mTLD applicants response to comments
- To: <stld-rfp-mobi@xxxxxxxxx>
- Subject: mTLD applicants response to comments
- From: <ritva.siren@xxxxxxxxx>
- Date: Thu, 29 Apr 2004 22:02:33 +0300
- Thread-index: AcQuHIaV6ptiJuN4Q+KZX0C1dZVQbw==
- Thread-topic: mTLD applicants response to comments
Concern # 1 - mTLD a walled garden with heavy restrictions
mTLD uses existing Internet standards and protocols. It is intended to
bridge the Internet, its existing web sites, and its technologies to a
mobile experience - not create a mobile Internet that is separate and
exceptionally restricted in connections with the Internet. mTLD doesn't
limit the functionality of the new domain except as required by ICANN,
i.e. use of names need to be connected to a mobile experience. Like with
current Internet ISPs and other service providers, some registrants of
.mobi may have limitations, but that's not something which mTLD registry
can rule. The provision of services for mTLD will assume access to/from
services of other TLDs as well. The content and services from those
domains can be tailored in their existing backend servers to consider
mobile limitations (i.e., screen sizes, navigation, etc) by using content
adaptation technologies. In this use case, the additional mTLD name serves
as a visible indication to end-users that adaptation for mobile use has
been done, while continuing to provide the brand value of the SLD
content/service provider (i.e., Mapquest will retain its brand position
regardless of whether it is followed by .com or .mobi). Many companies
offer adaptation technologies, including some of the mTLD investors;
however we don't see any conflict of interest. Having a mobile TLD,
content providers can choose between methods of service provisioning
making it possible for less sophisticated content developers and web
servers to also succeed with mobile content offerings. mTLD also gives an
end-user a choice to download unadapted content that targets PC users.
With adaptation alone that is not possible.
The sponsoring investors have no interest in limiting the registrations in
the TLD further than what is required by ICANN ruling to stay within the
defined business area. Small businesses have at least an equal possibility
to register names in the TLD as the big ones and the pricing of the SLDs
for the small entities is planned to be in the current regular price level.
Additionally, most of the sales of these names are expected to happen through
ICANN accredited registrars.
Concern #2 - mTLD a monopoly of Microsoft, Nokia and Vodafone
The companies who have invested in the mTLD effort have been especially
careful to ensure that none of the participants, not even founders combined,
could have a dominating or controlling position in the registry. We felt so
strongly about this that the governance model for the JV company states that
none of the industry groups, - 1) mobile operators, 2) mobile vendors and
3) mobile content providers - can have a dominant position in the company.
We included provisions that extend into covering potential future cases like
the selling of shares, mergers of the investing companies, etc.
Concern # 3 - Antitrust issues
The Mobi JV will be located within the EU and as such will strictly adhere
to the antitrust and corporate ethics as well as transparency required and
expected in the EU. Many of the investors are multinational companies in
the JV and are aware of and follow the antitrust regulation of different
parts of the world. Furthermore, the applicants don't seek control for the
mTLD registry or for themselves of the end to end process of mobile
naming. Our application asks for only a capability to develop mobile
communication and mobile businesses towards being part of the
Internet in a functional, meaningful way, thus allowing mobile
subscribers, using whatever wireless access technology they choose, to
enjoy, and benefit from the broader communications and service
capabilities that exist in the Internet. We see a large opportunity for
better, more predictable and entirely new types of services that the names
in the mTLD could be used for.
Concern # 4 - Business volume
mTLD addresses a market with huge long term potential. However, both
Internet capable mobile devices and services targeting these
devices are just emerging. Therefore, it will take some time before the
market can fully benefit and use the full extent of the possible mTLD
features and services. That applies to the situation in both the
traditional mobile telecommunications services and new mobile services
based on unlicensed or unregulated wireless access. The application only
covers the time up to 2008. We expect significant mass-market growth to
begin closer to the end of this decade, i.e. after the period defined in
the application. Critical to that growth are a number of things including
the development and availability of solutions, establishing roaming
agreements for new services, etc. To get these items in place we need to
start now and that requires as a component the existence of the mTLD.
Investors have discussed how potential future profits will be used. The
consensus is, that investors themselves target only payback of their
investment with very modest interest with the rest of the profit being
reinvested in the business to foster further innovation and enhance mobile
business possibilities in different parts of the world. Developing
countries in particular have been mentioned.
