[nc-transfer] RE: Status Report Comments

["Cade,Marilyn S - LGA" <mcade@att.com>]

Paul, I am happy to post this for you, as requested, as one of the 
respondents on the TR-TF outreach calls.  

Thanks for your participation.  

Again, a reminder to those who are submitting
documents, or submissions of some kind directly relevant to the deletions/WLS 
issue, I will forward relevant documents and submissions to the TR-TF list.

I've posted some submissions from Verisign which I invited, and I appreciate 
their submissions.  SnapNames spoke in support of the WLS proposal, and I invite 
them to provide any comments or additional documents in support. 

If there are other constituency submissions, please note that you should submit them
ASAP.  At least advise me that you expect to have a submission and when we might 
expect it. 

Please note: submissions are welcomed re your views, perspectives.  If you have 
submitted something already to the ICANN web site, I suggest that you merely note that and 
then our TF list can just serve as a reminder to others to view your submission there.

 
I again remind the TF to read both the GA list and the ICANN comment site submissions.

Regards, Marilyn Cade

-----Original Message-----
From: Paul Stahura [mailto:stahura@enom.com]
Sent: Sunday, June 09, 2002 7:40 PM
To: 'nc-transfer@dnso.org'; Cade,Marilyn S - LGA
Subject: Status Report Comments


Marilyn and nc-transfer task force members,
follows are my comments on "Status Report regarding Deletions, Solutions,
and WLS" document.

Overall, I totally agree with the vast majority of the report.

To start, I agree with all the points 1-5 under "preliminary findings" but
especially: 
'These competitive services are differentiated from one another and are used
by "regular" registrants, as well as bulk purchasers of  names.  Comments
were received that indicate that some IP owners also use the services'

eNom's service is either used directly by "regular" registrants or
indirectly through the
resellers who are using it.  Also, eNom has decreased the price of it's
competitive 
service (we call it "club drop") to zero, so
participants no longer pay a monthly fee to participate, only the normal
registration
fee if eNom is successful in actually registering a name on their behalf.
We are still limiting its use to 10 customers because we are limited by the
registry
(as all registrars are) in the number of connections which we can use to get
dropped names,
and we want to use these connections efficiently.
Understandably, with the current setup, this restriction helps limit the
technical resources used
at the registry.  

BTW, if :
 "III.  Technical Solutions to "Add Storms:"  
It was acknowledged that present practices of competitive services result in
"add storms" which are affecting the registry's services, and according to
the registry, adding significant costs for support of all the attempts to
"grab" names but without resulting in transactions which provide revenue to
the registry. 

I wonder why doesn't the registry implement one of the low cost solutions to
lower these "add storm" costs?

The technical solution to the "add storms", in my opinion, is so
easy to implement, and at such a low cost, that it makes me spit, 
because that means it has NOT been implemented either: 
1) so that the registry can use "add storms" as a reason
to implement WLS, which they can use to capture some of the revenue that is
currently
going to registrars or staying in the consumer's pockets, which would mean
they
think they would make more money later by not fixing it now than save now by
fixing it now.
Or
2) becuase it must be that the registry believes the cost of implementing
the solution is larger
than the "significant costs for support of all the attempts to "grab"
names".
Or
3) because they are incapable of making improvements, which I'm pretty sure
is not the
case, and maybe they beleive #2, but I don't, so I'm back to #1.


If the registry were to implement the simple to implement (IMO)
deterministic round-robin
(were each registrar sends an ordered list and the registry picks from the
lists in a round-robin fashion),
or one of a number of other methods to eliminate "add storms" and equitably,
fairly and efficiently
allow registrars to compete re-register deleted names,
eNom could open its service to everyone, thereby including even more
"regular" registrants,
and for sure register deleted names for a lower cost (compared to WLS) for
everyone, "regular" or not.

