[bc-gnso] Comments from Marilyn Cade: Another Last Call: BC Position - Baseline Registry Operations Report

berrycobb at infinityportals.com berrycobb at infinityportals.com
Wed Mar 31 22:48:58 UTC 2010

Mariyln & CBUC,

I just crafted a nice response and then lost it on this crappy  
hospital network, because all I have right now is web based mail  
access.  Excuse ye being brief and if I sound rude that is not my  
intent, its frustration.

- Mariyln thank you for your feed back.  It was helpful and I included  
all but 2 points.  Attached is the latest draft for your review.

- Discussion Point 1 - I will be happy to include what is needed here.  
  However, I am confused by the reasoning supplied.  It only mentions  
why people may register domains in a ccTLD and not in reference to  
comparing an operating model from a ccTLD with other TLDs.  I  
understand the operating models to be drastically different both  
technically and in business operations.  I have very little experience  
here....so I am wide open for suggested language for the "Survey  

- Discussion Point 2 - Outsourcing of Compliance.  The study reveals  
that small Registries outsource their compliance.  It does not suggest  
that ICANN outsource its compliance.  Therefore, I think the last  
bullet with "Survey Demographics" in our position statement stands as  
is.  ICANN should take a close look as this to ensure it is done  
correctly.  I do not oppose outsourcing it, but doing so does increase  
risk and ICANN should have a pulse as to WHEN and HOW.

Thank you for the feedback again.  Please advise of any other changes.


Berry Cobb
infinity Portals LLC

Quoting Marilyn Cade <marilynscade at hotmail.com>:

