Beckstrom: next ICANN CEO should be an outsider

ICANN CEO Rod Beckstrom has called on the organization to replace him with somebody from outside of the domain name industry.
His remarks, at the opening ceremony of its meeting in Dakar yesterday, came as the organization’s decisions are coming under increasing scrutiny from outside the domain name industry.
“I hope that the person who replaces me will be of the highest integrity and has no recent or current commercial or career interests in the domain industry, because ICANN’s fairness, objectivity and independence are of paramount importance to the future of the internet,” Beckstrom said.
“We are not here in the domain name business,” he said. “We are here to serve the global public interest.”
Beckstrom generally uses his ICANN meeting opening remarks to fire-fight the latest pieces of criticism directed at the organization and yesterday was no exception.
His comments should be read in the light of ongoing claims that the new gTLDs program was approved prematurely due in part to the business interests of former chair Peter Dengate Thrush.
Dengate Thrush left ICANN in June, shortly after helping to approve the program, and promptly took up a position with gTLD applicant Minds + Machines.
Organizations opposed to the program, such as the Association of National Advertisers, have seized on the controversy as a stick to bash ICANN with.
Since June, there have been calls for ICANN to revisit its conflicts of interest and ethics policies, which it seems to be taking very seriously.
Every member of the ICANN board of directors has already been ruled out of the CEO search, for example.
Beckstrom elaborated on his comments at a press conference yesterday.
“My view very strongly is that the organization can and should be led a party who does not have a vested personal business interest or history specifically in the domain name industry,” he said, “lest the efforts of the organization be potentially skewed in such a direction from a policy or operational standpoint, in terms of being more sensitive to the needs of the industry as opposed to the global public interest.”
Chairman of the board Steve Crocker said Beckstrom’s opinions were valuable, but his own, representing only one input into the process of creating CEO search criteria.
“We obviously want to balance two factors,” he said. “We’re very concerned about conflicts of interest and at same time we want the widest and most capable pool of candidates possible.”
There have previously been calls for ICANN to hire somebody already familiar with its operation, in order to reduce the learning curve for Beckstrom’s replacement at a time when the organization is in the midst of the new gTLD evaluation process.

IANA contract only for US companies

The US Department of Commerce has announced the date of its RFP for the IANA contract, stating that only wholly US-based organizations are welcome to apply.
Commerce, via the National Telecommunications and Information Administration, said it intends to accept proposals from potential contractors between November 4 and December 4.
Among other things, the IANA contract is what gives ICANN its powers over the domain name system’s root – its ability to delegate gTLDs and ccTLDs to registries.
It is due to expire at the end of March next year, having been extended from its original expiry date of September 30. ICANN is of course the favorite candidate.
ICANN had asked for a longer-term or more arms-length contract, to dilute the perception that IANA is too US-centric, but NTIA has indicated that it intends to decline that request.
However, the duration of the contract has been changed.
The current IANA contract was a one-year deal, with four one-year renewal options. The next will be for a three-year base period, followed by two two-year renewal options, according to Commerce.
“The current unilateral structure of the IANA functions contract should evolve to meet the needs of the global community,” ICANN CEO Rod Beckstrom said during his opening remarks at ICANN’s 42nd public meeting in Dakar, Senegal yesterday.
He noted that the US government originally said, in a 1998 white paper, that ICANN would ultimately take over the IANA functions entirely, cutting it off from government.
“We hope that progress towards the vision articulated by the US government’s white paper will be made in the next agreement and we hope and we expect to see a roadmap for the realization of this vision in the future,” Beckstrom said.
Now that Commerce has made such a big deal out of the fact that only US-based organizations are welcome to apply to run IANA, that goal seems further away.
It’s also notable that the next IANA contract will be a single document.
The NTIA had previously floated the possibility of splitting it into three functions – protocol management, DNS root management and IP address allocation – but the idea was not well-received.

