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ICANN has operated on the fundamental principle that there should be separation within the domain name marketplace between registries and registrars .

This fundamental principle has been a pillar upon which ICANN has provided registrants (consumers) with increased choice, innovation, and price savings. Therefore it was with great surprise when ICANN staff unilaterally undertook this initial vertical separation analysis through exclusive consultation with ICANN contracting parties (registrars and registries), while totally excluding non-contracting parties (individual, business and non-commercial registrants). ICANN staff proposal to remove these important vertical separation safeguards in the most recent Draft Applicant Guidebook under the auspices of anti-trust concerns totally ignores the important and legally justifiable safeguards that vertical separation has provided registrants.
The anti-trust red herring
ICANN has expended several hundreds of thousands of dollars undertaking an economic and anti-trust analysis of registry-registrar vertical separation in the marketplace, including the high priced panel of experts that it flew half way around the world in connection with its most recent regional meeting in Sydney, Australia. While this panel discussed hypothetical analysis of how competition could be enhanced through the removal of vertical separation safeguards, they have totally ignored the harms in the current marketplace and how those harms would be heightened if vertical separation safeguards were improperly removed.

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