> Barry, Steve,
> Thanks Barry, for your work on this.  I have a couple of   
> suggestions, and point out a couple of editorial changes that you   
> will want to make.  I provide several suggestions ,and put into bold  
>  some of the key words/and new proposed language to try to make this  
>  easier to understand and follow.
> Overall great job. A few critical changes proposed.
> For the longer term, I know that there are other discussions to be   
> had about a 'template'  or 'templates' for BC policy positions and,   
> I do hope that you will play a leadership role in that process.
> On the substance of this comment, I would suggest that you change   
> the legend on some of the elements to !. For instance, although the   
> category: "Reserves" says no comment, actually the BC does have a   
> comment. Capital Expenditures: says no comments, but does offer a   
> very important comment. Continuity Planning, legend says no comment,  
>  but we do have a comment.  I'd just suggest changing the legend to   
> "!", and editing out the /NO comment on those issues.
> Finally, I wanted to call your attention and others to the need to   
> have a category that is 'brands related gTLD registry'.  Youcould   
> add a footnote to 'registry population', noting that there may be a   
> category of registries that are operated by a brand holder, for   
> their subscribers, or employees, and that this category is not   
> addressed, to date, in ICANN's work.
> In the Survey Demographics section. The first bullet point needs to   
> have an edit in the last reference to the ccTLDs. it should read   
> "..... under different contractual obligations to ICANN than ccTLDs.  
>    I think you mean ... "than gTLDs".
> Discussion Point:  I spent a good deal of time studying ccTLDs when   
> I was chairing the first WHOIS Task Force. The working methods of   
> the cc's are indeed a good barometer for learning. Sometimes this is  
>  not well understood by business users who primarily register in  
> cc's  defensively.  And, there are other factors that limit the  
> exposure  of business users to the ccTLD managers -- e.g. while we  
> once held  dialogues with the cc's that has gone by the wayside and  
> the primary  focus is on the gTLDs.   And, then the reality is that  
> the gTLDs  registries often believe that they are the 'rightful  
> choice' for  back engines for future gTLDs and even for ccTLDs.  As  
> BC, we need  to agnostic about business preferences. Business uses  
> can register  in either gTLDs or ccTLDs and need to have a broadened  
> understanding  of the role and activities of the ccTLDs for many  
> reasons.  I'd  propose that we soften the comments about the cc's.
> For instance, I disagree with the proposal that the review of cc's   
> be limited to those  ccTLDs that mimic gTLDs -- I do not agree. That  
>  would eliminate .de; .uk, and .ca, and .cn, for example, all of   
> which are large and complex ccTLDS, often more complex and   
> technically sophisticated than many of the smaller gTLDs.  A few   
> cc's are marketed as 'global' TLDs, and that has disconcerted, or   
> annoyed some gTLD registries.  That is a perspective of gTLD   
> registries that may not not actually serve the broader global   
> business user communities' interest. For instance, if you are a   
> small Kenyan business, you may both prefer to register in .ky and   
> find advantage in doing so. You may also want to register in a gTLD   
> as well, however. Global business users are registering in ccTLDs in  
>  many cases to have identity in the country they are doing business   
> in.  Understanding cc's practices is a 'good thing'.
> I'd prefer to strike the statement "Perhaps ccTLDs that mimic a gTLD  
>  should be chosen'.  Instead, I'd propose that the BC statement  
> read:   The CBUC supports the inclusion of ccTLDs in this study and  
> is  interested in ensuring that the sample is fully representative  
> of  different practices and models, including analyzing different   
> 'sizes" of cc TLD registries.
> In your bullet about slide 4, the language seems to need some editing.
> Finally, I do not support ICANN's outsourcing of compliance, and I   
> suggest that the BC should not support that.  The present position   
> offered could be strengthened by changing the statement to proposed   
> new statement:
> "Enforcement and compliance should remain a primary function of   
> ICANN itself.  Outsourcing of such functions may create   
> vulnerabilities for ICANN to fulfull its core responsibilities and   
> any proposed outsourcing should be carefully studied, and the   
> subject of further public comment before proceeding with any such   
> initiatives. ICANN may be proposing an initial cost savings approach  
>  that will ultimately harm the registrants and limit ICANN's ability  
>  to fulfill its core responsibilities. "
> Technical and Network Architecture:  This BC statement could use the  
>  same footnore reference mentioned above regarding brands registries.
>> Date: Tue, 30 Mar 2010 18:57:58 -0400
>> Subject: [bc-gnso] Another Last Call:   BC Position - Baseline   
>> Registry Operations Report
>> From: sdelbianco at netchoice.org
>> To: bc-GNSO at icann.org
>> Another Last Call before closing on a BC comment.
>> Attached is the draft BC position regarding the report on Baseline Registry
>> Operations.
>> Berry Cobb circulated the draft back on 23-Mar (see below).  I¹ve signaled
>> my agreement.
>> Absent objections by COB tomorrow, we will file as consensus BC comments on
>> 1-Apr-2010.
>> --Steve
>> On 3/23/10 3:16 AM, "Berry Cobb" <berrycobb at infinityportals.com> wrote:
>> BC,
>> Attached is the first draft of the CBUC position statement for the Baseline
>> Registry Operation report released by ICANN.  Overall, I feel KPMG performed
>> well and provided meaningful views of the data. It is ashamed that more
>> participants were not a part of the sample data.
>> My Registry operations experience is limited, so I ask the BC team to take a
>> strong look at the report and the initial comments I provided.  I especially
>> invite our members that have direct Registry operations experience
>> to enhance our position about this study and its future use by the gTLD
>> Evaluation teams.
>> This material is sure to have a direct impact to the next Draft Applicant
>> Guidebook version 4 to be released just prior to Brussels.  In a
>> quick review, the following are what I believe to be sections of the DAGv3
>> where  this study could influence the Application Evaluation Criteria, or
>> the Application Process both of which will be used by the gTLD Evaluation
>> teams.
>> 1.2.2 Required Documents for Application
>> 1.4.2 Application Form
>> 2.1.2 Applicant Reviews
>> 2.1.3 Registry Services Review
>> 2.2.1 Technical/Operational or Financial Extended Evaluation
>> 2.2.2 DNS Stability Extended Evaluation
>> 2.2.3 Registry Services Extended Evaluation
>> The comment period closes April 1st, so I ask for your quick
>> turn-around.  As Steve DelBianco eluded to in our last BC call, there are a
>> large number of comment period closings converging at once.  I thank you for
>> your quick response.  I will compile all feedback and incorporate changes on
>> 3/30/2010.
>> Berry Cobb
>> Infinity Portals LLC
>> San Jose, CA
>> mailto:berrycobb at infinityportals.com
>> http://infinityportals.com <http://infinityportals.com/>
>> 866.921.8891

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