cctld Please do this now to ensure we have a fair and open TBR system.

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msn

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I have given this matter some thought:

If anything, CIRA could/should have put up a 'sandbox' for registrar partners to use in testing the new TBR concept if it was so complicated that 'many' registrars could not reasonably determine the correct manner in which to interface with the CIRA system.

Shame on CIRA.

On the other hand, if the Momentous group could not, after four weeks, determine that it was not able to handle the new transactional method and instead made a telephone call to CIRA to withdraw a running TBR, shame on both of them.

An obvious conclusion here is that this episode was entirely avoidable.

At issue is the matter of allowing multiple registrar partners for a single entity, which really is a very bad practice.

Multiple affiliated registrar partners are allowed by CIRA but this clearly places CIRA in a conflict of interest as it then collects a fee for each new registrar partner created and an annual renewal fee for every registrar partner. This incentivises CIRA to have as many registrar partners as possible even when those are concentrated in the hands of only a few groups.

Given the high volume of .ca domain name registrations there could be no excuse that CIRA relies upon this as a crucial source of funding.

Here I will note that the registry operator of .de in Germany, DENIC, specifically prohibits multiple registry partners for entities with automatic cancellation of the registry partner if such situation occurs.

Had CIRA this same policy, the problem of multiple registrars on the very same IP address and/or server from last week would most likely not have happened.

Likewise, the actual and apparent oversize voice the Momentous group has with CIRA would be brought into line with all other registrar partners.

I therefore call upon everyone to contact the Competition Bureau to direct CIRA to require that every CIRA registrar partner as of January 1, 2011 be independent as under the DENIC best practice. This can instantly be accomplished by CIRA ending the registrar partner agreements with every entity which holds more than one .ca registry connection, and can be enforced by ordinary users by researching the company registry forms in your local government offices and by checking any registrar or TBR web site which offers results from two or more registrar partners.

The current situation has created a 'first amongst equals' situation for registrars and caused higher costs for us since one group with a significant proportion of the TBR transactions is able to thereby increase the cost of TBR domain name registrations from the industry average of $12.99 to $60.00

All of this is very clearly anti-competitive and contrary to a free and open market. I call upon everyone, especially registrar partners, to contact the Competition Bureau, Industry Canada and your local Member of Parliament.
 
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