Proposed wildcard use by .travel is low risk

["Thomas Barrett - EnCirca" <tbarrett@xxxxxxxxxxx>]

To: Lyman Chapin, Chair of ICANN's Registry Services Technical Evaluation
panel.

From: EnCirca, Inc. - ICANN Registrar.

Re: Tralliance Proposed New Registry Service.


RECOMMENDATION:

Proposed use of the DNS wildcard by .travel is low risk to internet
stability and should be approved.

EnCirca recommends that .travel be granted use of the DNS wildcard feature
on a trial basis.  On a periodic basis, relevant parties such as the IAB and
SSAC can assess wildcard use by .travel to determine if any stability issues
have arisen due to its use and recommend remedies to mitigate these issues,
including suspension of the wildcard feature.


RATIONALE:

The .museum TLD has been using the DNS wildcard feature for five years
without causing any stability issues to the internet.  .travel deserves the
same opportunity to employ the DNS Wildcard feature.

ICANN has already granted .museum the right to use the wildcard feature.
ICANN's "Equitable Treatment" clause with Tralliance says that ICANN will
not "apply standards, policies, procedures or practices arbitrarily,
unjustifiably, or inequitably and shall not single out Registry for
disparate treatment unless justified by substantial and reasonable cause."

There does not appear to be any substantial or reasonable cause to deny
.travel the right to use the DNS wildcard feature. 

Size matters.  More research may be warranted before Site Finder is
re-introduced into the .com namespace.  But the risk for new namespaces
using the DNS wildcard is minimal because of their small size.  As .museum
and .travel grow to millions of registrations, no one knows if wildcard use
will cause stability issues or if the internet will adapt gracefully.  But
we do know that it will be years before .travel becomes a significant part
of the overall internet traffic.

Employing the wildcard in .travel while the namespace is small is a safe way
to introduce change to the internet.  There is minimal disruption to
existing users and their applications.  There is ample time for the Legacy
internet to recognize and adapt to the .travel wildcard feature as the
namespace grows.  Thus, the issues caused by Site Finder's sudden
introduction are not likely to surface.

Proposed wildcard use by .travel is low risk because:

(1) No evidence exists that use of the wildcard feature causes any stability
or security issues in the DNS

(2) .museum has shown for five years that the DNS wildcard feature in small
TLD namespaces does not introduce stability issues to the global internet

(3) It will be years before DNS traffic in .travel will achieve significant
levels compared to total DNS traffic in the overall internet.  It is highly
unlikely that .travel's wildcard use would ever become a stability issue for
the internet

(4) The .travel wildcard does not need to be considered permanent.  It could
easily be turned off if stability or security problems actually arise

(5) Granting .travel the ability to employ the wildcard does not
automatically grant the same right to .com -- this fear is the root of all
opposition to this request

Let's not stifle innovation due to fear about disruption to the status quo.
Approve .travel's request to use the wildcard feature.


FEAR THAT SITE FINDER WILL RETURN IS THE ROOT OF ALL OPPOSITION TO THIS
REQUEST:

The opposition to this wildcard request can be summarized as follows: any
new feature or service that deviates from behavior expected in the .com
namespace, should be viewed as a threat to the stability of the internet.
But five years of wildcard use by .museum, as well as over twelve other
ccTLD's suggests that wildcard use does not cause stability problems.

The .com Site Finder service is commonly used to justify opposition to any
DNS wildcard use.  However, in its August 5, 2004 review of the SSAC Site
Finder report, Verisign found that the SSAC Site Finder report "contained no
evidence that the introduction of Site Finder destabilized the naming
("Domain Name System" or "DNS") .or the internet".  

The 2004 SSAC Site Finder report states that SSAC's focus was to examine the
effects of "change introduced abruptly without broad notice, testing,
refinement or community involvement".  This is a HUGE material difference
from what .travel is proposing to do.

The IAB suggests there should be a burden of proof that wildcard use will
not "...pose a threat to predictable behavior for applications and users..."
since this highlights potential damage... "...for third parties that the
registry has contact with ---the entities that are delegated within the
zone--- and third parties that the registry does not have contact with ---
all Internet users and their applications."

This IAB suggestion is disingenuous.  The suggested "burden of proof" is
inappropriate since it tries to apply subjective criteria, such as "threats"
and "predictableness" that can't be satisfied for the universe of internet
users.  While we would agree that the user experience on the Legacy internet
should not be impacted, this test suggests that new namespaces must deliver
the same user experience that users receive from Legacy namespaces.  It is
essentially an argument against innovation and any competition to the status
quo.  It is therefore not an honest technical test.

It is already widely known that use of the DNS wildcard will break certain
applications, such as anti-spam filters and browsers displaying search
pages.  Do these issues fall under IAB's potential "threats" and
"predictability"?  ICANN should not automatically assume that all TLDs are
required to, or will use the same supply chain as the Legacy internet.  


LET'S ENCOURAGE INNOVATION IN NEW TLDS:

Some parties will oppose all attempts by Registries to act as profit-seeking
entities:  opposing efforts by the Registries to refine their business
models from what was originally proposed, or from developing new revenue
streams that might conflict with third parties who generate revenue in the
Legacy internet.  

ICANN needs to avoid regulating the business models of the DNS industry
because it leads to unjust maintenance of the status quo (com, net and org).
Instead, ICANN should allow new TLDs to compete with not only other TLDs,
but also any part of the Legacy supply chain they choose to.  

Despite owning an ICANN-accredited Registrar, I fully expect that new TLDs
will emerge that will compete with the current Registrar channel, as well as
the rest of the supply chain, including  ISP's, "domain tasters",
"monetizers" and anti-spam providers.  All of these are legal business
pursuits.  But it is not ICANN's mandate to preserve these business models
in new TLDs.  Nor is it ICANN's job to require that every new TLD delivers
the exact same "predictable" user experience as .com.  

The reality is that .museum has used the wildcard feature for five years
without incident.  Continued wildcard use by .museum is not expected to
cause any issues.  There is no evidence to suspect that wildcard use by
.travel would be any different.

Since there is not any substantial or reasonable cause to deny .travel the
right to use the DNS wildcard feature, this new registry service should be
approved by RSTEP and ICANN. 

Sincerely Yours,
 

Thomas Barrett
EnCirca, Inc. President
Woburn, Massachusetts, USA
October 18, 2006