Comments on strategic plan
- To: strategic-plan-comments@xxxxxxxxx
- Subject: Comments on strategic plan
- From: "Ken Ryan " <ken.ryan@xxxxxxxxxxxxx>
- Date: Sat, 26 Feb 2005 04:59:20 +0100
If ICANN's mission is to coordinate the allocation and assignment of (i.e.
make available) a globally unique 'public name space' and numbering system for
the Internet, then your primary customer base is the large group of individuals
and organizations that acquire and use these unique identifiers - not just the
?organizations and individuals who transact directly with ICANN.?
ICANN has always prioritized its stakeholders ? these may include customers but
in many cases they are identifiable as part of a supply chain for delivering
products and services, the unique Internet identifiers, to your primary
With a Government mandate in a growing market, ICANN risks subordinating market
needs to the requirements and desires of your other stakeholders, and
consequently downplaying market mechanisms.
ICANN's second strategic priority is to increase competition and choice in the
domain name market. The number of accredited registrars and resellers has
grown since ICANN was created, resulting in lower consumer costs, but further
increasing competition between registries is more problematical.
In 2000 there were 44 proposals for new generic TLDs; seven new gTLDs were
selected but have not been successful in the market. According to ICANN's
minutes of the Autumn '03 meeting in Tunisia they ?have faced significant
acceptance problems." Your Evaluation of New TLDs of August, '04 reiterates
Based on market reactions to the new gTLDs only 10 proposals were submitted for
expansion TLDs in the most recent round. At that rate of decrease, when will
the concept of increasing registry competition by adding TLDs implode?
If a registry were to fail economically, which is a legitimate risk in a
competitive market, what impact would it have on the stability of the Internet
and the risks that subsequent prospective registries would be willing to
Does a further increase in registries support, or collide with, market demands?
Registration statistics indicate that your primary customer base has already
exercised its choice. Today the .COM top level domain owns 96.9% of all
registrations in the combined .COM/.BIZ name pool and 70.8% of registrations in
the larger name pool including .NET, .ORG, .INFO and .US. In both cases, this
hegemony has increased during the month of February, 2005.
New TLDs may be confusing, suspicious or meaningless for information seekers,
prompting businesses to reject them. While the cost of registering a domain
name has fallen, the addition of new TLDs increases costs for those businesses
that want defensive registrations in multiple TLDs, and sunrise registration
periods limit the number of new domain names actually made available for new
Bottom-up consensus cannot determine what will succeed in the marketplace
unless bottom-up means market based. Is it strange that an expensive secondary
market and wait list system have developed in parallel with the expansion TLDs?
The market is best served when choice is available, of course, and these offer
an alternative, however limited, to the hand-me-down notion of more TLDs.
Does your primary customer base know or care whether ICANN completes the MoU
process with the US DoC, your first 'identified objective from ICANN
stakeholders'? Has your primary customer base shown it prefers namespace
within the traditional TLDs rather than 'efficient introduction of new TLDs to
increase competition in the domain name space', another identified objective?
In a letter dated Jan. 4, 2004, Assistant Secretary Michael Gallagher of the
Department of Commerce wrote to US Senator George Allen of Virginia, with a
copy to Dr. Paul Twomey at ICANN: ?...the Department's position [is] supportive
of the introduction of new Top Level Domains, which we have adopted as a means
of increasing competition and choice in the domain name market. However,
consistent with the underlying policy of private sector management of the
Internet, the Department does not proscribe or otherwise direct ICANN as to the
means of introducing such competition.?
The Internet community has often found powerful technical solutions to vexing
problems - IDN and IPv6 are two recent examples which enjoy a high profile
because they address customer needs. The Strategy states: ?As with other
global standards, the DNS must be updated as technical innovations are
Additional innovation is possible. One example - name multiplexing within TLDs
would solve traditional problems such as lack of namespace, it would remove
the rationale for cybersquatting, name hoarding and speculation, make
contentious UDRP unnecessary and could generate a new class of Internet related
services. Entirely different approaches may also exist.
ICANN does not author Internet protocols, but prodding your supply chain to
propose alternative means of solving identified problems, then testing these
proposals in a market environment, should fit within your mission of
coordinating, at the overall level, the global Internet's system of unique
identifiers. It maps well to your core values.
Suggesting that ICANN's ultimate success rests on meeting customer needs may
be platitudinal, but I miss the market orientation in ICANN's proposed
Thank you for the opportunity to comment.