.Pro Proposal Feedback

[andrew campbell <akcampbell@xxxxxxxxxxx>]

I support the proposal to widen the eligibility criteria for .Pro domain 
registration. The current geographical and profession based restrictions are 
unfair and unworkable. My concern is that these proposals fail to aknowledge 
the scale of .Pro's failure and the role uncommercial pricing and profiteering 
has played in that. 

The November 2007 Registry Operator's Report shows just 6,297 .Pro 
registrations. 4,354 of these are registered by Encirca using its proxy service 
and a further 902 are held by Registry.Pro so there are actually only 1,041 
.Pros registered in accordance with the original restrictions. To put that into 
context, on the first day of landrush, .Asia received 266,663 applications. 

Since March 2005, 80% of .Pros have been held via Encirca's proxy service so 
for the vast majority of .Pro registrants, restrictions have not been an issue. 
Hence, easing them is not a cure-all for .Pro's ills.
  
Registry.Pro are contractually obliged to charge registrars $6 for third level 
and $6.50 for second level .Pro's. In reality, they charge $125 and $50 
respectively. This additional mark-up is supposed to cover the cost of bundled 
digital certificates but these are not provided to the majority of .Pro 
registrants. Encirca follows Registry.Pro's lead, marking up the $50 wholesale 
cost to $99 but in the absence of A/V checks the justification for a further 
100% mark up is questionable. 

The $99 .Pro reg fee is ten to twentyfold higher than other gTLD's. This puts 
most people off registering and discriminates against professionals in 
developing countries. ICANN has an obligation to ensure .Pro is affordable for 
qualifying professionals, irrespective of where they work. Until all parties 
involved stop milking .Pro registrants for excessive fees, it will continue to 
languish even if these proposals are approved.  

I would urge ICANN to make one addition to Registry.Pro's proposals;
 
1) Remove the requirement for second level .Pro's to be issued with digital 
certificates. This would slash the wholesale cost of .Pros by 87% and encourage 
take up among bigger registrars. Failing that, unbundle the provision of 
digital certificates so registrants can choose who they buy them from.

Andrew Campbell