[registrars] Legal compliance with the RAA

["Bhavin Turakhia" <bhavin.t@xxxxxxxxxxx>]

I just checked the ICANN RAA and found -

3.9.2 Variable Accreditation Fee. Registrar shall pay the variable
accreditation fees established by the ICANN Board of Directors, in
conformity with ICANN's bylaws and articles of incorporation, provided that
in each case such fees are reasonably allocated among all registrars that
contract with ICANN and that any such fees must be expressly approved by
registrars accounting, in the aggregate, for payment of two-thirds of all
registrar-level fees."


The above paragraph explicitly states - "provided that in each case such
fees are reasonably allocated among all registrars"

* I wonder if this current budget which charges all registrars a $19000 fee
irrespective of their size would be considered as a "reasonable allocation"
amongst registrars

* I also realise now that this contract favours the larger registrars due to
the statement "and that any such fees must be expressly approved by
registrars accounting, in the aggregate, for payment of two-thirds of all
registrar-level fees"


- bhavin