Subject: GA-DIGEST V1 #1071
From: [email-masked] (GA-DIGEST)
To: [email-masked]

GA-DIGEST           Saturday, March 9 2002           Volume 01 : Number 1071

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

Date: Sat, 09 Mar 2002 01:41:16 -0800
From: Jeff Williams <[email-masked]>
Subject: Re: [ga] FYI: Staff Draft towards Mission Statement

Peter and all assembly members,

  There is treatment available!  >;)  But I also essentially said
below that it's not just the job change.  Kent has for some time
been a ICANN staff and most of the BoD supporter.  Also
remember that at one point he was "Consulting" for ICANN
as well...

  However Kents new position with ICANN may not
influence his positions.  But I haven't seen any thing he
has stated recently that would indicate such...

Peter de Blanc wrote:

> Right- I forgot that Kent changed jobs recently. Must be "old-timer's"
> syndrome.
>
> Peter
>
> -----Original Message-----
> From: [email-masked] [mailto:[email-masked]] On Behalf Of Jeff
> Williams
> Sent: Saturday, March 09, 2002 1:14 AM
> To: Peter de Blanc
> Cc: 'Per Koelle'; 'Kent Crispin'; [email-masked]; [email-masked]
> Subject: Re: [ga] FYI: Staff Draft towards Mission Statement
>
> Peter and all assembly members,
>
>   Perhaps some have already forgotten.  Kent has recently
> been hired by ICANN in a technical capacity.  This would
> tend to be a motivation for him to "Pull the ICANN staff
> Line" so to speak.  This of course is not a change for
> Kent, as he has been a long time supporter (Brown nose?)
> when it comes to the ICANN staff and most of the
> BoD members for quite some time.  Only now of course
> it is official.  >;)
>
> Peter de Blanc wrote:
>
> > Kent, I agree with Per Koelle-
> >
> > Again, I speak of ccTLDs, not gTLDs, ICANN-approved registrars, and
> > other "by contract" situations.
> >
> > There are only about 244 ccTLDs possible, according to iso3166, and we
>
> > know that many of those are not operational.
> >
> > Peter de Blanc
> >
> > -----Original Message-----
> > From: [email-masked] [mailto:[email-masked]] On Behalf Of Per
> > Koelle
> > Sent: Friday, March 08, 2002 11:40 AM
> > To: Kent Crispin
> > Cc: [email-masked]
> > Subject: Re: [ga] FYI: Staff Draft towards Mission Statement
> >
> > On Fri, 8 Mar 2002, Kent Crispin wrote:
> >
> > > On Fri, Mar 08, 2002 at 06:32:38AM -0500, Peter de Blanc wrote:
> > > > It is truely amazing that something once  done by volunteers, like
>
> > > > building and co-ordinating the operation of the global Internet
> > > > prior to, say 1995 or 1996,
> > >
> > > 1) In 95/96 there was a paid IANA staff, though it is true that a
> > > lot of work was done by people who were paid under rather
> > > non-specific contracts.
> > [SNIP]
> >
> > >
> > > > What is even MORE amazing is that the US $ 5 million  is just the
> > > > tip of the iceberg.
> > >
> > > No, it is not amazing at all.  If anything, given the demands made
> > > on ICANN, it is amazingly *cheap*.  As an end user, this is working
> > > out to around $.20/domain name per year (3% of the dominant
> > > wholesale
> > > cost) to pay for the global coordination functions that ICANN
> > > provides.
> >
> > Dear Kent,
> >
> > This is rubbish (and you af all should know),
> >
> > As far as TLD's is concerned, ICANN/IANA is (only) managing a database
>
> > with
> > +250 entries !!!!
> > I (for one) run a similar thing with +370.000 entries for around USD 3
>
> > mil.!
> >
> > Regards
> > Per Kølle
> > ..DK
> >
> > >
> > >
> > > --
> > > Kent Crispin                               "Be good, and you will be
> > > [email-masked]                           lonesome." -- Mark Twain
> > > --
> >
> > --
> > This message was passed to you via the [email-masked] list.
> > Send mail to [email-masked] to unsubscribe
> > ("unsubscribe ga" in the body of the message).
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> >
> > --
> > This message was passed to you via the [email-masked] list.
> > Send mail to [email-masked] to unsubscribe
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>
> 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
>
> --
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>
> --
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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

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

Date: Sat, 09 Mar 2002 13:57:41 +0100
From: Jefsey Morfin <[email-masked]>
Subject: Re: [ga] FYI: Staff Draft towards Mission Statement

On 10:41 09/03/02, Jeff Williams said:
>However Kents new position with ICANN may not
>influence his positions.  But I haven't seen any thing he
>has stated recently that would indicate such...

Kent is involved with security isn't it? I suppose that he is sharing into 
Lynn's brutal change concerning the root server system, its take over by 
the ICANN and the ICANN take over by the USG undr the "plural alibi" to 
call on Gov(s).

Would some US citizen object to a root server system coneived as an US Fort 
to protect from the terrorists from the outer world? This is not really an 
Alamo syndrom. It is a serious strategi matter. And for Kent it would be 
great to build/share in/rule such a kingdom.

Frankly, I would certainly support that and I think Kent has the experience 
asn skills for that. If not the community support. Bringing back all the 
USG root servers on US soil; under DNSSEC and close protection/scrutiny of 
the CIA; on distributed locations. This is exactly what New.net is 
advocating. I am for it, with a big IF:

IF:
- - other geographical areas develop *parallel/synchronous* root server systems
- - the private systems servicing registrants consortium TLDs (cf. RFC 920) 
like New.net or global roots like Pacific, ORSC, etc. may share into the 
used root file so it is a really global root file.

