RE: [registrars] RC WLS Response

[Elana Broitman <ebroitman@register.com>]

I want to second Rick's comments.  We are reacting to the current WLS, and
it leaves us with the opportunity to continue to object to any modified WLS.
But, we believed that we put ourselves in the strongest position to
negotiate by taking this stance. We should not be negotiating against
ourselves by telling VGRS what we'd be willing to settle for.  We would only
end up with a position somewhere in between theirs and ours.

-----Original Message-----
From: wessorh@ar.com 
Sent: Wednesday, January 16, 2002 2:57 AM
To: Nikolaj Nyholm
Cc: 'Registrars List'
Subject: RE: [registrars] RC WLS Response



Nikolaj,


On Wed, 16 Jan 2002, Nikolaj Nyholm wrote:

> I think it is insufficiently nuanced to write: "in fact the unanimous vote
> of all those taking a position - is to oppose the WLS."
>
> I believe that several registrars, ourselves included, were in favour of
> working with Verisign on enhancing the WLS, but oppose it in it's current
> form.

since we could not negotiate with VGRS we could only vote on the proposal
as given to us. When we have other proposals on the table I'm sure the
vote will come out differently.

It also make complete sense that a different WLS proposal may get
a completely different voting result. Since every registrar had some way to
improve the WLS it was impractical to list every registrars vote and their
alternative; we just can't make a consensus statement that says "it would
be ok with some changes..." without all agreeing on those changes and VGRS
capable of incorporating those into the proposal.

> I hope that alternative proposals ("The RC will address these proposals in
a
> separate position paper.") will include suggestions on how to revise the
WLS
> proposal.

I too expect to see more alternative proposals, we have several at
www.icann-registrars.org please review them and provide comments to their
authors.

