dotShabaka Registry Public Comment – Report on Supporting the Domain Name Industry in Underserved Regions

["Yasmin Omer (DotShabaka)" <yasmin.omer@xxxxxxxxxxxxxx>]

6 June 2014

dotShabaka Registry Public Comment – Report on Supporting the Domain Name 
Industry in Underserved Regions

dotShabaka Registry is the Registry Operator for an Arabic new generic Top 
Level Domain (TLD) -  شبكة. The شبكة. TLD was launched in October 2013 and is 
targeted at speakers of the Arabic language. Our efforts to promote and market 
the شبكة. TLD are therefore primarily applied in regions with a high density of 
Arabic language speakers. Unfortunately, the domain name industry in these 
regions is far from robust which at times compromises our efforts. dotShabaka 
Registry therefore welcomes and encourages ICANN’s exploration of ideas and 
strategies to help promote the domain name industry in regions identified by 
ICANN as being underserved.

dotShabaka Registry thank ICANN for the opportunity to comment on the report 
subject of this public forum. It is our contention that the report demonstrates 
the absence of a holistic approach being taken to develop a robust domain name 
industry in these regions.

The challenges and issues identified in the report are symptoms, and not 
causes, of an underdeveloped domain name industry. The proposed solutions may 
alleviate these symptoms but will fail to address the root causes of an 
underdeveloped domain name industry. Research must be conducted at the outset 
to identify and address the root causes. This research should at the very least:

•                     Identify qualities (and their associated statistics) of a 
robust domain name industry e.g. over 80% Internet penetration.

•                     Define the eligibility criteria for an ‘underserved 
region’ based on the qualities of a robust domain name industry e.g. less than 
40% Internet penetration.

•                     Identify ‘underserved regions’.

•                     Analyse in detail the differences between the domain name 
industry in the underserved region and a robust domain name industry by 
reference to the profile of the Registry Operator, registrar, registrant and 
Internet user.

•                     Identify proven measures aimed at addressing the 
deficiencies of the domain name industry in the ‘underserved region’. A 
holistic approach should be taken in this regard that is not limited to 
measures within ICANN’s perceived purview.

•                     Implement measures aimed at addressing these deficiencies 
e.g. poor consumer awareness may be addressed by a Domain Name Industry 
Roadshow in ‘underserved regions’.
We note that the report focuses on registrar issues and places great emphasis 
on increasing the number of registrars in these regions as the primary 
mechanism to develop a robust domain name industry. We believe this focus is 
misplaced. This focus is based on the ill-conceived notion that increasing the 
supply of domain names is the panacea for the challenges faced by the domain 
name industry in these regions. It is not.

Measures to increase the supply of domain names will be met with futility where 
the demand is lacking. Our first-hand experience in these regions indicates 
that one of the root causes of an underdeveloped domain name industry is a 
deficiency in the demand for domain names. We need to identify why the demand 
is lacking. We need to implement measures to increase demand at which point, as 
dictated by the basic principles of economics, supply will increase as a matter 
of course.

Once the demand is increased, registrars will be presented with the incentive 
necessary to overcome the challenges identified in the report. It is at that 
point that it would be appropriate to implement measures, if required, to 
address the supply of domain names as proposed in this report.

Implementation of the proposed solutions aimed at increasing the supply of 
domain names now is premature and will see the establishment of registrars who 
cannot support their own operations due to a lack of demand for domain names in 
these regions. We recognise that increasing the number of registrars in these 
regions may be an attractive way of measuring achievements and setting Key 
Performance Indicators (KPIs) for ICANN staff but emphasise that this is an 
exercise fraught with futility. Our first-hand experience demonstrates that 
registrars will not create demand. They will meet established demand. Absent 
the adoption of measures to address the deficiency in demand for domain names, 
these registrars will effectively be set up to fail. Such an approach is not 
sustainable and will add further instability to the domain name industries in 
these regions.

Finally, care must be taken not to undermine established policies that have 
come about via a bottom up multi-stakeholder process by adopting a non-uniform 
approach to the application of these policies. These policies are in most part 
informed by a need to protect the security, stability and resiliency of the DNS.

dotShabaka Registry emphasizes the need to address the root causes and not the 
symptoms of an underdeveloped domain name industry. We look forward to working 
with ICANN to address these causes and anticipate that doing so will be 
conducive to the achievement of our mission which is to build an Arabic 
Internet.


Yasmin Omer
General Manager
dotShabaka Registry
+971 4 453 2761
Dubai Marina, Dubai
dotshabaka.com<http://www.dotshabaka.com/>
@Yasmin_Omer<https://twitter.com/Yasmin_Omer>


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