The ICANN could then resume its IANA service, registering the TLDs as per 
the RFC 920 conflict resolution procedures. I would only propose to enhance 
them with the industry proposed RT/BP anti-TLD squatting criteria and 
probably some others from future experience.

This is the way situation will necessarily evolve because it is the way it 
started and stayed stable for a while. So why to delay it. If Kent wants to 
be the US Master and stops the ICANN from wanting to be the world's master, 
we would all agree.

But is that what Kent wants?
Jefsey

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

Date: Sat, 09 Mar 2002 12:51:55 -0800
From: Jeff Williams <[email-masked]>
Subject: Re: [ga] FYI: Staff Draft towards Mission Statement

Jefsey and all assembly members,

Jefsey Morfin wrote:

> On 10:41 09/03/02, Jeff Williams said:
> >However Kents new position with ICANN may not
> >influence his positions.  But I haven't seen any thing he
> >has stated recently that would indicate such...
>
> Kent is involved with security isn't it?

  He has been on a low level in the past with PKI technology.  However
in his new position with ICANN I am not sure what his specific duties
are now, or will be.  Steve Crocker was hired by ICANN just after
Kent (Announced by ICANN and posted to this list) for the
security related considerations that ICANN needs to get moving
forward on as I understand it...

> I suppose that he is sharing into
> Lynn's brutal change concerning the root server system, its take over by
> the ICANN and the ICANN take over by the USG undr the "plural alibi" to
> call on Gov(s).

  Yes, this seems to be at least part of the plan as I understand it...

>
>
> Would some US citizen object to a root server system coneived as an US Fort
> to protect from the terrorists from the outer world?

  The answer to this would vary from group to group and Corp. to Corp.
I believe.  But overall, or in general the security of the Root servers
is and should be a high priority all be it one that ICANN has dragged
it's feet on for about 2 yrs now...

> This is not really an
> Alamo syndrom. It is a serious strategi matter. And for Kent it would be
> great to build/share in/rule such a kingdom.

  Yes it would.

>
>
> Frankly, I would certainly support that and I think Kent has the experience
> asn skills for that. If not the community support.

  Community support yes.  I have serious reservations from Kent's own
historical comments regarding PKI alone regarding security matters.

> Bringing back all the
> USG root servers on US soil; under DNSSEC and close protection/scrutiny of
> the CIA; on distributed locations. This is exactly what New.net is
> advocating. I am for it, with a big IF:

  First, I don't believe that anyone has come out publicly and stated
that all the Root Servers should be on US soil...

>
>
> IF:
> - other geographical areas develop *parallel/synchronous* root server systems
> - the private systems servicing registrants consortium TLDs (cf. RFC 920)
> like New.net or global roots like Pacific, ORSC, etc. may share into the
> used root file so it is a really global root file.

  RFC 920 has been obsolete for some time now.  It is especially not
usable as a guide after 9/11.

  What you are advocating here it seem to me is a shared root structure.
If so, we have been advocating that for about 5 years now.  We have
done tests and partial implementations on a number of occasions going
back to 1995.  I passed the test raw data to John Postal and the IANA
in 1996.

>
>
> The ICANN could then resume its IANA service, registering the TLDs as per
> the RFC 920 conflict resolution procedures. I would only propose to enhance
> them with the industry proposed RT/BP anti-TLD squatting criteria and
> probably some others from future experience.
>
> This is the way situation will necessarily evolve because it is the way it
> started and stayed stable for a while. So why to delay it. If Kent wants to
> be the US Master and stops the ICANN from wanting to be the world's master,
> we would all agree.

  Clever statement here Jefsey.  But even I don't believe that this is what
Kent wants nor will ICANN pursue...

>
>
> But is that what Kent wants?

  Again, no I don't believe so...  Perhaps he will answer that one directly
himself.

>
> Jefsey
>
> --
> This message was passed to you via the [email-masked] list.
> Send mail to [email-masked] to unsubscribe
> ("unsubscribe ga" in the body of the message).
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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

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

Date: 09 Mar 2002 20:19:28 +0000
From: Abel Wisman <[email-masked]>
Subject: [ga] WLS reply

Assembly,

Just a few short hours or a few hours late, still we have not reacted in
full to the VGRS proposal which we should.

Don prepared this document and I had some input to, based upon all prior
discussion, without to much objections we propose to send this document
of asap (say tonight) to VGRS.

let us know.

abel wisman

This document represents the final feedback from the DNSO General
Assembly (GA) to VeriSign Global Registry Services (VGRS), with
respect to the VGRS proposed Domain Name Wait Listing Service (WLS).
More specifically, this document is responsive to, and consistent with
the Procedural Guidelines contained in, VGRS's revised WLS proposal,
dated January 28, 2002.

Background
On December 30, 2001, VGRS submitted to the Registrar Constituency its
WLS proposal (http://www.icann-registrars.org/pdfs/VeriSign_wls.pdf).

On January 18, 2002, the Registrar Constituency submitted its timely
response to the VGRS proposal
(http://www.dnso.org/clubpublic/registrars/Arc01/msg01907.html).

On January 28, 2002, VGRS posted to the GA list, its revised WLS
proposal along with the "Justification for a Registry-based Wait
Listing Service" document
(http://www.dnso.org/clubpublic/ga/Arc09/msg00773.html). This proposal
requests questions from the GA by February 8, 2001 and final feedback
from the GA by March 1, 2002, pursuant to the "procedural guidelines"
presented in it.

On February 9, 2002, the DNSO General Assembly submitted questions to
VGRS regarding the WLS
(http://www.dnso.org/clubpublic/ga-full/Arc09/msg01085.html).

