Subject: GA-DIGEST V1 #1023
From: [email-masked] (GA-DIGEST)
To: [email-masked]

GA-DIGEST         Wednesday, January 30 2002         Volume 01 : Number 1023

----------------------------------------------------------------------

Date: Wed, 30 Jan 2002 08:06:21 -0500
From: "Gomes, Chuck" <[email-masked]>
Subject: RE: [ga] Revised WLS Proposal

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Here's the revised proposal:

Domain Name
Wait Listing Service

Revised by VeriSign Global Registry Services

January 28, 2002

=20
=20
Preface to the Revised Version
This document is a revision to VeriSign Global Registry Services (VGRS)
Wait Listing Service (WLS) proposal sent to the DNSO Registrars
Constituency on December 30, 2001.  In this revision VGRS has tried to
respond as much as possible to feedback received from registrars and
other interested parties.  To make it easier for registrars and others
to identify where changes were made, the Word version that accompanies
the text proposal shows major content changes in italic font.

With the submission of the initial proposal on December 30, VGRS
suggested that discussion of the proposal first occur with registrars
because they would be one of the most significantly impacted parties if
the WLS was implemented.  The plan at the time was to open up the
discussion to other gTLD registries and other DNSO constituencies after
time was allowed for discussion between VGRS and registrars.  Our intent
was not to limit input by others but rather to make the feedback process
more manageable.  Some good feedback has already been received from
other constituencies and individuals interested in this issue and it is
appreciated.

With the changes made in this document, VGRS is again requesting
feedback from the Registrars Constituency, in particular regarding the
revisions made in this document.  VGRS is also formally asking for
feedback from any other DNSO constituencies, the DNSO General Assembly,
and other interested parties, including other registries.  The purpose
of the requests for feedback is to assist VGRS in making an informed
decisionabout whether and how to proceed with its proposal for the WLS.

Procedures for Asking Questions and Providing Feedback
VGRS recognizes that processes and procedures for fostering discussion
and obtaining feedback from members of the Internet community are still
relatively undeveloped in the DNSO and the community at-large.  With
that in mind, we would like to attempt to add some structure to the WLS
discussion that we believe will make it easier to answer questions, to
organize feedback received and to quantify that feedback in a way that
leads to results that are based on objective analysis rather than
subjective, unfairly biased or unsubstantiated opinions.  We believe
that the guidelines below will facilitate these objectives and make the
process more manageable for all parties.

As a registry business, we are of course concerned that our business
needs be met and that the concerns of our customers (registrars) be
heard and addressed as possible.  At the same time, we believe that the
needs of end-users (registrants and prospective registrants) are of the
utmost importance with regard to domain name services.  Consequently, we
suggest that, in the end, after the feedback is received, that the
highest priority should be to objectively evaluate the WLS in light of
the ultimate beneficiary, domain name consumers.  It is our hope that
the guidelines below will allow that to happen.

Procedural Guidelines

1.	Questions and feedback should be  consolidated by each
organization wishing to ask questions and/or provide feedback.
Organizations may include DNSO Constituencies, the DNSO General
Assembly, or other groups of interested parties that are formally or
informally organized.  For individuals who wish to contribute who are
not part of a larger group, it is requested that they provide their
input through one of the DNSO Constituencies or the DNSO General
Assembly.
2.	In the case of groups of people not associated with DNSO
organizations, please provide the following information with your
initial input:
o	A brief explanation of what your interest is in the proposed WLS
offering
o	Objective data regarding the size of your group
o	A brief characterization of the members of your group (e.g.,
domain name registrants, intellectual property owners, intellectual
property associations, etc.)
o	A statement of the general purpose or mission of your group.
3.	Every group submitting questions and/or feedback must provide a
point of contact and email address that VGRS may use for communicating
with the group.
4.	Deadline for questions:  February 8, 2002
o	Questions consolidated as requested in item 1 above and
applicable information requested in item 2 above should be sent to Chuck
Gomes, VP of Policy and Compliance for VGRS at [email-masked]..
5.	Deadline for VGRS responses to questions:  February 15, 2002 .
6.	Deadline for final feedback:  March 1, 2002
o	Final feedback consolidated as requested in item 1 above and
applicable information as requested in item 2 above should be sent to
Chuck Gomes, VP of Policy and Compliance for VGRS at
[email-masked].
o	To assist VGRS in evaluating feedback, please provide the
following objective data:
=A7	What is the nature of the members of your group (e.g.,
individuals, registrars, registries, trade organizations, etc.)?
=A7	What is the total size of your membership?[chuck=97INEGroup has
114k members!]
=A7	How many members of your group participated in the WLS feedback
process leading up to the final feedback provided?
=A7	How many members who contributed to the WLS feedback you
provided to VGRS are involved or planning to be involved in the process
of directly or indirectly using the VGRS batch delete system for
registering just-deleted names?
=A7	What efforts did your group make to reach out to members of your
group who did not participate in the WLS discussion process?
o	In preparing feedback	 to the revised proposal, it is
important to remember that the proposal is not submitted as a permanent
offering but rather a 12-month trial.  Although based on the information
it has seen to date VGRS believes that there is more than enough
evidence to support consumer demand for such a service and that the best
way to offer such a service from a consumer point of view is to offer it
at the registry level, we also recognize that there is still
considerable debate about some issues.  A 12-month trial period will
allow time to get empirical answers to questions that have been raised.
o	Constructive suggestions for improving the proposed WLS offering
are encouraged and welcomed.  Statements of opposition are also welcome
but should be accompanied with briefly stated reasons.
7.	Target for VGRS decision regarding the WLS proposal:  March 8,
2001
o	VGRS will attempt to evaluate the feedback received not later
than March 8, 2002 and, if it is decided to consider proceeding with the
offering, will submit a final pricing proposal to ICANN for its approval
per the requirements of Appendix G of the ICANN-VeriSign registry
agreements=20

Complementary Paper
Please note that a complementary paper was prepared by VGRS titled
=91Justification for a Registry-based Wait Listing Service.=92  The =
purpose
of the paper is four-fold:
1.	To provide a brief overview of the VGRS proposed WLS for .com
and .net second-level domain names.
2.	To provide members of the Internet community a high level
overview of the current situation with regard to registering previously
registered .com, .net and .org second-level domain names
3.	To highlight what VGRS sees as the advantages of the WLS
4.	To provide responses to some of the criticism that has been
presented to date in opposition to a Registry-based Wait Listing
Service.

