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[ga] Email Response to Letter from Verisign's Roger Cochetti dated July 16, 2001

This is a copy of a letter sent today via email, fax, and postal mail
to Stuart Lynn, CEO of ICANN, in response to a letter from Roger
Cochetti to Mr Lynn dated July 16th regarding domain name transfer

You are receiving this email because you are either on the DNSO
General Assembly mailing list, or because you are a member of the DNSO
Names Council or the Board of Directors of ICANN.

Names Council members, the signers of this letter request that you
forward a copy of this letter to your constituency members for their

William Walsh

This is a forwarded message
From: William X. Walsh <william@userfriendly.com>
To: Stuart Lynn <lynn@icann.org>
Date: Friday, July 20, 2001, 1:12:49 PM
Subject: Email Response to Letter from Verisign's Roger Cochetti dated July 16, 2001

===8<==============Original message text===============

[Copy to Follow via Fax and Postal Mail]

July 20, 2001
Mr. Stuart Lynn
President and Chief Executive Officer
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA

RE: Response to Cochetti letter dated July 16, 2001

Dear Mr. Lynn,

In his July 16th letter, Mr Cochetti referred to rampant unauthorized
domain name transfers from the Verisign Registrar.  In his letter he
mentioned a survey that Verisign conducted which he claims illustrated
that a significant number of domain registrants whose domain names
were transferred out of Verisign to other competing registrars were in
fact unauthorized by the domain registrant.  His evidence is that
roughly 24% of those surveyed claimed they did not ever request to be
transferred, and that 33% did not even know they had been transferred.

These numbers sure sound ominous on their face.  However, they only
appear that way because the survey did not take into account many
realities that have been involved in the domain registration industry
since prior to the introduction of competitive registrars in 1999.

ISPs/IPPs (Internet Service Providers and Internet Presence Providers)
have for many years handled the domain registration service on behalf
of their customers, and did so with their customers' consent.  In
fact, the management of the domain registration, renewal, and updates,
were considered a part of the complete customer service that ISPs and
IPPs had long offered.  Many times the customer was not even aware of
who Network Solutions was, and if they had heard of them,  had no idea
what their role was.  They expected that their ISP/IPP was responsible
for that, and entrusted the management of their domain registration to

Prior to the introduction of competitive registrars, Network
Solutions' tremendous growth in domain registrations was probably more
directly a result of this kind of service from ISP/IPPs.  Many
ISP/IPPs felt mistreated by Network Solutions' when they began
advertising web hosting services on whois pages and other pages in the
Network Solutions site, which motivated many more of them to add
additional buffers between NSI and the customers of the ISP/IPP.

When companies such as Tucows and BulkRegister.com began offering
competitive domain name registration, and specifically catered to the
needs and concerns of the ISP/IPP community, many thousands of them
flocked to sign up to process domain registrations and renewals (aka
transfers) through their wholesale offerings.  Most of them had
numerous domains at Network Solutions registered to themselves and
their customers.  While many did mass transfers of all their domains,
others did them over time, or as they would come close to renewal.
The end users, or registrants, expected their ISP/IPPs to make these
decisions for them, and if they were asked to approve an email notice
they received, they simply did it.  Again, this was a part of the
trust they put into their ISP/IPP.

As ISP/IPPs it was our responsibility to provide the best service to
our customers, and that included managing their domain name service
for them, and making decisions with regard to suppliers.  Suppliers
are not only those companies who provide the dedicated connectivity
that we host their sites on, but also their domain name registrations.
 Just as we would not seek a customer's permission to move our servers
 off of a connection from one Telco to another who can provide better
 service to us, we would not ask our customers to learn and understand
 all the intricacies of the domain registration business and all the
 companies and names involved simply because we were switching
 wholesale providers.  Those decisions are ones they expect us to
 make, and prefer to be as distant from them as possible.

It is our contention that the survey Verisign conducted was flawed at
its most basic levels by making assumptions that domain registrants
were even aware of what a domain transfer was, or that their domain
was ever registered at Verisign, or even what any of that meant.
According to comments made by Tucows CEO Elliot Noss to Newsbytes, the
cases that Verisign has quoted to the registrars as examples of the
unauthorized transfers were exactly the types of cases referred to