BTW, my guess is that if WLS is implemented there would nevertheless be
similar
"add storms" : 
1) to switch WLS subscriptions from one name to another to beat the next guy

to the subscription when it is discovered that a certain name will
definitely be deleted
2) Names that do not have a WLS subscription will end up in the batch pool
as they
do now, so since it does not cost anything for registrars to "add storm" the
pool for non-WLS names,
the "add storm" will continue even after WLS is implemented, necessitating a
solution
regardless.  Even though there will be less names leftover after WLS gets
first dib,
registrars will "add storm" just as much for "aleftover.com" as they would
have done for
"wlsfirstdib.com" 

I would also like to say that if WLS is implemented, it will pre-empt eNom's
"club drop" service because all WLS subscribers will be advantaged by
jumping the line to be in front of anyone else who currently wishes to get
deleted names.
eNom will not be able to offer "club drop" service for any names that have
WLS subscriptions.
Grand fathering SnapName's WLS subscribers is, IMO, totally ridiculous
because
it will give SnapName's, a competitor of eNom and others, advantage over all
of us.
If WLS goes live, how about "grand fathering" all of eNom's and all the
other registrar's customers who
currently want a particular name that is already registered?  
Obviously, those SnapNames customers would be guaranteed to get these
names, so that any of eNom's customers who may currently want the names will
not
be able to get them.

Beyond this, if WLS is implemented, any registrar who is about to delete a
name
will have an advantage over another registrar because the former is able to
sell
the WLS subscription at less risk (that the subscription will actually
ripen) to the consumer 
than the later registrar because the later registrar does not know that the
former registrar will actually
delete the name.  Since the large registrars delete the most names, this
will
advantage the larger registrars, who can then charge more (for less risk) to
the consumer. 
 
Who would buy (lets say for cost) a WLS from registrar1 and not know they
will actually get the name, 
when they could go to registrar2, even pay more, and be assured that the WLS
subscription 
will ripen and they will definately get the name?
This inserts a tilt to the currently balanced registrar competitive playing
field 
that has been so painstakingly setup. It will help to freeze the market
share at the
level that each registrar has gained to date.  Coincidentally, Verisign is
the WLS implementer
and the registrar that will gain the most advantage due to the fact that it
has the largest
number of sponsored names and is losing them the fastest.  WLS will most
disadvantage
smaller registrars who are gaining market share.

I would add  that if WLS is implemented, that WLS subscriptions not be
allowed 
at any time on names that are passed expiration.  So that once a name
expires,
it is no longer eligible for a WLS subscription.  This will help reduce the
advantage
that WLS would benefit larger registrars (or any registrar that knows for
sure a name 
will be deleted, which is knowledge that does not benefit the registrar
currently, at least to
the same degree that it would if WLS were implemented) because it takes
names off the table
before the registrar has certain knowledge the registrant wants to delete
them.


Finally,
I fail to see how WLS provides "more good stuff" and/or "cheaper stuff" to
regular registrants 
(or anyone else for that matter) when:
1) a number of registrars and others (like SnapNames) are already providing
competing 
services that do the exact same thing (re-register deleted names)
1a) It does not provide an "insurance policy" against mistakes (more stuff),
because we already have
existing procedures (such as UDRP) to handle this
1b) if the "more stuff" is that the WLS subscriber will definitely get the
name, this
is not true, because I doubt that if Joe Smith got the WLS for "icann.org"
he'd actually get the
name if "icann.org" was deleted.  So with WLS, you *may* get the name, which
is exactly
what SnapNames is offering today.
2) most are doing it for way less $$$ than WLS will charge the registrar,
let alone
what the registrar will charge the consumer.

Plus I don't see how WLS reduces "bad stuff" like add storms.

Even if the registry charged $1 per WLS it is still not cheaper than
re-registering a deleted name today at eNom, and I admit, probably our
competitors too.

If the dropped-name problem requires a "test" like WLS supposedly would be,
why not 
hold off on WLS for now, and let another competitive registry propose a
different method, 
get some consensus on that, implement it, and see how that goes?


Paul Stahura
CEO
eNom, Inc.