Summary of Major Revisions

Here is a summary of the major changes made with this revision:
=A7	An introductory explanation was added at the beginning of the
proposal.
=A7	The maximum number of times a subscriber would be allowed to
transfer a subscription to a different name was changed from three to
five (see Section 2.a.vii).
=A7	The proposed 15-day Registry Hold period has been omitted from
this document.  Although the proposal has merit in addressing several
problems that have arisen, including inadvertently deleted names, it is
a distinct idea and VGRS believes that it is best considered separately.
=A7	Specific key milestone dates were changed to TBD in Section 3.
=A7	Possible terms were suggested for the Signed Service Agreement
in Section 4.a based on feedback received from the DNSO Intellectual
Property Constituency.
=A7	The original billing and fee structure was replaced with a new
one in Section 5.
=A7	A companion paper titled =91Justification for a Registry-based
Wait Listing Service=92 was issued at the same time as this revised
proposal.

1.	Introduction

In response to a formal request by Rick Wesson on behalf of the
Registrar Constituency, VeriSign, Inc. is providing this paper to
describe its proposed Domain Name Wait Listing Service (WLS).
Specifically, the proposed WLS is intended to provide both (1) a new,
streamlined business opportunity for the entire registrar community, and
(2) some measure of relief in dealing with the =93deleted domains=94 =
issue.
VeriSign believes that introduction of WLS will benefit all interested
constituencies (e.g., registries, registrars, resellers, intellectual
property owners and domain name registrants).  To that end, we address
the following topics in this paper:

=B7	High-level mechanics of how the WLS will be delivered and
distributed;
=B7	WLS implementation milestones and go-live requirements for
registrars;
=B7	Billing model;
=B7	Effects on interested parties; and,
=B7	Market potential and rationale.

Pursuant to a license from SnapNames of its Parallel RegistryTM
technology, VeriSign, Inc., through its VeriSign Global Registry
Services (=93VGRS=94) division, is prepared to offer the WLS to VGRS=92s
ICANN-accredited registrar channel.    VGRS anticipates that it would
offer WLS for a one-year test, beginning at a date to be determined.
Results would be compiled during the last two months of the test and
provided to ICANN.

Accordingly, VeriSign solicits constructive feedback from all members of
the Registrar Constituency as well as other DNSO constituencies, the
DNSO General Assembly and other interested parties in the Internet
community.  We have reserved time with our engineering and operations
staff during the February and March timeframe to move this project
forward.  Due to this time schedule, we request that feedback regarding
the revised proposal be received by March 1, 2002, so that we will have
time to compile, evaluate, and respond to comments.  Questions and
comments should be consolidated as requested at the beginning of this
document and directed to Chuck Gomes ([email-masked]).

2.	Service Overview and Mechanics

WLS is a service whereby potential registrants (hereinafter referred to
as =93subscriber(s)=94), through their selected, participating =
registrar,
may purchase a subscription tied to a domain name currently registered.
Only ICANN-accredited registrars would be able to offer the subscription
service for .com and .net domain name registrations.  WLS subscriptions
for the .org TLD would not be available during the one-year test period.
Registrars would have the opportunity to decide whether or not to allow
their resellers to offer the service.  Registrars would perform all
subscription transactions directly with VGRS, using an interface
separate from the Shared Registration System (SRS).  The VeriSign
Registry Registrar Protocol (RRP) would not be used in the
implementation of WLS.  All current processes would remain unchanged
with one exception.  A domain name registration that is subscribed to on
WLS will be registered to the subscriber when the current domain name
registration is deleted through normal operational procedures.
Initially, a domain name registration could only have one (1)
subscription pending at a time.  If demand exists, a deeper subscription
queue could be considered for a future phase of WLS.  The processes for
placing and fulfilling subscription(s) would be as follows:

a.	Process for subscribing to WLS:

=B7	Only in the event that a domain name is already registered
within the SRS, the registrar checks the WLS to see if a subscription
already exists for that domain name.
1.	Note:  Only two scenarios will prevent a registrar in good
standing from being able to submit a subscription.  The first is if a
subscription already exists for a specific domain name.  The second is
if the selected domain name registration does not already exist within
the SRS database.
=B7	If the domain name is not already subscribed to in WLS, then the
registrar submits a subscription for that name to WLS.
=B7	NOTE:  The subscription submitted to WLS by the registrar is the
same data (minus nameserver information) that registrars currently
submit to "ADD" new .com and .net domain names.  WLS collects no
subscriber data and, as today, VGRS will have no direct contact with a
subscriber.  The subscriber stays the registrar=92s customer.  The
subscription registrar will add nameserver data after the selected
domain name is actually registered in the registry for the registrar on
behalf of the subscriber.
=B7	WLS notifies the SRS that the domain name is on the subscription
list.  The SRS identifies the name in the SRS database as being a
subscribed name.
=B7	WLS notifies the registrar of the successful subscription.
=B7	The subscription registrar notifies the subscriber of the
successful subscription.
=B7	NOTE:  The subscription is tied to a single domain name at any
point in time.  However, over the life of the one-year subscription
period, the subscriber can change the domain name tied to the
subscription up to a maximum of five times.
=B7	After the last day of each calendar month, VGRS will send each
registrar an invoice for all subscriptions successfully submitted during
the previous month.  For further information on the billing model and
specific pricing, see Section 5 of this paper.

