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[comments-deletes] no WLS Verisign/SnapNames

Title: no WLS Verisign/SnapNames

To Whom It May Concern

I am writing to oppose WLS/Versign. I am a consumer owning many domain names and am a web developer/hosting company that secures domains on a regular basis for clients. Having dealt with VeriSign for the last 4 years I am very familiar with their business practices and customer service. Verisign is a company that has not been responsive to customer's needs and has not successfully dealt with domain transfer issues in a timely or businesslike manner. On top of these poor business ethics, their pricing is considerably higher than most others in the industry. This facts spell MONOPOLY, and ICANN should not in fair business practice allow the WLS proposal to go through.

I am opposed to WLS for the following reasons:

Customers currently have a choice of providers and service offerings. WLS will force customers
 to accept one type of service and to do business with one vendor.

In response to Verisign's poor service i.e.: excessive phone wait times, non-responsive tech support, exorbitant fees and wait times, my clients and myself have chosen to use Registrars that provide timely service and are responsive to our needs. This would be eliminated with Versign's current proposal, once again, we would be held hostage by an unacceptable level of product/service.

Restricting our choice of vendor and service only benefits the
Verisign, leaving me and other consumers with no choice
and no real benefit. Why would you restrict my choice of deciding who
I want to deal with and what type of service I want to receive?
Moreover, how could you possibly justify doing that?

Today, the wholesale cost of a domain name is $6, but the proposed
wholesale cost of a WLS is $24, with domain name registration being
extra. How can it possibly be 4 times as expensive to merely capture a
deleted domain name? Particularly so, when I can now get a deleted
name for an equivalent or lesser RETAIL price?

It seems that the majority of the proposed cost is profit for
SnapNames and VeriSign. This seems well supported by SnapNames public
media announcement in which it indicated that its revenues will grow
$17 million (a 700% increase) in the first year of WLS, alone.

There is no guaranty that I will be able to get a WLS on even my own
domain name, unless I get it simultaneously with its initial
registration. Could this be a ploy to return to those magical numbers
of $35 or $50 per domain year?

Healthy "competition" is what America is all about and
that's what drives our economy. Why then, would anyone want to create
a monopoly?

WLS will replace a competitive market served by many and damage those
businesses.  For that reason alone, WLS should be denied.

Testing WLS will really be a test to see how many of the current
competitors in the secondary market survive. These Registrars have
innovated in order to bolster their revenues and they have invested
time, energy and money to do so. Stopping their offerings, in favor of
a test period, will damage these businesses and in some cases the
damage may well be devastating.

In my view, the test is nothing more that a ploy to gain monopoly
control over an existing and thriving market and put all competitors
out of business.

WLS is calculated to be anti-competitive, in more ways than just the
so-called test. For that reason alone, WLS should be denied.

Frankly, the proposed provider doesn't have the best reputation
in terms of customer service, ethics and scruples.  That remains true,
even after it has had to compete for a good period of time as opposed
to being a monopoly provider of domain registrations.

This is the same corporation which does not honor the standard
practice for domain transfers between Registrars. It's also the same
firm which is hoarding domain names which expired over a year ago.

Under the WLS proposal there is no incentive for the monopoly provider
to innovate or offer good service.  Moreover, there's certainly no
incentive to reduce the price to the consumer.

Monopolies, even when regulated, have proven time and again to be
detrimental to consumers. 

ICANN's mission was to break up monopoly and promote
competition. The WLS is opposite that mission and, therefore, WLS
should be denied for that reason alone.

The only real benefactors of WLS will be the monopoly provider and its
partner, but that will be at the expense of the consumer and those
already serving this market.

WLS should be denied for all of the reasons stated above.

Thank you,

Sherri Graves
Worldwide Web Creations
Bringing Your Business To The World!

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