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[registrars] RE: WLS Comments


Thanks Mike.  Now I understand what you meant with regard to
speculators.

I don't know whether you are right or not but I certainly never thought
of it the way you do.  I know that some people disagree with me on this,
but I am one who thinks that speculator involvement would be indirectly
proportional to price.  Do you think that speculators will increase if
the cost is higher than it is today?

As a business we are always interested in new business opportuntities
and the WLS certainly fits that category.  But your suggestion is the
first time I am aware of that anyone has suggested that we intentionally
are going after the speculator market.

Chuck

> -----Original Message-----
> From: Mike [mailto:mike@awregistry.net]
> Sent: Friday, January 18, 2002 1:24 PM
> To: Gomes, Chuck
> Cc: registrars@dnso.org
> Subject: 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
> >>proposed.
> >>
> >>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.
> >>
> >>Sincerely,
> >>
> >>Mike Brown
> >>Project Manager
> >>All West Communications, Inc. D/B/A AWRegistry
> >>
> >>
> >>cc: registrars@dnso.org
> >>
> >>
> 

smime.p7s



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