In a letter to ICANN, Alexa Raad, CEO of .ORG, the Public Interest Registry outlines the combined comments of PIR, Afilias and NeuStar on the issues of Registry-Registrar Separation. Ms. Raad's letter calls on ICANN not to abolish the current successful separation policiy and highlights five scenarios that illustrate the result this change is likely to have on the industry.

In summary these comments note that:

"The public interest in supporting competition does not support elimination of the current separation of Registry and Registrar ownership. The end result would be further consolidation of the top tier registrars, gaming of the loopholes in the reciprocity provisions which will, in the very least, provide a “time to market” advantage for select Registrars, among others. These changes would, in conclusion, present a severe negative impact on competition among Registries and among Registrars and harm to end users. Because of the dangers of the competitive abuses described above, PIR, Afilias and Neustar strongly urge the ICANN Board to maintain the separation in the current contracts and as well as maintain the regulations against Registry-Registrar cross ownership for both Registries and Registrars."

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