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===EC Concerns Over the Full Removal of Vertical Separation===
 
===EC Concerns Over the Full Removal of Vertical Separation===
On June 17, 2011, the Information Society and Media Directorate General of the [[European Commission]] (EC) submitted a non-paper regarding ICANN's proposed full removal of the vertical separation to the ICANN Board. Copies were furnished to [[NTIA]] Assistant Secretary [[Larry Strickling]] and to Assistant Attorney General Christine Varney of the Department of Justice Antitrust Division. The EC cited some issues and recommendations, which include:<ref>[http://www.icann.org/en/correspondence/eu-to-icann-17jun11-en.pdf Removal of Vertical Separation Between registries and Registrars for New and Existing gTLDs]</ref>
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On June 17, 2011, the Information Society and Media Directorate General of the [[European Commission]] (EC) submitted a non-paper regarding ICANN's proposed full removal of the vertical separation to the ICANN Board. Copies were furnished to the U.S. [[NTIA]] Assistant Secretary [[Larry Strickling]] and to Assistant Attorney General Christine Varney of the Department of Justice Antitrust Division. The EC cited some issues and recommendations, which include:<ref>[http://www.icann.org/en/correspondence/eu-to-icann-17jun11-en.pdf Removal of Vertical Separation Between registries and Registrars for New and Existing gTLDs]</ref>
 
* Vertical separation provides a balanced playing field for competition between registrars. The absence of expert advice to remove vertical separation and stakeholders consensus shows that the move may be premature and might result in negative market output for consumers.
 
* Vertical separation provides a balanced playing field for competition between registrars. The absence of expert advice to remove vertical separation and stakeholders consensus shows that the move may be premature and might result in negative market output for consumers.
 
* Vertical Integration might harm competition. The European Commission cited the CRA International Report of 2008, which emphasized the risk of vertical integration wherein registries may discriminate independent registrars by lowering prices and providing better registry services to their affiliate registrars.  
 
* Vertical Integration might harm competition. The European Commission cited the CRA International Report of 2008, which emphasized the risk of vertical integration wherein registries may discriminate independent registrars by lowering prices and providing better registry services to their affiliate registrars.  

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