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Date: Fri, 14 Nov 2003 10:15:49 -0500
From: "Ross Wm. Rader"

Barbara,

I write to you on behalf of Tucows Inc. and those registrars that chose to provide me with the feedback I solicited in my message to the Registrar Constituency of November 4, 2003 (<http://www.gnso.icann.org/mailing-lists/archives/registrars/msg00820.html>) concerning your draft report, "Excerpt from Draft Version of Staff Managers Issues Report for the Development of a Process for the Introduction of New or Modified Registry Services". This communication is not an official communication of the Registrar Constituency and should not be viewed as such. Thank you in advance for taking the time to review these (late) comments concerning your report excerpt.

The excerpt is quite comprehensive and will likely serve as a useful basis for discussion and resolution of the issues you have identified. There are however three items of specific interest to registrars that you may wish to consider for inclusion in your document;

1. Specifically determining the definition of a "registry service". This is very unclear to the registrars that I spoke to and will be the lynchpin in any discussions moving forward. There is a strongly held belief held by members of the constituency that there needs to be a distinction drawn between the evaluation of services that benefit from the registry having exclusive access to the TLD database and those that do not.
2. Clarifying the intended nature of the registry contracts. This is not so much a matter for the policy development process, but rather, a statement that the ICANN Staff or Board can make to clarify whether the existing registry contracts are, as one member put it

   "...intended to be in the form of an outsourced arrangement where a registry operator provides a specified service (e.g domain name registration) for a specified price (e.g $6) for the ICANN community, OR is the registry agreement intended to be in the form of a licence right to operate a particular TLD and generate revenue based on the services possible from such a role (subject to some maximum price controls on core services)?"

3. First examining the question of whether or not new registry services should be introduced prior to examining the question of how new registry services should be introduced.

We would appreciate specific clarification on each of these questions.

Given that a significant portion of the policy development process is analysis, we must ensure that we promote a complete and thorough analysis of the salient issues. The answers to each of these question will shape the nature of the policy development discussion on a very fundamental level and it is imperative that the community proceeds with the policy development process with the context that answers to these questions can provide. We therefore strongly urge that these matters are considered in some way by your report.

I thank you again for your time and attention to this matter. Please do not hesitate to contact me if you require further clarification regarding the issues that I raise with this message.

Warm regards,

Ross Wm. Rader
Tucows Inc.