Summary and Analysis of Comments

[Francisco Arias <francisco.arias@xxxxxxxxx>]

Summary and Analysis of Comments for: Allow allocation of numeric-only
domains (excluding single-digit) in .TEL
 
Summary:
 
The comment period was open from 14 October to 13 November 2010. Three
comments were received before the closing date; one comment was received
after the close of the comment period. All comments can be viewed at:
http://forum.icann.org/lists/tel-numeric-only-domains/
 
Overall there was no clear consensus view on whether or not the amendment
should be approved; each commenter provided input suggesting a different
path.
 
Analysis:
 
Matthias Jungbauer, supports the proposal. He proposes ³to create only real
existing phone numbers as tel domains² by cooperating with phone companies.
 
Volodya does not explicitly support to the proposal, but proposes that the
country code will be a forced addition to the domain in order to avoid ³US
centricity², also recognizing that it would increase the complexity of
verification mechanisms.
 
Tim Ruiz (registrar GoDaddy.com, Inc.) opposes the proposal stating that
requesting this change through the Registry Service Evaluation Policy (RSEP)
process is inappropriate since it does not simply involve a new Registry
Service as defined under the RSEP, but rather involves a fundamental change
to .TEL charter.
 
Tim also comments that it is unfair to other applicants and potential
applicants to allow a sTLD to change its purpose after it has been
delegated. He further adds that Telnic's promise not to allow numeric-only
second-level registrations was a fundamental aspect of its application and a
primary reason why .TEL was awarded to Telnic and not Pulver (another bidder
for .TEL sTLD at the time). He concludes that this request cannot be granted
without requiring the rebidding of the .TEL sTLD itself, giving an
opportunity for others to bid competitively.
 
Tim also expressed concern about ³certain other recent [RSEP] requests² by
sTLDs for similar reasons, without further specifying.
 
Khashayar Mahdavi, CEO of Telnic Limited (.TEL registry) submitted a
response to Tim Ruiz¹s comment after the close of the public comment period.
He asserts that the proposal is not a fundamental change to the nature of
.TEL, since the restriction on all-numeric strings has nothing to do with
the nature of .TEL and was instead a measure put in place to address initial
concerns about potential conflicts with ENUM. He states that .TEL¹s purpose,
as described in its charter, is to serve the community of users who wish to
use a TLD to store and publish their contact information in the DNS. He
concludes that the removal of the restriction for numeric-only domains is
therefore non-essential to the core mission of.TEL.
 
Khashayar further commented that:

* The requirement to restrict availability of numeric-only names was
established to address an isolated concern that existed at that time: the
concern of a conflict between the .TEL concept and ITU¹s ENUM system. He
adds that time and the growing understanding of the .TEL technology has
proven such a conflict does not exist. He points out that the proposal, by
excluding single-digit domains, avoids the perceived conflict with ENUM;
 
* Telnic¹s sTLD proponent competitor (Pulver) mentioned by Tim Ruiz proposed
an ENUM competitor system while Telnic¹s bid was specifically avoided such
competition with ENUM by limiting the purposes of .TEL domain names. He
remarked that was the reason why Telnic won the bid over Pulver and not
because of the numeric-only restriction; and,

* The RSEP is the process that has been used in the past for similar
proposals and therefore sees no reason why the RSEP should not apply to this
request. 
 
Next Steps:
 
ICANN will consider approval of the proposed amendment to the .TEL
Agreement, taking into account the comments received.
 
Commenters:
 
2010 Oct 23
 - Matthias Jungbauer
 
2010 Oct 26
 - Volodya
 
2010 Nov 13
 - Tim Ruiz
 
2010 Nov 16
 - Vladimir Shadrunov / Khashayar Mahdavi

Best regards,

__ 
Francisco Arias
gTLD Registry Technical Liaison
ICANN
Phone: +1 310 823 9358
PGP fingerprint: FE95 C7E7 36C7 A039 94BB  C781 FD75 BB9D C55F 51B5