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A personal perspective on the proposed renewal of the .TEL registry agreement.

  • To: comments-tel-renewal-04aug16@xxxxxxxxx
  • Subject: A personal perspective on the proposed renewal of the .TEL registry agreement.
  • From: Jonathan Curley <jonathan.p.curley@xxxxxxxxx>
  • Date: Mon, 12 Sep 2016 23:52:53 +0100

This is much more than a comment and is more like an open letter to
ICANN / Telnic, I also believe this is my last opportunity to express
most of these issues in a way that is useful to ICANN, and of which I
feel have been ignored for the periods this extension has been in

I feel passionate about this domain extension because I can see its
potential just over the horizon, I also feel if it were improved and
managed for the betterment of the community it would become a tool we
could all use on a day to day basis while being as independent or as
integrated to whichever services we chose, when we choose it.

It is essential that dot tel owners and those of us who manage
self-representations or brands online are provided with the core
infrastructure tools that give back the control we require over our
online experiences and virtual representations, and this is why I see
dot tel as having the potential to be such a tool and one that is
crying out for advanced development and mandated integration.

And so a simple online card with URL links it is not. What I have
written below I believe is true and accurate, and to the best of my
knowledge is based on my own direct experiences and perceptions over
many years, my intent in writing this is non-malicious and is for
critical feedback on the extension and its end product that I have
used in the past, and of which I will continue to use in the future if
ICANN allows dot tel to remain viable.

At the time of posting this I'm unaware if there's a restriction on
the length of comment that is allowed to be posted through this
process, and as such if need be I will re-send it in short form with a
URL to the full comment so that any party, legal, or otherwise can
view it in full, should this be an issue and my comments are only
half, more, or less posted.

It is my hope that ICANN will listen, if not to me but to the direct
experiences of other customers and then work towards a solution; so
that I and other customers who have paid for access to our domain's,
and the end product will finally be able to realize its potential as a
mandatory integrated tool into wider infrastructure services, and reap
the beneficial networking rewards, and or other uses thereof.

Disclaimer: I'm not acting as a representative of the tel community or
as a developer of tel domains, nor will I receive any payments or
anything else for suggesting anything below other than access to an
improved service. I use my domains for myself and for my own reasons,
and of which are in a raw proxy state, and I suggest the next
statements as a way they can re-engage with the dot tel community and
its developers, but this is merely the opinion of one registrant.

To start I do not believe Telnic should be allowed to renew (at least
in their current form) on the basis of their track record, and that I
believe they no longer have a vision that sits with their end
customers requirements other than opening the extension up to a
degree, and of which is too little too late, as by this point anyone
who takes over the extension can open it up. I also believe Telnic
hold a position that is not able to beacon the technology community
and its associated industries to take the domain extension seriously;
for marketing and core service internet infrastructure / developmental
integration and other use cases.

If this is because of 3rd parties, ICANN restrictions, or because it's
their own ethos or a combination of both, or even if its because of
other reasons they need to be transparent about it and be backed up by
a professional non-ICANN source for us to believe them, as we have
lost faith in their entrepreneurship and reputation, and as there are
many technical and legal documents generated as part of this process
it is hard for an end registrant to understand the limitations of the
end product they can receive from Telnic compared to other
high-quality and sometimes free 3rd party services. The first issue
ICANN should tackle is the trust the community lacks in TELNIC and
ICANN to turn this implementation into a satisfactory extension and
end product, as over many years the community has complained to ICANN
through social media as well as shared their frustrations and views
through teltalk.org, and I and they may feel our concerns have been
ignored and allowed to fester to a highly negative degree.

Also while public / open comments are nice and just for the
transparency of process, it does not allow customers every opportunity
to express their true feelings without the fear of being sued, and as
such I question ICANNs intent when only allowing public comments, and
not also allowing private ones to protect registrants from legal
issues or commissioning surveys directed at actual whois registrants
to ensure a full balance of responses is achieved.

