PAB Magaziner Paper, comments thereon.

Robert F. Connelly (
Mon, 23 Mar 1998 14:46:24 +0900

To whom it may concern:

The Magaziner Paper states, "NSI and the U.S. government must reach agreement on the terms and conditions of NSI's evolution into one competitor among many in the registrar and registry marketplaces. A level paying field for competition must be established."

I do not believe a level playing field can exist when one firm has held an exclusive for five years to three gTLDs and has operated and will continue to operate as a for profit enterprise. The GP elsewhere proposes a "division between its current registry business and its current registrar business". There is no way that a satisfactory "division" can be built between two parts of a for profit enterprise which will provide a "level playing field". The possibilities of cross subsidization and sharing of references and contacts cannot be prevented.

There should be a total separation of the registry and registrar functions of the present NSI. Since NSI has seen fit to become a public corporation, it would seem best to spin off the registry as a not for profit enterprise. The existing NSI registration business could be conducted under the present corporate shell, with other registrars permitted to officer registration services for .com, .org and .net on an equal footing with NSI.

Respectfully submitted,
Robert F. Connelly