Register.com's Submission to ICANN's Public Forum on sTLD applications

["Elana Broitman" <ebroitman@xxxxxxxxxxxx>]

As one of the oldest and largest ICANN accredited registrars, Register.com 
appreciates the opportunity to share its long-term perspective regarding these 
registry applicants.  We believe that healthy registrars and registries, 
competition, consumer protection and stability are the foremost considerations 
for a vibrant domain name industry that addresses registrants' needs.  New 
domains should only be added if they are consistent with these goals, and below 
are the key factors to consider in order to ensure that they would:

        1.      All global and sponsored TLDs must be offered solely through 
ICANN Accredited Registrars.  Registrars have experience with, and therefore 
understand, registrants' needs.  Moreover, Registrars operate pursuant to 
contractual requirements established to protect registrants, intellectual 
property owners, and other stakeholders.  Therefore, it is in the best 
interests of ICANN and its stakeholders to require that domain names be 
registered solely through ICANN Accredited Registrars.
                        o       The one exception to this rule may be in cases 
of an sTLD intended to serve a very small community, which is very well defined 
and pre-screened, and which would not otherwise be served by ICANN registrars.  
In such a case, additional registration channels that uniquely serve an sTLD's 
community may be added to ICANN registrars.  
                        o       However, even in such cases, the additional 
registration authorities must be required to comply with the appropriate 
requirements and equivalent fee obligations on par with registrars.  
Furthermore if an sTLD's market size grows beyond a small community of users, 
such additional registration authorities must become accredited.

        2.      ICANN should approve those business proposals that support the 
growth of a vibrant, competitive domain name industry.  Industry growth 
requires stable, healthy companies with reasonable margins that allow them to 
adhere to ICANN requirements, provide innovation and protect their customers.  
New registries should frame their business plans with a view toward promoting 
such healthy registrars, rather than fostering a race to the bottom, which only 
cuts out the ability of the industry to satisfy the requirements of the ICANN 
community. 

        3.      The new sTLDs must utilize robust, redundant, and reliable 
technology platforms and set up mechanisms that help to protect registrants 
from the impact of registry failure.  

        4.      The new sTLD registries must roll out technology platforms that 
comply with current IETF standards and protocols, so that they do not increase 
the burden for registrars' systems.  In fact, ICANN should encourage the new 
registries to coordinate testing, pre-registration, and launch schedules in 
order to minimize the burden on registrars.

        5.      This is an opportunity for ICANN to advance to a fairer funding 
model where registries match registrars' share of support for ICANN.  The new 
sTLDs must be required to pay set registry fees - at a level that makes 
registries comparable to registrars - and variable fees on registry services - 
which are not passed to registrars or registrants.

        6.      New sTLDs must provide a pre-registration period during which 
time ICANN accredited registrars would be eligible to register their company 
names in the new domains in order to protect their brands, comparable to the 
provision in the last set of registry contracts. 



Elana Broitman
Register.com
575 Eighth Avenue
New York, NY 10018
Phone (212) 798-9215
> EFax  (800) 886-2716
Fax   (212) 629-9309
ebroitman@xxxxxxxxxxxx