Dear Registrars: Background: 1. We have been told by ICANN that one of the major reasons for the large increase in total budget is the demands by the Department of Commerce (DOC). 2. It appears that we registrars are the source of last resort for ICANN. That is, every dollar beyond what they can collect from registries (including ccTLD registries) and a few other sources must be collected from registrars. 3. A significant number of ICANN Accredited Registrars are small businesses. 4. Small businesses under the rules of the U.S. Small Business Administration (SBA) are defined based upon the business type. 5. These classifications are found in the SBA web site: https://eweb1.sba.gov/naics/dsp_naicslist2.cfm http://www.sba.gov/size/summary-whatis.html https://eweb1.sba.gov/naics/dsp_naicssearch2.cfm The last seems to be the best for our purposes. The best fit appears to be as follows: Information Technology Value Added Resellers NAICS Code 541519 Not to exceed 150 employees SIC Code 7379 NAICS code 541519 has two other entries which have the limit of not to exceed US$21,000,000. annual turn over. The Small Business classification also appears to apply to any small business with at least one office in the United States. 6. I suspect that many ICANN Accredited Registrars constitute "small businesses" within the SBA rules. Action: 1. I propose that we survey our members and determine which may be classified as small businesses. 2. I propose that Small Business registrars then appeal to the SBA to obtain relief from the excessive burden resulting from the DOC demands upon ICANN. I am undertaking this endeavor in my capacity as representative of PSI-Japan, Inc., not wearing my Secretary hat. Please respond to me directly, with or without copying <registrars@dnso.org>. Regards, BobC