New gTLDs: no advantage to applying early

ICANN has confirmed that new top-level domain applications filed early in next year’s application window will not get priority over those filed right at the end.
The subject of “batching” – the way ICANN plans to divide applications into more easily managed chunks of 500 – has seen some debate recently.
Some applicants and consultants have said that filing your application January 12 rather than April 12 would be a wise move, despite the evidence to the contrary.
Now ICANN senior vice president of stakeholder relations Kurt Pritz has busted the myth, during a session on new gTLDs with the Generic Names Supporting Organization in Dakar today.
“There’s no advantage to applying early or later in the process,” he said. “As long as your application is in by the due date it has the same chance of being in any batch.”
It doesn’t come much clearer than that.
ICANN has said that it only plans to process 500 applications at a time. If there are significantly more than 500, then it will process them in batches.
Due to the length of time it is expected to take to process an application, finding yourself in dumped into the second batch could add a few quarters to your go-live runway.
If you’re a commercial gTLD applicant, there could be a significant first-mover advantage to being in the first batch. Revenues from speculative and defensive registrations could be higher, before the novelty of new gTLDs gives way to fatigue.
Applicants in that position are going to use every trick in the book to streamline their process through ICANN and maximize their chances of being in the first batch.
While ICANN has not yet decided how to create the batches, it has ruled out filing time from the criteria. Pritz talked the GNSO through some of its current thinking today.
The preferred option is random selection. The problem with this idea is that it may fall foul of US gambling laws if it fits the definition of a lottery.
It sounds stupid, but it’s happened before: when Neustar introduced a random element to its launch of .biz, it would up having to pay $1.2 million to settle claims that it ran an illegal lottery.
“The issue of random selection is that we just have to make sure it complies with all possible applicable laws,” Pritz said. “Our initial legal research points out that this is real risk… but it is the most attractive form of selection because it is objective and fair.”
The other option under consideration is a “secondary time stamp”, Pritz said. This unhelpful label caused some head-scratching during the GNSO session today.
Pritz explained by analogy: imagine every applicant was asked to send a letter to ICANN, and the order of the batches would be determined by the order in which the letters are received.
The important thing to note is that this secondary time stamp would not be based on the date the application itself was submitted to ICANN.
Pritz said that ICANN had also discussed a “charity auction” batching method, but that this idea has now been ruled out.
Whatever mechanism is decided upon, it seems that applicants will have the opportunity to opt in or opt out of the first batch. Some .brand applicants currently clueless about how to use their gTLD may not be super-interested in getting priority processing, for example.
“We think those numbers are non-negligible,” Pritz said.

Will ICANN approve cheap gTLDs for poor applicants?

One of the big questions at ICANN’s 42nd public meeting in Dakar next week is whether the board of directors plans to approve subsidized new gTLD application fees for worthy applicants.
A volunteer working group known as JAS came up with a set of recommendations last month that would lower the $185,000 fee for applicants from developing nations with public benefit missions.
It was a wide-ranging set of proposals that would stretch beyond the scope of the $1 million to $2 million ICANN approved for applicant support initiatives at its last meeting in June.
Chiefly, JAS wants the application fee reduced to $45,000 for qualified developing-world applicants, meaning ICANN would have to find the funds to cover the $140,000 shortfall elsewhere.
In addition, JAS wants ICANN to set up a fund to loan money to these same applicants. It also wants these applicants to be able to pay fees on a staggered schedule.
Whether it was deliberate or not (I suspect it was semi-deliberate), the JAS wish-list seems to me to go above and beyond the support the ICANN board said it was prepared to offer in June.
I don’t think the board will grant those wishes when it meets next Friday, and here’s a few reasons why.
First, CEO Rod Beckstrom has already basically ruled out blanket fee reductions, even for poorer applicants, and he did so after the board had already discussed them.
At an ICANN panel on new gTLDs in London last month, Beckstrom was asked by an audience member if the application fee could be reduced before January.

At roughly 32 minutes into the embedded video, this is what he said:

There’s no plans to reduce the fee and I could not contemplate that happening before the program opens. The fees have been determined and there’s no process to review them, and there would be no basis at the present time because the costing estimates in the program appear to be reasonably accurate.

He went on to say that economies of scale may lead to a reduction in fees in future rounds, but did not mention the JAS recommendations at all.
As I was also on the panel, I called him on the omission later in the discussion, roughly 45 minutes into the video above. He said:

The board of directors did make a directional indication in Singapore to set aside up to a million to two million dollars for financial support for applicants…
However, it’s not a repricing of the fees, it would be some type of support for those applicants. A reduction in the application fee or effectively subsidizing the application fee is one possible concept, but what I can tell you as the CEO and as a board member is that board’s indication is one to two million dollars, not an unlimited number, so can do math and figure out what might be possible and what might not.
We’re not going to change the program fees, it just means there might be some benefit to or some support for some applicants, but it may not come in the form of that subsidy for the fee.