If hypothetically Telnic was allowed to renew I at bare minimum would
hope to see them forced to change their company from a for-profit
limited company into a non-profit limited by guarantee, but ideally
Telnic should be separated from the direct management side, and ICANN
should set up a committee and a UK CIC to administer and develop the
extension with (non-dividend unpaid) directors chosen by ICANN
professionals, as well as mandate actual customers of whom used to be
developers and have now left due to their own perceptions of e.g.
"being up against a brick wall" to come back and be honorary or full
directors; to help guide this extension and the end product to the
betterment of the tel community.

This may give rise to some conflict's of interest and as such certain
aspects of voting on certain policy's and implementations would have
to be restricted, e.g some subjects should be restricted from
developers being able to vote on them, while others would fully
embrace their vote as well as that of all registrants through the
control panel, but I believe a balance could be struck.

If Telnic agreed to be separated from the direct management side they
can still be involved as technical support (paid fees), and as they
(Telnic) allegedly hold patents for the system of storage and
retrieval e.t.c and this could potentially allow Telnic (for profit in
its current form) to receive payments for the continued implemented
usage of them by the non-profit / CIC? and so they would be able to
recover their initial investments over a long period but it would
provide the "under new management" team with a better reputation as
well as ensure they talk to and develop alongside the community as its
a community interest company.

Being a CIC would ensure a majority of the profits and fees made from
this extension stay in the company other than for wages, reasonable
expenses, 3rd party fees, bills, and patent use payments, and would
ensure improvement and modernization of the template and
infrastructure, and that ultimately the extension works toward the
best interests of itself and the community that the extension was
meant to support.

Now on to something else, I would also like to see a dot tel reverse
amnesty program so that developers who have left and dropped their
domain portfolios, and of whom can prove they owned particular ones
can get them back (if available for registration) or an equivalent dot
tel/tels of their choice re-registered for free. This would be on the
basis and conditions of being free for one year, and that they can't
re-sell them for four years if they continue to renew them thereafter
one year, and must be an active developing member of the community
throughout each year.

I would also expect ICANN to waive their fees on these domains for the
respective periods, and to follow on with a reduced renewal price for
year two to four but only for those still active as directors and
developers making policy, community, and template improvements, as
this is an extension that has been heavily invested in with the time
and money of many companies, registrant's and investors, and of whom
deserve the opportunity to restart their developments and recover
their losses and so getting them back involved must be a priority also
on the basis of they are the only ones who have really tried to make
the product better other than Telnic staff developing a service
through Telnames.

Being able to recover losses does not always happen in the real world
as its hard to recover investments once you make a loss, but doing
this would aim to repair the relationship between the extension and
the rightly disgruntled developers who have lost unfathomable amounts
of money, this would directly give the extension a fighting chance and
ensure all owners of tel domains own a world class digital product for
their intended use thereof, and are not stuck with an alleged
decrepit, underdeveloped and outdated service that is at risk of
disappearing from the Internet, or a huge loss of investment that
breeds negativity far outside the confines of the dot tel community.

Sharing a tel URL with a customer, with anyone else and or for any
purpose should not be an embarrassment, it should be understood as
being used as a refined and integrated tool that is fit for purpose
and has the theming abilities and implementations that make it stand
out as Telnames did but with more content. To this end I also would
like to see the template process opened up to the public so that
anyone may sign up for it as long as they own a tel and can develop
within its framework, much like with normal web stores that sell
templates and themes, but this should all be done through the control
panel, and that the community (using control panel login) can then
vote and approve each and every integration or policy change
(democracy in action, but should only register one vote per Tel, one
per whois user), and of which should be searchable in the control
panel by the end registrant, and of whom can make a purchase through
it thus providing the developers of the theme with income and ensuring
the continued modernization and development of the templates, as well
as providing the non-profit / CIC with a small fee on each and every

This will increase bandwidth costs and will produce other indirect
costings as it did with Telnames but if done correctly it should bring
it in line with what a customer expects from a 2016 web product,
Telnic staff have tried to do many improvements e.g the Telnames theme
and control panel integration's, but outside of this (and china locked
proxies) it has been proven over time to those who are watching and
using the products that domain registrars will not invest in or
develop anything tel related for their customers, other than when
legal requirements are placed upon them to do so, and this is why dot
tel developers must be helped to come back to restart their
developments and repair the community.