Concern # 5 - Registrars bypassed
SLD name sales in mTLD are expected to follow the current business
practices for ICANN accredited registrars. The mTLD coalition will
actively seek support from registrars and hopes that as many as possible
will use the significant additional opportunity and start selling names in
the mTLD. Some mobile operators may also see a business opportunity in
selling names to their subscribers. They would have the choice of
becoming an ICANN Approved registrar but many of them will feel more
comfortable in buying these services from established and experienced
Just as today's Internet subscribers very often have a name under the
domain of their service provider, we see the same evolution likely in
the mobile name space. mTLD is also planning to enable portability for
names as has recently been mandated by regulators for phone number
portability in many countries. We feel that being proactive about this
flexibility is important for end user adoption.
The amount of generic names that will be reserved for auctioning or
bidding will be limited. The main reason for the reservations is
not to primarily financially benefit the registry but rather to provide
valuable names to real service providers by decreasing the possibility
of cyber squatting.
The auctioning principles and the associated pricing policy that goes
with it will be defined to ensure that 1) the SLD registrant has
financing sufficient to support these services and 2) it's in the
interest of the buyer to offer services and not just reserve the
name for later reselling. The potential downside to registrars from
these reservations is minimal compared to the incremental revenue
potential from name sales in a new large TLD.
Concern # 6 - Outsourcing the service as an indication of lack of interest
ICANN indicated in the RFP a clear preference for outsourcing the service
of new TLDs to an established root service provider. We followed that
advice. Registry business itself is indeed not the main interest of any of
the mTLD coalition applicants. The main reason for the application is to
have a name space for mobile services and subscribers to enhance the
success possibilities of new mobile businesses. The applicants understand,
that real success is possible only by openness and fair treatment of
everybody in the value chain and above all by having end-user accepted
solutions, not by control or a garden-fencing mentality.
We also hope, that the mobile businesses are not forced inside the fences
of the current PC Internet. Mobility does have certain aspects, which do
not exist today in Internet, like e.g. roaming agreements and related
technical and business solutions between operators, which enable
application traffic to traverse across operator boundaries or a visiting
customer to use a foreign network transparently and effortlessly, when
needed. mTLD solutions can build models for true mobility for the wireless
business overall and thus expand the mobile community in Internet.
Concern # 7 - mTLD will thwart the VoIP revolution
There is no reason, why a new independent VoIP operator, which is capable
of providing mobile services couldn't have an SLD within the mTLD. Mobile
means near constant reachability of a mobile node by potential callers and
that will in future include mobile VoIP.
We believe, that there will be VoIP businesses, which are not always
necessarily mobile. Providing VoIP over fixed lines is expected to be
comparably cheap in future. Combinations of fixed and mobile VoIP will
foster various business models from pure mobile service to combinations of
fixed and mobile services to pure fixed service. The mTLD can even
accelerate the development by providing new service naming choices.
Concern # 8 - TLD for an access technology versus TLD for the mobile business and its
Current mobile telecommunication thrives as an independent business
separated from fixed telecommunication even when the owner also has fixed
business. Separation has been required to guarantee independent
development possibilities of both technical and business solutions for
Mobility requires special features, which don't advance well under the
control of regular mainstream business. This can also be seen from the
opposition of some current content providers, who want to believe, that
mobile consumers don't need special attention. In areas, where the mobile
business has been successful, mobile subscribers often have had their own
number space and therefore mobile connectivity is recognizable by caller
on a national level. We can make this recognition of mobility to be global
in the Internet side in the simplest possible way by having a mobile TLD.
Contributing to the success of mobile businesses and end-user value of
mobility are agreements between operators for inter-operability and
roaming, which are not so common in the Internet side, but will be needed
for WLAN business models to succeed.
Concern #9 - TLD for a protocol or because of a screen size not meaningful
The main issue of the mTLD is not to have names for specific nodes or
protocol implementation; the purpose is to have a name space for mobile
businesses. That allows identification of mobile users on a global scale
as well as makes space for new content providers and new business models
while maintaining and even expanding the possibilities of existing ones.
Mere node name indication of mobility doesn't allow new service providers
for already established generic services, like directory.com or news.com.
But rather, it expects current owners of the SLD's to start catering to
mobile needs as well. With the new TLD both the existing players and new
service providers have a fair chance to offer services to the mobile
Mobile handsets will continue to be smaller due to consumer preference
reasons and will continue to have slower processors and less memory than
mainstream PCs at the same point in time. Processor and memory limitations
come mainly from the need to minimize power consumption. Capacity of the
networks and the fact that cost per bit transmitted over the air is higher
are other important factors. Fixed access can always add cables, but we
have only one spectrum and although the wireless technologies will evolve
the capacity gap between wireless and wireline will remain.
