[registrars] Comments on Proposed Domain Name Wait Listing Service

[Bruce Tonkin <Bruce.Tonkin@melbourneit.com.au>]

Hello Chuck,

Thanks for providing details of the proposed Domain Name Wait Listing
Service for comment by registrars.  It looks like a well thought out
document.

In section 1: Introduction:
it states "prepared to offer the WLS to Verisign GRS's ICANN-accredited
registrar channel".
- it would be better to state that the service will be offered EXCLUSIVELY
through the ICANN-accredited registrar channel as discussed in Section 2.

In Section 2 (a) (iv), it states that the SRS will identify the name as
being a subscribed name.  I recommend that this information be made
available on the WHOIS service at http://www.verisign-grs.com, it would also
be preferable to list the registrar responsible for the subscription in the
interests of transparency of the system.  This will allow domain name
registrants to see if anyone has placed a subscription on their domain name.

In section 2 (a) (vii) - it states that the subscriber can change the domain
name tied to the subscription.  I assume this will be part of the EPP
protocol interface, and that the subscriber must submit changes through a
registrar.


Section 2 (b) (ii) discusses a grace period.  I believe that this is
absolutely critical.  From experience domain names are often not renewed
inadvertently (ie the registrant was out of contact and did not receive a
renewal notice).  With the use of automated systems to immediately register
deleted names, registrars are increasingly dealing with the customer service
problem of trying to get a domain name back that has been deleted by
mistake.
I strongly recommend that a hold grace period be used before the deleted
name is allocated to a the subscriber, during which the name is removed from
the zone file.  I recommend that the period be extended to 30 days.   In
".com.au" we use two grace periods, after a domain name is expired we allow
28 days before it is undelegated (ie removed from the zone file), and then
allow a further 28 days before it is finally deleted from the registry.
Usually once a domain name is removed from a zonefile, the domain name
registrant contacts the registrar and arranges for the domain name to be
renewed.  During the hold period the original registrant should have the
right to renew the domain name.

Section 2 (d) - I support the initial plan to not allow subscription
transfers

Section 3 (a) - I support the use of the EPP protocol for this new service.

Section 5
With regard to the pricing model, I agree with the principal that Verisign
should be able to recoup its costs and make a reasonable profit.  The
question is what is "reasonable".

It should be noted that this is a monopoly service - it can only be offered
by Verisign GRS with 100% success rate.  Thus Verisign should make more
transparent its business model - costs, volume of names etc - for assessment
by members of the DNSO and for final approval by ICANN.  An independent and
open assessment of costs would be useful.

Given a total of around 30 million names in the Verisign registry and
assuming an initial penetration of 5%, gives a revenue of US$60 million.
This seems well in excess of what I would have thought it would cost to
build and operate, but I would need more information to give informed
comment.

If agreement can't be made on the "costs", then perhaps the provision of the
service should be put out to competitive tender.

I agree that the "price point" should be set high enough so as not to
encourage abusive speculation of WLS subscriptions.

If there is a difference between the fee that Verisign should charge based
on cost and reasonable profit, and the appropriate "price point" - then
maybe the difference could go towards funding other ICANN activities such as
the At Large membership processes.

Section 6 (d) (v) - I think it is important that registrants may place a
subscription on their own domain name if they wish.  In fact I recommend
that a sunrise period (e.g for 30 days) be used where existing domain name
registrants be offered a "first-right" of refusal to place a subscription on
their own domain name in preference to the first-come first-served system.
This will allow registrants to place an additional level of protection
against accidental deletion.  My biggest concern is registrants
inadvertently losing their domain name.  When a new domain name is
registered, registrants should be able to purchase a subscription as back-up
at the time of their registration (as a form of insurance).

Regards,
Bruce Tonkin
Melbourne IT