Re: [registrars] Comments on Proposed Domain Name Wait Listing Service

["Ken Stubbs" <kstubbs@digitel.net>]

i too share Bruce's concerns about registrants inadvertantly losing their
names.

I  also believe that the pricing model as currently described does not
provide adequate justification for the proposed structure (given the
monopoly model proposed).

ken stubbs

----- Original Message -----
From: "Bruce Tonkin" <Bruce.Tonkin@melbourneit.com.au>
To: "'Gomes, Chuck'" <cgomes@verisign.com>
Cc: <registrars@dnso.org>; "'Rick H Wesson'" <wessorh@ar.com>
Sent: Thursday, January 03, 2002 3:58 AM
Subject: [registrars] Comments on Proposed Domain Name Wait Listing Service


> 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
>
>