The most I have seen registrars do other than host the control panels
is the most basic integration with their own website for the purpose
of sale, adding HTML URLs and adding small sections to their website
are not real developments but merely minor administrative in function
and is about as far as they will go bare a few other minor
administration aspects, even when a registrar (unnamed for legal
reasons) of whom was the first to become the no-1 tel registrar (much
publicised by themselves) and as such held the most dot Tel customers,
which generated the most dot tel income from them because of the price
they were sold at, would itself never run a proxy, or upgrade and
modify the control beyond what Telnic released and when repetitively
asked to do so by customers like myself have found an unjust brick
wall put up in respect of any request or comment, and as such this is
perhaps indicative of profiteering while avoiding anything to do with
the actual improvements their customers (of whom I was one) requested
or needed.

If this unnamed registrar was themselves running their own web hosting
service as an add-on to selling other types of extensions, do you
think they would not make improvements to their own service to keep
their customers happy, and to ensure they keep renewing the domains?
so just because Telnic releases a basic control panel and makes minor
adjustments to it over time, is this really an excuse to not re-invest
profits taken for doing nothing back into the control panel or into a
proxy of their own, so as to help retain their no-1 tel status and
keep their customers happy? or do they not even care what they sell?
or why, as long as the good times roll on?

This is also not to say the subsequent registrar I moved to (unnamed
for legal reasons) did not look into making improvements, and has
corresponded with me but has never followed up with me or followed up
with another party to a satisfactory degree (why is this?), is this
again indicative of a lack of interest and a desire to let Telnic do
all the work? and themselves only do what is legally required of them
to resell and make a profit, or is this because of Telnic not letting
them partner up? or because they have some ethos or company policies
that prevent anyone who has tried to do something from actually doing
it. Whatever it is that is causing issues its not acceptable to let it
go on and on for years on end, while Telnic themselves appear to have
sunk to a degree of not wanting to invest in any more developments in
the much used basic proxy, they may not even be able to afford to and
so this is another issue that we need to ask, why are these people
still employed at Telnic if they now don't do enough to make this a
success?, if they are burned out from trying to deal with this, is it
not another reason for ICANN to get a fresh management team involved?

This is why I think a non-profit aspect should be implemented in the
extensions administration as a core feature, and registrars should be
stripped of the ability to host and run the control panel or any proxy
as it does not really work as a business model in the long run, this
is regardless of Telnics short term Chinese proxy investment boost.
There should be a single central control panel that is administrated
by a non-profit entity with the ability and legal mandate to integrate
and upgrade it, and of one we can donate to for such improvements, and
of which is allowed to take and transfer the fees, payments, and other
such monetary payments to be given to those 3rd parties who develop
within it, and I believe that ICANN should mandate (if it can do so)
the resale of the updated control panel that used to belong to
Telnames, and that it should be transferred to this new administrative
body so as to be able to build upon it and make it a world class

Putting the olive branch aside, while the back-end underlying service
is somewhat fit for purpose as hinted to above, many perhaps like
myself e.g others in the dot tel community may feel the front end is
not fit for purpose, and never has been other than in a partial state
when Telnames existed for a few years as a 2-3rd party expensive
service, many who have used dot tel via both proxies want to do so in
ways that were not intended by Telnic / ICANN or many like myself want
it to naturally expand it's usage capabilities but can't convince
Telnic / ICANN to lift some of the restrictions that are in place, and
we cannot convince them and you to take on development costs for the
betterment of the communities registrants and the wider Internet data
service industry, though Telnames may have been born based on the
needs of registrants it was unsatisfactorily implemented beyond it's
control panel and theme with too many restrictions on content and
service, and if this was an attempt to convey ICANN restrictions to
its wider customer base who like me cried out for more development by
making explorative developments within the restrictions, it shows more
so that due to its failure ICANN must lift as many of these
restrictions as it can to prevent further failures of any service tied
into dot tel.

