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[registrars] Re: WLS Comments

Hi Chuck,

What I mean is, it looks like speculators are the main consumer group 
targeted by WLS.  Not that WLS will help them more than current systems, 
quite the opposite (see my point number 2), but it is likely that most 
WLS subscriptions will be purchased by speculators.  Now, there is 
nothing wrong with creating new products aimed at speculators.  That is 
exactly what we, Snapnames, other registrars, Afternic, and many others 
have done in offering products that attempt to register deleted domains 
for speculators.  The success of all these offerings has created healthy 
markets and proven that there is good money to be made from product 
offerings that cater to speculators.

It is obvious to me that the REAL purpose of WLS, though not stated, is 
to enable VeriSign to grab a larger portion of the speculation market 
pie, of which they currently get only a thin slice.  Again, nothing 
wrong with this, if it is done fairly.

The problem with WLS is that it UNFAIRLY reapportions the "pie" so that 
VeriSign would get a fat slice, while registrars would get a much 
smaller piece than they do now.  It would have a major, negative impact 
on many currently profitable businesses.  Nothing wrong with offering a 
product that negatively impacts your competitor's business, but we are 
not VeriSign's competitor, we are your CUSTOMER!

The reason it is unfair is because of VeriSign's unique position as the 
    only entity able to offer WLS.  Should a registrar become 
dissatisfied with WLS service, there would be no one else who could 
offer them a similar service at a better price, with better customer 
service, etc.  The only choice would be to resell or not resell the WLS. 
  This is not the American way!  Admittedly, a similar situation exists 
with .com registrations, but we are afforded protections from arbitrary 
price increases, service level decreases, etc., through the contracts 
with ICANN.  No such protections have even been hinted at in regard to WLS.

Well, that was a little long-winded, but I hope I have clarified our 
point #3.  Thanks again for hearing us.

Mike Brown
All West Communications, Inc. D/B/A AWRegistry

Gomes, Chuck wrote:

> Thanks for your feedback Mike.  I have just one request of you: please
> help me understand how the WLS would aid speculators any more than the
> current process especially if it is priced at a higher level.  My
> opinion is that the current process greatly aids speculators and there
> seems to be lots of evidence to support that.  So if you don't want the
> WLS because you think it aids speculators, you must be opposed to the
> current process.  But since you state below that you do not have
> problems with the current auto pool, I am confused.
> Chuck
>>-----Original Message-----
>>From: Mike [mailto:mike@awregistry.net]
>>Sent: Thursday, January 17, 2002 10:00 PM
>>To: cgomes@verisign.com
>>Cc: registrars@dnso.org
>>Subject: WLS Comments
>>Dear Mr. Gomes,
>>All West Communications, Inc. (AWRegistry) is opposed to the
>>proposed VeriSign WLS for the following reasons:
>>1.  We believe implementation of the WLS will force upon us
>>significant changes to the way we do business, thus necessitating
>>spending on unplanned costs and business expenses, while
>>seriously and negatively impacting an important revenue stream,
>>specifically registrations of recently deleted domain names.
>>2.  We believe WLS will negatively impact the businesses of many
>>resellers and speculators, who will no longer be able to register
>>expired domain names in the same ways they do now.  They too will
>>incur unplanned costs in order to continue their businesses.
>>3.  The WLS seems to be specifically designed to aid speculators,
>>but moves much of the revenue generated by this speculation from
>>registrars to registry.  Our opinion is that this is an abuse of the
>>registry's position as the only entity able to offer this service as
>>4.  We do not believe that the stated goals of WLS, which are:
>>          to provide both (1) a new, streamlined business
>>          opportunity for the entire registrar community,
>>          and (2) some measure of relief in dealing with
>>          the deleted domains issue.
>>will be successfully met.  On (1), while it does provide a new
>>product offering, we think it will not make up for the adverse
>>effects it will have on existing markets.  On (2), there will
>>continue to be heavy traffic in the auto pool for registrations
>>of deleted names that have no WLS subscriptions.  Also, we do not
>>see significant problems with the current auto pool.  Our
>>"pounding" of the server during drop times does not seem to crash
>>the server, nor does it cause problems in the normal pool.  We
>>think the auto pool was a good solution to a problem which is no
>>more, and if there are still technical problems, they should be
>>solved by technical means.
>>5.  We believe the current system of deletions is a fair and
>>efficient way to re-allocate expired names to registrants, providing
>>many choices to registrants, registrars, and resellers, and enabling
>>various thriving markets in deleted domain names.
>>6.  We do not believe it is ethical to sell "chances" of anything.
>>To be specific, we think that by selling a WLS subscription, we
>>would be selling a chance to register a domain name if and only if
>>the name is deleted within the subscription period.  There isn't
>>even any way to calculate the odds that a particular name will ever
>>be deleted.  Though legally WLS would probably not fall into the
>>category of a lottery, we think many consumers would be duped into
>>buying WLS subscriptions that will never come to fruition.  Some
>>may take on a "gambler" mentality and buy subscriptions for high
>>profile names (the business.com type), knowing that they probably
>>won't be deleted; but some people can't resist the urge to gamble.
>>We want no part of that.
>>Thank you for accepting our comments.
>>Mike Brown
>>Project Manager
>>All West Communications, Inc. D/B/A AWRegistry
>>cc: registrars@dnso.org

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