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

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

Bruce,

Thanks for the very thoughtful comments.  I have provided some initial
responses below and will forward all of your suggestions to our business
development people.

Chuck

> -----Original Message-----
> From: Bruce Tonkin [mailto:Bruce.Tonkin@melbourneit.com.au]
> Sent: Thursday, January 03, 2002 3:59 AM
> To: 'Gomes, Chuck'
> Cc: 'registrars@dnso.org'; 'Rick H Wesson'
> Subject: 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.

It is our intent to offer it exclusively through the ICANN-accredited
registrar channel so adding the word EXCLUSIVELY would not be a problem.

> 
> 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.

Making a modification to Whois would introduce several complications.
First of all, large numbers of people use Whois, oftentimes using
automated scripts, so changes in the display can create problems for
users.  Second, because this is proposed as a 12-month trial, it might
not make sense to consider doing the work necessary to change Whois
until the WLS becomes a permanent offering.  Third, we would have to
have our engineers scope out the level of effort required to do this.

I will ask our business development people to investigate this further
and possible provide further feedback in this regard.
 
> 
> 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.

I believe you are correct here but I will have our business development
team confirm.

> 
> 
> 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.

I will ask our business development team to consider the possibility of
an extension of the proposed 15 days.  I personally think that however
many days is given that the name should be removed from the zone because
that is sometimes the only way a registrant discovers there is a
problem.

> 
> 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.

In my opinion it would be very inappropriate and totally unacceptable
for the DNSO to be provided VGRS cost information.  That would be well
beyond the limited technical coordination functions of ICANN and would
involve disclosure of business sensitive information.  It would also
create problems for us as a publicly traded company with regard to the
public disclosure of such sensitive information.
  
> 
> 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.

The 5% figure is just an estimate of possible penetration; it could be
high or low, but it seems to me if it is an accurate estimate that it
quite likely would take a number of years to reach that level of
penetration.  The WLS is proposed as a 12-month trial.  That means that
it could be disbanded at the end of the trial, so the initial investment
costs could actually create a loss.

The reality of the matter is that there are lots of unknowns associated
with the WLS.  We would not be pursuing it if we didn't think the
potential was good, but in fact we will not know for sure until we test
it.  As with any new service offering, there are risks; some new ideas
work out well, some don't.  Hopefully, by the end of the trial we should
have good data upon which to evaluate the price point.

All that said, I will still go back to our business people and to see if
they think there is room for any adjustments.

> 
> 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.

This is an issue that I personally feel very strongly about.  If the
price point is anywhere close to what registrations now cost, we will
simply create a problem with the WLS service that mimics what has
happened with deleted names.

> 
> 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).

I think we are in agreement with regard to the concern for inadvertant
deletions, but I don't think I fully understand what you are suggesting
with a sunrise period.  If, as we proposed, there is a Registry Hold
period before deletions occur in the 45-day grace period, wouldn't that
solve the problem you are dealing with?

> 
> Regards,
> Bruce Tonkin
> Melbourne IT
>

smime.p7s