On February 14, 2002, ICANN posted its "Discussion Paper: Redemption
Grace Periods for Deleted Names"
(http://www.icann.org/registrars/redemption-proposal-14feb02.htm) and
invited comments and questions. ICANN's document, will hereinafter be
referred to as "ICANN Redemption Grace," for the purpose of brevity.

On February 15, 2002, VGRS posted their responses "VeriSign GRS
Responses to Domain Name Wait Listing Service Questions"
(http://verisign-grs.com/wls_responses.pdf). VGRS's document, will
hereinafter be referred to as "VGRS Responses," for the purpose of
brevity.

Additional background information is available at
http://www.byte.org/rc-deletes/ and
http://www.icann-registrars.org/deletes.htm.

Observations
In considering the WLS proposal, various members of the GA made the
following observations:

1. Nothing in any of the various contracts specifically grants the
Registry or any Registrar the right to sell an option (or future) to
acquire a domain name, when that domain name is not available to the
public.

        VGRS states that it is free to offer the WLS service under its
        existing contract with ICANN, (see VGRS Responses at B.7. and
        B.9.), although VGRS admits that to do so is subject to
        ICANN's approval, (see VGRS Response at B.20.).

        A current domain name registration may be sold by its current
        Registrant to another person or entity. The Registrant enjoys
        extended, post-expiration renewal rights (the length of which
        is currently at the discretion of the Registrar - See
        http://www.dnso.org/clubpublic/ga-full/Arc09/msg01011.html)
        until the name is deleted and made available to the general
        public.

        The Registry and Registrars only have the expressed,
        contractual authority to register a name to the general public
        on a first come and first served basis. There is no expressed
        contractual authority to sell a future right to register a
        domain name, at the time when that domain name "may" expire
        and be deleted in the future. The spirit and intent of the
        contracts appears to assume that domain names will expire and
        be deleted and that those expired and deleted names will then,
        and only then, be available to the general public for
        registration.

        Additional services can be, and have been, "invented" by the
        Registrars as part of their marketing strategies, but no
        Registrar has been, or should be given, any unique rights with
        respect to domain name registration or after-market services.
        The same should apply to the Registry, as well.

	In addition to that it can be stipulated that the next step for
 	the registry could be to "pre-register" all possible domains 
	in accordance with a WLS to get a better profit margin and hence
	raise prices more then considerable.

2. There is no explicit policy and procedure for the handling of
expired registrations, as referenced in 3.7.5 and 3.7.11 of the
Registrar
Accreditation Agreement (RAA).

        It is clear, after reading the ICANN Redemption Grace
        document, that ICANN intends to modify the procedures
        surrounding expired and deleted domain names (possibly by
        adopting a policy and procedure as referenced in 3.7.5 and
        3.7.11 of the RAA) in order to reduce complaints from
        businesses and consumers. ICANN has called upon the Internet
        community for questions and comments during the time leading
        up to, and at, the meeting on March 10-14, 2002.

        The ICANN Redemption Grace document states, in paragraph 3
        under "Effects of Unintentional Deletions," that a
        "significant portion of the demand for registration of deleted
        domains involves domains that the former registrant did not
        intend to have deleted" and that "the registry operator
        involved is forced to cope with extraordinary re-registration
        demand from domain-name speculators for the rights to domains
        that were mistakenly or unintentionally deleted." Although
        VGRS has acknowledged the existence of the ICANN Redemption
        Grace document, it never-the-less wishes to push forward with
        implementation of WLS (See VeriSign Responses at A.3., B.8.,
        B.22.c. and D.12.).

        It seems to be generally accepted that all Registrars will
        drop/delete domain names within 45 days following expiration
        and it is recognized that Registrars have the latitude to
        delete a name the day following expiration, if they chose to
        do so. Maintaining the expired registration during the 45 day
        period is capital intensive and, therefore, expensive for the
        Registrar (see
        http://www.dnso.org/clubpublic/ga-full/Arc09/msg01011.html),
        which actually encourages a Registrar to delete the domain
        name sooner than later.

        In addition to the foregoing, there is no authority in the
        current procedure for addressing potential abuses, i.e.
        nothing explicitly denies a Registrar the right to auction, or
        otherwise sell, an expired domain name during the grace
        period, to otherwise hoard expired domain names or to charge
        the Registrant more, simply because they renewed during the
        post-expiration grace period. In fact, there have been
        frequent complaints on the GA list about the hoarding of
        domain names by Registrars.

3. There is consumer demand for deleted domain names.

        According to Chuck Gomes,
        (http://www.dnso.org/clubpublic/ga/Arc08/msg04010.html),
        potential domain name holders have requested some sort of a
        wait list service since 1996.

        In fact, in the Spring of 2001, VGRS temporarily shut off
        Registrar' connections and temporarily closed the process of
        deleting expired names, to address the load problem on VGRS
        systems. This load problem was due to the demand for deleted
        names. Thereafter, VGRS implemented a solution of relegating
        batch requests for deleting names to one of three pools and
        rate limiting to prevent this high volume traffic from
        overloading its systems.

        Further, the concept of a VGRS/SnapNames system was introduced
        by VGRS, as a result of the increased load on VGRS systems, in
        Montevideo, Uruguay in September 2001. However, VGRS now
        states that WLS is not a solution (see VGRS Responses at
        B.1.).

        Today, however, there are several entities providing some sort
        of deleted name registration service, including, but not
        limited to: SnapNames, eNom, NicGenie, IARegistry, AWRegistry,
        Signature Domains, INWW, OnlineNic, AddressCreation,
        AllDomains, EastCom, PayCenter, ExpireFish. Others may also
        offer competitive and differing services, in response to
        market demand, in the future.

