RE: [registrars] Draft WLS Response

["Timothy Denton" <tim@tmdenton.com>]

Greetings all: This material has been placed on the website at

http://www.icann-registrars.org/deletes.htm

Timothy Denton, BA,BCL
Secretary, ICANN-Registrars Constituency
37 Heney Street
Ottawa, Ontario
Canada K1N 5V6
www.tmdenton.com
1-613-789-5397 Ottawa
1-819-842-2238 North Hatley
tmdenton@magma.ca

-----Original Message-----
From: owner-registrars@dnso.org [mailto:owner-registrars@dnso.org]On
Behalf Of Rick H Wesson
Sent: Wednesday, February 27, 2002 12:03 AM
To: Registrars List
Cc: WLS-Response@registrars.dnso.org; rick@ar.com
Subject: [registrars] Draft WLS Response



Registrars:

Attached is the proposed final draft response we will be voting on. Please
comment on the draft over the 36 hours. The draft will be finalized on the
27th and the final draft recirculated on the 28th.

A vote will be initiated on the 1st of March, the ballot will contain a
item for approval of the draft as our final comment to VGRS in regards to
the WLS. All registrars voting to approve the draft will be named on it as
signators.

Our vote will be made public with the names of each voting registrar and
how they voted on each issue.

The ballot will also contain a resolution much like the one Jim Archer
posted last week. Jim's original proposed resolution is at
http://forum.registrars.dnso.org/thread.jsp?forum=1&thread=85

Please comment on the draft so that it reflects as closely as possible the
consensus of this constituency.

A sample ballot will be posted on the 28th and the official voting period
will commence on the evening of the 1st, baring any technical glitches.

Make your voice herd BEFORE the vote and comment on the draft so that we
can express, as closely as possible, the wises of this constituency.

best,

-rick



------------------- draft-rc-wls-comments-03.txt ----------------





                        [proposed final draft]

                       Registrar Constituency (RC)
                            Position Paper
                        Regarding the proposed
                        Wait List Service (WLS)



The RC opposes the revised WLS proposal in its current form. The
concerns are as follows:

   1) Price.
     a. The price has not been justified on a cost plus a reasonable
        profit, or any other, basis.

     b. The proposed WLS subscription price combined with the $6
        registration price continues to be too high.  It effectively
        multiplies the total registry price on the most attractive
        deleted names about 6-fold.  The effect is to undermine
        competitive registrars and raise the cost of registration for
        consumers

   2) Competition
     a. WLS reduces competition by substituting a single model for
        the many and varied current registrar business models for
        re-registering deleted names for consumers.  WLS pre-empts all
        other models.  The current system imposes nearly no
        restriction as to business model offered to consumers.

   3) Equal Access
     a. The existing system allows each registrar equal access to
        re-registering deleted names.  The WLS system limits
        re-registration to the holder of the WLS subscription.

     b. With WLS, registrars with larger databanks of deleted names
        (e.g., the VeriSign registrar, which has a large legacy of
        expiring names) would have an advantage over smaller
        registrars due to the fact that the larger registrars would be
        able to offer many more WLS subscriptions with a guaranteed
        chance of "ripening" (because only the registrar-of-record
        would know that it is about to issue a delete on a particular
        name).  In contrast, other registrars would have to offer the
        same WLS subscription at a much higher risk.  This fact
        effectively unbalances the equal access to re-registering any
        deleted name that exists today.

   4) Transparency
     a. VeriSign runs the primary registry, the largest registrar,
        and the subscription service. As long as the same company is
        operating this vertically powerful chain of companies, it may
        be possible for it to shift domain names from the $6.00
        registry to the $41.00 WLS.  In fact, only the registry would
        know all of the WLS subscriptions and the timing for deleting
        names.  Such information could be abused by its registrar.
        Considering that there is a history - some of it still
        unresolved - of VeriSign not deleting expired names, and the
        fact that a WLS subscription will be allowed for names that
        are past expiration, the RC is doubly concerned that
        VeriSign's operating the WLS provides new opportunities for
        domain name hoarding.  The current system provides sufficient
        transparency to ensure that one registrar is not advantaged
        relative to another.  The current system provides less
        incentive for a registrar to not delete names that are more
        than 45 days past expiration.  The expectation of a pending
        WLS system release provides incentive for registrars to hold
        names past expiration.  VeriSign effectively bears no cost,
        and has the most to gain in extra WLS fees, for it's holding
        of expired names.  VeriSign registrar has dramatically
        decreased the number of names it would routinely delete and
        increased the number of names it holds more than 45 days
        passed expiration.

   5) Grandfathering of Current Subscriptions
     a. The WLS proposal states that current Snapbacks would be
        grandfathered into the system.  In other words, the registry
        would respect and effectively make whole those consumers that
        had used a SnapNames approach to obtaining a registered domain
        name.  It is unfair to favor one secondary market provider
        above others.  A number of entities, including domain name
        auction brokers and registrars, have offered consumers the
        opportunity to place orders on registered names.  All of these
        should receive equal treatment - meaning a grandfathering into
        any WLS system.

While the RC continues to oppose the WLS in its current form, and
believes that denying its introduction would be reasonable, it
recognizes the need for a permanent solution to the apparent problem
of deleted names not being released or being released in a manner that
undermines other registry functions.  Therefore, the RC welcomes the
Names Council's consideration of alternate ideas for addressing these
issues, many of which have been discussed by the RC


--WLS Drafting Team <WLS-Response@registrars.dnso.org>