What we have here is JAS asking for a fundamental restructuring of the application fee in certain circumstances, and ICANN’s CEO saying that’s not likely to happen.
At that time, the JAS report had not been formally submitted to the board, but it had nevertheless been seen and discussed by the board at its two-day retreat in mid-September.
The GNSO, which had been frustrated with the cross-constituency structure of the JAS for some time, didn’t even formally approve the report before forwarding it to the board, due to time constraints.
Another indication of the board’s thinking on the JAS recommendations comes from the minutes of its Finance Committee meeting, September 15. Here’s an extract:

Staff has initiated efforts to be ready for implementation if and when approved. Establishment of a fund – a short-term mechanism for earmarking funds for applicant support, and a long-term formal mechanism for several purposes. Meeting community expectations: Board had approved US $2mm, while the JAS/GAC-ALAC recommendations would be more costly. Four tasks: developing criteria based on the JAS report plus practical concerns, developing procedures, entity for considering applications, and mechanism for holding the funds. Discussed the need to stay within the mission and purpose of ICANN and the ability to set-up special funds.

There’s no mention of application fees, but there is an acknowledgment that the JAS recommendations would be more expensive to implement than just the $2 million ICANN has already set aside.
There’s also talk of “practical concerns” and the “need to stay within the mission and purpose of ICANN”, all of which says to me that there’s a worry JAS asked for too much.
We’ll have to wait until next Friday to find out for sure, but my guess is that the board will likely side with ICANN’s bean-counters and that the JAS will not get much of what it asked for.

What’s At Stake conference bans new gTLD consultants

A conference in New York next month has been set up for marketers to discuss ICANN’s new top-level domains program without pitches from consultants.
What’s At Stake, scheduled for November 1, is for new gTLD skeptics, primarily marketers from large companies that will be impacted by the program.
It’s going to discuss the implications of the program and a few ways ICANN could tweak it to make it less daunting for large corporate applicants.
The conference, found at whatsatstake.com, is being organized by New York marketing pro Judy Shapiro, in conjunction with CADNA, the Coalition Against Domain Name Abuse.
Former ICANN chair Esther Dyson, who has recently emerged as a fierce critic of the program, is scheduled to keynote the event.
The goal is not to “bash ICANN”, Shapiro told DI in an interview yesterday.
Unlike the Association of National Advertisers and other trade groups, the conference will focus on changes that could be made to the program, rather than its outright suspension, she said.
Primarily, Shapiro wants to see ICANN name the date for a second round of applications.
“If they just said they’re going to do another auction in so many months time, it would be a thousand times better right away,” she said, referring to a second application round rather than an actual “auction”.
Currently, the first application window is scheduled to run from January 12 to April 12 next year. There’s no fixed date for a second round, and some say it could be five years before we see one.
This has economically incentivized new gTLD consultants and registry service providers to play up the “clock is ticking” and “it may be your only chance to apply” memes.
While accurate, this has arguably helped cast the domain name industry yet again as a bunch of borderline extortionists focused primarily on pumping defensive registrations.
It also could mean that some large companies fire off applications for far more gTLDs than they could conceivably need or use, just in order to “defensively” own a keyword related to their industry.
If that happens, it’s quite possible that we’ll see a bunch of dormant or otherwise half-assed extensions go live, substantiating the view that new gTLDs are a waste of time and that .com is king, etc. etc. etc.
The ICANN program as it stands today is “brilliantly constructed to force everyone to buy everything they want in one fell swoop,” Shapiro said.
The problem with naming a second-round date is of course that the first one is likely to take years to run its course. Everybody is expecting some kind of litigation, which could delay any schedule.
Shapiro herself expects that there will be a lawsuit designed to delay the program at some point between now and January.
Shapiro’s background is in corporate brand management for companies such as AT&T, Lucent and CA. She currently runs the online marketing company engageSimply.
“I was very familiar with ICANN. It was not a mystery to me,” she said, explaining her decision to launch the conference. “But I found I was clueless [about the new gTLD program] and I was shocked that I was clueless. I did a survey of 40 friends at top companies, and they were clueless too.”
She decided to offer a conference after she read an August 16 AdAge op-ed by Alexa Raad, CEO of the consultancy Architelos, which she said many marketers dd not understand.
But What’s At Stake is an invitation-only event, and new gTLD consultants are not welcome.
“I am paying for it, I do not want any pitches,” said Shapiro.
While she is trying to secure the attendance of an ICANN executive, she said the organization is being “not so forthcoming”, even maybe a little “defensive”.
If true, this is a pity. It strikes me that these the kinds of people ICANN needs to be reaching out to, even if it means one of its regular expository go-to guys has to squirm in his chair for a few hours.
“They’ve done such a bad job reaching out to this community,” Shapiro said. “Everyone I’m talking to has said: Why are they doing this?”
I put it to her that the new gTLD program has been in development for several years, and that literally anybody was able to participate in the creation of the Applicant Guidebook.
“The problem has been that the issue of domain management falls usually under the technical and legal sides of the house,” she said. “There’s been no collaboration between the IT, legal and marketing folks.”
Marketing people, usually focused on making short-term numbers, are only just waking up to the possibilities and potential problems that new gTLDs will create, she indicated.
The message that the new gTLD program is a cross-disciplinary challenge is also one that many new gTLD consultants have been preaching since even before ICANN approved the program in June.
There’s a convergence of views, to an extent, here. The problem seems to be the apparent disconnect between what the domain name industry thinks marketers should think and what they do think.
Marketers have been far more focused recently on the “local/mobile/social triad” of disruptive advertising technologies, rather than on new gTLDs, Shapiro said.
“The ICANN industry is completely disconnected from the realities of marketing industry,” she said.
The other demand Shapiro/CADNA has for ICANN is for the program to be made more corporate-friendly, but this appears to be very much a secondary concern.
The program currently requires applicants to disclose personal information about their company principals, which sits uncomfortably with many senior executives at large brands, for example.
The Continued Operations Instrument, a financial bond designed to fund failover support for defunct registries, is also a concern. As I noted earlier in the week, it seems unnecessary to impose this on single-registrant .brand applicants.
There are already at least two special provisions in the Applicant Guidebook that exclude .brand registries from certain commitments, so creating more would not be unprecedented.
The problem of course is that as soon as ICANN starts giving extra privileges to certain classes of applicant, it runs the risk of creating loopholes that can be gamed by other applicants.
What’s At Stake starts at 8.45am local time November 1. Shapiro said she’s hoping to webcast it and possibly even allow questions from people not able to attend in person.

