inventory they seek to acquire costs less than the revenue it is projected to return, and therefore not defrauded, as these are not all the parties targeted by "facilitiating" registrars for "pre-registration" enticements. There is also the interference with applicants, creating non-market, and non-contract (with ICANN and also with all registrars upon delegation) costs, which of necessity harms applicants, and therefore harms registrants. Eric