Hello,

Verisign requires that interested parties submit their questions by
Friday. I was curious if OpenSRS resellers, as a group, would be
interested in submitting questions (i.e. are we a "constituency"?)

We'd need to provide:

- brief explanation of what our interest is in the proposed WLS
offering (I suppose we'd be resellers of it)
- objective data regarding the size of the group (maybe Tucows can fill
in this blank; something like 3000+ resellers representing registrants
for 3 million domains?)
- characterization of the members of the group (I'd say it's a mix of
domain resellers and domain holders)
- mission of the group (a group of OpenSRS resellers?)

We also need a point of contact for the group. If someone at Tucows
would like to be the liaison, that might be best. Or, if there are no
volunteers, I can do it, although perhaps someone with more experience
like William Walsh, Genie, Don, or others who've been following this
issue would like to take the lead being the representative -- consider
yourselves nominated! :).

Here are some questions I've already thought would be of use in
assessing the impact of WLS. If others can add to it before Friday, we
can make one big list and submit it to Chuck Gomes 

NB: to save bandwidth, please don't copy the entire set of questions if
adding others.....maybe just create new numbers, like 101, 102, 103,
etc., and then we'd piece them all together from the archives. :)

1. CIRA, the registry for dot-ca, was able to manage 100-times
scalability when it released expired names recently for re-registration
(see http://www.cira.ca/news-releases/63.html ). Given that this
non-profit registry did not require a wait-list system, nor a
surcharge, what are the technical flaws in Verisign systems that
prevent a similar system as CIRA?

2. a) What are the success criteria that Verisign/ICANN intend to use
at the end of the 1-year WLS testing period (these should be specified
ex-ante, not ex-post)? 
   b) Do those criteria take into account the existing competitive
landscape that exists in the market?
   c) If so, what market measurements has Verisign/ICANN made of the
current competitive landscape (NameWinner, eNom, AWRegistry,
ExpireFish, SnapNames, NicGenie, IARegistry, Signature Domains, and
other competitors), to serve as the basis for a comparison?
   d) Under what metrics will the WLS test be considered a failure?

3. At: http://www.dnso.org/clubpublic/ga/Arc09/msg00081.html Chuck
Gomes wrote "The value to the Internet community therefore seems rather
obvious to me. But, if there is none as you suggest, then the service
will be a failure.  On the other hand, if there is demand and hence
value, it will succeed.  The level of success will depend on how much
demand and value there is.  The best way to test it is to let the
market prove it one way or other."

There currently exists a competitive market in the automotive industry
(as there is for the expired domain names industry). If it was replaced
by a single monopolistic seller for a 1-year test period, cars would
undoubtedly still be bought, as there is a intrinsic demand for cars
themselves. How does Verisign/ICANN intend to differentiate the demand
for WLS from the demand for the expired names themselves, when there
would be no alternative mechanism for securing those expired names for
which there is a basic demand already that is being satisfied in the
market?

4. If the WLS is deemed to be illegal (due to anti-trust law, and/or
relevant Commodity Futures law), will Verisign/ICANN indemnify affected
resellers, registrants and other market participants from all
liability, legal costs, and implementation costs associated with the
1-year test?

5. a) How much is Snapnames being paid per reservation? Why?
   b) What are the relevant patent-pending registration numbers for any
intellectual property that is involved in the creation of the WLS, in
particular the "Parallel Registry" technology?

6. What is the definition of "abusive speculation"? In particular, do
any of the 55 examples from the SnapNames Hot 100 referenced at:

http://www.dnso.org/clubpublic/ga/Arc09/msg00085.html

constitute "abusive speculation"? (I will note that as of this writing,
the Hot 100 list on SnapNames' website is apparently no longer
available, although the mirror is available)

7. Why has Verisign refused to implement various technical fixes to
reduce registry load issues, including "rate-limiting" technology and
"extended response codes"?

8. a) What is Verisign's proposed wholesale price for a variant of WLS
with zero (0) exchanges?
   b) What are Verisign's proposed wholesale prices for a variant of
WLS with a two-stage  mechanism, where the WLS holder is charged $X for
their place in queue, and then and additional $Y if and only if the
domain is deleted, with no exchanges? (i.e. tell us X and Y)

9. a) Verisign has highlighted that there are 80-100 million domain
"checks" per day. What is the number of checks per day on average,
broken down by each of the accredited registrars?
   b) Which of the above registrars are performing these checks on
behalf of SnapNames?

10. Has Verisign considered implementing a 1-year test on the dot-TV
and dot-CC TLDs, instead of on dot-COM and dot-NET? Why wouldn't a test
on those two TLDs suffice, if it's merely a "test"? (rationale: a test
on dot-TV and dot-CC would not impact the existing competitive deleted
domains industry, and would also provide the further advantage of
comparison between the two alternative markets on the same time-scale)

11. a) Will existing holders of SnapNames SnapBacks be grandfathered
into the WLS? 
    b) If not, what are the proposed Sunrise and Landrush mechanisms
for the WLS?

12. Since WLS subscriptions purchased in the final month of the "test"
will continue be honoured, doesn't this mean that the impact of this
"test" on the deleted domains market will be for 2 years and not merely
1 year?

13. a) Under what metrics does Verisign plan to decide that there is a
stakeholders "consensus" for bringing forth this proposal to ICANN? In
particular, what level and nature of opposition must exist to abandon
the proposal?
    b) Under what conditions do counter-proposals by other stakeholders
receive attention as viable alternatives to WLS?
    c) Why is the "Status Quo" proposal not an option? (it seems to
have greater support and consensus at this time than the WLS) If it has
greater support than the WLS, why is the "Status Quo" not the best
option?

14. Verisign has not had a batch deletion in about 4 weeks. Have batch
deletions been suspended pending the resolution of the WLS proposal?

15. a) Will the WHOIS information for the WLS subscription holder be
made public?
    b) If not, why not?

16. a) If a name is deleted "in error", does it go back to the original
registrant?
    b) What are the exact conditions that constitute a deletion "in
error"?

17. Will WLS subscriptions be refused on names that expire after the
end of the WLS subscription?

18. How does the WLS system handle credit-card chargebacks by
registrants (and the associated chargeback fees) who fail to acquire a
name?

19. How will WLS enhance competition and innovation in the deleted
domain industry, when it will reduce the number of available business
models that presently exist in the marketplace?

20. Which of the existing business models that are active in the
deleted domains market (eNom, SnapNames, NameWinner, NicGenie,
Signature Domains, IARegistry, AWRegistry, ExpireFish, and others) are
inappropriate and/or violations of their respective registrar
agreements?

Sincerely,

George Kirikos
http://www.kirikos.com/



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