b.	Process for subscription fulfillment:
=B7	A domain name is deleted through the normal course of operation
(e.g., registrar submits a delete request).
=B7	NOTE:  Any deletion grace period, as applicable, will still
apply. =20
=B7	The SRS processes the deletion and checks to see if the deleted
name is on WLS.
=B7	If the name is on WLS, the name is automatically "added" to the
SRS database using the registration data supplied by the subscription
registrar at the time the subscription was made.
=B7	At this time, the registrar=92s VGRS account is debited $6 for the
domain name registration fee.  All other regular business rules
affecting registration of domain names will apply at this time.
=B7	VGRS then notifies the subscription registrar of the
subscription fulfillment.
=B7	The subscription registrar modifies the registration record to
include nameserver data and updates its WHOIS database in accordance
with the registrar=92s responsibilities under the current
Registry-Registrar Agreement and ICANN Accreditation Agreement.
=B7	The subscription registrar notifies the subscriber of the
successful registration.  The =93subscriber=94 is now a registrant.
=B7	The subscription will be cleared from WLS and a new subscription
can be placed for the domain name by any registrar.

c.	Subscription Renewals:  At the time a subscriber submits an
application for a subscription, it can choose whether or not to have the
subscription auto-renew at the end of its term.  If the subscriber does
not choose auto-renewal at the initial subscription period, then it may
still choose that feature at any time during its term.  If it never
chooses auto-renewal, the subscription will automatically terminate (be
deleted) when the one-year term expires.  All renewal terms are for one
year.

d.	Subscription Transfers:  In an effort to keep the one-year test
as simple as possible, VGRS does not plan to allow subscribers to
transfer subscriptions from one registrar to another registrar, as can
be done with domain name registrations today. =20

e.	Subscription Cancellations:  A subscriber may cancel a
subscription at any time by submitting, through its registrar of record,
a =93delete=94 request through the WLS.  Please note that subscription =
fees
are non-refundable.

f.	Subscription Disputes:  The Uniform Dispute Resolution Policy
(=93UDRP=94) would not apply to subscriptions within the WLS, as the =
domain
names associated with subscriptions would not actually be registered.
As the UDRP only applies to registered domain names, a party wishing to
dispute a domain name associated with a subscription would wait until
after the domain name is actually registered to employ the provisions of
the UDRP.

g.	Conclusion of 12-Month Trial:  VGRS assumes the following:

=B7	Subscriptions continuing beyond the end of the trial period
would continue to be serviced by VGRS and registrars.
=B7	Registrars, ICANN and VGRS will mutually develop evaluation
criteria for the 12-month trial.

3.	Key Milestones (for ramping and going live)

As stated earlier, VeriSign will remain poised to move the WLS project
forward to implementation.

a.	Software Development Kit (SDK) available to Registrars =96 TBD:
The SDK will enable the registrar to develop an EPP API to connect to
WLS.  All of the items outlined below are needed for development.  Also
included are actual Java binaries and build codes, which, if used,
provide the registrar with a completed Java-based EPP API that can be
used to connect to the WLS with minimal development work

i)	Framework overview;
ii)	Interfaces class diagrams;
iii)	EPP mappings;
iv)	Java binaries and build code - this will allow registrars to
build a working WLS EPP Java API by using the build codes;
v)	Open source code; and,
vi)	Implementation examples.

b.	Implementation materials available to Registrars =96 TBD

i)	Registrar Reference Manual =96 guide to all EPP commands, Ramp-up
Processes, OT&E, Accounts Receivable, Registrar tool, and FAQs;
ii)	Quick start ramp up guide =96 necessary steps to become a
certified registrar; and,
iii)	OTE Acceptance Criteria (registrar testing document) =96 the
technical test a registrar must pass.

c.	Marketing materials available to Registrars =96 TBD

i)	HTML Content =96 content for registrars to post on their web sites
and incorporate into their domain name check and/or purchase flow
promoting the benefits of WLS;
ii)	Detailed Product Description =96 a PDF- or HTML-based document
that provides the complete details (e.g., how it works, limitations,
risks, etc.) of WLS that potential subscribers can access from the above
content; and,
iii)	Email content =96 content for registrars to send to current and
prospective subscribers, communicating the availability and value of
WLS.

d.	Operation Test and Evaluation Launch (OT&E) =96a + 30 days.  The
OT&E will be available to registrars for development testing and
certification.  The OT&E period will continue from a + 30 days
throughout the trial.

e.	Production Launch =96 d + 60 days.  All registrars that have
successfully completed OT&E testing will go live at the same time on the
Production Launch date.  Other registrars will go live as they are OT&E
qualified.

4.	Registrar Go-Live Requirements

a.	Signed Service Agreement; and,
=A7	Details of the WLS Service Agreement will be provided at a later
date.
=A7	VGRS suggests that terms of the WLS Service Agreement should
include requirements for registrars to:
o	Verify previously submitted subscriber contact data at the time
a WLS subscription is converted into a domain name registration to
ensure that contact information is accurate
o	Take reasonable measures to ensure that a domain name
registration that is cancelled as the result of a UDRP proceeding will
not be awarded to the wait list subscriber for that domain name unless
the subscriber is the UDRP complainant, thereby avoiding undermining the
integrity of the UDRP process
o	Keep the identity of wait list subscribers confidential except
as required by law enforcement agencies.

b.	OT&E Certification.

