In its comments submitted to the National Telecommunications and Information Administration concerning the expiry of ICANN's JPA, the International Trademark Administration (INTA) noted that removal of Registry-Registrar separation would create priviledged access, inhibiting competition, and could lead to increased problems with domain monetization.

"... ICANN’s proposal to relax the current vertical separation requirements between registrars and registries will not enhance competition but, indeed, will inhibit competition. Since many registrars own vast portfolios of domain name registrations, granting registrars preferential access to domain names in certain registries will deny equal access and inhibit competition. Equal
access and vertical separation prevent particular registrants from having preferred access to domains in particular registries. Preventing this privileged access is a compelling reason to maintain vertical separation, especially since ICANN has not developed a consensus policy limiting registrar warehousing of domain names as envisioned since the RAA was drafted. The current regime already suffers from the problem wherein registrars are encouraged to passively register domain names incorporating well-known trademarks and populate the holding pages on those sites with pay-per-click advertisements or other practices that generate revenue for the registrar. Relaxing the current vertical separation between registries and registrars does not appear to do anything towards ameliorating this problem and likely exacerbates it."

Attachment	Date	Size
INTA letter to NTIA June 2009.pdf	23/06/09 9:21 pm	318.31 KB