[nc-transfer] RE: Verisign WLS Proposal

["Cade,Marilyn S - LGA" <mcade@att.com>]

Title: Fwd: Verisign WLS Proposal

Kenneth, thank you for your post. I have forwarded to the Transfer TF, as requested.   I apologize that we were so hard to find. Thanks for making the extra effort.

 

Thanks, Stuart, for forwarding.

 

 

Marilyn Cade

-----Original Message-----

Warm regards

Stuart

X-Sender: kahirsch/pop-server.san.rr.com@pop3.norton.antivirus
Date: Sun, 14 Jul 2002 21:21:08 -0700
To: lynn@icann.org

From: Kenneth Hirsch <KAHirsch@san.rr.com>
Subject: Verisign WLS Proposal

Dear Mr Lyon:

Please forgive me for contacting you directly on a matter which is being handled by an assigned task force. however, nowhere on the ICANN site could I find an appropriate address to which to send my comments other than the public discussion board. My comments on the WLS are somewhat lengthy (forgive me again), and I felt a direct communication was therefore more appropriate. If this should not go to you, I would like to impose upon you or your staff to redirect it to the appropriate party. I attach my comments both in a Word document and below.

I thank you in advance for your kind attention and assistance,

Kenneth A Hirsch
@Com Technology, LLC
(accredited, but not yet operating)

@Com Technology, LLC
9878 Caminito Laswane
San Diego, California 92131

To:     Marilyn Cade, Chairperson
       WLS Task Force

RE:       Verisign WLS Proposal

Dear Ms. Cade:

I am the CEO of @Com Technology, LLC, an ICANN-accredited registrar about to "go live" or operational. I would like to express my views and that of our firm regarding the proposal set forth by Verisign. In doing so I will ask for forgiveness in advance for certain "editorial" comments which serve as a prelude to my comments about the issue itself. I feel, however, that they are necessary in order to better define the context which led to my perspective and opinion.

1.      While @Com is not yet operational, both I and my primary business partner have owned registration service companies for several years. The specific purpose for this was to income-generation, but to learn as much as possible about the registry system on a first-hand basis, in preparation for developing our own ICANN-accredited firm.


2. Consistently throughout the 2½  years during which we have prepared for this endeavor, we have been strongly and negatively impressed with the business practices of Network Solutions, and now Verisign since those practices have been continued and further developed since Verisign's acquisition of Network Solutions.  The practices of which I speak range from the very basic of poor customer support to the more concerning policies of making it extra-ordinarily difficult for their existing customers to leave Network Solutions for other registrars (e.g., to transfer their domains elsewhere). This issue is important, in my limited opinion, because it makes me inherently suspicious  and perhaps inappropriately so  on any proposal set forth by Verisign. I feel it is important to identify at the outset that I have a bias in evaluating Verisign's proposal.


3.     Network Solutions / Verisign has a demonstrated track record of not complying with their own stated policies in the realm of expiring domains. To be specific, I have found a number of domains that have expired in excess of two years ago, but which have not been released to the public for registration. This typically occurs involving domains that speculators consider to have intrinsic value.


4.     I wholeheartedly support a systematic approach to dealing with the expiring domain situation. Various registrars have different deletion policies, and many registrars do not even follow the policies which they public  Verisign being chief among the latter category. I would therefore urge and support a single governing policy established by ICANN that dictates the policy for all registrars. I would gladly give up the autonomy that I possess as a registrar in order to have equity in the field. I would submit that a policy requiring deletion after either 30 days or 45 days post-expiration would be most appropriate.

5.      Verisign's proposal gives precedence  actually exclusivity  to SnapNames. I must state here that my firm is a SnapNames partner. We enjoy a comfortable and profitable relationship with SnapNames. Yet, I am advocating against the very policy that SnapNames endorses and from which my company would benefit, simply because it is an unfair policy. It eliminates competition. Were the task force to accept my perspective and reject Verisign's proposal, my firm would lose money - but I am proposing just that. The Verisign proposal is an exercise of unfair trade practice and unfair restraint of trade. Please note that my conviction in this regard must be rather strong if I am willing to curtail a revenue stream in order to support principle...


6. Looking at the historical development of the internet, however brief that history has been, one finds in general two opposing trends. The first is towards democratization and egalitarianism is the sense that the "little person" is able to enter the marketplace with relative ease. The second is the degree of consolidation that has occurred, especially over the past four years. Four years ago a small business could find ways of placing itself in high rankings in search engines without bankrupting itself in premium payments  in a competitive area that is no longer true. Many existing registrars have been purchased, primarily by Network Solutions / Verisign and secondarily by certain other players in the market. Network Solutions was forced to divest itself of its monopoly in com/net/org registrations  and prices for those services plummeted. I note that despite this, Network Solutions continued to make profits  even though it was selling domains at wholesale prices to resellers who were underselling Network Solutions. It continues to make attempts to establish (or re-establish) its monopoly in at least some portions of the domain namespace. The current WLS proposal constitutes nothing more than another such attempt. I ardently reject  and urge you to reject  any proposal which limits competition. Such limitations do not serve the consumer.


7.        I have already indicated that I run a firm which has partnered with SnapNames  and that despite this I am opposed to this proposal. Since that firm is also an ICANN-accredited registrar, my firm could also benefit from the proposal by virtue of that capacity, e.g., we could profitably market the very service against which I am arguing. Again, please accept this letter as a statement of my belief in the free enterprise system. The consumer should have a choice  including the choice to go to a firm other than my own  to make his or her purchases.

Thank you very much for you kind attention to my diatribe...

I remain, very respectfully yours,

Kenneth A Hirsch
Chief Executive Officer
@Com Technology, LLC

-- 

__________________
Stuart Lynn
President and CEO
ICANN
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Email: lynn@icann.org