        VGRS was specifically contracted by ICANN to maintain a
        registry free of commercial and possible monopolistic
        marketing and, as such, has no marketing tasks. The WLS would,
        in fact, replace the diversity of products which already serve
        this market leaving the consumer with no alternative choices.

	VGRS and Snapnames base their proposal now on "market demands" 
	however they do not bring any evidence that there is such a 
	thing as market demand, nor do they give any thesis upon which 
	this demand should be based.
	
	Pricing is determined by "what the market can bare", whilst any
	proof of cost for such a system is denied based upon 	confidentiality
of such data, yet in order to ascertain the 
	value of a product, cost-price is an important "given".
	To determine consensus on the new product without all relevant 
	data is impossible.

4. WLS and VGRS System Load Problem.

        The WLS proposal dated 12/30/2001 suggested that WLS would
        solve the VGRS system problems which were brought about by
        demand for deleted names. The revised WLS proposal also speaks
        to the VGRS system in section 7. However, according to Chuck
        Gomes,
        (http://www.dnso.org/clubpublic/ga/Arc09/msg00301.html), WLS
        "could make" a positive impact, but it "won't solve" the
        problem. However, VGRS states that WLS is not a solution, at
        all (see VGRS Responses at B.1.).

        Furthermore, VGRS states they have implemented changes which
        solved the VGRS system load problem (see VGRS Responses at
        B.2., B.3. D.3.a. and D.3.b.), and that a long range solution
	may never be feasible (see VGRS Responses at D.3.b.).

5. It is one of ICANN's responsibilities, under its agreement with the
Department of Commerce (DOC), to ensure a competitive market.

        ICANN has promoted and created competing Registrars. ICANN has
        promoted and created additional Registries. The TLD .org is in
        the early process of divestiture.

6. The name space belongs to the public.

        Neither ICANN, the Registry or the Registrars have any right
        to any domain name, unless they have registered that name and
        paid the appropriate registration fee. This concept is equally
        applicable to expired domain names which have not yet been
        deleted and made available to the public for registration.

        VGRS seems to have a different position (see VGRS Responses at
        A.1.).

	Remains whether a clear deletion of a name should not be that 
	what it pertains to be, a "deletion" :

	Pronunciation: di-'lEt, dE-
	Function: transitive verb
	Inflected Form(s): de·let·ed; de·let·ing
	Etymology: Latin deletus, past participle of delEre to wipe out,
	destroy
	Date: circa 1605
	: to eliminate especially by blotting out, cutting out, or 	erasing

	Once something is erased, can it be sold again as "still 	existing" or
is it gone and can it only be sold as "new" hence 	upfront eliminating
the option of a WLS.

Concerns
The GA has several concerns about the proposed WLS:

1. VGRS is the Sole Authority

        The metrics and the determination of the success or failure of
        the WLS test is in the exclusive control of VGRS and not
        consensus based (see VGRS Responses at B.14.d.).

2. SnapNames will Have an Advantage

        VGRS has devised a means to protect the existing business of
        its partner, SnapNames, but has not done the same for the
        other participants in the after-market (See VGRS Responses at
        B.18.a.)

3. It is Not Just a 1 Year Test

        Subscriptions do not expire at the end of the test period (see
        VGRS Responses at B.23.) but continue until maturity.
        Consequently, a subscription taken on the last day of the 12
        month test period will not expire for another year. However,
        VGRS will not accept new subscriptions beyond the 12 month
        test (see VGRS Responses at D.4.).

4. No Consumer Choice

        Today, the potential registrants have a choice of several
        diverse service offerings, with differing price structures.
        Implementation of the WLS guarantees that there will be no
        additional and differentiated offerings to enter the market. In
        fact, it absolutely guarantees there will be only one service
        offering.

        Price differentiation, if any is possible under the last
        proposed pricing structure, does not make a differentiated
        market. Even in the revised pricing structure, VGRS is clearly
        the benefactor.

5. No Innovation or Service Differentiation

        Today, Registrars compete on the basis of price and service
        differentiation. Under the proposal, the lion's share of the
        revenue goes to VGRS, leaving a thin margin for Registrars
        and, effectively, no margin for Resellers. Consequently, it
        limits the capability of the Registrars and Resellers to
        innovate and differentiate their offerings.

        Further, since VGRS is in full control of the entire delivery
        mechanism, there is little opportunity, if any, for the
        Registrars to innovate, irrespective of the already
        substantial cost structure.

6. Runs-Out/Kills the Current Participants

        The WLS will remove all competitors from an already thriving
        and growing market. WLS guarantees that there will be no
        competition and therefore, the consumers will have no
        competitive choice. This flies in the face of ICANN's
        responsibilities under its agreement with the DOC and
        contravenes the rudimentary principles of free enterprise and
        a competitive marketplace.

        Indeed, VGRS seems to have no concern for the already
        competitive market, to those entities already serving this
        market or to consumer choice (See VGRS Responses at B.14.a.,
        B.15., B.24. and D.2.).

7. Expanded Monopolistic Powers

        This proposal extends VGRS's registry status to that of an
        active market participant, taking the lion's share of the
        revenue, eliminating all current competition and completely
        controlling an already thriving market. Although we recognize,
        and agree with, VGRS's rebuttal that the Registrar is not
        contractually limited to fixing their own price, price is not
        the only consideration and certainly not the major concern.

        It is ICANN's charter and responsibility to break-up monopoly
        power - not add to it.

8. Consumers Pay, but May Not Receive Any Value

        The WLS requires payment, regardless of whether the consumer
        receives the value of actually being able to register the
        name. In contrast, the current market includes services which
        only require payment in the event the consumer actually gets
        to register the name.

        Some consumers may not mind taking the risk of paying for a
        WLS subscriptions, but other consumers are likely to take
        issue and seek out an alternative. Alas, however, WLS will be
        the "only game in town" and the consumer will have no
        alternative.