Orange sponsors ICANN 42

The telecoms firm Orange has become a platinum sponsor of ICANN’s 42nd public meeting in Dakar, Senegal next week.
It’s a rare example of a company from outside the domain name industry handing over the big bucks to associate itself with ICANN.
While the company says it’s doing it for branding purposes, I’m sure it’s likely to set tongues wagging that Orange is a potential candidate for a .brand top-level domain.
If .apple is the no-brainer that is constantly used in articles to illustrate what a .brand is – and to highlight possible contention/objection issues – then .orange surely falls into the same category.
Platinum sponsorship for the Dakar meeting, which kicks off at the weekend, starts at $75,000. There are no takers for any of the other more-expensive sponsorship tiers this time.
Others paying up at this level are VeriSign, as usual, and the Public Interest Registry, which is publicizing its .ngo (non-governmental organizations) gTLD application.

With 86 days to go, the cost of new gTLDs is still unknown

If you’re planning to apply for a new generic top-level domain or two, wouldn’t it be nice to know how much it’s going to cost you?
It’s less than three months before ICANN opens the floodgates to new gTLD applicants, but you’re probably not going to find out how big your bank account needs to be until the last minute.
With 86 days on the clock until the application window opens, and 177 until it closes, there are still at least two huge pricing policies that have yet to be finalized by ICANN.
The first relates to reduced application fees and/or financial support handouts for worthy applicants from developing nations. I’ll get to that in a separate piece before Dakar.
The second is the controversial Continued Operations Instrument, a cash reserve designed to ensure that new gTLDs continue to operate even if the registry manager goes out of business.
In the current Applicant Guidebook, prospective registries are told to prove that they have enough money – either with a letter of credit or in a cash escrow – to keep their gTLD alive for three years.
To be clear, the COI money doesn’t go into ICANN’s coffers; applicants just need to show that the cash exists, somewhere.
The funds would be used to pay the Emergency Back-End Registry Operator (whichever company that turns out to be) in the event of a catastrophic gTLD business failure.
With hundreds of new gTLDs predicted, many of them likely to be laughably naive, we’re likely to see plenty of such failures.
With that in mind, ICANN wants to make sure that registrants and end users are not impacted by too much downtime if they put their faith in incompetent or unlucky registries.
It is estimated that the COI will amount to a six-figure sum for almost all commercial registries. For generics with a higher projected registration volume it could easily run into the millions.
It’s controversial for a number of reasons.
First, it raises the financial bar to applying considerably.
Forget the $185,000 application fee. Under the COI provision, applicants need to be flush enough to be able to leave millions of dollars dormant in escrow for at least five years.
It’s been sensibly argued that this money would be better devoted to making sure the registry doesn’t fail in the first place.
Second, even though the Guidebook gives .brand applicants the ability to shut down their gTLDs without the risk of another provider taking them over, it also expects them to create a COI.
This appears to be an unnecessary waste of cash. If a single-registrant .brand gTLD fails, the registry itself is the only registrant affected and the COI is essentially redundant.
Third, some applicants are thinking about low-balling their business model projections in order to keep their COI to a manageable amount.
This, as the better new gTLD consultants will tell you, could be a bad idea. When applications are reviewed the evaluators will be looking for discrepancies like this.
If you’re making one set of financial projections to investors and another to ICANN, you risk losing points on and possibly failing the evaluation.
Anyway, with all this in mind (and with apologies for burying the lead) ICANN has just said that it’s thinking about completely revamping the COI policy before applications are accepted.
Seriously.
