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[registrars] Certification


Hello,

On the subject of certification there appears to be a few loose ends of
which some I think have been raised recently by Michael Forrester.  Also
another recent issue raised by Rick Wesson.  It appears to me that this is
not a clear cut issue and there are several issues which I hope ICANN will
address before signing its agreements between with the new registries.  In
particular my concern is barrier to entry.  ICANN is essentially empowering
the registries when it signs its agreements to do as they wish and I feel
this empowerment needs to be addressed now before it is too late.

ISSUES of concern:

1) Will Registries be allowed to charge for a license to its system?  If so
how much and will it be capped?  Yes, we know NSI charged $10,000 for its
license but if each registry imposes similar charges it will certainly
restrict the number of users to the registries I'm sure.

2) As has already been mentioned will a performance bond be required for
each registry?  This is certainly a barrier to entry as based on my own
experiences this was no mean feat try to get one of these.  Beside this fact
you have to tie up a substantial amount of money in a deposit account to
secure against your performance bond.  

3) If the registry has the power to decide who becomes certified as a
registrar to their registry then surely this could be anti-competitive,
particularly if that registry considers you to be a major competitor.  They
could even delay your certification if they like until after the land rush
period so that you benefit least from the advent of a new gTLD.

4) If a registry is also a registrar then this too could be construed as
anti-competitive in the respect that they could delay certification to
registrars until their own registrar benefit from the initial land rush
period.  I think that some restrictions are certainly needed here.

I am sure I could think of some more issues given time but I think this area
has not really been discussed nor has it been an open forum to any degree
with ICANN or the new registries.

I would like to hear other comments from the group to see if anyone shares
my fears.

Miesha Vukasinovic. 

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