5.	Billing Model and Fee Structure

VGRS will follow a wholesale billing model.  Specifically, VGRS will
charge registrars for each subscription at the time the subscription is
placed.  The registrars would be responsible for promoting/retailing WLS
to its resellers and customers.  Registrars are free to set a
competitive retail price for this service.

VGRS envisions setting the uniform wholesale price between VGRS and
registrars as follows:
=A7	$35 (lowered from $40)
=A7	To incentivize registrars to properly educate subscribers about
the costs, risks and benefits of the WLS, VGRS will pay a rebate to
registrars for each subscription registered during a calendar quarter
during which registrars demonstrate they have made reasonable efforts to
fulfill this objective.
=A7	Rebates will be paid to all qualifying registrars as follows,
regardless of a registrar=92s individual volume:

o	For  each  subscription registered up to the first 250,000
aggregate subscriptions:
=A7	$7
o	For each subscription registered after the first 250,000
aggregate subscriptions:
=A7	$11
=A7	Rebates will be paid 60 days after the end of the applicable
calendar quarter.
=A7	VGRS, registrars and ICANN will agree to what constitutes
reasonable efforts to qualify for this rebate.

This rebate price break  point has been chosen for the following primary
reasons:

=B7	VGRS must recoup costs associated with securing and maintaining
partners and licenses to offer WLS.
=B7	VGRS must recoup its costs of developing, implementing, and
maintaining the technology and resulting WLS.
=B7	VGRS envisions making a reasonable profit on providing the
service.
=B7	As further detailed in the market rationale section below, a
service similar but inferior to WLS currently retails for $69.  The rate
of uptake on the service by registrars and subscribers is increasing
even at this current $69 retail price.  We envision that the customers
would be willing to pay a higher price for a greater success rate (100%)
offered by VGRS=92s WLS as compared to the current estimated success =
rate
of 70%.  When a domain name registration is deleted within the SRS, WLS
guarantees success.
=B7	VGRS believes that because the WLS could provide a new avenue
for speculators, the price point should be set high enough so as not to
encourage abusive speculation of WLS subscriptions.
=B7	Starting off with a higher price point allows VGRS to have
better chances of recovering development and implementation costs should
overall subscription volume be low and/or should the service not be
continued beyond the 12-month trial period.
=B7	Because VGRS has no direct contact with potential registrants or
potential WLS subscribers, it must rely on registrars to effectively
educate end-users of the service.  Giving rebates is a way that VGRS can
encourage that consumers are well informed about the service they might
consider purchasing.

**NOTE:  Unlike the scenario registrars are familiar with in registering
domain names, the WLS will not debit a registrar=92s VGRS credit balance
as subscriptions are entered into the WLS.  However, the service
agreement between VGRS and each registrar will provide for the current
registrar payment security vehicle to be used by VGRS to recover lost
funds in the unlikely event of a registrar payment default related to
WLS subscriptions.

6.	Effects on Interested Parties

a.	Effect on registries:
i)	New service to offer to registrars.
ii)	New revenue stream that would support the investment costs.
iii)	Reduction in system usage for constant checks for the target
name once a WLS subscription is placed.
iv)	Elimination of many desired domain name registrations from the
speculator market so that the current excessive demand on operational
resources is reduced and system access is maintained at a much more
reasonable level.

b.	Effect on registrars:
i)	New service to offer to customers.
ii)	New revenue stream.
iii)	Reduction of registrar system usage for constant checks once a
subscription is placed.
iv)	Ensures a fair playing field / equivalent access for all
registrars, regardless of their market or technological advantage.

c.	Effect on resellers.  All effects on registrars could flow down
to resellers.

d.	Effect on registrants:
i)	Current domain name registrations would not be affected in any
way.  A registrant could remain the registrant of its domain name
indefinitely so long as it continues to meet the requirements of its
chosen registrar.
ii)	A WLS subscription would only kick in when a name is finally
deleted.
iii)	A registrant=92s =93rights=94 to its registered domain name
registration service would not be affected in any way.
iv)	Registrants may still transfer or otherwise make their
registered domain names available in the secondary market (i.e.,
=93auctions,=94 person to person transactions, etc.).
v)	No restrictions on registrants placing a subscription on their
own domain name registrations if they wish.
vi)	Subscriptions would be processed on a first-come, first-served
basis.

e.	Effect on intellectual property owners:
i)	Same effect as on registrants, as above
ii)	No negative effect on IP owners.
iii)	Provides a low cost alternative to the current UDRP or other
dispute mechanisms for IP owners who choose to wait out a current domain
name registration.  This could be likely in the event that a domain name
registrant is not using a current registration in commerce or for other
activities.

7.	Market Potential and Rationale

As the primary market for domain name registrations in all Top-Level
Domains (TLDs) approaches maturity, commercial market participants
(i.e., registries, registrars, and resellers) are evaluating ways to
continue commercial viability and growth in their core businesses.
Adding services complementary to domain name registration services,
which would be available to all ICANN-accredited registrars and which
would meet consumer (i.e., registrant) demand, is one important way to
accomplish these goals.

Historically, and as is evident by the current number of domain name
=93checks=94 processed at the registry level each and every day (roughly
80-100 million checks per day, or over 95% of all transactions per day),
registrants clearly have been and continue to look for ways to =93get in
line=94 for a domain name when it becomes available.  Moreover, the rate
of increase for =93check=94 commands continues to grow each and every =
month.
Many interested parties, including applicants, wish to monitor current
domain name registrations for various reasons (e.g., trademark concerns)
without having to continually query registrar and registry systems or to
monitor outdated WHOIS information.  Due to system constraints and
desired efficiencies through out the registration system, all parties
could benefit from this new, ordered approach to handling =93recycled=94
domain name registrations, which does not favor speculators and robotic
systems.  VGRS believes WLS will address these needs and market demands
of both industry and consumers.

