RE: [registrars] RC WLS Response

[Nikolaj Nyholm <nikolajn@ascio.com>]

I disagree with this black and white point of view.


While the poll showed unanimous opposition to WLS _as is_, I believe that
the general sentiment was to work _with_ VGRS on improving certain aspects
of the proposal, rather than focusing on new, alternative proposals.

The document does not reflect this nuance, and I can therefore not support
it in it's current form.


Kindest regards
Nikolaj Nyholm

> -----Original Message-----
> From: Elana Broitman [mailto:ebroitman@register.com] 
> Sent: 16. januar 2002 16:05
> To: wessorh@ar.com; Nikolaj Nyholm
> Cc: 'Registrars List'
> Subject: RE: [registrars] RC WLS Response
> 
> 
> 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.
> > >
> > >
> > >
> >
>