Register.com's Submission to ICANN's Public Forum on sTLD applications
- To: <stld-rfp-general@xxxxxxxxx>
- Subject: Register.com's Submission to ICANN's Public Forum on sTLD applications
- From: "Elana Broitman" <ebroitman@xxxxxxxxxxxx>
- Date: Fri, 30 Apr 2004 14:40:31 -0400
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
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.
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