The Registrar Constituency responds to the request by the ICANN Board for input regarding the proposed 2001 agreements between ICANN and VeriSign supports Registry-Registrar Separation.
On page 8 of the attached response to ICANN, the Registrar Constituency highlighted how a vertically integrated VeriSign would create unfair pricing:
"VeriSign, unlike competitor registrars, will continue to bear essentially zero wholesale cost. The registry fee is the principal cost of selling a registration. VeriSign’s registry fee is simply a payment from one VeriSign division to another, which nets out on the corporate income statement and balance sheet. For other registrars this is a real cost. This position allows the VeriSign registrar to offer aggressive and sometimes free promotions to customers that its competitors cannot meet or sustain. Today, VeriSign remains the largest global registrar by far, and the continuation of this unfair advantage would help perpetuate its position. Over time, VeriSign’s predatory tactics will be used to drive competition out of the registrar business, thereby undoing the initial progress made by ICANN to date in the industry."