-rick



> Regards
> Nikolaj
>
> > -----Original Message-----
> > From: Rick H Wesson [mailto:wessorh@ar.com]
> > Sent: 16. januar 2002 05:21
> > To: Registrars List
> > Cc: WLSDraftingTeam@ar.com
> > Subject: [registrars] RC WLS Response
> >
> >
> >
> > all:
> >
> > attached is the draft response from the WLS Drafting Team composed of
> > the following:
> >
> >    George DeCarlo - dotster
> >    Bruce Tonkin - melbourneit.com.au
> >    E. Broitman  - register.com
> >    David Wascher - iaregistry.com
> >    Paul Stahura - enom.com
> >
> > Please comment on the draft as to if this is an acceptable response.
> > The WLS Drafting Team used the comments from the meeting and
> > additional
> > comments forwarded to them to draft this response.
> >
> > If you find a general exception to the response please contact the
> > drafting team via WLSDraftingTeam@ar.com
> >
> > A text version is included below for ease in quoting. We must
> > finish this
> > response by Thursday so that we can formally deliver it to VGRS as
> > requested by Friday the 18th of January, 2002.
> >
> > Thanks for your corporation.
> >
> > -rick
> >
> > Rick Wesson
> > CTO, Registrars Constituency
> >
> > -------------------- txt version of RC-WLS-Response.pdf
> > ---------------
> >
> >
> > To Chuck Gomes,
> >
> >  The Registrar Constituency (RC) is hereby providing its formal
> >  position to the VeriSign Global Registry Services (VGRS) regarding
> >  its proposal to manage a Wait Listing Service (WLS), the subscription
> >  service for deleted domain names.  VRSN sent its proposal to the
> >  Registrar Constituency on December 30, 2001, and allowed registrars
> >  to comment until January 18, 2002.
> >
> >
> >  The RC has considered the WLS, holding discussions and voting by
> >  email and through a conference call.  The overwhelming posi tion of
> >  the RC - in fact the unanimous vote of all those taking a position -
> >  is to oppose the WLS.  Considering VRSN's obligation under its
> >  agreements with ICANN to vet any proposed price increases or service
> >  modifications for registry services with ICANN, and ICANN's bottom
> >  -up approach, it is the RC's understanding that the RC position will
> >  be considered within the Domain Name Supporting Organization (DNSO)
> >  before the DNSO would make a recommendation to the ICANN Board, and
> >  that the RC position would be a significant factor in ICANN's
> >  consideration of the WLS proposal.
> >
> >  Prior to reviewing the RC's concerns, it would be instructive to
> >  recall the history of this issue.  In Spring 2001, VGRS temporarily
> >  shut off registrar connections, preventing new and/or s mall
> >  registrars from registering .com, .net and .org domain names.
> >  Ostensibly to address this technical load problem VGRS had
> >  temporarily closed the process of deleting expired names.  Rather
> >  than effectively solving the technical load problem, VGRS implemented
> >  an interim solution, relegating batch requests for deleting names to
> >  one of three pools to prevent this high -volume traffic from
> >  overloading its systems.  But according to VGRS, this solution has
> >  not solved the connection problems.  In fact, VGRS is once again
> >  announcing that it is limiting connections.
> >
> >  The RC has a number of key concerns with WLS: a) price, b)
> >  transparency, c) benefit to the Internet, and d) lack of a solution:
> >
> >    a) The proposed $40.00 price point for WLS (which is in addition to
> >       the $6.00 registry fee) is exorbitant.  VGRS has not justified
> >       this price with cost requirements.  Not only does WLS create a
> >       much higher price point for the end consumer, it effectively
> >       undermines competitive registrars' financial wherewithal.  It is
> >       highly u nlikely that registrars would be able to increase their
> >       margins in proportion to the increased margin charged by VGRS.
> >       In fact, market data (such as the Snapames price point of $49)
> >       demonstrates that competitive registrars would have to
> >       dramatically lower , or eliminate, their current margins in
> >       order to compete for WLS names.  This would undermine
> >       competitive registrars' revenues and jeopardize their ability to
> >       remain profitable.  * The one registrar that may be able to take
> >       effectively advantage of this price is the VeriSign registrar,
> >       which continues to enjoy the largest market share. It would be
> >       able to use the new higher margin of $46.00 to price below
> >       wholesale, as it has in the past with the $6.00 fee.  The result
> >       is to unfairly undermine competitor regi strars.
> >
> >    b) There would be a lack of transparency if VGRS runs the primary
> >       registry, the largest registrar, and the subscription service.
> >       As long as the same company is operating this vertically
> >       powerful chain of companies, it may be possible for it to shift
> >       domain names from the $6.00 registry to the $46.00 WLS.  In
> >       fact, only the registry would know all of the WLS subscriptions
> >       and the timing for deleting names.  Such information could be
> >       abused by its registrar.  Considering that there is a history -
> >       some of it still unresolved - of VeriSign not deleting expired
> >       names, the RC is doubly concerned that VGRS' operating the WLS
> >       provides new opportunities for domain name hoarding.
> >
> >    c) The WLS provides an incentive and reward for speculators, while
> >       squeezing registrants seeking to build a web presence and
> >       registrars (as explained above).  The WLS provides a "sure
> >       thing" to Internet insiders who are savvy enough to get to the
> >       head of the line.  This primarily means speculators.  They will
> >       be willing to pay the adde d $40 fee for a guarantee of getting
> >       the expired name if 1) they are sure the name will be deleted
> >       and 2) they believe that they can resell the domain name at a
> >       higher price.  Insiders will be virtually the only ones able to
> >       ensure that a certain name will be deleted.  The end user will
> >       still have to pay the market price, which will be determined on
> >       the secondary market.  Moreover, the fact that a WLS
> >       subscription has been placed on any given name would prompt a
> >       speculator holding such domain name to renew it, rather than
> >       release it.
> >
> >    d) In addition to creating new problems, WLS will not solve the
> >       problem of batch pool slamming.  In fact, t here is the
> >       potential to create the same technical loading problems on the
> >       WLS as currently exist on the main registry.  F or example,
> >       there will be competition amongst speculators to be the first to
> >       get the WLS on the best names about to be deleted.  There could
> >       also be a landrush effect to place WLS on well known popular
> >       names, at the moment when the new WLS service goes liv e.
> >       Registrars will still compete for the expiring names that do not
> >       have WLS subscriptions.  Since it costs the same "to slam" a $40
> >       name as to slam a name greater than $40, there is no incentive
> >       not to.  Finally, since WLS subscriptions are not tied to a
> >       name, this will create many WLS -switches immediately after the
> >       zone file is released daily.
> >
> >  While the RC opposes the WLS in its current form, it recognizes the
> >  need for a permanent solution to the apparent problem of deleted
> >  names not being released or b eing released in a manner that
> >  undermines other registry functions.  Therefore, the RC welcomes
> >  other ideas for addressing these issues, and has discussed other
> >  alternatives.  The RC will address these proposals in a separate
> >  position paper.  The RC is ope n to VGRS' comments on these other
> >  proposals, as well as any modified VGRS proposal that modifies the
> >  WLS per the comments herein.
> >
> >  The RC  is  clearly  very  interested  in  this  issue and   welcomes
> >  questions or further dialogue.
> >
> >
> >
>