        Further, all of the financial risk, with respect to credit
        card charge-backs and similar disputes, is placed solely on
        the shoulders of the Registrars, with no indemnification from,
        or participation by, VGRS, although VGRS is clearly the
        benefactor of the lion's share of the revenue (See VGRS
        Responses at B.6., B.12..

9. No Solution to VGRS System Problems

        As cited above, the initial WLS proposal of 12/30/01 and the
        revised WLS proposal of 1/28/02 speak to the benefit of WLS to
        the VGRS system problems. However, as also cited above, WLS is
        not a solution to the VGRS problems in the short or long term.
        Furthermore, as also indicated above, VGRS now states that the
        problems are solved and that no other longer range solution
        may ever be feasible.

        However, it seems that WLS is intended to decrease demand, by
        narrowing the market to one service, one provider, one
        delivery mechanism and by increasing the price, in order to
        deal with the load problem, instead of dealing with it
        appropriately, at a technical level. The only obvious
        benefactors of this approach are VGRS and its partner,
        SnapNames. There is no merit in it for the rest of the
        universe.

10. Increased Costs to Potential Registrants

        VGRS bases the pricing of WLS upon the concept of "what the
        market will bear" and not based upon cost (See VGRS Responses
        at B.11.). VGRS and SnapNames have presented several
        arguments, and unsubstantiated data, on the GA list in support
        this pricing model. Further, VGRS and SnapNames have argued
        that the system costs are substantial, but have not presented
        any credible facts to support these assertions. Although, the
        VGRS contract with ICANN is on the basis of "cost-related"
        pricing, VGRS now to seeks to introduce a very different price
        model and to obtain consensus for it.

        There is no denying the fact that the current participants in
        this market (including VGRS) need to make a profit, in order
        to survive and to flourish. Considering the high wholesale
        cost of this service to Registrars, as compared to a normal
        registration, we speculate (as does VGRS and SnapNames,
        speculate to the contrary in prior rebuttals), that the
        service is over-priced. Therefore, we conclude it is not
        reasonably calculated to benefit anyone except VGRS and its
        partner, SnapNames.

        The consumer's cost to register a deleted domain name will be
        roughly 500% more than registering a deleted domain name in
        the current market. We fail to see how this increased cost
        benefits the consumer. This is particularly troublesome when
        considering that some, maybe most, consumers will pay a high
        fee, but never actually receive the right to register a
        deleted domain name.

        Cost, however, is not the only major point of concern, when
        objectively evaluating WLS in light of domain name customers
        and potential Registrants.

Position
The GA discussed many concerns with respect to the WLS proposal and
cited the major, but not all, concerns, above.

      Respectfully, and due to the major concerns cited above, the GA
      does not support or endorse the WLS proposal in any manner.

Alternatively
The GA's submits the following alternative ideas for consideration:

1. That we now turn our attention to the ICANN Redemption Grace
document and work with dispatch to achieve consensus which results in
a policy and procedure to be adopted for 3.7.5 and 3.7.11 of the RAA.
In particular, the policy and procedure should safeguard the rights of
Registrants during the post-expiration grace period and it should
contain specific language designed to prevent potential abuses by the
Registries and Registrars.

2. That ICANN should enforce the RAA with VeriSign Registrar and other
Registrars, as may be appropriate under the circumstances, with
respect to dropping all of the hoarded domain names and discontinuing
the practice of hoarding domain names.

                Respectfully submitted,
The DNSO General Assembly

- -- 
Abel S.H. Wisman

Scottish Provident House 
76-80 College Road
Harrow Middlesex
HA1 1BQ 
UK
+44 20 8424 2422
+44 78 1214 1916

www.able-towers.com
www.url.org
www.grid9.net
www.telesave.net

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Date: Sat, 09 Mar 2002 15:49:36 -0600
From: [email-masked] (Kristy McKee)
Subject: Re: [ga] WLS reply

Don & Abel,

Thank you for creating this document and sharing it with our group.  The 
concerns I raised online are covered within it, I support it.  I appreciate 
your time and attention to this matter.

:)

~k

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Date: Sat, 09 Mar 2002 14:24:22 -0800
From: Harold Whiting <[email-masked]>
Subject: Re: [ga] WLS reply

I support this document.
Nice job.