To follow on many of us and over the years this extension has been
administrated are now blocked via email or blocked on social media
networks by Telnic and their employee's accounts, and we have
allegedly been internally branded as "trolls" all because we
passionately wanted to provide feedback on the product's we paid for
but Telnic are unable to deal with the ferocious feedback and
complaints about their quality of service and other ongoing issues, we
are not playing the victim card in this situation but both parties
hold opposing views on how it should be administrated and what should
be developed, yet we're the party that paid the long term fees to
them, and who will continue to do so if ICANN does not choose another
company, and it is us who will actively use the product, and it is us
who should hold more sway over this process and its developmental
aspirations, as in reality it is a community-based extension due to
the end product being a sharing based networking tool / asset / DNS
database, it's not just open-ended and barebones extension as with
most of the other ICANN approved additions on offer, it comes with
customer needs, desires and the natural evolution required of any
product to be competitive with other respective services on price,
design, and implementation.

If we the registrant stop paying our fees like many of Telnics end
customers are doing so now by a gradual reduction in ownership, Telnic
will no longer be able to pay those fees on this extension to ICANN
and the extension will collapse, this is a great travesty of their
community / customer miss management of a relationship that transcends
3rd party domain registrars, dot tel is unlike most other extensions
that do not impact on the end registrant significantly, this extension
has an end service intention and customers should be listened to and
be provided for as they are impacted by a lack of investment, and a
poor quality template / service as well as high fees on occasion
depending on what proxy they purchased into and through whom they
purchased, as well as directly impacted by those who manage it or lack

The way Telnic might now might designate its end customers to be the
domains registrars themselves and not the actual end customers who use
the product, might be another reason why this domain is slowly dying,
as domain registrars are not interested in passing on feedback or
doing Telnic's developmental work (as stated above), or in running
their own proxy or upgrading the essentially open source control panel
to be more user friendly (as stated above), and neither is Telnic
beyond minor fixes regardless of what they state publicly and legally
vs the failure of Telnames, because if they really wanted to make
Telnames a success when they attempted to run this semi-independent
proxy themselves why did they restrict it to one page? and not even
attempt to squeeze deeper search and multilayer data aspects into it?
did pride override customer requests and needs for more pages? though
some requests were granted but not all were and pushing for one page
(to reduce costs?) might have killed it off along with the price, as
well as their reluctance to develop what is naturally a networking
tool into a stand alone control panel based social network wrapped
around the DNS contact data.

And so Telnames which was owned by a Telnic staff member could have
then chosen to sell its upgraded control panel and template to Telnic
and integrated it into the core service, and it didn't do so, is this
perhaps for legal reasons? or because it would break their ethos?
because of shame? or perhaps it's because Telnic wants to continue to
follow the failed policy of 2nd/3rd/4th party proxy hosting, and so
perhaps in light of this it would prevent future fees from partners
who would pay them to Telnic to run their own proxy, and of whom we
can see currently and historically can't and won't invest in their
proxy beyond a minor amount, but will charge high fees to their
customers thus resulting in a cycle of degradation and what appears to
be an end customer base abuse.

Perhaps it would not be as frustrating if the community support
employee specifically taken on to mediate with us had not left Telnic
far too soon after its public trading really began (selling dot tel
domains through registrars), and as such was replaced by the founders
and developers; they are hearing some of the direct community
aspirations that don't fit in with their end vision and are rejecting
them outright, while still holding onto an outdated vision, this is
causing this extension to die off.

Furthermore while Telnic did take on some of the aspiration's of their
end registrants through Telnames (as stated above, but not all needed
and requested) the fact it failed as a proxy product just goes to show
that they can produce a high-quality template but can not convince
industry leaders and technology professionals to take the domain
seriously, or even get people to buy it, and certainly can not get
them to integrate and merge it with new and popular services, they
themselves seem to just prefer linking to external services and
technically we're far beyond basic HTML hyperlinks in expectations on
any product that is expected to compete and thrive in a marketplace of
ideas, it should have evolved into a social network as that is what a
business card is for.