As ISP/IPPs dealing with customers who want and expect better domain
name registration service, we have had to deal with the existing
change in policy at Verisign that requires an additional
acknowledgement to Verisign of the registrant's intent to transfer or
the transfer is blocked.  We are in the trenches seeing the real world
implementation of this policy, and we can tell you first hand that it
is not working the way Verisign is claiming it is.  Many times these
verification messages are sent out very late, if at all, and the
default blocking policy goes into effect before the registrant has
anything resembling a reasonable chance to respond.  Many times they
don't even understand the message, so their response is delayed
further while they contact their ISP/IPP asking what to do.  If these
messages were always sent out the first day the registrar received the
automated notice of the outgoing transfer request, this might not be
such a big issue.  However, Verisign's systems regularly fail to do

The delays caused by this policy are great.  The transfer request has
to be resubmitted, after the initial one has timed out at the
registry, and the process starts again.  Hopefully, Verisign sends the
notice out with more expediency the second time around.  However, many
domain registrants are experiencing such long delays in finally
getting a domain transfer processed because of this policy, that their
domain names pass the renewal date, and then Verisign denies the
transfer claiming they are then owed the renewal fee of $35.00USD
before they will release the domain for a transfer.

We are seeing this in so many cases on a weekly basis, that we can
only believe that this system was intentionally put in place to hamper
the transfer process and thus stem the tide of domain registrations,
and the related revenue, that has been flooding out of the Verisign
Registrar.   And when Verisign was called on it by providers such as
Tucows, Verisign created this excuse to justify their policy, and to
justify an even more extreme suggested policy that would effectively
force transfers to have a much steeper expense in both monetary cost
as well as time and convenience.

These actions are anti-competitive in the extreme.  We find Verisign's
accusations which claim actions by ISP/IPPs such as ourselves
constitute "domain slamming" to be offensive accusations, which
deliberately leave out the full and true facts of the cases in order
to justify their anti-competitive positions and stance, and protect
their dominant position which they hold only because of their prior
monopolistic state.

Cochetti states in this letter that "most customers register with the
VeriSign Registrar because of its uniquely strong commitment to
customer service and the notion of trust on the Internet."  However,
the truth of the matter is that the most customers do not even know
who Verisign is, or exactly what their role is in the market, or the
difference between Verisign's registrar and registry services.  It
also ignores the fact that most of the domain name registrants in
their service were funneled to them via ISP/IPPs who marketed the
concept of having a domain name and internet presence to these
registrants.  The business Verisign got from those transactions was
incidental, and mostly a result of there being no competitive market
or alternatives at the time.

As ISP/IPPs we are all deeply involved and concerned in matters of
domain policy, and see first hand the effects of those policies on
both our own businesses and the end user/registrants.  We are deeply
concerned with any movement by Verisign to push ICANN into developing
excessively prohibitive policies that are meant more to bolster the
position of Verisign rather than to meet ICANN's obligation under its
Memorandum of Understanding with the US Government Department of
Commerce to foster a competitive environment in the domain name

If Verisign was truly concerned about making sure that domain
registrants are given the opportunity to block unwanted transfers from
them, they would instead adopt a policy similar to the one that Tucows
has adopted for outgoing transfers.  The administrative contact for
the domain is given notice that a transfer request has been received,
and who the receiving registrar is.  They are then given the
opportunity to block the transfer, or to explicitly approve the
transfer.  The transfer is approved if it is not blocked by the
registrant.  Explicitly approving the transfer is not required, but if
they do the transfer is ACK'd automatically, which speeds up the
process for the registrant.

The Tucows policy is an example of one that protects the registrant
from unauthorized "slamming" but which doesn't create a prohibitively
complicated system that is geared to keeping the customer who has
already decided to leave, or whom has delegated that decision to their

We urge ICANN to reject any suggestion by Verisign that ICANN enforce
prohibitive policies on domain transfers, and to use the force of its
contracts to mandate that Verisign not engage in these types of
anti-competitive actions.


William X Walsh <william@userfriendly.com>
Owner, Userfriendly.com

Charles T. Smith, Jr  <Charles.Smith@ispc.org>
Chair, ISP/C
Internet Service Providers' Consortium

Matthew Gallant <business@i-dotter.com>
Owner, I-Dotter.com

Brent Sims, Owner
WebOkay Internet Services
 (719) 595-1427 (Voice/Fax)

Jim Larrabee <jdl@ticnet.com>
Webland Enterprises

Nicholas B. Swift < nswift@dmcom.net>
President, Digital Marketplace, Inc.

Marc Schneiders <Marc@Schneiders.ORG>
Venster DNS Solutions (http://venster.nl/)

William Himmelstoss  <whimmel@onefingertech.com>
Owner, One Finger Technology

Bill Gerrard <bill@daze.net>
Vice President, Daze Networks, Inc.

