mTLD applicants response to comments

[<ritva.siren@xxxxxxxxx>]

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 
registrars.

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 
customers

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 
mobile.

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 
community.

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 
services. 

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 
limited.
 
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 
devices.  
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 
communications.

Conclusion:

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

Ritva Siren
Nokia member in mTLD partnership work