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[comments-dotorg] Re: [council] Final report of .org Task Force

Introductory Comments:

I'm ambivalent on the structural form of the delegee. The case for non-profit
was argued with back during the WG-C period, without ever getting down to the
awkward bits of actual capital outlay, cost-recovery, cleaning up the current
operator's mess, etc. The closest the newTLD process has manifested to this 
point of view is the .coop delegation and its operator, a cooperative.

1. Characteristics of the Organization to Administer .org 

Subsection 1b, final sentence, is highly problematic. Absent any other bar on
the construction of the delegee, policy body, operator, registry, registrars,
resellers and registrants, this one sentence allows highly fictional forms of
"non-profit" policy and operational management oversight of the "new" .org.

If the first thesis is worth testing with the .org registry, registrars and
registrants, that "for profit" is infra dig, then the corollary should also
be worth testing, and the below sentence modified by the insertion of "not".

	    1b. ...
		Subcontracting of operational functions to for-profit
		providers is permitted. 

Subsection 1d is interesting also. The goal stated is to create "the largest
number of qualified" applicants. The condition is a lowering of the bar for
financial resources. There are two things "wrong" with this picture. First,
the cost of entry for registry operators is falling, the NeuLevel figure of
$20 million is an artifact of poor judgement, other registries have gone-live
on a tenth of that. However, the cost to meet existing ICANN gTLD functional
and non-functional requirements is significantly greater than the 200k bogie,
and under-capitalization or limited access to capital resources is just asking
for trouble. Second, who cares if there are two or more "qualified" applicants?
One will do very nicely, and beauty contests among entities that haven't any
registry, or registrar operational experience, is a waste of everyone's time.

I suggest the following substitution for the original text:

	1d. In order to ensure the capability of the applicant(s), the Board
	should require the equivalent of USD$500,000 in demonstrated financial
	resources from applicants. 

2. Policy Guidelines for Applicants to Administer .org 

Subsection 2b contradicts the notion that the incoming operator will utilize
a distinct policy from the outgoing operator. This is an endorsement of the
policy that is elsewhere deprecated.

Subsection 2c presumes no capital accumulation is consistent with the goals
of the delegee, policy body, operator, registrars, resellers, or registrants.
If no capital accumulation is allowed under the operating agreement, then the
ability of the parties to invest accumulated capital in improved services is

3. The Verisign endowment

While soaking Verisign is always a good idea, selecting an operator that can
not succeed without $5 million in "found money" is absurd. If there is any
case for burning $5 million of Verisign's money, it is in cleaning up the
current pool of illegitimate registrants from the current registry. If there
is any case for qualification from an applicant, it is non-dependency upon
"found monies" for operational transfer and maintenance.

4. The Registry Operator

This is a wasted paragraph. The functional and non-functional requirements
will be sufficiently close to the ICANN newTLD form. The pricing verbiage
is unimaginative. Whether the registry uses RRP or EPP is irrelevant.

6. Follow up 

The final sentence of the final para is interesting. Application fees are
viewed not as a reasonable fee to cover ICANN's evaluation process, but as
some brand of "non-frivolousness". This is a poor way to view both the cost
to ICANN, and the ability of the applicant to raise funds. Given the 200K,
or the 500K figures (Milton, et alia, and my own, respectively), the current
50K figure is not prohibitive.

Concluding Comments:

The .org registry is a 10^^7 sized registry, significantly smaller than the
.edu registry, transferred earlier. It could be transferred to some existing
non-commercial registry operator, or put up for competitive bid. Of the set
of possible existing non-commercial registry operators, several ccTLD and a
very few gTLD registry operators appear to be viable and appropriate choices.

Questions are welcome.

Eric Brunner-Williams
wampumpeag, llc
The EPP Trade Association, a 501(c)(6) not-for-profit, Deleware Incorporation

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