The public interest in supporting competition and protecting end-users does not support elimination of the current separation of Registry and Registrar ownership. The end result would be further consolidation of the top tier registrars, gaming of the loopholes in the current contractual reciprocity provisions, and potential increased brand abuses. These changes would, in conclusion, present a severe negative impact on competition among Registries and among Registrars and harm to end users.
Because several registrars own vast domain portfolios, the equal access and vertical separation requirements also have the positive effect of preventing particular registrants from having privileged access to domains in particular registries. Relaxing the requirements could inhibit competition in the market for domain names. Worse, it could make it essentially impossible for brand owners to prevent abusive registrations of their domains in registries where a particular registrant has a pre-emptive ability to register domains. Therefore, preventing registrants from gaining privileged access to particular registries is a compelling reason to preserve the vertical separation requirements. Because of the dangers of the competitive abuses described above, Cyveillance strongly urges the ICANN Board to maintain the separation in the current ICANN contracts and ensure the implementation of regulations that will maintain this clear separation.
More information as well as the opportunity to comment on the proposed change can be found at http://www.icann.org/en/public-comment/.