ICANN’s Registry Stakeholder Group community has made a proposal – which appears to be utterly sensible on the face of it – that would reduce costs by pooling the risk among successful applicants.
The RySG said it that the COI “should not be so burdensome as to actually become a roadblock to the success of new registries by causing capital to be tied up unduly.”
Rather than putting up enough cash to cover its own failure, each successful applicant would pay $50,000 up-front into a Continued Operations Fund that would cover all potential registry failures.
The COF would be administered by ICANN (or possibly a third party), and would be capped at $20 million. In a round of 400 new gTLDs, that target would be reached immediately.
If the COF fell short of $20 million, each registry would have to pay $0.05 per domain name per year into the fund until the cap was reached.
It’s a shared-risk insurance model, essentially.
While ICANN’s COI policy is ultra-cautious, implicitly assuming that ALL new gTLDs could simultaneously fail, the COF proposal assumes that only a small subset will.
Reverse-engineering the RySG’s numbers, the COF appears to cover the risk of failure for registries representing some 10 million domain-years.
ICANN has opened up the proposal to public comments until December 2.
This means we’re unlikely to see any concrete action to approve or reject the COF alternative until, at the earliest, about a month before the first round application window opens.
ICANN likes cutting things fine, doesn’t it?

ICANN directors ruled out of CEO search

ICANN’s directors have been barred from applying for the soon-to-be-vacated CEO position.
The board elected a panel of directors to get the CEO search underway last Tuesday, but noted:

no current or incoming member of the Board or liaisons may be considered as a candidate for the role of the CEO for the current CEO Selection process.

A replacement for Rod Beckstrom, who announced that he will step down when his contract expires next June, will now be overseen by a special CEO Search Process Management Work Committee.
The committee will comprise: Steve Crocker, Bertrand de La Chapelle, Erika Mann Chris Disspain, Cherine Chalaby, Ray Plzak and R. Ramaraj. George Sadowsky will chair.
I had previously put at least three of those on my speculative list of “insiders” who could conceivably apply for the CEO’s job.

Google loses Goggle.com cybersquatting complaint

File this one under: “Good for UDRP, terrible for internet users.”
Google has managed to lose a cybersquatting complaint over the domain name goggle.com, after a National Arbitration Forum panel declined to consider the case.
Goggle.com, like so many other typos of the world’s most-popular sites, is currently being used to get people to sign up to expensive text messaging services via bogus surveys and competitions.
As Domain Name Wire reported when the complaint was filed, up until recently the site was using a confusingly similar style to Google’s familiar look and feel.
It’s got bad faith written all over it.
But “goggle” it is also a genuine English word.
And it turns out that the previous owner of goggle.com, Knowledge Associates, had entered into a “co-existence relationship” with Google that enabled it to operate the domain without fear of litigation.
The current owner was able to present NAF with documentation showing that this right may have been transferred when he bought the domain.
So the three-person NAF panel decided not to consider the complaint, concluding: “this case is foremost a business and/or contractual dispute between two companies that falls outside the scope of the Policy.”
The panel wrote:

Does the Co-existence Agreement apply to the disputed domain names? Does Respondent stand in the shoes of the original registrant? Does the consent of Complainant extend in time to the current actions of Respondent and in person to the Respondent? Has the Respondent complied with the obligations of the original registrant? Does the “no public statements” provision in the Co-existence Agreement prohibit its disclosure or use as a defense by Respondent?
These are factual and legal issues that go far beyond the scope of the Policy.
These are factual and legal issues that must be resolved before any consideration of confusing similarity, legitimate rights and interest, and bad faith under the Policy can be made.

