[registrars] WLS Comments

[Mike <mike@awregistry.net>]

Dear Mr. Gomes,

All West Communications, Inc. (AWRegistry) is opposed to the
proposed VeriSign WLS for the following reasons:

1.  We believe implementation of the WLS will force upon us
significant changes to the way we do business, thus necessitating
spending on unplanned costs and business expenses, while
seriously and negatively impacting an important revenue stream,
specifically registrations of recently deleted domain names.

2.  We believe WLS will negatively impact the businesses of many
resellers and speculators, who will no longer be able to register
expired domain names in the same ways they do now.  They too will
incur unplanned costs in order to continue their businesses.

3.  The WLS seems to be specifically designed to aid speculators,
but moves much of the revenue generated by this speculation from
registrars to registry.  Our opinion is that this is an abuse of the
registry's position as the only entity able to offer this service as
proposed.

4.  We do not believe that the stated goals of WLS, which are:

          to provide both (1) a new, streamlined business
          opportunity for the entire registrar community,
          and (2) some measure of relief in dealing with
          the deleted domains issue.

will be successfully met.  On (1), while it does provide a new
product offering, we think it will not make up for the adverse
effects it will have on existing markets.  On (2), there will
continue to be heavy traffic in the auto pool for registrations
of deleted names that have no WLS subscriptions.  Also, we do not
see significant problems with the current auto pool.  Our
"pounding" of the server during drop times does not seem to crash
the server, nor does it cause problems in the normal pool.  We
think the auto pool was a good solution to a problem which is no
more, and if there are still technical problems, they should be
solved by technical means.

5.  We believe the current system of deletions is a fair and
efficient way to re-allocate expired names to registrants, providing
many choices to registrants, registrars, and resellers, and enabling
various thriving markets in deleted domain names.

6.  We do not believe it is ethical to sell "chances" of anything.
To be specific, we think that by selling a WLS subscription, we
would be selling a chance to register a domain name if and only if
the name is deleted within the subscription period.  There isn't
even any way to calculate the odds that a particular name will ever
be deleted.  Though legally WLS would probably not fall into the
category of a lottery, we think many consumers would be duped into
buying WLS subscriptions that will never come to fruition.  Some
may take on a "gambler" mentality and buy subscriptions for high
profile names (the business.com type), knowing that they probably
won't be deleted; but some people can't resist the urge to gamble.
We want no part of that.

Thank you for accepting our comments.

Sincerely,

Mike Brown
Project Manager
All West Communications, Inc. D/B/A AWRegistry


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