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C31. Give your analysis of how selecting your application would affect competition in the provision of registration services at both the registry and registrar level. Registry Competition Selecting the DotOrg Foundation increases competition at the registry level by bringing a new registry operator to the domain name sector. The DotOrg Foundation, which is governed by a Board of distinguished directors, who are leaders in their fields, will draw upon the experience, expertise and perspective of an Advisory Council that itself will be broadly representative of the .org community – including advisors selected directly by both registrars and registrants. The Foundation will be staffed by independent, experienced personnel who are not affiliated in other registries. Therefore, the Foundation is confident that the DotOrg Foundation will bring a fresh focus to the domain name space, reflecting the views of the community it serves, and receiving oversight from the community most affected by competition issues. These measures will help the Foundation craft a competitive and responsive registry. The DotOrg Foundation will rely for technical services on two experienced vendors, one of which has registry experience. Though Registry Advantage operates the back end for the .pro gTLD and a number of ccTLDs, none of its registries account for a substantial percentage of the registry market, yet its infrastructure is robust enough to handle the .org TLD both at the time of reassignment and well into the future. (See description of systems testing and experience in C17.) At the same time, potential competition concerns in choosing an experienced registry operator are minimized by the fact that Registry Advantage does not operate the major gTLDs - .com and .net; the two largest new gTLDs - .info and .biz; or the ccTLDs – like .us or .uk – which may also raise competition questions. Yet by adding a substantial registry to Registry Advantage’s collection of smaller TLD clients, the award of this contract would allow Registry Advantage to leverage economies of scale needed to build a competitive registry. As has been demonstrated by the recent domain name industry track record, a certain economy of scale is important to building viable competitors to the existing registries. The goal of enhancing competition is also furthered by a registry that adheres to ICANN policies. Registry Advantage already complies with the separation and equivalent access requirements that ICANN imposes on all gTLDs, and therefore would likewise comply with such safeguard for the management of the .org TLD. This ensures Registry Advantage’s ability to provide an independent and therefore competitive sub-contract for registry services. Moreover, the DotOrg Foundation’s CTO and other staff will have oversight responsibilities and audit rights to enable it to ensure fair access and competition. In the event that DotOrg Foundation ever replaces Registry Advantage as the provider of the registry services, it would agree to select a new operator that provided the same competitive advantages and service level agreements, per ICANN specifications. The DotOrg Foundation will provide additional, optional services designed to entice noncommercial .org registrants. By increasing the .org registrations in this manner and through extensive marketing and outreach, the DotOrg Foundation offer a more competitive product to current TLD registries. Registrar Competition At the registrar level, the DotOrg Foundation will increase competition in several ways. First, it will provide equivalent service and pricing to all accredited registrars, ensuring that they can compete on a level playing field. Second, the registry’s thick Whois database would allow registrars that do not want to build their own authoritative Whois databases to rely on the registry Whois database. This would lower the entry costs for new registrars. Third, the DotOrg Foundation does not plan to operate other DNS registries, nor does its mission include other unconnected purposes, so that it will focus on providing the best service for the .org registrars. By the same token, it will not treat .org as a secondary registry, which may otherwise negatively impact its services or operations. Under the DotOrg Foundation’s operation, registrars sponsoring .org will enjoy increased levels of service and new products geared at increasing the number of noncommercial registrants in .org, allowing registrars to improve their ability to attract more registrants. This will be particularly helpful for competitor and new registrants that have not benefited from legacy registrants that use the legacy registrar. The DotOrg Foundation would like to increase the accessibility (financial and technological) of .noncommercial entities to .org registration, particularly those in developing countries and regions. The DotOrg Foundation would use the endowment to support and encourage entrance of new registrars to primarily service noncommercial organizations in developing regions.
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