[registrars] RE: Comments on Proposed Domain Name Wait Listing Service

["Gomes, Chuck" <cgomes@verisign.com>]

> -----Original Message-----
> From: Bruce Tonkin [mailto:Bruce.Tonkin@melbourneit.com.au]
> Sent: Sunday, January 06, 2002 2:05 AM
> To: 'Gomes, Chuck'
> Cc: 'registrars@dnso.org'
> Subject: RE: Comments on Proposed Domain Name Wait Listing Service
> 
> 
> Hello Chuck,
> 
> > 
> > Thanks for the very thoughtful comments.  I have provided 
> some initial
> > responses below and will forward all of your suggestions to 
> > our business
> > development people.
> > 
> 
> Thanks for your quick response.  I will also briefly follow 
> up on some of
> your points.
> 
> > 
> > Making a modification to Whois would introduce several 
> complications.
> > First of all, large numbers of people use Whois, oftentimes using
> > automated scripts, so changes in the display can create problems for
> > users.  Second, because this is proposed as a 12-month 
> trial, it might
> > not make sense to consider doing the work necessary to change Whois
> > until the WLS becomes a permanent offering.  Third, we would have to
> > have our engineers scope out the level of effort required 
> to do this.
> > 
> > I will ask our business development people to investigate 
> this further
> > and possible provide further feedback in this regard.
> 
> If a change to your standard WHOIS is not possible, perhaps 
> you could make
> available a simple service that allows an Internet user to query the
> registry to see whether a particular domain name has a WLS subscrption
> associated with it.
> 
> Again I think that it is important for an internet user to 
> find out from the
> source the status of a particular domain name in the registry.

We are in agreement here and there would be a way to check the status
but it might not be through Whois, at least at first if it is
implemented.
 
> 
> > 
> > I will ask our business development team to consider the 
> > possibility of
> > an extension of the proposed 15 days.  I personally think 
> that however
> > many days is given that the name should be removed from the 
> > zone because
> > that is sometimes the only way a registrant discovers there is a
> > problem.
> > 
> 
> Yes - that makes sense.
> 
> >In my opinion it would be very inappropriate and totally unacceptable
> >for the DNSO to be provided VGRS cost information.  That 
> would be well
> >beyond the limited technical coordination functions of ICANN 
> and would
> >involve disclosure of business sensitive information.  It would also
> >create problems for us as a publicly traded company with 
> regard to the
> >public disclosure of such sensitive information.
> 
> 
> I view ICANN as an industry self regulator, in addition to 
> its role with
> respect to technical coordination.  The application process 
> for new TLDs was
> certainly outside the role as a technical coordinator.  The contracts
> between ICANN and the Registry operators certainly give ICANN 
> responsibility
> for agreeing the prices for Registry Services (see clause 22 
> of the ".com"
> agreement).
> 
> It is normal for a regulator to require some information on costs that
> justify a particular price point for a monopoly function.  It 
> is also normal
> for an independent assessment be made on these costs.  This 
> works best when
> the company being regulated is open about the cost models.  In other
> postings you have provided a framework for the items in your 
> cost model
> which was useful and valid, but you have not provided the 
> numbers necessary
> to assess the costs.
> 
> The issue of being a public traded company is not relevant unless the
> information is not made generally public.  I also work for a 
> publicly traded
> company and I am well aware of the issues.
> 
> I expect that Verisign and the other gtld operators will increasingly
> innovate with new services, and thus in the case of this 
> first new service
> provided on a monopoly basis (following the signing of the registry
> agreements) it is important to have a framework for 
> determining the registry
> price.  I urge Verisign to propose a method of doing this.
> 
> It is important that there is an incentive for the registry 
> operators to
> introduce new services, but also important that undue 
> advantage of their
> monopoly position with respect to the specific gltd is not taken.  
> 
> 
> > 
> > The 5% figure is just an estimate of possible penetration; 
> it could be
> > high or low, but it seems to me if it is an accurate 
> estimate that it
> > quite likely would take a number of years to reach that level of
> > penetration.  The WLS is proposed as a 12-month trial.  That 
> > means that
> > it could be disbanded at the end of the trial, so the initial 
> > investment
> > costs could actually create a loss.
> > 
> > The reality of the matter is that there are lots of unknowns 
> > associated
> > with the WLS.  We would not be pursuing it if we didn't think the
> > potential was good, but in fact we will not know for sure 
> > until we test
> > it.  As with any new service offering, there are risks; 
> some new ideas
> > work out well, some don't.  Hopefully, by the end of the 
> > trial we should
> > have good data upon which to evaluate the price point.
> > 
> > All that said, I will still go back to our business people 
> > and to see if
> > they think there is room for any adjustments.
> 
> I agree there is market uncertainty - as there is for each of 
> the new gtld
> registries which had to provide business model information as 
> part of the
> application process for a new gtld.
> 
> On the one hand I hear people saying (including yourself and 
> Snapnames) that
> this is a great opportunity for registrars as the market is 
> large (which
> will all be fiercely competing), and on the other hand I hear 
> the company
> (Versign( that gets revenue for every WLS subscription saying that the
> market may not be as large hence the need for large margin to 
> offset the
> business risk.
> 
> > 
> > > 
> > > If agreement can't be made on the "costs", then perhaps the 
> > > provision of the
> > > service should be put out to competitive tender.
> > > 
> > > I agree that the "price point" should be set high enough so 
> > as not to
> > > encourage abusive speculation of WLS subscriptions.
> > 
> > This is an issue that I personally feel very strongly about.  If the
> > price point is anywhere close to what registrations now 
> cost, we will
> > simply create a problem with the WLS service that mimics what has
> > happened with deleted names.
> 
> I agree with you there.  I have pointed out in the past, that 
> you may need a
> WLS service for the WLS service etc.  There is a danger that the same
> problems will repeat themselves - e.g high check loads on the 
> WLS offering
> etc.  I recommend that the trial last for at least 18 months, 
> to allow the
> renewal behaviour for the WLS subscription after 12 months to 
> be evaluated.
> 
> 
> > 
> > I think we are in agreement with regard to the concern for 
> inadvertant
> > deletions, but I don't think I fully understand what you are 
> > suggesting
> > with a sunrise period.  If, as we proposed, there is a Registry Hold
> > period before deletions occur in the 45-day grace period, 
> > wouldn't that
> > solve the problem you are dealing with?
> > 
> 
> No, I am thinking in terms of the registrant with a valuable business,
> wanting to maximise the protection on their domain name.
> This can be done via:
> (1) Purchasing up to a 10 year registration (to avoid a 
> renewal problem)
> (2) Purchasing an option on the domain name via WLS - as 
> added protection in
> case of system errors that may result in inadvertently 
> deleting the domain
> name
> 
> The above is an attractive "insurance" package that can be sold by
> registrars as an up-sell on the price of a basic 1 year domain name
> registration.  The up-sell can be made to those that already 
> have their
> domain names, via the sunrise period.  It provides a revenue 
> benefit to
> registrars and the registry.
> 
> It is similar to the concept of 1+1 redundancy in 
> telecommunication networks
> - ie you purchase two links to the same place, in case one fails.
> 
> My view is that the existing registrant should have the first right to
> subscribe to the option on their domain.

How would you propose doing this?  A sunrise period?

> 
> Regards,
> Bruce
> > 
>

smime.p7s