Such a service is currently offered by a private industry player,
SnapNames, albeit with a much lower efficacy rate than that expected if
WLS is offered by VGRS.  Nonetheless, SnapNames=92 success thus far,
coupled with other demand indicators, speaks to a large applicant market
awaiting WLS.  VGRS believes that it is reasonable to assume that the
industry could see an initial penetration of at least five (5%) for WLS
across the base of the current domain name registration market.  This
rather large market offers a substantial up-side opportunity for
registrars and resellers and provides a clearly defined, easy to use
service for consumers.

> -----Original Message-----
> From: Jeff Williams [mailto:[email-masked]]
> Sent: Tuesday, January 29, 2002 8:37 PM
> To: Gomes, Chuck
> Cc: [email-masked]'
> Subject: Re: [ga] Revised WLS Proposal
>=20
>=20
> Chuck and all assembly members,
>=20
>   Chuck, is there a HTML format for this Revised WLS proposal?
> Or even a Text version?  If so, could you send it in either of those
> two formats, or provide a pointer/URL?
>=20
> Gomes, Chuck wrote:
>=20
> >    Part 1.1.1.1       Type: Plain Text (text/plain)
> >                   Encoding: 7bit
> >
> >
>=20
> Regards,
> --
> Jeffrey A. Williams
> Spokesman for INEGroup - (Over 121k members/stakeholdes strong!)
> CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
> Information Network Eng. Group. INEG. INC.
> E-Mail [email-masked]
> Contact Number:  972-244-3801 or 214-244-4827
> Address: 5 East Kirkwood Blvd. Grapevine Texas 75208
>=20

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------------------------------

Date: Wed, 30 Jan 2002 08:07:07 -0500
From: "Gomes, Chuck" <[email-masked]>
Subject: RE: [ga] Revised WLS Proposal

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Here's the justification paper:

Justification for a Registry-based Wait Listing Service

January 28, 2002

This paper was prepared by VeriSign Global Registry Services (VGRS), the
registry for .com, .net and .org second-level Internet domain names.  It
is designed to be a supplement to the revised proposal for the VGRS Wait
Listing Service (WLS) proposal issued for comment on January 28, 2002.
The WLS proposal was originally submitted by VGRS to the ICANN Domain
Name Supporting Organization (DNSO) Registrars Constituency in response
to a request from that constituency received in November 2001.

The purpose of the paper is four-fold:
1.	To provide a brief overview of the VGRS proposed WLS for .com
and .net second-level domain names.
2.	To provide members of the Internet community a high level
overview of the current situation with regard to registering previously
registered .com, .net and .org second-level domain names
3.	To highlight what VGRS sees as the advantages of the WLS
4.	To provide responses to some of the concerns raised with respect
to a Registry-based Wait Listing Service.

1. Overview of the proposed WLS

WLS is a service whereby potential registrants (referred to as
=93subscriber(s)=94 in the proposal), through their selected, =
participating
registrar, may purchase a subscription tied to a currently registered
.com or .net domain name.  The WLS subscription would allow a subscriber
to be the first in line to register a deleting domain name.  A deleting
name is a domain name whose registration expires and which again becomes
available for registration.

Subscriptions would be available only through ICANN-accredited
registrars, who would perform all subscription transactions directly
with VGRS.  All current processes would remain unchanged, with one
exception:  A domain name secured through a WLS subscription would be
registered to the WLS subscriber if and when the current domain name
registration is deleted through normal operational procedures.

The VGRS proposal recommends a 12-month trial period for the WLS after
which an evaluation would determine whether to continue the service.
For additional details about the WLS, refer to the revised proposal.

2. Overview of current processes for registering deleted names

In the current gTLD registry environment, if a consumer would like to
obtain a domain name that is already registered, there are several
options including but not limited to:
i)	Waiting and then competing with speculator and registrar
technology - end-users waiting until the domain name is deleted from the
applicable registry=92s database and then trying to register it through
any ICANN-accredited registrar for the applicable top-level domain.
Deletions can happen in several ways, including: a) an explicit deletion
by the current registrant through his/her registrar before or after the
registration period expires; b) an explicit deletion by the registrar
before or after the registration period expires because of violations of
the registration agreement by the registrant; c) an explicit deletion by
the registrar because a registrant failed to renew its registration.
Nothing, of course, guarantees that the consumer will be the first to
register the deleted name.  Indeed, given the robotic attacks by
speculators who routinely register many names within moments of their
deletion, the chance that a consumer will be =93first come, first =
served=94
is the exception rather than the normal rule.
ii)	Negotiating with the current registrant =96 end-users contacting
the current registrant and offering to purchase the registration. If
this is successful, the current registrant has to work with its
registrar to change the registrant information and other applicable
registration information.
iii)	Initiating dispute proceedings =96 end-users initiating an ICANN
Uniform Dispute Resolution Policy (UDRP) complaint and/or a court
proceeding. If the UDRP or court action is successful, the registrar
involved would transfer the registration to the new registrant.
iv)	Scouring auction sites =96 end-users checking to see if the name
is offered on one of several domain name auction sites and, if it is,
following the applicable procedures of the auction site to bid on the
name. If the bid is successful, the current registrant would have to
work with its registrar to change the registrant information and other
applicable registration information as in i) above.
v)	Subscribing to SnapNames back-orders =96 end-users purchasing a
SnapBackTM for the name.  (Amazonshopping.com and AmericanExpress.net
were recovered by their respective owners using this SnapBack=99 =
service.)
SnapBacks are offered by SnapNames, Inc. through various ICANN
accredited registrars who have opted to participate in this offering.
SnapNames then works through registrars to compete for the registration
of the name, if and when the name is deleted from the registry database.
vi)	Using a registrar that specializes in registering newly deleted
names =96 end-users identifying a registrar or a registrar reseller who
specializes in registering newly deleted names.  There are a variety of
companies who are involved in providing variations of this service.
vii)	Negotiating with speculators =96 end-users identifying a domain
name speculator who has successfully registered the desired name and
agreeing to the speculator=92s terms for obtaining the registration of =
the
name.

