[registrars] Small business defined for registrars

["Robert F. Connelly" <rconnell@xxxxxxxxxxxxx>]

Dear Registrars:

Background:

1.  We have been told by ICANN that one of the major reasons for the large 
increase in total budget is the demands by the Department of Commerce (DOC).
2.  It appears that we registrars are the source of last resort for 
ICANN.  That is, every dollar beyond what they can collect from registries 
(including ccTLD registries) and a few other sources must be collected from 
registrars.
3.  A significant number of ICANN Accredited Registrars are small businesses.

4.  Small businesses under the rules of the U.S. Small Business 
Administration (SBA) are defined based upon the business type.
5.  These classifications are found in the SBA web site:

	https://eweb1.sba.gov/naics/dsp_naicslist2.cfm

	http://www.sba.gov/size/summary-whatis.html

	https://eweb1.sba.gov/naics/dsp_naicssearch2.cfm

The last seems to be the best for our purposes.

The best fit appears to be as follows:

Information Technology
Value Added Resellers
NAICS Code 541519
Not to exceed  150 employees
SIC Code  7379

NAICS code 541519 has two other entries which have the limit of not to 
exceed US$21,000,000. annual turn over.
The Small Business classification also appears to apply to any small 
business with at least one office in the United States.
6.  I suspect that many ICANN Accredited Registrars constitute "small 
businesses" within the SBA rules.
Action:

1.  I propose that we survey our members and determine which may be 
classified as small businesses.
2.  I propose that Small Business registrars then appeal to the SBA to 
obtain relief from the excessive burden resulting from the DOC demands upon 
ICANN.
I am undertaking this endeavor in my capacity as representative of 
PSI-Japan, Inc., not wearing my Secretary hat.  Please respond to me 
directly, with or without copying <registrars@xxxxxxxx>.
Regards, BobC