- --HJW--

At 08:19 PM 3/9/2002 +0000, Abel Wisman wrote:
>Assembly,
>
>Just a few short hours or a few hours late, still we have not reacted in
>full to the VGRS proposal which we should.
>
>Don prepared this document and I had some input to, based upon all prior
>discussion, without to much objections we propose to send this document
>of asap (say tonight) to VGRS.
>
>let us know.
>
>abel wisman
>
>
>
>
>This document represents the final feedback from the DNSO General
>Assembly (GA) to VeriSign Global Registry Services (VGRS), with
>respect to the VGRS proposed Domain Name Wait Listing Service (WLS).
>More specifically, this document is responsive to, and consistent with
>the Procedural Guidelines contained in, VGRS's revised WLS proposal,
>dated January 28, 2002.
>
>
>
>Background
>On December 30, 2001, VGRS submitted to the Registrar Constituency its
>WLS proposal (http://www.icann-registrars.org/pdfs/VeriSign_wls.pdf).
>
>On January 18, 2002, the Registrar Constituency submitted its timely
>response to the VGRS proposal
>(http://www.dnso.org/clubpublic/registrars/Arc01/msg01907.html).
>
>On January 28, 2002, VGRS posted to the GA list, its revised WLS
>proposal along with the "Justification for a Registry-based Wait
>Listing Service" document
>(http://www.dnso.org/clubpublic/ga/Arc09/msg00773.html). This proposal
>requests questions from the GA by February 8, 2001 and final feedback
>from the GA by March 1, 2002, pursuant to the "procedural guidelines"
>presented in it.
>
>On February 9, 2002, the DNSO General Assembly submitted questions to
>VGRS regarding the WLS
>(http://www.dnso.org/clubpublic/ga-full/Arc09/msg01085.html).
>
>On February 14, 2002, ICANN posted its "Discussion Paper: Redemption
>Grace Periods for Deleted Names"
>(http://www.icann.org/registrars/redemption-proposal-14feb02.htm) and
>invited comments and questions. ICANN's document, will hereinafter be
>referred to as "ICANN Redemption Grace," for the purpose of brevity.
>
>On February 15, 2002, VGRS posted their responses "VeriSign GRS
>Responses to Domain Name Wait Listing Service Questions"
>(http://verisign-grs.com/wls_responses.pdf). VGRS's document, will
>hereinafter be referred to as "VGRS Responses," for the purpose of
>brevity.
>
>Additional background information is available at
>http://www.byte.org/rc-deletes/ and
>http://www.icann-registrars.org/deletes.htm.
>
>
>
>Observations
>In considering the WLS proposal, various members of the GA made the
>following observations:
>
>1. Nothing in any of the various contracts specifically grants the
>Registry or any Registrar the right to sell an option (or future) to
>acquire a domain name, when that domain name is not available to the
>public.
>
>        VGRS states that it is free to offer the WLS service under its
>        existing contract with ICANN, (see VGRS Responses at B.7. and
>        B.9.), although VGRS admits that to do so is subject to
>        ICANN's approval, (see VGRS Response at B.20.).
>
>        A current domain name registration may be sold by its current
>        Registrant to another person or entity. The Registrant enjoys
>        extended, post-expiration renewal rights (the length of which
>        is currently at the discretion of the Registrar - See
>        http://www.dnso.org/clubpublic/ga-full/Arc09/msg01011.html)
>        until the name is deleted and made available to the general
>        public.
>
>        The Registry and Registrars only have the expressed,
>        contractual authority to register a name to the general public
>        on a first come and first served basis. There is no expressed
>        contractual authority to sell a future right to register a
>        domain name, at the time when that domain name "may" expire
>        and be deleted in the future. The spirit and intent of the
>        contracts appears to assume that domain names will expire and
>        be deleted and that those expired and deleted names will then,
>        and only then, be available to the general public for
>        registration.
>
>        Additional services can be, and have been, "invented" by the
>        Registrars as part of their marketing strategies, but no
>        Registrar has been, or should be given, any unique rights with
>        respect to domain name registration or after-market services.
>        The same should apply to the Registry, as well.
>
>	In addition to that it can be stipulated that the next step for
> 	the registry could be to "pre-register" all possible domains 
>	in accordance with a WLS to get a better profit margin and hence
>	raise prices more then considerable.
>
>
>2. There is no explicit policy and procedure for the handling of
>expired registrations, as referenced in 3.7.5 and 3.7.11 of the
>Registrar
>Accreditation Agreement (RAA).
>
>        It is clear, after reading the ICANN Redemption Grace
>        document, that ICANN intends to modify the procedures
>        surrounding expired and deleted domain names (possibly by
>        adopting a policy and procedure as referenced in 3.7.5 and
>        3.7.11 of the RAA) in order to reduce complaints from
>        businesses and consumers. ICANN has called upon the Internet
>        community for questions and comments during the time leading
>        up to, and at, the meeting on March 10-14, 2002.
>
>        The ICANN Redemption Grace document states, in paragraph 3
>        under "Effects of Unintentional Deletions," that a
>        "significant portion of the demand for registration of deleted
>        domains involves domains that the former registrant did not
>        intend to have deleted" and that "the registry operator
>        involved is forced to cope with extraordinary re-registration
>        demand from domain-name speculators for the rights to domains
>        that were mistakenly or unintentionally deleted." Although
>        VGRS has acknowledged the existence of the ICANN Redemption
>        Grace document, it never-the-less wishes to push forward with
>        implementation of WLS (See VeriSign Responses at A.3., B.8.,
>        B.22.c. and D.12.).
>
>        It seems to be generally accepted that all Registrars will
>        drop/delete domain names within 45 days following expiration
>        and it is recognized that Registrars have the latitude to
>        delete a name the day following expiration, if they chose to
>        do so. Maintaining the expired registration during the 45 day
>        period is capital intensive and, therefore, expensive for the
>        Registrar (see
>        http://www.dnso.org/clubpublic/ga-full/Arc09/msg01011.html),
>        which actually encourages a Registrar to delete the domain
>        name sooner than later.
>
>        In addition to the foregoing, there is no authority in the
>        current procedure for addressing potential abuses, i.e.
>        nothing explicitly denies a Registrar the right to auction, or
>        otherwise sell, an expired domain name during the grace
>        period, to otherwise hoard expired domain names or to charge
