Dear Chuck, As per sections 2 and 3 of the Procedural Guidelines, I hereby submit to you questions on behalf of the OPENSRS RSPs Group regarding the proposed WLS.
The point of contact is George Kirikos ([EMAIL PROTECTED] or [EMAIL PROTECTED]). OPENSRS RSPs (registration service providers) are the clients of OpenSRS, and are responsible for providing domain name registration services to registrants of approximately 2.6 million domain names in the com/net/org TLDs. The number of OpenSRS RSPs is confidential for business reasons, but exceeds 1000. OPENSRS RSPs are a diverse mix of internet service providers, webhosting companies, web design firms, individual domain name holders, domain developers, corporations with domain holdings, and companies that resell domain registrations to end users. As such, this group has interests regarding the WLS both as registrants and as resellers of products in the domain name industry. The general purpose of OPENSRS RSPs is the maximization of profits as resellers of domain name products, and maximization of consumer choice and service as domain registrants. As befits a group with the word "open" in its name, all discussions by the group have taken place openly on the OpenSRS mailing lists, and are archived at: http://www.opensrs.org/archives/mailing.index.shtml (discussions have taken place on WLS and its variants since December 2001 to help create these questions) As the point of contact, I hereby submit the following questions on behalf of the group: 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 system similar to CIRA's? 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 competitive landscape that currently 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 that is already 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 an 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 to 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? 21. a) How does Verisign plan to rectify and answer for its current flawed and inadequate processes in domain deletion process from its position as a Registrar? Verisign has been hoarding expired domains for months or years past the expiration dates (for instance see: http://www.eyeondomain.com/_expired-domains.htm , a list of domains with expiration dates from MARCH 30, 1999 up to FEB 27, 2001 being monitored for some customers). These consumers repeatedly phone, fax, and email Verisign and ICANN demanding that Verisign release these domains with no success. Under WLS, the situation will be exacerbated, as WLS holders will want the domains deleted as quickly as possible. b) What mechanisms will be in place to force a Registrar to delete an expired name in a timely fashion when the WLS holder is using a different registrar? c) What is the longest time after a domain has expired that a domain MUST be deleted? (this will affect the value of the WLS subscription, if domains can be hoarded and not deleted even 2 years after expiry, for instance) 22. Verisign has been the subject of a great many consumer and registrar complaints, which are independently verified by ratings at Epinions (3% recommended): http://www.epinions.com/cmsw-EmailChat-All-networksolutions_com/display_~reviews and other postings at: http://www.infoworld.com/articles/op/xml/01/04/02/010402opfoster.xml http://www.icannwatch.org/article.php?sid=535&mode=thread&order=0 http://www.nsihorrorstories.com http://forum.icann.org/offtopic/ a) Given this poor record, on what basis can Verisign justify adding additional services at the registry level, when a large number of consumers want minimal contact with Verisign and would prefer innovation to take place at the registrar level? b) What steps will Verisign take to ensure that low quality service will not rub off on resellers of WLS who must deal directly with end-users? c) What customer support (both to end-users and resellers) will Verisign have in place with regards to WLS to minimize problems? We look forward to receiving Verisign's responses to the above questions, and shall submit final feedback on March 1, 2002. Sincerely, George Kirikos http://www.kirikos.com/ __________________________________________________ Do You Yahoo!? Send FREE Valentine eCards with Yahoo! Greetings! http://greetings.yahoo.com
