[bc-gnso] BC Position Statement on Vertical Integration (VI) -- single registrant TLDs

Steve DelBianco sdelbianco at netchoice.org
Fri May 14 17:19:56 UTC 2010

Thanks to Berry and the other BC members on the VI working group for keeping
us apprised of your work there.

As we form our constituency position on the proposed VI models, I wanted to
focus briefly on one issue: single registrant TLDs.

Most of the 9 proposed VI models mentions single registrant TLDs and most
would allow  the TLD to manage its registrations -- but with caps of 30,000
or 50,000.  Let me offer a few examples that show how companies (even some
BC members) would want more control over their own TLD registrations:

Case 1: employees of a company.    This is the example cited most often, as
in, IBM might want to create 2nd level registrations for all its employees,
for HR functions, scheduling, or even "mail at steve.delbianco.ibm".   If a
company were to do this, they would rightfully insist upon total control
over 2nd level registrations, and would not want to let all registrars have
equal access to sell names.  The employer might create its own accredited
registrar, in which case 100% cross ownership and self-distribution would
need to be allowed under the new VI policy.   For this case, there is no
justification to impose an arbitrary cap of 50,000 on the number of
registrations that could be done before opening it up to all registrars.
IBM, for instance, has 400,000 worldwide employees, according to its 2009
Annual Report.  

Case 2: bank customers.  A global consumer bank might pursue its own TLD,
hoping to give each of its customers their own 2nd level registration to
enable secure access to a DNSSEC-signed online banking page.   An arbitrary
limit of 50,000 registrations would not be sufficient for even medium-sized
regional banks.   When a bank reaches the registration cap, it will not want
to be forced to compensate and cooperate with all ICANN registrars to
enroll, authenticate, or remove banking customer registrations.

Case 3: social network services.   A global social network platform might
want to operate its own TLD in order to give each of its users their own 2nd
level web address.  (e.g. SteveDelbianco.facebook ) Even sites like Flickr,
dropBox, and Twitter might want to offer this service to enrolled customers.
An arbitrary limit of 50,000 registrations would be too low a threshold, and
no service would want to lose total control over the privacy and security of
its users' data.   These services would not want to be forced to compensate
and cooperate with all ICANN registrars to enroll, authenticate, or remove
their users.

I am not aware of any BC member (or NetChoice member) who's planning to
apply for their own TLD, but I doubt any would want to operate their own TLD
if arbitrary caps were placed on self-managed registrations.

I believe the BC is in the best position to argue for potential needs of
single registrant TLDs like those described in these examples.

Let's acknowledge that single-registrant TLDs would need to conform with
ICANN's contract and consensus policies.  It's also acceptable to require
the use of a single accredited registrar, as long as this registrar can be
wholly-owned and controlled by the single registrant company.    But let's
argue against arbitrary registration caps that would force single-registrant
TLDs to use all ICANN registrars once those caps were reached.


Steve DelBianco
Executive Director
http://www.NetChoice.org and http://blog.netchoice.org

<berrycobb at infinityportals.com> wrote:

> VI WG,
> Attached is the CBUC position statement from Aug 2009 regarding the
> issue of Vertical Integration.  While several CBUC members participate
> on the VI WG, no substantial change has occurred requiring
> modification to our consensus.  The CBUC reserves a change to our
> consensus position, if any, when the VI WG creates its final report
> and opens the final community comment period.
> In summary, Our present consensus position basically aligns to the
> ICANN board resolution in Nairobi and we are pleased with the
> substantial and adequate discussion with respect to VI/CO & also
> Single Registrant TLDs.  The CBUC looks forward to the analysis of
> proposals by the VI WG and we are optimistic a solution will be
> created to match the expansion of gTLDs.
> Any specific questions to the CBUC can be filed through Berry Cobb.
> Thank you.
> Berry Cobb
> Infinity Portals LLC
> berrycobb at infinityportals.com
> http://www.infinityportals.com
> 866.921.8891

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