If the WLS is implemented, the predicted impact on the above options
would be as follows:
i)	Waiting and then competing with speculator and registrar
technology =96 There is no impact if there is not an active wait listing
subscription for a name.  If there is an active wait listing
subscription for a name, the name would not be available for
registration after deletion.
ii)	Negotiating with the current registrant =96 no impact
iii)	Initiating dispute proceedings =96 no impact
iv)	Scouring auction sites =96 no impact
v)	Subscribing to SnapNames back-orders =96 The WLS would improve
upon the current registrar-based SnapBack offering.  Instead of relying
on SnapNames=92 estimated 70%+ success in competing with speculators=92 =
and
registrars=92 attempts to register just-deleted names [options i), vi) =
and
vii) above], a customer with an active WLS subscription would be 100%
guaranteed to have the domain name registered if it is deleted in the
registration database.  (Note: VGRS has licensed SnapNames=92 technology
in case the WLS service is implemented.)
vi)	Using a registrar that specializes in registering newly deleted
names =96 Businesses that specialize in registering newly deleted names
for speculators could participate in the WLS offering while also
offering their current services, although it seems reasonable to expect
that the number of names deleted (i.e., those without WLS subscriptions)
would decline.
vii)	Negotiating with speculators =96 Speculators would be free to
subscribe to the WLS service, although presumably at a higher cost (and
therefore at a reduced frequency) as compared to today.  They would also
still be able to pursue the registration of deleted domain names just as
they do now, though the number of names not wait-listed would probably
be less than it is currently.

3. Advantages of the proposed WLS

The proposed WLS embodies the following critical principles:
=A7	All end-users (registrant or potential registrant) are provided
equal opportunity to register a name that may potentially be deleted in
a way that:
o	Is simple and clear
o	Provides 100% certainty if the name is deleted  (Note: the only
way this level of certainty can be provided is for the service to be
offered at the registry level.)
o	Allows mainstream would-be registrants equal access to deleting
names without losing opportunity to speculators who have sophisticated
systems or relationships that allow them superior access.
o	Is more open and transparent than today=92s informal system in its
risks, benefits, and access to the system.
=A7	Registrars are given equal opportunity at an equal wholesale
price to participate in the WLS offering while at the same time having
the option of not participating.  Registrars that do not currently
benefit from the large number of deleting names because they do not
primarily service speculators can, by implementing the WLS offering,
begin to participate in the secondary market and its rewards for the
first time.
=A7	The WLS is proposed as a 12-month trial to allow for:
o	Thorough evaluation of the service before making it a permanent
offering
o	The opportunity to gather empirical evidence with regard to:
=A7	Demand in the marketplace for such an offering (a demand that
has already been demonstrated for several years)
=A7	Market price tolerance for the WLS
=A7	The ability of registrars to differentiate WLS service offerings
=A7	Internet policy concerns
o	To specifically allow for refinements to the offering if it is
determined to be a valuable service to the community.

Following are what VGRS believes are advantages to key members of the
Internet community as related to the proposed WLS offering:

=A7	Advantages for consumers:
o	For those consumers wishing to obtain an already registered
domain name, the WLS provides:
=A7	A simple, fair, low-cost and easy to understand procedure for
acquiring deleting names, in contrast to the multitude of options
available today that have varying degrees of complexity and price and
that in practical terms are often not options reasonably available for
mainstream users
=A7	A 100% chance of registering a name if it is deleted, with the
attendant business certainty of being able to know whether one can or
should not go forward with business plans relying upon a domain name=92s
acquisition
=A7	An alternative to dealing with speculators in the deleted name
market.
=A7	A process whereby WLS subscriptions are processed on a
first-come, first served basis.
o	For current registrants, the WLS provides:
=A7	Assurance that a domain name registration would not be affected
in any way.  A registrant will still remain the registrant of a domain
name indefinitely so long as it continues to meet the contractual
requirements of its chosen registrar.
=A7	Confidence that their domain name registration services would
not be affected in any way.
=A7	The option of further protecting a name against inadvertent or
negligent expiration through wait listing (Note:  such protection could
probably be obtained more economically by simply extending the
registration period.)
=A7	Complete freedom to continue to make names available in the
secondary market, as is possible today (e.g., auctions, person-to-person
transactions, etc.).

=A7	Advantages for registrars and registrar resellers:
o	The ability to offer increased certainty to customers interested
in registering currently registered names.
o	The ability to offer consumers a new service alternative in the
secondary market for domain names.
o	The option to offer added value to the WLS and thereby
differentiate their WLS offerings from competitors.
o	The opportunity to create a new, additional revenue stream:
first the subscription fee, second the registration fee.

=A7	Advantages for gTLD registries
o	Ability to offer registrars a service that would help impart
greater confidence to customers interested in securing names through the
secondary market.
o	Reduction in resources necessary to support transactions made by
registrars trying to register recently deleted domain names (Note: In a
recent 17-day period, VGRS estimated that nearly 1.5 billion
=93transactions=94 (i.e., adds, modifies, checks, queries, etc.) =
occurred in
its systems in efforts by registrars to register just-deleted names.
That resulted in only 3,156 registrations, meaning that on average
465,399 transactions were made for every added domain name.)
o	The opportunity to create a new revenue stream

=A7	Advantages for intellectual property owners
o	Provides a low cost alternative to the current UDRP or other
dispute mechanisms for IP owners who simply elect to wait out a current
domain name registration  (Note: This could be likely in the event that
the current registrant is not actively using the name for commercial or
other activities.)
o	Maintains the integrity of the UDRP process.