I have also not yet taken a customer satisfaction survey about this
end product and I believe neither has anyone else who is or has been a
registrant, neither have I witnessed much bulk interaction that one
might be a custom to take part in when one owns the temporary long
term rental of an end product, what I'm saying is as a long term
customer with multiple dot tel domains I have not seen any industry
standard way of them gathering mass feedback, other than the forum
they once ran and then dumped not long before the renewal date of this
extension in favour of an email based one, this old forum got dumped
to Teltalk.org which was a graceful act on their behalf, but ideally
they should have converted or archived all the old forum
correspondence and kept it publicly hosted, searchable and linked to
Telnic, and not just for legal reasons but because teltalk.org is
allegedly customer owned and not staff / Telnic owned, and all
comments from customers are important and should be acted on if able
to do so at any time their business limitations and opportunities

Furthermore in the past the speculative numbers of potential sale
units that was submitted in the initial bid to operate this extension
are and were demonstrated to be a fantasy, and as such are completely
unattainable in the past, and are unattainable in the current digital
climate with the extensions restrictions enacted in its current form,
this especially with a company that is competing with many free
services, apps, mobile integrated services and algorithms that don't
need the infrastructure and the outlay costs this extension has
developed around while trying to stick to an outdated vision.

They also seem to not have the staff to implement any significant
development that we the registrant need to overhaul the extension, and
appear not to want to or can't hire anyone else (not to say they
won't), they do not have a dedicated staff member to provide feedback
to who is not a member of the original team, and can not implement a
community support network other than this total control email forum
where they can decide who gets to comment, staff are believed to be
only willing and able to make very small minor adjustments and hot
fixes, they also have allegedly burnt bridges with industry leaders,
services and end customers and so are very unlikely to be able to
re-invest in development, marketing, and support of the domain
extension and the community surrounding it for the period the renewal
covers, regardless of what new numbers are put forward in this renewal

And while for now they may have formed what many end customers may see
as short term partnerships with companies in China, and have generated
some income from this to support their financial position's; which may
make their bid for renewal more appealing to ICANN, this is not a long
term solution anymore as partners are not living up to their end of
the deal and de-investing at every opportunity when they perhaps come
up against these metaphorical and legal developmental restrictions, or
are just outright not investing in their theme and are trying to
charge large fees on the back of the dot tel infrastructure as if that
in is own right is worth the cost of ownership, the community has
witnessed mass dumps of domains as a consequence of these partners
disappearing for one reason or another, as well as because of Telnics
policies on development and customer support, and attempts so far to
create these partnership templates has resulted in a watering down of
the quality of service for the end registrant while some have tried to
charge exorbitant fees to their end registrants / businesses (as
stated above), and in a way could be seen to be an abuse of the
service as currently implemented by external partners to rake in
investment while not investing in the actual front end product beyond
a minuscule amount.

As mentioned previously so far only the Telnames development (now sold
off and alleged to be redundant) has been of the quality the current
registrant base is crying out for as a front end product, but came
with back end restriction's we did not want and of which they would
not remove, and all other partners attempting to develop themes /
templates as mentioned above has been underfunded and of such low
quality compared to the prior Telnames investment's that it could
almost be seen as an insult to their end customers to try to market
and sell such a low-quality product, though while we all recognise
that there is significant cost's in running a proxy and bandwidth
costs for assets do add up the more customers you have to manage, many
of us are willing to pay a more reasonable fee should we get the
services the domain extension require's to be a success, but many like
me may feel the Telnames fee was too high a price for the rendering of
only one page and so many of us have just dropped them in favour of
the basic proxy, which ultimately probably also lead to its collapse.

