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Username: msteward
Date/Time: Tue, October 24, 2000 at 4:12 PM GMT
Browser: Microsoft Internet Explorer V5.5 using Windows 98
Score: 5
Subject: IATA's proposal unacceptable


        1. IATA does not impartially represent the travel industry

According to their 2000 Annual Report, their Mission is “To represent and to serve the airline industry.”  Also from their 2000 Annual Report, their goals are:
To promote safe, reliable and secure air services.
To achieve recognition of the importance of a healthy air transport industry to world-wide social and economic development.
To develop cost-effective, environmentally-friendly standards and procedures to facilitate the operation of international air transport.

Nowhere in their report will you find any mention of improving any other sector of the travel industry (cruise line, tour operator, agency, rail, bus, etc.).

Their membership currently consists of 273 airlines, and is limited to airlines. IATA's member list is available online at

2. IATA’s constituents are better served by SITA’s proposal
Société Internationale de Télécommunications Aéronautiques (SITA), an organization closely related to IATA, has applied for a new gTLD, .air, to represent the airline industry.  SITA’s proposal fairly represents the interests of the SITA/IATA members, without imposing bureaucracy and arbitrary limitations on the rest of the travel industry.

3. IATA lacks standing to represent the rest of the travel industry
There are many other segments of the travel industry which have little or no involvement with IATA.  Since IATA membership is restricted to airlines, it is impossible for IATA to fairly represent the rest of the industry. It is unreasonable to give any degree of control of the entire industry to a small segment of that industry.

4. IATA doesn’t truly represent agencies in the United States
The 35,673 IATAN Endorsed travel agencies in the United States participate to provide their employees with IATAN identification cards. These cards are required by most airlines in order to qualify for reduced-rate travel privileges. In the United States, accreditation of travel agents for the purpose of selling airline tickets is solely undertaken by the Airlines Reporting Corporation.
Other than applicable state/local laws and business regulations, there are no accreditation requirements for travel agencies that do not sell airline tickets.

5. IATA doesn’t truly represent travel agencies globally
IATA’s appointment process for travel agencies outside the United States only deals with those agencies engaged in general sales of scheduled airline tickets. In the United Kingdom, for example, a large percentage of travel agencies sell charter air, hotel, cruise products, etc., without selling scheduled airline products. Those agencies operate without IATA registration (or interference).

6. IATA is not equipped to be an “honest broker”
By their nature and charter, IATA is focused exclusively on the airline industry.  As such, they are not equipped by experience or culture to fairly evaluate the requirements for a viable business outside of their industry.

7. IATA’s proposed fees are too high, and represent a barrier to competition
In their application, IATA states: “Significantly for the broader Internet community, this proposal offers the potential to introduce much needed competition in the provision of registry services, which will drive down prices and increase the array of choices to the benefit of users not only of “.travel” but of all TLDs”
In direct contrast to their statement, their proposed fee structure is higher than that proposed by any other applicant.  While data is not available to evaluate if their proposed application fees are truly based on a cost-recovery basis, if we assume IATA is honest in this, their fee structure suggests a bloated bureaucracy.  More significantly, their proposed domain registration fees are clearly designed as a profitable source of funding for IATA.  In separate proposals for other gTLD’s, JVTeam (IATA’s registry operator contractor) quotes wholesale registration fees of $5.30 per name, per year.  What is the justification for IATA’s “cut” of $94.70 (single country) or $494.70 (global)? When Network Solutions held a monopoly on .com, .net and .org registrations, they charged $35 per name, per year.  IATA’s fees are egregiously high.

8. There is an alternative .travel application
Name.Space has also applied to manage the .travel TLD. Name.Space proposes the .travel domain be open to all applicants, in the same fashion as the three existing gTLDs (.com, .net, .org). Name.Space’s application will do much to foster competition in the marketplace. IATA’s proposal will stifle competition and increase the leverage of the airline industry over the entire travel industry.

I urge ICANN to reject IATA's application.


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