VeriSign Comments re: .net applications

["McLaughlin, Mark" <MMcLaughlin@xxxxxxxxxxxx>]

VeriSign is very proud of our service delivery record and the strong value
we are proposing for .net. We welcome all questions, verifications and
potential performance testing of our registry offerings. I wanted to briefly
respond to some other posted comments as a matter of factual accuracy.

 

NeuStar WNP Ambiguity

In a post by NeuStar on 3 February 2005, NeuStar provided a description of
the launch of wireless number portability and took partial responsibility
for the service disruptions. This posting was a response to VeriSign's
application which highlighted these service problems. The references in
Section 8 [again, those references include: Richard J. Dalton Jr., "Cell
phone users find change is slow; Switching carriers but not number isn't so
quick," The Kansas City Star, December 28, 2003 and Tricia Duryee, "AT&T
Wireless lists issues causing switching problems," The Seattle Times,
December 11, 2003] are but 2 examples of dozens of articles which chronicled
the prolonged problems with the service launch of wireless number
portability. To add further clarification, a complaint [letter from Douglas
I. Brandon, AT&T Wireless to John B. Muleta, Chief, Wireless
Telecommunications Bureau, Federal Communications Commission on December 10,
2003] clarified the problems encountered with Nightfire (a subsidiary of
NeuStar) that

 

"...produced delays in each of the steps of the intercarrier communications
process... creating a considerable backlog of port-out requests.
Specifically, Nightfire took too long to verify and submit the port requests
to AWS for customer validation. Further, due to these processing delays, AWS
routinely responded to the port requests after "due date" and "time" of the
port request had expired, which in turn resulted in the system generating a
"resolution required - due date expired" response... The system also delayed
transmitting these responses back to the requesting carriers. Compounding
the delayed ports was the fact that the Nightfire workflow management tool
used by AWS' Porting Administration Group representatives to resolve errors
would either freeze or crash, causing additional delays in resolving the
backlog problems." 

 

This clarification underscores the importance of integrity in the operation
of a registry as critical as .net. Specifically, 2 keys issues must be
considered:

1.       The validity of all claims made in the applications should be
independently verified through consistent testing, research and historical
analysis. This should extend to subcontractors in the event the Applicant of
record does not perform registration or resolution activities.

2.       The commitment of the Applicants, or where applicable, the parent
organizations, to dedicate requisite resources and oversight to all lines of
business, regardless of the entities status as an acquisition or joint
venture, and take full responsibility for any subsidiaries actions.

 

Given the critical nature of .net, these types of potential problems with
service delivery by an Applicant or affiliated party providing services for
the Applicant would have a severe, negative impact on service. With a
responsibility for supporting over $1.4 million in eCommerce each minute, no
interruption, errors or delays can be accepted.

 

 

DENIC Clarifications

Response to the comments from DENIC are addressed in order:

 

*       Registrar support.  The latest Registry Operator Monthly Report
posted is October 2004 at
http://www.icann.org/tlds/monthly-reports/com-net/verisign-200410.pdf
<http://www.icann.org/tlds/monthly-reports/com-net/verisign-200410.pdf> . As
the October 2004 report states, there were 252 .net registrars (of these,
249 had active .net registrations).  Additionally, there were 56 registrars
in ramp-up and 90 in pre-ramp-up, bringing the total number of registrars
supported to 398. Of DENIC's 216 registrars, roughly 20 are
ICANN-Accredited. Thus, in addition to the 216 .de registrars, if DENIC were
to operate .net, they would need to support 378 additional registrars. This
brings the total number of registrars requiring support for .de and .net to
594 (based on October 2004 statistics). Based on DENIC's posting of 4
February 2005, they can support up to 500 registrars. Thus, the volume as of
October exceeds DENIC's planned capacity. Growth of .de and .net registrars
from October through June will also add to DENIC's capacity deficit.

*       System outages and reliability. Currently, .net provides near
real-time registrations. DENIC's SRS expertise is limited to asynchronous
registration systems (not real-time). Therefore, DENIC does not have a
history of registration performance supporting the scalability and response
time requirements consistent with current .net performance. Any transition
should consider potential performance impacts as a result of limited
experience.

*       Name server locations. According to domain server listings with
IANA, the number of .de DNS sites has dropped from 11 (what is stated in the
application) to 6. DENIC's application also claims that they will have 14
sites by June with 19 by December. This is a very aggressive target.
Coordination for a typical site, including site selection, facilities,
equipment, installation, testing, and monitoring takes many months per site.
DENIC should provide detailed plans for how they will accomplish these tasks
in that timeframe.

 

 

VeriSign is very proud of our service delivery record and the strong value
we are proposing for .net.

The .net registry supports over 58% of the world's hosts, and over $700
million in eCommerce and 155 billion emails each year. This critical service
is delivered through VeriSign's proven, secure, stable and scalable registry
infrastructure. Dozens of international corporations - including registrars,
technology firms, and telecommunications providers - understand this
importance. These groups support VeriSign's performance record and endorse
our continued administration of .net; a full rendering of endorsements can
be found at: www.verisign.com/nds <http://www.verisign.com/nds> . 

 

VeriSign's proposal represents the most technically robust application for
.net:

*       Leading performance commitments (including 100 percent resolution
availability, 100 percent Whois availability and 99.99 percent SRS
availability) and the most strict SLAs

*       Expanding the .net infrastructure from 7 countries and 13 locations
to 12 countries and 18 locations

*       Comprehensive system and Internet monitoring through our "Heads-Up
Display" monitoring tool

*       Continued efforts to increase competition in domain name
registration with a variety of marketing tools, global expansion, and
additional feature functionality

*       24x7 customer support in 150 languages

*       On-call account management staff for registrars and in-country
account and office support in the U.S., Latin America, Australia, Germany,
U.K., Japan, Korea and China

*       On-going support for 9 technology pilots.

 

We are proud to offer this comprehensive service offering at the greatest
value of any applicant.

 

            Regards,

            Mark McLaughlin

            General Manager, VeriSign Naming and Directory Service