4. Responses to criticism to the proposed WLS

Discussion of the concepts that led to this proposal began in September
2001 at ICANN=92s meetings in Montevideo, Uruguay, in an open meeting
among registrars, registries and other interested parties.  Those
discussions continued on a list set up by the ICANN DNSO Registrars
Constituency (the =93ICANN-Delete=94 list), and finally resulted in a
request for this proposal by that constituency.  As noted at the
beginning of this paper, VeriSign presented the original WLS proposal to
the Registrars Constituency on December 30, 2001.  Discussion of the
proposal has occurred on and off since that time.

A variety of arguments have been made in opposition to the proposed WLS.
The intent of this section of the paper is to provide brief VGRS
responses to some of the criticism.  First, responses are provided to
the formal feedback received from the Registrars Constituency on January
18, 2002.  Then responses to other arguments are provided.

4.1 Comments regarding Registrars Constituency Response to Initial WLS
Proposal

a. =93The proposed wholesale price for the service is too high.=94

VGRS initially proposed a WLS cost to registrars of $40 per annual
subscription with the following objectives in mind:
=A7	To allow significant room for registrar margins and still result
in retail prices that the market would bear =96 current retail prices =
are
increasing, and are in the $69 range at present.
=A7	To discourage abusive speculation that we believe is encouraged
by too low a price point  (Note: VGRS believes that the concern for the
mainstream customer is best addressed by not setting the price so low
that there would be, more frequently, a wider margin or gap, for
speculators, between a name=92s WLS price and its fair market value.)
=A7	To recover VGRS=92 investment and ongoing license costs in the WLS
even if the volume of subscriptions is lower than anticipated and if the
service is discontinued after a one-year trial.
Because feedback received from some registrars disagreed with our
assessment in this regard, we carefully reevaluated our pricing model to
attempt to address registrars=92 concerns while at the same time
continuing positively toward the above three objectives.  The
adjustments made are detailed in the revised proposal.

Additional comments with regard to price are included in Section 4.2
below.

b. =93There could be conflicts of interest between VGRS and the VeriSign
Registrar.=94
VGRS understands the source of this concern but we would like to call
attention to the requirements in the ICANN registry agreements found in
Section 23 for .com and Section 3.5 for .net and .org along with
Appendices H and I of all three agreements.  We have diligently
fulfilled the equivalent access and organizational conflicts of interest
requirements contained therein and are fully committed to continue to do
so.  Representatives from our VGRS compliance office would be pleased to
provide registrars any information they like about our compliance
program.  Moreover, we openly invite registrars to present any evidence
of cases where VGRS is believed to have treated the VeriSign Registrar
any differently from other registrars with regard to the WLS or any of
our .com, .net and .org registry services.  Any such evidence received
will be appropriately investigated and appropriate action will be taken.

In addition to the existing safeguards that prevent favoritism toward
any registrar and to ensure equivalent access for all registrars,
VeriSign is also currently in the process of taking one more step to
further ensure separation of VeriSign Registry and Registrar functions.
This will involve additional organizational changes and it is
anticipated that further details of these changes will be announced in
the next few weeks.

c. =93There will be incentive and award for speculators.=94
This is one area for which VGRS confesses lack of understanding so it is
difficult to respond.  We do agree with the statements made by some
registrars that the WLS will not eliminate speculation.  At the same
time, as we said in the initial WLS proposal a higher price for wait
list subscriptions will result in a decrease in speculator activity that
is dependent upon low-cost acquisitions.  There is no empirical evidence
supporting the speculative conjecture that a higher price point for the
WLS will disproportionately encourage speculation.  To the contrary, we
believe that the closer to fair market price a subscription is sold, the
less likely it is that a speculator would purchase a subscription in
hopes of profiting from the spread between the WLS price and the market
price.  We accept that there is disagreement on this point and suggest
that the most effective way to evaluate the relationship is to collect
and interpret empirical data during the 12-month trial period.

VGRS definitely believes that the current methods for handling deleted
names provide incentive and awards for speculators.  As noted by a
registrar in the WLS discussions that have occurred during the last
several weeks, it costs registrars virtually nothing to repeatedly send
transactions to VGRS systems.  When a name is successfully registered in
this way, the registrar only has to pay $6 for a one-year registration.
The WLS as proposed would increase this cost significantly and therefore
has the potential of decreasing speculator activity.  It is not clear
how the WLS could increase speculator activity.

d. =93Solving the Problem of the Rush to Register Deleted Names=94
VGRS is in full agreement with registrars that the WLS does not solve
this operational problem.  We believe that the WLS could have an
incidental benefit on this problem but we recognize that the WLS is not
a solution for the deleted names issue.  In Chuck Gomes=92 analysis =
posted
to the ICANN-delete list in the fall of 2001, he specifically stated
that VGRS would be willing to consider implementing the WLS along with
other steps to deal with the deleted names problems.  One of the
possible =93other steps=94 suggested by registrars on that list was to =
make
the =93batch pool=94 a permanent solution and to charge for access to =
that
pool.  We are not prepared to commit to making the =93batch pool=94 a
permanent fixture but we are willing to continue making it available
free of charge as it is today until it is improved and more cost
effective measures can be implemented.