Therefore, while ISPs mostly follow flat rate fees, mobile operator
pricing structures vary. At best, some follow a flat rate fee up to a
limit and some operators, already with today's rather limited availability
and use of new services, have had to return back to usage-based pricing.
Consumers need to trust that there will be no massive billing surprises
when they access the Internet while mobile. They also want downloads to
happen fast, which is not always possible with heavy content sites, which
trust on increasing availability of broadband access with capacity in the
megabit/s level for individual users.
The mTLD allows us to indicate, in a visible and globally uniform way,
that adaptations are made, thus building trust to encourage the use of
Equally important aspect in relation of end user naming is by the mTLD
based name indicated message of constant reachability regardless of that
the target may be mobile or that the target capabilities may be more
Concern #10 - Policy formulation for the support organization and lack of
individuals as supporters
The mobile community is a large community, which is the reason why we are
looking at consumer organization representatives rather than individual
consumers to be represented in the Support Organization (SO). However,
there will be a mechanism for the general public to give their input.
A policy will be formulated in cooperation with the to-be-formed MAG
members for interactions between the mTLD registry and the SO. PAG acts as
the board of the SO and thus acts as an interface between the registry and
the SO and other participating organizations. PAG will include invited
members to guarantee consumer organizations influence within the mTLD.
Mobi JV will therefore have strong input and influence both from
businesses and consumers within the mobile community.
Concern #11 - Technical risk of increased load on root and other DNS servers
First, about the use of Dynamic DNS style of naming:
Due to predicted use of Mobile IP and SIP in future mobile services there
is no reason why mTLD would need to have frequent name - address mapping
changes. There are still some inter-networking definitions to be done for
roaming purposes, but the main concerns are the same as for the Internet
as a whole. For mobile businesses it is important that we can consider the
methods of use and reliability of DNS at the same time as other inter-
networking definitions are done, and that's best done under mobile's own
TLD. However, it's already clear that the reliability, response time and
overall root load concerns are at least as important for mobile service
providers as they are for current Internet services. Therefore, mTLD
should not be considered a problem from that viewpoint. The probable
mapping of the node/domain name happens in the home network address level,
and temporary addresses from the visited network do not obviously need to
be named. Therefore, mobile use doesn't create, in that sense, dramatic
additional traffic in the Internet root level.
Furthermore, NOT granting a TLD doesn't "save" the Internet from mobiles,
but can keep the use of Internet by mobiles somewhat inconvenient and can
create far "wilder" approaches to solve mobility requirements.
Other DNS Advantages of the mTLD:
A separate mobile TLD also means that a very large part of the name
resolution traffic remains within that TLD and therefore in fact reduces
the load to the main root. As mobile devices become more prevalent in
society as both clients and servers, as well as in peer-to-peer networks,
a significant portion of the increased traffic will occur between mobile
If second or third level domains in random TLDs are used, the entire
burden of all DNS traffic will fall on the existing DNS infrastructure.
As different mobile providers utilize different domain spaces, there will
indeed be increased traffic on the root and TLD servers. For example, a
device on .Provider_A.com's network may try to lookup a device on
.Provider_B.net's network. All non-cached lookups in this scenario could
potentially traverse the roots.
However, with the mobile having its own TLD, this problem is contained
within the mTLD name space. In this scenario, a device on
.Provider_A.mTLD's network will attempt to contact a device on the
.Provider_B.mTLD's network. In the worst case, Provider_B is typed
incorrectly, and the traffic crosses to the mTLD root servers. The main
root servers in this case are not touched. In most intra-mTLD cases, the
traffic is contained with the mTLD zone. Noting that a second or third
level domain would have the same inherent DNS characteristics when inter-
zone queries are performed, and actually could increase traffic when
mobile devices communicate with each other, therefore the placing of these
mobile devices under the mTLD is a positive step towards the future mobile
As has happened countless times in the past, there will undoubtedly be
technical challenges that arise from a technology shift such as the advent
of mobile communications. These issues need to be addressed in an
organized way by people whose interest is to have new services function
and interoperate with existing services in cooperation with the Internet
community. By adding the mTLD, we bring concerns, which are unique to
this environment to highest possible level, potentially reducing the risks
and the load on the current DNS infrastructure in the future.
On behalf of the mTLD partners
Nokia member in mTLD partnership work