>        the Registrant more, simply because they renewed during the
>        post-expiration grace period. In fact, there have been
>        frequent complaints on the GA list about the hoarding of
>        domain names by Registrars.
>	
>	
>3. There is consumer demand for deleted domain names.
>
>        According to Chuck Gomes,
>        (http://www.dnso.org/clubpublic/ga/Arc08/msg04010.html),
>        potential domain name holders have requested some sort of a
>        wait list service since 1996.
>
>        In fact, in the Spring of 2001, VGRS temporarily shut off
>        Registrar' connections and temporarily closed the process of
>        deleting expired names, to address the load problem on VGRS
>        systems. This load problem was due to the demand for deleted
>        names. Thereafter, VGRS implemented a solution of relegating
>        batch requests for deleting names to one of three pools and
>        rate limiting to prevent this high volume traffic from
>        overloading its systems.
>
>        Further, the concept of a VGRS/SnapNames system was introduced
>        by VGRS, as a result of the increased load on VGRS systems, in
>        Montevideo, Uruguay in September 2001. However, VGRS now
>        states that WLS is not a solution (see VGRS Responses at
>        B.1.).
>
>        Today, however, there are several entities providing some sort
>        of deleted name registration service, including, but not
>        limited to: SnapNames, eNom, NicGenie, IARegistry, AWRegistry,
>        Signature Domains, INWW, OnlineNic, AddressCreation,
>        AllDomains, EastCom, PayCenter, ExpireFish. Others may also
>        offer competitive and differing services, in response to
>        market demand, in the future.
>
>        VGRS was specifically contracted by ICANN to maintain a
>        registry free of commercial and possible monopolistic
>        marketing and, as such, has no marketing tasks. The WLS would,
>        in fact, replace the diversity of products which already serve
>        this market leaving the consumer with no alternative choices.
>
>	VGRS and Snapnames base their proposal now on "market demands" 
>	however they do not bring any evidence that there is such a 
>	thing as market demand, nor do they give any thesis upon which 
>	this demand should be based.
>	
>	Pricing is determined by "what the market can bare", whilst any
>	proof of cost for such a system is denied based upon 	confidentiality
>of such data, yet in order to ascertain the 
>	value of a product, cost-price is an important "given".
>	To determine consensus on the new product without all relevant 
>	data is impossible.
>
>4. WLS and VGRS System Load Problem.
>
>        The WLS proposal dated 12/30/2001 suggested that WLS would
>        solve the VGRS system problems which were brought about by
>        demand for deleted names. The revised WLS proposal also speaks
>        to the VGRS system in section 7. However, according to Chuck
>        Gomes,
>        (http://www.dnso.org/clubpublic/ga/Arc09/msg00301.html), WLS
>        "could make" a positive impact, but it "won't solve" the
>        problem. However, VGRS states that WLS is not a solution, at
>        all (see VGRS Responses at B.1.).
>
>        Furthermore, VGRS states they have implemented changes which
>        solved the VGRS system load problem (see VGRS Responses at
>        B.2., B.3. D.3.a. and D.3.b.), and that a long range solution
>	may never be feasible (see VGRS Responses at D.3.b.).
>
>5. It is one of ICANN's responsibilities, under its agreement with the
>Department of Commerce (DOC), to ensure a competitive market.
>
>        ICANN has promoted and created competing Registrars. ICANN has
>        promoted and created additional Registries. The TLD .org is in
>        the early process of divestiture.
>
>6. The name space belongs to the public.
>
>        Neither ICANN, the Registry or the Registrars have any right
>        to any domain name, unless they have registered that name and
>        paid the appropriate registration fee. This concept is equally
>        applicable to expired domain names which have not yet been
>        deleted and made available to the public for registration.
>
>        VGRS seems to have a different position (see VGRS Responses at
>        A.1.).
>
>	Remains whether a clear deletion of a name should not be that 
>	what it pertains to be, a "deletion" :
>
>	Pronunciation: di-'lEt, dE-
>	Function: transitive verb
>	Inflected Form(s): de·let·ed; de·let·ing
>	Etymology: Latin deletus, past participle of delEre to wipe out,
>	destroy
>	Date: circa 1605
>	: to eliminate especially by blotting out, cutting out, or 	erasing
>
>	Once something is erased, can it be sold again as "still 	existing" or
>is it gone and can it only be sold as "new" hence 	upfront eliminating
>the option of a WLS.
>
>Concerns
>The GA has several concerns about the proposed WLS:
>
>1. VGRS is the Sole Authority
>
>        The metrics and the determination of the success or failure of
>        the WLS test is in the exclusive control of VGRS and not
>        consensus based (see VGRS Responses at B.14.d.).
>
>2. SnapNames will Have an Advantage
>
>        VGRS has devised a means to protect the existing business of
>        its partner, SnapNames, but has not done the same for the
>        other participants in the after-market (See VGRS Responses at
>        B.18.a.)
>
>3. It is Not Just a 1 Year Test
>
>        Subscriptions do not expire at the end of the test period (see
>        VGRS Responses at B.23.) but continue until maturity.
>        Consequently, a subscription taken on the last day of the 12
>        month test period will not expire for another year. However,
>        VGRS will not accept new subscriptions beyond the 12 month
>        test (see VGRS Responses at D.4.).
>
>4. No Consumer Choice
>
>        Today, the potential registrants have a choice of several
>        diverse service offerings, with differing price structures.
>        Implementation of the WLS guarantees that there will be no
>        additional and differentiated offerings to enter the market. In
>        fact, it absolutely guarantees there will be only one service
>        offering.
>
>        Price differentiation, if any is possible under the last
>        proposed pricing structure, does not make a differentiated
>        market. Even in the revised pricing structure, VGRS is clearly
>        the benefactor.
>
>5. No Innovation or Service Differentiation
>
>        Today, Registrars compete on the basis of price and service
>        differentiation. Under the proposal, the lion's share of the
>        revenue goes to VGRS, leaving a thin margin for Registrars
>        and, effectively, no margin for Resellers. Consequently, it
>        limits the capability of the Registrars and Resellers to
>        innovate and differentiate their offerings.
>
>        Further, since VGRS is in full control of the entire delivery
