Dear Sir or Madam:
It is pity for other registrars
to see that Verisign plays a dual role in the domain industry, i.e., as both registrar
and registry. Because of this particular situation, the competition is never
fair. In my view, other registrars stand at a lower level because they have
get approved by the “big brother” registrar Network Solutions. It is
a pity. As a result, this arrangement has caused damage to other registrars
and registrants as well because Network Solutions has all kinds of advantages over
other registrars. One damage is the domain hoarding by Network Solutions.
Because Network Solutions has a
double-edged sword (registry and registrar), they
do not have to pay a dime to keep the expired domain names. Because the expired
domain names have not been released for the public to register, the interest of consumers
and other registrars has been significantly damaged.
We, a domain reseller,
have always heard people’s complaint about the service of Network Solutions including
its domain hoarding. It is very surprising to hear ICANN’s claim that
it has not received many complaints about the practice of Network Solutions.
The government wanted to break Network Solutions’ role as both registry and registrar
based on the belief that the separation is the basis for a fair competition among
the registrars. It seems to me that the reason the government has not broken
Network Solutions at its first attempt because it will need to take some time and
administrative process to smoothly break it up. This fairness can only be realized
when the registry has been separated from the registrar.
the competition among the registrars is still unfair. ICANN cited the domain
share as the evidence to support its arguement that the competition is good enough
that no separation of the registry and the registrar is necessary. While we
acknowledge that there is some severe competition among the registrars, we have to
emphasize that the fact that the share of Network Solutions has shrunken does not
mean the competition is fair. The share distribution change is only an incitation
of competition. It does not necessarily mean this competition is fair.
The fairness can only achieved by the separation of the registry and the registrar.
Without the separation, Verisign can use the $6.00 domain fee from other registrars
to support its competition with the other registrars. Or without paying a fee, hoarding
expired domain names so that other registrars can not register them for their clients.
We do not think ICANN has offered sufficient evidence or even explanation to
support its argument that the separation is not necessary. As a domain reseller
with ample experience dealing with registrants, we strongly believe that the fairness
of competition among the registrars has not been achieved. Verisign must separate
its dual function in order to maximally secure a real fair competition.
the other hand, we do not see any potential damage to the Internet community could
be caused by this separation. The big loss for Verisign, though, is that it can no
longer use the domain fee to support its competition with its rivals.
petition ICANN speaks for fairness
Marsgerm Technologies, Inc.
Note: anyone who is interested
in sending a comment or petition to iCANN or the Department of Commerce, feel free
to use the content of this petition if deemed to be useful.