Why ICANN should reject .MOBI

["pierceswanson " <pierceswanson@xxxxxxxx>]

While on the surface .MOBI has all the requirements of a potentially acceptable 
application for a sTLD, it is a disguised attempt by Nokia, Microsoft and the mobile 
operators to create a lock on the telecom sector and the mobile Internet, which ICANN 
cannot accept.

1-      Background

In the competitive telecommunications and mobile Internet environment, addressing 
architectures, whether digit or letter based, have a key strategic value for telecom 
service operators: they create a lock on the customer by tying him through his address 
to their services. Because changing an address is cumbersome, time consuming and even 
expensive for the customer, it is a powerful mean to stifle competition.

The coming new order of a letter based addressing architecture, sitting on top of the 
old digit based one, is a major threat to the telecom industry: it breaks the last lock 
between the customer and the service operator and therefore will unleash unprecedented 
competition between telecom operators. With a letter based structure, customers could 
easily change their underlying digit based number, as and when needed. Furthermore, as 
alternative operators benefit from the much lower IP cost base, this new addressing 
architecture could provide them with the long expected opening to compete heads on 
with, and threaten the very existence of the PSTN based traditional operators.


2-      On the face of it, the .MOBI application seems to be a very politically correct 
attempt to please ICANN

It is backed by an array of established companies led by founding members Nokia, 
Microsoft, and Vodafone. It has also the backing of successful companies like Orange, 
TIM and T Mobile, Samsung, Sun, and Hewlett Packard. 

However, it is important to note that many key mobile handset manufacturers as well as 
major operators have decided to not to join this consortium. More importantly, the UMTS 
Forum, which sets out the specifications for the G3 mobile service, has refused to back 
the .mobi application as proposed. 

All in all, this consortium seems to represent a low risk approach to a controversial 
issue: the granting of a telecom related sTLD. However, in practice, this approach 
entails high risks for the Internet community as detailed below.


3-      In fact, this consortium is a typical window dressing exercise to cover up the 
systemic weaknesses of the MobiJV application

What is the purpose of .mobi? The starting point of MobiJV's application focuses on the 
difficulty for users of small screen devices, such as mobile handsets and PDAs, to 
display web sites available today under .COM, a currently slow and cumbersome process. 
MobiJV's response to this issue is to request an sTLD, a sort of "sub.COM", to 
specifically address under .MOBI web sites which have been reformatted by .COM website 
operators to small screen specifications, and which can be easily downloaded on mobile 
phones and PDAs. This is unfortunately a temporary need as mobile bandwidth is being 
extended very quickly. More importantly, this 'tailored' need can be already served by 
the use of adroit server-based compression technology, such as the one promoted by POGO 
in the UK. It currently works even under the slow GSM, as it allows download of .COM 
websites without reformatting at already reasonable speeds and without loss of key 
information. Why should ICANN grant a new sTLD to r
 espond to a temporary need which can already be served? This is clearly not a 
constructive extension of the use of DNS.

Additionally, the MobiJV application raises severe anti-trust issues. It is backed by 2 
companies who control the main operating systems for high end mobile handsets: Nokia 
with Symbian and Microsoft with Windows Mobile. By refusing to make publicly available 
the source code of the application enabling .MOBI on mobile handsets, MobiJV will 
likely restrict its access to its members, thus controlling and overcharging the access 
to mobile services by content providers and ultimately consumers. Needless to say, both 
the US Justice Department and the E.U. anti-trust authorities should quickly 
investigate this issue.

Finally, the Nokia application is dangerous for the Internet as it is trying to break 
its very essence, i.e.: its universal access and open architecture. MobiJV is on course 
to recreating on the Internet the heavily fragmented addressing structure which 
currently exists within the PSTN world by proposing to implement an addressing 
architecture that: (i) is restricted to mobile services, (ii) excludes other forms of 
network access, such as landline, cable, WiFi, satellite, etc? and (iii) uses 
sub-addresses run by mobile operators. It therefore runs contrary to the very essence 
of the Internet, which is to provide universal and transparent access. It also 
recreates the very architecture which has allowed old telecom operators to stifle 
competition, and run afoul of customers interest. 


4-      More troubling is the fact that .MOBI represents an ill-conceived but concerted 
plan by the large mobile operators, led by Nokia, to take over the telecom and mobile 
Internet industry at the expense of the end users.

This cannot be understood without having in mind two revolutions which have started to 
impact the telecom industry: 

(1) Existing handset manufacturers are confronted with evolving business constraints. 
Indeed, differences between manufacturers are being eroded by the cross-fertilization 
and interweaving of technologies: PDA's merge with mobile phones, WiFi-only mobile 
phones are being produced and G2 mobile phones become Wifi and Bluetooth enabled. 
Furthermore, mobile and WiFi software and circuitry are being run on increasingly 
smaller chips produced by other better positioned manufacturers such as Intel.

(2) Existing telecom service operators are also on the verge of a major upheaval. Two 
separate networks are currently competing for telecom services, the 'old' PSTN and the 
'new' Internet, with the main access to the Internet, the so called 'last mile', still 
depending for most customers on the overcharged DSL-improved PSTN link. This situation 
is changing quickly as a number of technologies providing extended bandwidth, the 
so-called 'pipes', have started to compete on the Internet last mile: cable, satellite, 
mobile, Radio, Wifi, electric networks and even TV digital broadcasting. This has three 
major consequences: (i) it is driving pipe prices down, including mobile access prices, 
(ii) it is allowing the low-cost Internet network to progressively become the sole 
conduit for voice, data and video traffic, thus marginalizing overpriced PSTN. For 
example, the PSTN core phone service is currently being driven out of business by Voice 
over IP, whose bandwidth requirements and t
 herefore cost is negligible, and (iii) it is blurring the differences between 
distributors of digital content, breaking up their respective competitive advantage, 
driving down their margins, while improving drastically the bargaining position of 
content producers: music, games, films, and services. 

In such a context, it is not difficult to understand why Nokia has been moving from 
handsets to software, and is now moving from software to mobile services through the 
hopeful control of .MOBI. The .MOBI will act as springboard to control the telecom 
industry and the mobile Internet by creating a lock over third party content providers, 
thus creating a huge competitive advantage over all other network access providers. 


5-        Conclusion

The constituent members supporting .MOBI are entirely mobile driven and only represent 
a segment of the telecom industry. MobiJV's governance is self-serving and more 
importantly, it lacks representation of the end consumer, .MOBI's ultimate community, 
who has the most to loose by this proposal. Control over this new addressing structure 
is too important to place in the hands of Nokia, Microsoft and Vodafone, who will 
likely stifle competition. 

It is the essence of the ICANN mandate to protect the Internet community from such 
predators. As such, the .MOBI application should be rejected. 


--
P. Swanson




















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