[nc-transfer] FW: WLS Task Force submissions

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

Thanks, George.
-----Original Message-----
From: George Kirikos [mailto:gkirikos@yahoo.com]
Sent: Tuesday, June 18, 2002 4:33 PM
To: Cade,Marilyn S - LGA
Subject: WLS Task Force submissions


Hi Marilyn,

I don't think it was officially posted to the transfers task for list,
but I'd like to have my posting which appeared at www.intangibles.com
part of the official record. It's below.

Sincerely,

George Kirikos
http://www.kirikos.com/

WLS Statement

May 21, 2002 

My perspective on WLS is that of a consumer and also someone coming
from a finance and economics background. 

Briefly, I'm against the proposal as it stands now, as it will have
negative consequences on registrars and consumers alike. Verisign is
simply leveraging its existing monopoly at the registry level to
capture a highly competitive and innovative market that currently
exists at the registrar level. By doing so, they restrict consumer
choice and raise prices. Part of ICANN's mission is to encourage
competition, and this proposal by Verisign would be a step in the wrong
direction. 

I as a consumer will be hurt due to the reduction in choices. Currently
I can choose amongst numerous business models, such as NameWinner,
NicGenie, SnapNames (and for the record, I am a customer of Snapnames
too), and other systems run by registrars, none of which Verisign
identified as illegitimate or abusive when asked directly in their
Questions and Answers document. 

Furthermore, the wholesale cost of names would rise by several hundred
percent, which eventually gets passed on to me as a consumer. For those
who've read some of my postings, I've shown how one could implement the
exact equivalent of WLS for the same cost as a new top-level-domain (or
TLD), a "shadow TLD" was the lingo I used, see:

http://www.dnso.org/clubpublic/ga/Arc10/msg01326.html

which would cost roughly the same as existing domains, that is, $6/name
or less. SnapNames alone expects to make $100 to $150 million over 5
years if WLS goes through, and you can bet that Verisign stands to make
the same if not more. All of this is at the expense of existing market
participants, and eventually consumers. 

Verisign has tried to position this proposal as merely a "test",
something that they should be allowed to do to simply see what happens.
However, this is difficult to believe. First of all, they've put their
heads in the sand and refused to analyze the current expired domains
market, to create a baseline on which to do a comparison, and to
measure the consquences of a change. They've simply accepted the
analysis of their partner SnapNames, an existing market participant,
and arrogantly ignored input from all other market participants
(consumers and registrars alike). If Verisign wants to do a test, as a
proof of concept, it could easily do so on the dot-TV top-level-domain,
which it owns. I'm from Canada, and the dot-CA registry handled expired
domains very efficiently and at no extra cost recently, showing that
the Status Quo option for dot-com is is in fact the normal case in
other registries. Given that the only way the "WLS test" fails is if
Verisign loses money, one can see that the test is simply a charade, a
way to stealthily go under the radar of ICANN and wedge itself in so
that it can't be removed in the future. 

I'd also like to point out that Verisign registrar is an existing
partner of SnapNames. The report about the Chinese wall between
Verisign registrar and Verisign registry has never been delivered, as
far as I know, and this is an example of a possible conflict on the
part of Verisign registry, who is supposed to provide equal competitive
access to all registrars, and not favour its own companies. 

In conclusion, given the policy mandates of ICANN, the proposal should
either be rejected flatly, or should go through the formal consensus
process, as it is clear that there will be detrimental effects to
numerous market participants. ICANN should be extremely wary of
creating new monopolies, especially ones that will hurt the industry
and have had no consensus approval. 



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