4.2 Comments regarding other arguments made against the WLS proposal

Numerous comments have been have been made regarding the proposed WLS
wholesale price to registrars, some of them based on the supposed
simplicity of constructing a =93parallel registry=94 such as the WLS.  =
Over
the past five to six years, there has been no shortage of people who put
forth their opinions regarding how cheaply they could provide a
particular Internet service.  The same thing is happening with regard to
the WLS.  But none espousing their own cost theories on the WLS have any
factual data about what is involved in developing and implementing a
system that could be integrated into VGRS operations, and it is highly
unlikely that they have factored in the strict quality control processes
and the demanding reliability and availability standards that VGRS
requires of its registry services operations.  VGRS provides registry
services that are unmatched anywhere in the world on a scale unmatched
anywhere in the world and the WLS will be positioned side-by-side with
already existing systems and services at that same level of quality.  It
is our belief that there are too many commercial enterprises around the
world that depend on the critical services we provide to not offer the
best that is possible.  Does that mean it costs us more to implement the
WLS than if we let others do it?  Probably.

When first considering the WLS service, VGRS weighed developing the
system in-house versus licensing the technology.  For time-to-market and
resource availability reasons, VGRS decided to license some of the
technology that would be needed at the registry and to facilitate
registrars=92 efforts in implementing the service for their customers.
VGRS selected SnapNames=92 technology because it offered the most tested
technology available.  Could VGRS have procured a license for a lesser
price from other providers?  Perhaps, but it is unlikely it would have
met our high standards.  SnapNames pioneered Parallel Registry=99
technology and have the widest experience in the industry with that
technology.

The WLS, using Parallel Registry=99 technology, is a full-scale registry
platform that is equivalent in many ways to an operational registry.
Consistent with VeriSign=92s long-standing technical reputation and
service, and SnapNames=92 newer versions of the same, the new WLS =
registry
platform is also world-class.  The hardware is very similar in
specifications and performance, and all systems must go through a
rigorous quality assurance to verify that the WLS will perform as well
as the core registry.  VGRS required that WLS technology be identical to
its own core systems technology with respect to security, scalability,
support of diverse features and functionality, customer support and
administrative interfaces, and software development kits supporting a
broad range of registrars.  The WLS provides a completely separate
EPP-based API for registrar-registry communication.  The WLS must be
able to scale across thousands of connections and across many machines
without performance or reliability problems (all transactions through
the system require complex two-phase commits).

There have been several requests for VGRS to release its cost
information.  That information is VeriSign=92s proprietary financial =
data.
It would be inappropriate to disclose such information based on common
business practices, based on the fact that it involves competitive
information, and based on the fact that it involves information that is
proprietary to our suppliers and partners.

Another misunderstanding is that the WLS would be a =93monopoly=94 =
service.
VGRS has no ability to =93control=94 WLS prices to consumers, in the
antitrust sense of being immune from competitive pressure.  Moreover,
with other gTLDs and ccTLDs now pervasive in the marketplace, neither
.com and .net registrations, nor a WLS subscription, are a necessity.
And there are alternative services that both registrars and consumers
may use instead of the WLS.

Some have criticized VGRS for trying to expand its services as the
registry for .com and .net.  Under its registry agreements with ICANN,
VGRS is the exclusive registry for all .com and .net Internet
second-level domain names and it provides these services under the
contractual relationships outlined in those agreements.  The WLS is
being offered at the registry level because a centralized WLS offers
more value and efficiency for consumers.  The fact is that offering the
WLS at the registry-level is the only way to maximize consumer value for
such a service.

Some have suggested it is =93unethical=94 to offer =93chances=94 at a =
name that
is already registered by someone else.  To have a guaranteed option on
some thing is to have something of real value.  There are numerous
analogous examples, from the securities industry to options on
screenplays.  The purchaser gets value by having the best, next, and
exclusive right to a good or service, as well as by foreclosing =
others=92
right to that good or service.  This value is worth something to the
purchaser.  Given all the relevant facts, the purchaser is free to
decide how much it is worth and to act accordingly.

A few wondered if trademark owners would be negatively impacted by the
WLS.  It should first be pointed out that the risk of failing to renew
in case a name that was wait listed would be the same as it is today.
Registrants with either superior and preferential access (the status
quo) or a WLS subscription would get the name after its
expiration=97trademark owners would undergo the cost and inconvenience =
in
getting it back.  As before, the best defense is through careful
custodianship of the name, either by renewing or pre-paying. =20

The WLS would, however, offer trademark owners one form of protection
they currently do not have:  today, domain names that are in dispute are
often allowed to expire, with the trademark owner then being forced to
try to register it again, failing more often than not, and starting all
over with the dispute process against another registrant.  A WLS
subscription on the disputed name may be used as a safety net in such
circumstances, just as many litigants, courts, and even the U.S.
Marshall=92s Service utilize SnapNames=92 SnapBack=99 for the same =
purpose.

We suggest to all concerned that the consumers=92 interest, not those of
the speculators or those with a business model based upon superior
technological access, should come first.  If registrars want a larger
income stream from a legitimate service provided in a high quality
manner, we suggest that a one-year test of the WLS should be allowed.

> -----Original Message-----
> From: Jeff Williams [mailto:[email-masked]]
> Sent: Tuesday, January 29, 2002 8:37 PM
> To: Gomes, Chuck
> Cc: [email-masked]'
> Subject: Re: [ga] Revised WLS Proposal
>=20
>=20
> Chuck and all assembly members,
>=20
>   Chuck, is there a HTML format for this Revised WLS proposal?
> Or even a Text version?  If so, could you send it in either of those
> two formats, or provide a pointer/URL?
>=20
> Gomes, Chuck wrote:
>=20
> >    Part 1.1.1.1       Type: Plain Text (text/plain)
> >                   Encoding: 7bit
> >
> >
>=20
> Regards,
> --
> Jeffrey A. Williams
> Spokesman for INEGroup - (Over 121k members/stakeholdes strong!)
> CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
> Information Network Eng. Group. INEG. INC.
> E-Mail [email-masked]
> Contact Number:  972-244-3801 or 214-244-4827
> Address: 5 East Kirkwood Blvd. Grapevine Texas 75208
>=20

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