>        mechanism, there is little opportunity, if any, for the
>        Registrars to innovate, irrespective of the already
>        substantial cost structure.
>
>6. Runs-Out/Kills the Current Participants
>
>        The WLS will remove all competitors from an already thriving
>        and growing market. WLS guarantees that there will be no
>        competition and therefore, the consumers will have no
>        competitive choice. This flies in the face of ICANN's
>        responsibilities under its agreement with the DOC and
>        contravenes the rudimentary principles of free enterprise and
>        a competitive marketplace.
>
>        Indeed, VGRS seems to have no concern for the already
>        competitive market, to those entities already serving this
>        market or to consumer choice (See VGRS Responses at B.14.a.,
>        B.15., B.24. and D.2.).
>
>7. Expanded Monopolistic Powers
>
>        This proposal extends VGRS's registry status to that of an
>        active market participant, taking the lion's share of the
>        revenue, eliminating all current competition and completely
>        controlling an already thriving market. Although we recognize,
>        and agree with, VGRS's rebuttal that the Registrar is not
>        contractually limited to fixing their own price, price is not
>        the only consideration and certainly not the major concern.
>
>        It is ICANN's charter and responsibility to break-up monopoly
>        power - not add to it.
>
>8. Consumers Pay, but May Not Receive Any Value
>
>        The WLS requires payment, regardless of whether the consumer
>        receives the value of actually being able to register the
>        name. In contrast, the current market includes services which
>        only require payment in the event the consumer actually gets
>        to register the name.
>
>        Some consumers may not mind taking the risk of paying for a
>        WLS subscriptions, but other consumers are likely to take
>        issue and seek out an alternative. Alas, however, WLS will be
>        the "only game in town" and the consumer will have no
>        alternative.
>
>        Further, all of the financial risk, with respect to credit
>        card charge-backs and similar disputes, is placed solely on
>        the shoulders of the Registrars, with no indemnification from,
>        or participation by, VGRS, although VGRS is clearly the
>        benefactor of the lion's share of the revenue (See VGRS
>        Responses at B.6., B.12..
>
>9. No Solution to VGRS System Problems
>
>        As cited above, the initial WLS proposal of 12/30/01 and the
>        revised WLS proposal of 1/28/02 speak to the benefit of WLS to
>        the VGRS system problems. However, as also cited above, WLS is
>        not a solution to the VGRS problems in the short or long term.
>        Furthermore, as also indicated above, VGRS now states that the
>        problems are solved and that no other longer range solution
>        may ever be feasible.
>
>        However, it seems that WLS is intended to decrease demand, by
>        narrowing the market to one service, one provider, one
>        delivery mechanism and by increasing the price, in order to
>        deal with the load problem, instead of dealing with it
>        appropriately, at a technical level. The only obvious
>        benefactors of this approach are VGRS and its partner,
>        SnapNames. There is no merit in it for the rest of the
>        universe.
>
>10. Increased Costs to Potential Registrants
>
>        VGRS bases the pricing of WLS upon the concept of "what the
>        market will bear" and not based upon cost (See VGRS Responses
>        at B.11.). VGRS and SnapNames have presented several
>        arguments, and unsubstantiated data, on the GA list in support
>        this pricing model. Further, VGRS and SnapNames have argued
>        that the system costs are substantial, but have not presented
>        any credible facts to support these assertions. Although, the
>        VGRS contract with ICANN is on the basis of "cost-related"
>        pricing, VGRS now to seeks to introduce a very different price
>        model and to obtain consensus for it.
>
>        There is no denying the fact that the current participants in
>        this market (including VGRS) need to make a profit, in order
>        to survive and to flourish. Considering the high wholesale
>        cost of this service to Registrars, as compared to a normal
>        registration, we speculate (as does VGRS and SnapNames,
>        speculate to the contrary in prior rebuttals), that the
>        service is over-priced. Therefore, we conclude it is not
>        reasonably calculated to benefit anyone except VGRS and its
>        partner, SnapNames.
>
>        The consumer's cost to register a deleted domain name will be
>        roughly 500% more than registering a deleted domain name in
>        the current market. We fail to see how this increased cost
>        benefits the consumer. This is particularly troublesome when
>        considering that some, maybe most, consumers will pay a high
>        fee, but never actually receive the right to register a
>        deleted domain name.
>
>        Cost, however, is not the only major point of concern, when
>        objectively evaluating WLS in light of domain name customers
>        and potential Registrants.
>
>
>
>Position
>The GA discussed many concerns with respect to the WLS proposal and
>cited the major, but not all, concerns, above.
>
>      Respectfully, and due to the major concerns cited above, the GA
>      does not support or endorse the WLS proposal in any manner.
>
>
>
>Alternatively
>The GA's submits the following alternative ideas for consideration:
>
>1. That we now turn our attention to the ICANN Redemption Grace
>document and work with dispatch to achieve consensus which results in
>a policy and procedure to be adopted for 3.7.5 and 3.7.11 of the RAA.
>In particular, the policy and procedure should safeguard the rights of
>Registrants during the post-expiration grace period and it should
>contain specific language designed to prevent potential abuses by the
>Registries and Registrars.
>
>2. That ICANN should enforce the RAA with VeriSign Registrar and other
>Registrars, as may be appropriate under the circumstances, with
>respect to dropping all of the hoarded domain names and discontinuing
>the practice of hoarding domain names.
>
>                Respectfully submitted,
>The DNSO General Assembly
>
>-- 
>Abel S.H. Wisman
>
>Scottish Provident House 
>76-80 College Road
>Harrow Middlesex
>HA1 1BQ 
>UK
>+44 20 8424 2422
>+44 78 1214 1916
>
>www.able-towers.com
>www.url.org
>www.grid9.net
>www.telesave.net
>
>--
>This message was passed to you via the [email-masked] list.
>Send mail to [email-masked] to unsubscribe
>("unsubscribe ga" in the body of the message).
>Archives at http://www.dnso.org/archives.html

Harold Whiting
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