This means that the current registrant gets to keep the domain, and to keep making cash from what in the vast majority of cases are likely to be clumsy typists.
Google now of course can either decide to pay off the registrant, or take him to court.
The registrant, David Csumrik, was represented by Zak Muscovitch.

VeriSign’s .com takedown power grab causing controversy

VeriSign’s request for a wide-ranging set of powers that would enable it to shut down .com and .net domain names that are suspected of abuse is already attracting criticism.
The proposals came in a Registry Services Evaluation Process request to ICANN that I reported on for The Register this morning.
It’s asking (pdf) to be able to create a new anti-abuse policy that would refocus many of the controls currently in the hands of registrars to the registry level instead.
The policy would “allow the denial, cancellation or transfer” of any VeriSign-managed domain if any any of these conditions were triggered:

(a) to protect the integrity, security and stability of the DNS;
(b) to comply with any applicable court orders, laws, government rules or requirements, requests of law enforcement or other governmental or quasi-governmental agency, or any dispute resolution process;
(c) to avoid any liability, civil or criminal, on the part of Verisign, as well as its affiliates, subsidiaries, officers, directors, and employees;
(d) per the terms of the registration agreement,
(e) to respond to or protect against any form of malware (defined to include, without limitation, malicious code or software that might affect the operation of the Internet),
(f) to comply with specifications adopted by any industry group generally recognized as authoritative with respect to the Internet (e.g., RFCs),
(g) to correct mistakes made by Verisign or any Registrar in connection with a domain name registration, or
(h) for the non-payment of fees to Verisign. Verisign also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute;

As you can see, that’s a pretty broad range of justifications.
Notably, it would enable a domain to be canceled or transferred at the “requests of law enforcement or other governmental or quasi-governmental agency”, which would seem to circumvent the current practice of a court order being obtained before a domain is seized.
The question of what constitutes a “quasi-governmental agency” is also interesting. Is ICANN itself such a thing?
The policy would also enable a take-down “to avoid any liability, civil or criminal”, which seems to be just begging for VeriSign to be named spuriously in commercial lawsuits between .com registrants.
The RSEP also suggests that VeriSign plans to extend its hand of friendship to law enforcement agencies from outside the US:

Pilots with European Law Enforcement, Government CERTS and Registrars are planned, and other global test pilots will follow, to ensure global collaboration in the continuing development of the procedures.

Today, US agencies can get court orders instructing VeriSign to hand over domains. While imposing US law on .com owners from other countries is controversial, at least overseas registrants know where they stand.
Now VeriSign is talking about cooperating with European law enforcement agencies too.
At the risk of getting dangerously close to invoking Godwin’s Law, this brings us back to an old jurisdictional problem – what if the French police demand the seizure of a .com site selling Nazi memorabilia, which is illegal in France but legal in the US, for example?
Taking it a step further, what if VeriSign starts entertaining takedown requests from some of the world’s least pleasant theocracies, banana republics and dictatorships?
Half of .com could disappear overnight.
Since VeriSign has a business to run, that’s obviously not going to happen. So the company is going to have to draw a line somewhere, separating criminality from legitimate behavior and free speech.
I’m speculating wildly here, of course, but the RSEP doesn’t contain nearly enough detailed information about VeriSign’s proposed procedures to make a more informed analysis.
VeriSign knows what it is proposing is controversial. The RSEP says:

Registrants may be concerned about an improper takedown of a legitimate website. Verisign will be offering a protest procedure to support restoring a domain name to the zone.

The proposals have been made following many months of discussions between registries, registrars, law enforcement agencies and other community stakeholders.
It’s not entirely clear from VeriSign’s RSEP, which sometimes confusingly conflates the abuse policy with a separate proposed malware scanning service, how a takedown notice would be processed.
One likely reading is that VeriSign would act almost like a centralized clearinghouse for takedown requests, forwarding them to individual registrars for enforcement.
The registrars could be obliged by the terms of an amended Registry-Registrar Agreement to follow whatever process had been laid down.
There seems to be some concern in the ICANN community about this.
ICANN senior VP of stakeholder relations Kurt Pritz recently sent a document to PIR’s David Maher and Oversee.net’s Mason Cole outlining the procedure for amending the RRA.
The flowchart (pdf) describes a trilateral negotiation between the registry proposing the change, the Registrars Stakeholder Group and ICANN, with the ICANN board having the ultimate decision-making authority.
However this proceeds through ICANN, it’s going to cause some heated community debate.