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.

Unity Registry believes that diversity and competition in the provision of registry services will benefit registrants, registrars and the registry operators themselves and will work to promote this.

It is also in the interests of the whole Internet that a diverse community of registries is operating the domain name system, limiting dependence on one particular technology, platform, toolset or database management system.

We will therefore work to enhance competition at the both registry and registrar level.

At the registry level, Unity Registry creates a new major entrant in the gTLD marketplace, increasing the number of parties trying to secure business and competing to provide higher levels of reliability and service at affordable prices.

Unity Registry is distinct from the other major gTLD parties (VeriSign, NeuLevel and Afilias) barring a non-controlling 4% stake by Afilias, ensuring its status as an independent new player. The organizations that have come together to form Unity Registry are from a different geographic regions, and bring international service standards and industry improvements gained through cross cultural improvements.

A top level domain is by definition the only supplier of services to registrars for a particular domain. However members of the noncommercial Internet user community may choose to register other domains - either the .org subdomain of their appropriate ccTLD or an alternative domain like .info.

The special position of registry operator can be abused in a number of ways, most notably through unwarranted price increases and the provision of services that are unresponsive to customer interests and demands.

Although registrants have an increasing variety of domains to register in, either globally or within ccTLDs, the issue is of great significance, particularly in the context of a domain as important and well established as .org.

Unity Registry is acutely aware of this issue and proposes to deal with it in several ways. The creation of a user cooperative with significant powers is intended to ensure that the registry is responsive to user interests, and that those interests are at the heart of the policy making machinery. We will also apply stringent standards for stakeholder accountability. These policies are described in detail in Section C35.

As stated in Section C26 we will ensure that a low level of pricing is maintained consistent with running a sustainable operation. We are also committed to fostering competition at the registry level by supporting the development of new special purpose registries in the noncommercial communities where there is demonstrable demand and within the framework of ICANN policy.

Just as we believe in competition at the registry level, we are keen to foster full and vigorous competition at the registrar level to ensure the .org community is serviced at the highest possible level. The contract terms and conditions we establish with our registrars will demonstrate industry best practice and will therefore enhance the efficient operation of the marketplace for registry-registrar services. In this way they may encourage other registries to reappraise their own agreements.

Unity Registry will provide a level playing field. As registry services will be offered on an equivalent basis to all registrars, as detailed in Section C21, competition is likely to increase as registrars will need to compete on customer service, value added services and brand.

Our proposals for differentiating .org within the gTLD space (see Section C38) will create a segmented market for domain registrations, providing registrars with a product which they can sell through to their registrants that is distinct from other gTLDs.

We will compete to ensure a greater participation of the noncommercial segment, by targeting our marketing to ensure that the .org gTLD is the noncommercial gTLD of choice. As neither Unity Registry nor its partner organisations will be providing
.org registrar services there will be no conflict of interest or preferential pricing, and by limiting the number of services we offer as a registry, we are allowing greater competition at the registrar end and greater variation in service levels.

Lastly, our registry Web front-end and support for the latest registry protocols will make it simpler, easier and cheaper for all registrars to deal with us on an equivalent basis, reducing the cost of entry into the market place and enhancing competition.

Other than the main partners in Unity Registry - Poptel and AusRegistry - other companies offering backend services, most notably Nominum, have not been asked to limit their participation in other applications or to refrain from offering their services. In fact Unity Registry is not aware of and has not asked whether its proposed providers of backend services are involved in or providing services to other applicants, believing that this information should be considered confidential prior to the public announcement of bids.