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Username: David Coombs
Date/Time: Tue, October 17, 2000 at 6:16 PM GMT
Browser: Microsoft Internet Explorer V5.01 using Windows NT 5.0
Score: 5
Subject: .web concerns


      I have some concerns about all thre applications for the .web domain.
      My first concern is the concept of a truly new "generic" gTLD.  It seems to me that this would only dilute the internet name system.  For instance, any unique users of the proposed '.web' domain (i.e., those not already using the same '.com' address) are going to differentiate their second level domain from the .com holder without a natural business reason (as would be provided if, for instance, a .shop, .coop, .pro, .union or other focused top-level domain would do).  However, this is more a concern of business model which would eventually be resolved by market forces.

      My second concern is the 'good faith' of the Neustar and Afilias applications.  Neustar appears to offer nothing that IOD does not, and really doesn't seem to differentiate itself at all.  Afilias has a heavy conflict of interst burden with Ken Stubbs, and, even if he were to withdraw, the competition argument against Afilias/NSI seems overwhelming.  Seeing as NSI already has exclusive rights to be the registry for .com, .net, and .org and I have no doubt their arrangement with Tucows would leave NSI a fair amount of equity (if not some other method of control) in the .web registry as well.

      My third concern lies with IOD's business model and it is twofold, both relating to competition. 
      1)  The way the proposal is written, IOD will not only be the registry but the sole registrar for '.web' domains, at least for the first 30-60 days (which is when the big rush will occur).  The argument that Mr. Ambler makes is the time needed to integrate accredited registrars into their architecture, however, I feel it is no coincident that this would lead to a immense financial boon to IOD and feel that the internet would be best served if competitive interests were better served and '.web' domain names were not available through IOD until they also made them available to a to-be-determined number of accredited registrars (perhaps covering a certain amount of market share?). 
      2)  The second competitive argument I have with IOD's business model is the extravagant registry fee in the proposal.  In its proposal, IOD charges a $15 registry fee.  Even in its monopolistic height, the highest I recall NSI charging is $9, they charge $6 now and that is basically what they propose to charge for the '.web' registry.  Mr Ambler responds elsewhere in this forum to this concern saying that if competetive forces dictate, that registry fee would fall, however that seems illogical to me, as there is only one registry for .web, so to what competition does he refer?  If the $15 reflects a fair profit margin on the cost of the registry to IOD, then I would say that they have a very ineffective composition of their registry as that is muchlarger than any other proposal I have seen in any of the applications (in fact, as I recall, I believe the '.i' registry offers $1 service).





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