GoDaddy.com's Comments on .TEL RSEP - Allocation of Numeric-Only Domains

["Tim Ruiz" <tim@xxxxxxxxxxx>]

GoDaddy.com's Comments on .TEL RSEP - Allocation of Numeric-Only Domains

We object to Telnic's request to allocate numeric only second level
domain names for the following reasons: 

We believe that requesting this change through the Registry Service
Evaluation Policy (RSEP) process is inappropriate. Telnic's request does
not simply involve a new Registry Service as defined under the RSEP. It
involves a fundamental change to its charter. The charter for a
sponsored Top Level Domain (sTLD) defines "the purposes for which the
.tel sTLD is delegated." This request from Telnic is to change its
purpose and not to employ a new service under its existing, agreed to
purpose.

We believe that this request cannot be granted without requiring the
rebidding of the .tel sTLD itself. It is unfair to other applicants and
potential applicants to allow an sTLD to change its purpose after the
fact. Telnic's promise not to allow numeric only second level
registrations was a fundamental aspect of its application and, if we
understand the decision correctly, a primary reason why .tel was awarded
to Telnic and not Pulver (numeric only second level names were
fundamental to Pulver's application for .tel at the same time).

Since community, purpose, and use were such important aspects of the
sTLD allocation decisions it seems inappropriate, fundamentally unfair,
and even smells a lot like gaming, to allow an sTLD to change those
aspects without an opportunity for others to bid competitively. One
possible solution might be to allow Telnic and other interested sTLD
registries to put their TLD up for reapplication in the new gTLD round.
If they retain it afterward, they will have done so through an open
competitive process and fundamental changes such this one being
requested by Telnic would not be an issue.

We believe that certain other recent requests under the guise of the
RSEP by sTLDs were also likely inappropriate for similar reasons and we
are concerned about what appears to be a growing trend to misuse the
RSEP. We hope our comments will encourage Staff and Board to review
these requests more critically in the future.

Respectfully submitted,
 
Tim Ruiz
GoDaddy.com, Inc.