While I don't speak for the community (they can do so on Teltalk.org
or here) I feel there are many ways to retain this one page ethos but
still provide deeper data storage and retrieval, it's just a case of
recognising and developing within the restrictions and providing a UI
capable of meeting the communities needs, unfortunately Telnic appears
to be unable to see how to integrate and develop beyond these Telnic /
ICANN restrictions and or those of their own bottom line, and so we
now end up with low-quality front end product's from multiple proxy
vendors, and an underutilized back end product that is burning
registrant fees, while not providing a high quality of service to the
end registrant, this coupled with the inability of the end registrant
to know how to use the domain / service, what it's really for, and how
to provide feedback in ways that get acted on (pretty much impossible
now) and not rejected outright (a majority are) is a major long-term
problem that needs resolving.

On to Business cards, they are in themselves are a form of offline
social network and Telnics attempt to digitise our business card /
profiles and to integrate them with our digital personas has been
poorly understood by themselves, partners, and tragically the end
customers who find themselves paying fee's that they feel are being
wasted on an unworthy and in incomprehensible low-quality end product.
While the designation of this extension is the storing and sharing of
phone numbers and other social metadata? it's really a digital
business/persona/asset directory card which I feel qualifies it to
naturally evolve into a full core service with a social network in its
own right, and Telnic and or ICANN's refusal to see or implement
anything more than the accumulation of URL links and minor metadata
has hampered its reach and potential growth.

Telnic in the past has outright refused to develop their supporting
private access system and other services supporting the proxy into a
social network, all the pieces are available and yet they restrict it
rather than grow it, why this is should be for Telnic to explain to a
panel of industry peers, I personally don't feel a company who shoots
themselves in the foot and actively works to ignore customers should
be allowed to continue to manage a domain extension like this, and so
it's time to retire Telnic's administration duties (while maybe
allowing them to still take on technical fees) and transfer it to a
new community interest company with a mandate to develop, expand, and
integrate to help ensure all registrants, be it if you're a business,
personal, or any other user has the tools they need to market, share
and retain a network at a reasonable price, and this can be utilized
as a fit for purpose digital business card / directory / persona point
of contact, that transcends services and is a primary integrated core
service of Internet interaction.

An example of expanding this service means innovations like, including
a full 3D avatar generated from an uploaded photo or taken from
another source (as file links in the DNS) that then becomes a set
storage, lookup, and transfer standard for importing and sharing
personal personas and corporate representative branding avatars
between many technical, gaming and media services, there are many more
simple improvements Telnic should have made and many technical hurdles
to overcome, but development should never stop as this is in direct
competition with so many other products and of which are operating at
a lower cost and are a much higher quality appealing product, and so
this must excel at what it does and provide something out of the box
that keeps registrants updating it and using it through many
integrated services.

In conclusion I feel that ICANN and Telnic are holding this extension
hostage with some of the alleged restrictions on development,
policies, their companies ethos and management structure, while the
community who use it want it to flourish for data storage and other
point of contact usage interests, and so it would be desirable from a
community point of view that Telnic should not be allowed to renew and
ICANN develop a UK CIC, a non-profit community interest company with a
board of technology professionals who are able to listen and guide the
extension to being a fit for community purpose service, and allow it
to become a social tool developed into a world-class integrated
digital product, it is also very important to ensure any money gets
heavily reinvested in the communities aspirations not least of
personification, networking and development, and that any management
issues and egos do not hold up this extension's future developments.

A full investigation should be conducted, you will find many
complaints and issues on http://www.teltalk.org/ as well as historic
data from actual registrants, and you should pool the email contacts
from historic and current whois data, so that they can be contacted
and surveyed so you can see what they actually need and want, as this
open feedback is not fit for purpose due to it not being able to reach
the end registrant of dot tels, and Telnic is not and will not
publicise it to its end customer base.

This means feedback will only come from sources like me and others who
use teltalk.org, but all registrants need to be contacted and given
the opportunity to respond even if its just a locked email poll or
survey, other opportunities and ways to comment are important because
it's also unlikely they will want to publicly comment here due to the
threat of being sued by Telnic so more opportunities to respond
without legal issues is desirable, though I see some like me have
thrown caution to the wind and laid it all bare.

I appreciate your time in reading this and I don't expect a response
other than a great outcome for dot tel.


Jonathan Curley


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