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DRAFT: New registry services statement.



Please find attached what could be a preliminary statement from the
ALAC on new registry services that could be submitted to Barbara.

Regards,
-- 
Thomas Roessler  <roessler@xxxxxxxxxxxxxxxxxx>
At-Large Advisory Committee: http://alac.info/
Individual Internet users can be affected by the introduction of new
registry services in several roles: As registrants, they are
affected by services that change the registration system, and by
services that might affect their ability to reach an intended
audience online.  As "DNS consumers", they are affected by changes
to DNS behavior.

Individual Internet users are also affected by indirect effects that
the introduction of new registry services (or, likewise, a failure
to introduce such services) might have: A registry service not
introduced might be a valuable offer that is not available to
Internet users.  A registry not able to operate in a commercially
viable manner may damage its registrants.  A TLD market that is
commercially attractive for new operators will give Internet users
more choice in the long term, and will enable competition. A
registry service that moves choice from the network's edges to its
center, though, means less choice for users, and will replace
competition at the network's edges by a monopoly at the center. A
change to DNS behavior that specifically targets a single
application-level protocol may improve user experience in the short
term, but will harm innovation in the long term.

These examples demonstrate that there is no simple and universal way
to answer the question whether some specific new registry services
should be introduced, by whom, and how.  

In very general terms, we would argue that the introduction of new
registry services should be permitted unless publicly detrimental.

As far as the implementation of this general principle is concerned,
we limit our comments at this point to some preliminary and basic
observations:

- Any decision about the introduction of new registry services
  should be based on well-defined, objective criteria that must be
  applied in an even-handed manner.  This should not prevent ICANN
  (or whatever entity is chartered with evaluating proposed registry
  services) from taking possible market dominance of the party that
  proposes a registry service into account.

- When a new registry service is both deliverable at the network's
  edges and at its core, then preference should -- in general -- be
  given to delivering this service at the network's edges, in order
  to foster user choice and competition. (See issue 6.6 from the
  staff manager's draft report.)

- The introduction of a new registry service should not create a
  situation in which commercial gain at the center comes at cost
  that is incurred by parties at the network's edges, without giving
  those who incur the cost a choice about it.

We appreciate the opportunity to comment, and look forward to
further contributing to the development of a fair and objective
process for assessing new registry services.