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[registrars] RE: Registrars Questions for VGRS Regarding the revised WLS proposal
Rick,
VGRS' responses to questions received regarding the revised Wait Listing
Proposal have been posted at:
http://verisign-grs.com/wls_responses.pdf
Chuck
> -----Original Message-----
> From: Rick H Wesson [mailto:wessorh@ar.com]
> Sent: Friday, February 08, 2002 8:01 PM
> To: Gomes, Chuck; wls@verisign.com
> Cc: council@dnso.org; Registrars List; halloran@icann.org;
> Louis Touton;
> execs@registrars.dnso.org
> Subject: Registrars Questions for VGRS Regarding the revised WLS
> proposal
>
>
>
> Chuck,
>
> Please find attached .PS and .PDF files which contains lists
> of questions
> the Registrars would like answered as requested in your
> amended proposal
> dated January 28, 2002.Please use the following address as a point of
> contact for our group: execs@registrars.dnso.org which we
> will forward to
> the Registrars list.
>
> A text copy of the attached document is below for easy
> cut/paste in e-mail
> discussions.
>
> Regards,
>
> -rick
>
> Rick Wesson
> CTO, Registrars constituency
>
>
>
>
> February 8, 2002
>
>
> To Chuck Gomes,
>
>
> The Registrar Constituency (RC) is hereby responding to
> the VeriSign
> Global Registry Services (VGRS) regarding its revised proposal to
> manage a Wait Listing Service (WLS), the subscription service for
> deleted domain names. After issuing its original WLS proposal on
> December 30, 2001, VGRS issued a revised proposal on January 29,
> 2002. VGRS allowed ICANN constituencies and other
> interested parties
> to submit comments and questions regarding the revised WLS.
>
>
> Having opposed the original WLS proposal (see January 18, 2002 RC
> letter to VRSN) and considered the revised proposal, the RC remains
> significantly concerned with this proposal. Therefore,
> the RC opposes
> the revised WLS proposal in its current form. Following
> are the RC's
> key concerns regarding the WLS, which focus on price and
> transparency:
>
>
>
> a) We continue to view the proposed $35.00 price point for WLS
> (which is in addition to the $6.00 registry fee) as exorbitant,
> even with the potential proposed rebate program. VGRS has never
> justified its price point with cost requirements. The fact that
> VGRS easily lowered its original price begs the question of what
> costs actually justify the proposed WLS price.
>
>
> As we had previously stated, the WLS would significantly raise
> the price point for the end consumer, effectively undermining
> competitive registrars' financial wherewithal. It is highly
> unlikely that registrars would be able to increase their margins
> in proportion to the increased margin charged by VGRS. In
> contrast, 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 to price below wholesale, as it has in the past
> with the $6.00 fee. The result is to unfairly undermine
> competitor registrars.
>
>
> b) The additional concern that continues to exist with the revised
> WLS proposal is regarding the 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
> $41.00 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) An additional inherent unfairness is the ability of the largest
> registrar to "game" the WLS system. Since VeriSign's registrars
> delete over 50% of domain names, they can offer (to potential
> WLS subscribers) a WLS subscription on its customers' names that
> only VeriSign knows are to be deleted. Other registrars'
> customers would be buying a WLS name without the benefit of
> knowing that a particular name will actually be deleted. The
> current system does not provide registrars an advantage based
> its size. With the WLS system what is to prevent a registrar
> extending its advantage over the other registrars by not
> deleting the names that have expired without renewal and thereby
> offering less risky WLS subscriptions on those names compared to
> the other registrars?
>
>
> In terms of the RC's questions, they are as follows:
>
> a) What are the costs that justify the WLS price? What is the
> intellectual property that SnapNames is providing?
>
> b) The introduction to the VGRS' "Justification" document states
> that the WLS "is not a solution for the deleted names issue." If
> the WLS system does not solve the batch pool problem (per VGRS
> explanation), why should it be adopted?
>
> c) What is the phase in procedure (ie: landrush)?
>
> a. The SnapNames Parallel Registries Proposal (Sept 21, 2001)
> identifies 25,000 deletions/day. This means that the annual
> demand on deleted names is roughly 4.5 million. It is very
> likely that there will be a landrush. Since VGRS could not
> handle the load of 160,000 domain release back in Aug ust 2001
> (which led us to today's condition), how will it deal with a
> WLS landrush?
>
> b. There will be competition amongst speculators to be the
> first to get the WLS on the best names about to be deleted,
> which may extend the landrush effect.
>
> d) What is the proposed length of the trial?
>
> a. Page 8, Paragraph g of the proposal states, "Subscriptions
> continuing beyond the end of the trial period would continue to
> be serviced by VGRS and registrars." Thus, the trial period
> lasts for two years, not one.
>
> e) How many expired names does VGRS Registrar have that have not
> been deleted? When will they be deleted? Will these names be
> deleted before the start of the WLS?
>
> f) Pages five and six of the proposal discuss registration data to
> be submitted to the WLS, which suggest potential added data. Would
> any data in addition to the current Whois information be required?
>
> g) The proposal allows registrars to delete a domain with full
> refund if it is less than 120 hours old. Is there a grace period
> for deletion (cancellation) of a WLS subscription, which will
> refund the fee?
>
> h) How would VGRS handle "charge-backs" for subscriptions?
>
> i) What are the criteria for a evaluation of a successful testbed?
>
> a. These should be specified prior to launch.
>
> b. Do those criteria take into account the existing competitive
> landscape? What are market measurements to serve as the basis
> for a comparison?
>
> c. Under what metrics will the WLS test be considered a
> failure?
>
> j) What are the technical impacts of the protocol (epp) ?
>
> k) Does the WLS proposal expose current registrars of record to
> different and/or additional risks than other registrars?
> Alternatively, do registrars of record have any advantage over
> other registrars?
>
> l) Many have requested an opt-out capability. Does the protocol
> used for registering a WLS subscription have this capability, if
> not why could this not be added?
>
> m) Registrars have requested several improvements and fixes of
> registry operations in order to address problems that are impeding
> registrations. When will the Registry fix these issues and why has
> the WLS taken precedent above fixing these issues?
>
> n) Why has VGRS not implemented batch deletions in several weeks?
>
> o) Has VGRS investigated the antitrust, auction law and commodity
> futures law implications of WLS? If it is deemed to be illegal or
> raise civil law implications, will VGRS indemnify affected
> registrars, resellers, registrants and other market participants?
> Does VGRS offer any assurances from legal staff that the WLS
> product is legal?
>
> p) Will VGRS release the actual proposed service agreement for
> comments at some point before a decision to deploy the WLS is made?
>
> q) Will VGRS release criteria for what constitutes an acceptable
> education program for the WLS service?
>
> r) Have financial projections been created for the WLS, for both
> the registry and the registrars? If so, we would like to see them.
>
> s) When will technical and operational documents of the WLS be made
> available?
>
>
> While the RC continues to oppose 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 being released in a
> manner that undermines other registry functions. Therefore, the RC
> welcomes the Names Council's consideration of alternate ideas for
> addressing these issues, many of which have been discussed by the
> RC.
>
>
> Regards,
>
>
> Rick Wesson
> Registrar Constituency
> Chief Technical Officer
>
>
> cc: Louis Touton
> Dan Halloran
> Names Council
>
>
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