Joseph Malinowski <webmaster@iwpp.com>
Owner, Internet Web Presence Provider
Ph: 609.893.3486

Hugh Buchanan <hbuchanan@harveyopolis.com>
President/CEO, Harveyopolis Corporation

Jeremy Luebke <jeremy@rockhosting.com>
Owner - RockHosting.com

Jim Jones, Jr. <jim@oct.net>
WTC Communications, Inc. (www.wamtelco.com)

Ryan Brown <rbrown@tbns.net>
Owner, TBNS.net

Drew Linsalata (drew@gothambus.com)
The Gotham Bus Company, Inc.

Eric Longman  <webwiz@atlcon.net>
Atl-Connect Internet Services

Hugh P Blair <registrar@wholesalenics.net>

Andy Paluch <apaluch@tele-base.net>
Owner, Tele-Base Inc.

Sťan Flynn <sflynn@tec-man.com>
Owner, TMS, Technology Management Services

Sheldon Koehler, Owner/Partner
Ten Forward Communications

Hossein Farmani <farmani@anet.net>
Anet Communications

Doug Renn <renn@nestegg.com>
Owner, Nestegg, LLC 

Eric Paynter <eric@arcticbears.com>
Owner, Arctic Bears Computing

Peter I. Mignone <pete@pbis.net>
President, PBIS.NET, Inc. 
803 Broadway
Ulster Park, NY 12487

Charles T. Smith, Jr. <cts@5sc.net>
CTO, Five Star Communications

Genie Livingstone <genie@magi.net>
Operations Director

David Moore < dwmoar@findmoore.net>
Owner, FindMoore.Net

Phillip Beazley < pcbmls@futuresights.com>

David Dorey  <david.dorey@xsession.com>
Director, Xsession.Com Limited
United Kingdom.

Jack Broughton, <jack@ctsolutions.com>
CanTech Solutions

Barbara Brasfield < barbbras@dbtech.net>
VP, db Technology, Inc.

Allen Jenkins <gkins@nwol.net>
President, NetWest Online, Inc.

Darryl Lynch <dassa@dhs.org>
CEO, DHS International

Elise L. Smith <admin@janrix.com>
VP of Operations

David Harris <dharris@drh.net>
President, DRH Internet Inc.
http://www.drh.net/ 410-461-5316
Web Host, OpenSRS RSP

Richard Pedersen <rich@cybernet1.com>
President Cybernet1, Inc

John Blakney <blakney@vdbs.com>
Owner, Visual Database Systems

Lee Gillett
Managing Director
UK Domains: www.ukdomains.net - UK Hosting: www.ukhosting.net
Gillett Multimedia Ltd.: www.gmm.co.uk

Kai Schštzl <maillists@conactive.com>
Web Operations Officer
Conactive GmbH & Co KG, Germany

Beric Farmer <bfarmer@xe.com>

William S. Lovell, PhD
Attorney at Law

Tim Jung <tjung@igateway.net>
Internet Gateway Inc.
St. Louis, Missouri, USA
OpenSRS RSP, OpenSRS Consultant

Oscar Petoskey
Rocket Network Solutions

Kirk L. Kroeker (kirk@NimbleDomain.com)
president, NimbleDomain, Inc.

Karl E. Peters
President & CEO Bridge International Holdings, Inc.
CEO Atlantic Root Network, Inc.
Tel.: (912) 638-1638
Fax: (912) 638-1467
E-Mail: karl.peters@bridgecompanies.com

Bruce M James  bmj@keyName.net
President / CEO / COB
KeyNames, Inc.
Ph: 409-781-6666

Bryce Weathersby, Owner
Weathersby Systems & Design
409-980-4310 Phone

Mike Mattox <mcm@mcmsys.com>
Owner, MCM Systems

Nico Morrison <nico.morrison@micronicos.com>
Managing Director
Micronicos Limited
London, UK

Sam Cogheil
Managing Director
E Business Services Ltd

Jeff Willis (jw@mis-sciences.com)
VP Technology
Commercial Internet Services
MIS Sciences Corporation
Burbank, California

Colin Viebrock
Co-Founder, easyDNS Technologies Inc.

Kristopher Gilbert (ogre@videogasm.com)
Videogasm: A Multimedia Explosion

Leah Gallegos <admin@biztld.net>
President, AtlanticRoot Network, Inc.
Owner, Creative CompuSec

A Michael Salim
CEO, American Data Technology, Inc.

J Scott Schiller
GIA Web Services, Inc.
10575 NE 4th
Bellevue, WA 98004

Joe Morlino
Owner, EDI Technologies

===8<===========End of original message text===========

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