Re: [registrars] Draft WLS Response

["Siegfried Langenbach" <svl@nrw.net>]

Hallo,

 first of all I want to thank the drafting group for the work they 
done for all of us.

some remarks :

3a) "equal accss" the limitation here does not seem to me to be 
false. It is obvious for me that only those applying can have access. 


2) "competition" It seems to me that any new would have a 
monopolistic appearance. I would call it "natural" monopoly.
While I strongly disagree that these new service must be run by the 
registry (there is no technical reason for that), 

and herby call for second:
that we (RC) start a process of describing the new system and then 
have a call for tender. 

The service should be done outside the registry under the supervision 
of RC. Publishing that, we show that we will present our own 
solution.

siegfried
> 
> Registrars:
> 
> Attached is the proposed final draft response we will be voting on. Please
> comment on the draft over the 36 hours. The draft will be finalized on the
> 27th and the final draft recirculated on the 28th.
> 
> A vote will be initiated on the 1st of March, the ballot will contain a
> item for approval of the draft as our final comment to VGRS in regards to
> the WLS. All registrars voting to approve the draft will be named on it as
> signators.
> 
> Our vote will be made public with the names of each voting registrar and
> how they voted on each issue.
> 
> The ballot will also contain a resolution much like the one Jim Archer
> posted last week. Jim's original proposed resolution is at
> http://forum.registrars.dnso.org/thread.jsp?forum=1&thread=85
> 
> Please comment on the draft so that it reflects as closely as possible the
> consensus of this constituency.
> 
> A sample ballot will be posted on the 28th and the official voting period
> will commence on the evening of the 1st, baring any technical glitches.
> 
> Make your voice herd BEFORE the vote and comment on the draft so that we
> can express, as closely as possible, the wises of this constituency.
> 
> best,
> 
> -rick
> 
> 
> 
> ------------------- draft-rc-wls-comments-03.txt ----------------
> 
> 
> 
> 
> 
>                         [proposed final draft]
> 
>                        Registrar Constituency (RC)
>                             Position Paper
>                         Regarding the proposed
>                         Wait List Service (WLS)
> 
> 
> 
> The RC opposes the revised WLS proposal in its current form. The
> concerns are as follows:
> 
>    1) Price.
>      a. The price has not been justified on a cost plus a reasonable
>         profit, or any other, basis.
> 
>      b. The proposed WLS subscription price combined with the $6
>         registration price continues to be too high.  It effectively
>         multiplies the total registry price on the most attractive
>         deleted names about 6-fold.  The effect is to undermine
>         competitive registrars and raise the cost of registration for
>         consumers
> 
>    2) Competition
>      a. WLS reduces competition by substituting a single model for
>         the many and varied current registrar business models for
>         re-registering deleted names for consumers.  WLS pre-empts all
>         other models.  The current system imposes nearly no
>         restriction as to business model offered to consumers.
> 
>    3) Equal Access
>      a. The existing system allows each registrar equal access to
>         re-registering deleted names.  The WLS system limits
>         re-registration to the holder of the WLS subscription.
> 
>      b. With WLS, registrars with larger databanks of deleted names
>         (e.g., the VeriSign registrar, which has a large legacy of
>         expiring names) would have an advantage over smaller
>         registrars due to the fact that the larger registrars would be
>         able to offer many more WLS subscriptions with a guaranteed
>         chance of "ripening" (because only the registrar-of-record
>         would know that it is about to issue a delete on a particular
>         name).  In contrast, other registrars would have to offer the
>         same WLS subscription at a much higher risk.  This fact
>         effectively unbalances the equal access to re-registering any
>         deleted name that exists today.
> 
>    4) Transparency
>      a. VeriSign 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, and the
>         fact that a WLS subscription will be allowed for names that
>         are past expiration, the RC is doubly concerned that
>         VeriSign's operating the WLS provides new opportunities for
>         domain name hoarding.  The current system provides sufficient
>         transparency to ensure that one registrar is not advantaged
>         relative to another.  The current system provides less
>         incentive for a registrar to not delete names that are more
>         than 45 days past expiration.  The expectation of a pending
>         WLS system release provides incentive for registrars to hold
>         names past expiration.  VeriSign effectively bears no cost,
>         and has the most to gain in extra WLS fees, for it's holding
>         of expired names.  VeriSign registrar has dramatically
>         decreased the number of names it would routinely delete and
>         increased the number of names it holds more than 45 days
>         passed expiration.
> 
>    5) Grandfathering of Current Subscriptions
>      a. The WLS proposal states that current Snapbacks would be
>         grandfathered into the system.  In other words, the registry
>         would respect and effectively make whole those consumers that
>         had used a SnapNames approach to obtaining a registered domain
>         name.  It is unfair to favor one secondary market provider
>         above others.  A number of entities, including domain name
>         auction brokers and registrars, have offered consumers the
>         opportunity to place orders on registered names.  All of these
>         should receive equal treatment - meaning a grandfathering into
>         any WLS system.
> 
> While the RC continues to oppose the WLS in its current form, and
> believes that denying its introduction would be reasonable, 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
> 
> 
> --WLS Drafting Team <WLS-Response@registrars.dnso.org>
> 
>