RE: [ga] WLS

["Gomes, Chuck" <cgomes@verisign.com>]

John,

Please note my comments below.

Chuck

> -----Original Message-----
> From: John Berryhill Ph.D. J.D. [mailto:john@johnberryhill.com]
> Sent: Wednesday, June 19, 2002 1:12 PM
> To: ga@dnso.org; Joe Sims
> Cc: mcade@att.com; gkirikos@yahoo.com
> Subject: Re: [ga] WLS
> 
> 
> >But I get the impression that at least some people believe that
> >there is more to the competitive concern than these point?
> >If that is right, could someone lay it out for me simply and
> >clearly, so that even I can understand it?  Thanks.
> 
> It is fairly simple and clear, and entirely missed in your 
> recapitulation of
> the competition concerns.  The "registrar harm" and "consumer 
> harm" points
> are flagged below with asterisks, so that even you can find them.
> 
> 1.  Presently, there are several different services which use 
> different
> business models to compete for the opportunity to register 
> domain names which
> come off registration.  For example, there is SnapNames.com, 
> Namewinner.com,
> and several others.  Some of these services are fixed price 
> services, some of
> them are auctions with payment due on contingency, some for a 
> "bounty", and
> so forth.  During the development of these services, which 
> involve various
> repetitive polling mechanisms, there was concern that these 
> services were
> overloading registry resources during name drop periods.   
> That problem has
> since been solved.
At extremely excessive expense to VGRS to support a business model that
results in one six dollar registration for as many as 500,000 transactions.
> 
> 2.  WLS as proposed, will be the only way to obtain an 
> expiring domain name,
> since it will operate at the registry level.  Hence, this 
> registry-level
> service will effectively eliminate the present range of competing
> registrar-level services for registration of expiring names.  
> Not compete -
> eliminate - as any other method will be entirely ineffective.
Not entirely true but it is reasonable to expect that there would be much
fewer desirable names.  At the same time, the registrars and their resellers
would have equal opportunity to participate in the WLS offering, thereby
replacing lost revenues with a service that has a higher probility of
success for end users, a probablilty that is only possible if offered at the
registry level. 
>  **This will
> eliminate a present revenue stream for some registrars.**  It 
> is not a matter
> of WLS providing a "competitive advantage" over the existing 
> mix of services,
> as you seem to perceive it.  The WLS as proposed will be the 
> only game in
> town, and will eliminate the existing mix of services, because it will
> operate with certainty at the registry level to provide 
> registration of an
> expiring domain name to the single person who managed to grab 
> the WLS slot
> first.
The WLS will not eliminate direct selling of names, name auctions for
existing names, etc.

>  There will be no competition to have an "advantage" 
> over, and if a
> WLS-squatter has the slot, you are out of luck.
> 
> 3.  From the consumer perspective, the WLS as proposed will 
> provide one, and
> only one, person with certainty that they will become the 
> registrant of an
> expiring domain name.
As you well know, that is the reality of the DNS.

>  Under the current situation, a 
> consumer may obtain at
> least an uncertain chance of obtaining the name through one 
> of the present
> competing services.  Presently, a consumer who finds that a SnapNames
> "snapback" is taken on the domain name they want, can go 
> elsewhere and have a
> chance to register the name.  Under WLS, a consumer who finds 
> that someone
> else has already obtained the WLS slot for the name they want 
> will have no
> choice, because **there will be no alternative available.**
> 
> 4.  To recap, the WLS will (a) eliminate a present registrar 
> revenue stream
> and a present competitive market, and (b) reduce consumer 
> choice.
Please elaborate on the consumer choice that is available today.  What
specifically are the choices?  How does a consumer find the choices?  What
will the consumer have to pay if he/she is successful?  How easy is it?
Everyone continues to make these broad generalizations but nobody puts
forward any measurable data to support them.

>  These
> effects are entirely independent of whether Verisign will make money.
> Verisign is entitled to make all of the money they lawfully 
> can, and nobody
> should have a problem with that.  Nobody has been saying that WLS is
> anti-competitive for the mere fact that Verisign will make 
> money from it.
> The competition concern is that the proposal under 
> consideration here is for
> a monopoly service which will have incidental effects (a) and 
> (b) noted
> above.
> 
> Whether the WLS as proposed is implemented or not, released 
> domain names will
> continue to be registered by the quick and the clever, just 
> as they are now.
> The race will only be shifted to obtaining WLS slots rather 
> than obtaining
> the domain names themselves.  The notion is simply absurd 
> that people who are
> generally unfamiliar with domain name policies and procedures 
> will have a
> level playing field with those who are expert and studious 
> followers of this
> arcane nonsense.  But, the WLS party line plays well with 
> those abused of a
> habit of wishful thinking and unsupported theories of human behavior.
> 
> On further reflection, we may well simply see a bloom of 
> competitive WLS
> "gaming" services...
> 
> 
> 
> 
> 
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