Roberto: All your comments are excellent. I have interspersed a few
comments in the section on multiple for-profit registries -- if I have
time I will post some more comments on your other sections:
> Kent,
>
> You wrote:
>
> > Far more important is to send comments on the Green Paper.
> >
> If my contribution may help, please find below my comments to the Green
> Paper, that I submitted to CORE few hours ago.
>
>
> Shared Registry versus multiple independent Registries
> Competition at the Registry level may look nice on paper (best if
> green), but doesn't work in practice.
> Competition at the Registrar level is useful, because it allows end
> users to choose a different supplier for the same goods he wants, but
> what benefit can the presence of multiple Registries bring to the end
> user?
> If somebody wants to register <myname.apple>, (s)he can do this with
> different Registrars (real competition), but only with one Registry (see
> Appendix 1 - "Each top-level domain (TLD) database will be maintained by
> only one registry"). Other Registries will allow him/her to register
> "similar" names, like <myname.orange>, but not the one (s)he wants. In
> formal economical terms, different Registries offer only "substitute
> goods", and nowhere in the economic bibles this is considered as "real
> competition" (I can browse my books for appropriate authoritative
> reference on the subject, but I'm sure that we have good professional
> economists onboard that could do this faster and better than myself).
I hope that someone with an economics background can fill in a little
bit about this.
> On the other hand, multiple registries have several drawbacks, like:
> 1 - a commercial (not non-profit) Registry can raise the price for
> renewal, blackmailing the customers that would prefer to pay rather than
> change domain name;
The key point here, I think, is that prices for renewals are under
totally different economic pressures than prices for new domain
names.
If domain names were one-use items, then the "cost of production"
would be the primary determinant of price, and prices should move to
an equilibrium slightly above the cost of production -- that is, the
cost of entering the name into the database.
However, once the name is in the database it is locked in. So the
primary determinant of price becomes the cost to the consumer of
changing domain names. This cost is very much greater than the cost
of maintaining the entry in the database -- the cost to Netscape for
changing their primary domain from .com to .net, for example, would
be very large, not even counting the hard to quantify aspects like
impact on customers.
> 2 - different Registries may well have different policies, different
> data format, different protocols and different interfaces to their
> Databases, which will cost more to Registrars to implement, i.e. which
> will cost more to the end user, and that will make the global operations
> on Trademark management (like search, verification of infringement,
> clearing) more complicated, if not impossible;
> 3 - from the practical point of view, who will oversee the "fairness" of
> the Registries to all Registrars? In other words, who will guarantee
> that NSI-Registry will not favour WorldNIC versus some CORE Registrar
> (or vice-versa, of course).
Some govenment regulatory body, of course, will be called for very
soon. :-( Either that, or the New IANA will have to be prepared to
deal with very expensive lawsuits...
-- Kent Crispin, PAB Chair "No reason to get excited", kent@songbird.com the thief he kindly spoke... PGP fingerprint: B1 8B 72 ED 55 21 5E 44 61 F4 58 0F 72 10 65 55 http://songbird.com/kent/pgp_key.html