[bc-gnso] ANNOUNCEMENT: BC call regarding VeriSign's proposed Registry Service: Tuesday, 4/20 11 a.m. EST

[Marilyn Cade <marilynscade@xxxxxxxxxxx>]

Dear BC colleagues
After some discussion within the ExComm,  I forwarded the following letter to 
ICANN staff to ask that they study the impact of VeriSign's proposed registry 
service in .net upon security and stability, rather than just approving it 
automatically.  
Please refer to Steve DelBianco's earlier email to the list explaining the 
proposed service. It was our view that BC members had sufficient questions that 
more examination is needed. 
In order to give BC members a chance to learn more about the proposed service 
and to ask questions of VeriSign, Steve DelBianco, our V.Chair, Policy 
Coordination, has undertaken organizing of a conference call with Pat Kane, 
VeriSign.  
The proposed time for the call is Tuesday, April 20, 11 a.m. EST. The call is 
solely purposed for discussing this service and will include a short overview 
of the proposed program by Pat Kane; followed by moderated Q and A.  All 
Members are encouraged to participate. 
BRIDGE NUMBER WILL BE PROVIDED TO MEMBERS WHO RSVP. 
To ensure that we have sufficient attendance at that call, I would ask that you 
rsvp [ off list] to marilynscade@xxxxxxxxxxx. Apologies to our Asian members -- 
I realize this is quite late in the evening for you. 
In the meantime, mark your calendars for the ICANN June meeting in Brussels -- 
workshops of relevance to BC begin on the Saturday and Sunday; Full meeting 
June 20-25.  
Marilyn CadeBC Chair






From: marilynscade@xxxxxxxxxxx
To: patrick.jones@xxxxxxxxx; excomm@xxxxxxxxxxxx
CC: pkane@xxxxxxxxxxxx
Subject: Request regarding VeriSign's proposed registry service
Date: Wed, 14 Apr 2010 01:56:35 -0400













April 13, 2010


Dear ICANN staff


As
Chair of the Business Constituency, I am writing  regarding VeriSign’s RSEP 
proposal for its
proposed new registry service, “Domain Exchange Service" in the
.net TLD.  On behalf of the BC executive leadership [ExComm], I request
that ICANN Staff make the preliminary determination that this proposal requires
further study because it could raise significant issues with regards to
security and stability and/or competition.  

The BC leadership’s concerns
are that, although not intended, the proposal may permit resumption of
commercial “domain tasting” activities which have been curbed by the AGP Limits
policy. In order to determine the implications of such risks, more time and
analysis is needed to ensure such service does not pose
significant consequences affecting the stability of the domain name system. 


As
we understand the proposed service submitted by VeriSign, the Domain Name
Exchange will permit domain name applicants to “repurpose” or exchange a domain
name registration that has significant time remaining until expiration. 
For the price of a single domain name, applicants will be permitted to register
at least 12 domain names a year.  As an example of the potential volume of
the service offering, if an applicant spent a mere $800 to register 100 domain
names, this service would permit the applicant to register 1200 different
domain names for that initial investment, over the course of a year. 
On its face, the increased churn of domain names and ability to monetize names
for a short period of time appears to raise red flags for increased domain
name abuse.   


 The
situation regarding harmful and abusive registrations of domain names
associated with brands continues to be a significant burden in both costs to
trademark holders and to users in terms of fraud and in other abusive uses of
such names. As we all remember, after extensive policy debate and work by the
ICANN community, ICANN specifically restricted the ability of registrars
to register domain names for five days or less under the AGP to
deter abusive practices, such as cyber squatting.  Despite the
closing of this loophole, business owners still face thousands
of instances of new infringements today because cyber squatters are
willing to pay a relatively low yearly registration fee for the high
quality names, including trademarks that drive traffic.  Although
VeriSign is permitting applicants to register domain names for 30
days rather than 5 days or less and is not offering
refunds, (different from the AGP), the proposed service reasonably
raises concerns that permitting applicants to register a
dozen domain names for the price of a single domain name
will invite speculators to game the system and use it for domain name
abuse.

Certainly, our concern is whether the new service would facilitate
abuse. However, in this case, it is also reasonable to ask staff to
explore whether VeriSign's new service might be used so excessively that it
would cause the same kinds of stability problems. We do understand that
VeriSign’s proposal would make changes by modifying the registry record – not
by an ‘add/delete’.  Nonetheless,
further exploration is needed to determine levels of use that could generate
stability concerns, whether the use was for tasting or for some new form of 
domain
recycling. 

 

We
appreciate that VeriSign has described steps that it has taken up front to
make their service more "transparent" but many of our members do not
believe that the steps they have taken thus far are sufficient.  None of the 
proposed remedies VeriSign
lists thus far actually prevent the registration of trademarks or
prevent domain name abuse at the front end of the service but appear
instead to place the entire burden, administrative costs and enforcement
costs on businesses and brand holders to deal with potential
abuses.  The BC has an extensive list of concerns and questions about
the service and its proposed remedies that it would be glad to provide to ICANN
separately as it begins its analysis of the proposed service. 

While
the service as currently proposed applies only to .net, we may
anticipate that if the current proposal is approved, VeriSign will next
seek to extend the service to .com, where the potential for abuse and churn in
the domain name system are even more pronounced.  Given all these
concerns, we urge ICANN to provide sufficient time to study this
proposal, its affect on the stability of the domain name system, potential
to contribute to abuse,  and its potential ramifications for all
affected stakeholders and to post the proposal for further public comment.
 


On behalf of the BC Executive
Committee

 

Marilyn Cade, BC Chair 

 

CC:  BC ExComm

       BC List       Pat Kane, VeriSign