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Re: [ga] Verisign proceeds with WLS, despite opposition
George,
On Sat, 23 Mar 2002, George Kirikos wrote:
> Hello,
>
> As most know, the DNSO GA and the RC (registrars) were overwhelmingly
> against the WLS proposal.
I had posted a PDF of the registrars response to the WLS, below is the
response reformatted in text.
-rick
Registrar Constituency (RC)
Position Paper
Regarding the proposed
Wait Listing Service (WLS)
March 16, 2002
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. (THIS
IS NOT A STRONG POINT SINCE WLS IS SIMPLY FIRST COME, FIRST
SERVED)
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 beabused 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
By a vote in the Registrars constituency the following registrars
are Signatories of this document.
Dotster CORE* DotRegistrar
Intercosmos Total Registrations* 007Names
InterDomain Registry at Info Avenue* All West*
Emarkmonitor* Enom 000Domains.com
Gandi Registration Technologies Interdomain
Nominalia* 000Domains TuCows
Active ISP
* Previous RC members with non-paid memberships as of 3/8/02
The following resolution was passed by the ICANN-DNSO Registrars
Constituency on March 10th 2002.
Whereas, VeriSign GRS has presented a proposal to create a "Wait
Listing Service" (hereinafter referred to as "WLS"), and
Whereas the Registrars Constituency has both the right and the
responsibility to adopt and express its position on proposals by
registries to introduce new services, and
Whereas many members of the Constituency have a variety of
significant concerns about this proposal as currently drafted, and
Whereas the Constituency as a body through the adoption of this
resolution wishes to oppose the implementation of WLS, and
Whereas the Constituency believes that the denial of permission by
ICANN for the introduction of WLS would be reasonable, and
Whereas ICANN, through its contract with VeriSign GRS, may withhold
permission for the introduction of a new registry services provided
that this permission is not withheld unreasonably, be it therefore
Resolved that the DNSO Registrars Constituency opposes the
implementation of WLS, and be it further
Resolved that this opposition be the official position of this
Constituency until such time as this position is revised by vote of
the Constituency, and be it further
Resolved that the DNSO Registrars Constituency urges ICANN to
withhold permission for the implementation of WLS, and be it
further
Resolved that the Executive Committee of the Registrar Constituency
is directed to communicate this position to VeriSign GRS, to ICANN
and to any other interested parties.
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