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Username: NetNumber
Date/Time: Wed, October 25, 2000 at 5:38 PM GMT
Browser: Microsoft Internet Explorer V5.0 using Windows NT
Score: 5
Subject: Competition At Risk


                                                            ".tel" versus ""

                                                       Competition At Risk

Two competing visions are being advanced within the Internet community for providing a top-level domain to address a critical addressing challenge for the emerging IP-Communications industry. 

".tel" Implementation:  The Pulver/Peek/Marschel ".tel" TLD application described in this document is the outgrowth of a three year intellectual property, technology development and standards body effort initiated by the team back in early 1997.  Note: the Pulver/Peek/Marschel ".tel" application is one of three ".tel" TLD applications currently under review by ICANN. 

"" Implementation:  As an alternative to the ICANN TLD process, the IETF's ENUM working group lead by co-chair Richard Shockey of NeuStar Communications is working with the International Telecommunications Union (ITU) to establish the sub-domain "" as a pseudo TLD for registering telephone numbers on the Internet. 

The goal of both ".tel" and "" is to provide an ENUM compliant (RFC 2916) top-level domain supporting a globally distributed directory solution that enables end-users to register their phone numbers on the Internet and associate those phone numbers with a list of IP-enabled communications services and devices: (IP-telephony, IP-fax, e-mail, PDA, Mobile SMS, etc.) 

Beyond this common vision, there are critical differences between these two implementations that have long-term implications for the deployment of IP-Communications services on a global basis.  This document seeks to crystallize the core differences between the two models and recommends a solution for allowing market forces and the Internet Community to determine the superior approach. 

The key difference between ".tel" and "" focuses on control over the ENUM services registration process.

1. Under the ".tel" implementation, the international non-profit "Internet-Telephony Addressing Board" ( defines policies for the TLD guaranteeing open and free competition for the provisioning of ENUM services on a global basis. 

2. Under "", control over the ENUM registration process is delegated to the 240+ national regulatory agencies that currently administer the PSTN on a country-by-country basis.  Under this model the key question for the Internet community becomes:

"Will the 240+ national PSTN regulatory agencies that are being given control over the ENUM registration process under the "" model set policies that advance the best interests of the emerging IP-Communications industry?"

We believe the answer is clear:  Distribution of control of "" to 240+ PSTN regulatory agencies will tend to maximize the best interests of the world's incumbent PTT's at the expense of the emerging IP-Communications industry.

Valid Concern For Emerging IP-Communications Industry

(a) Under the "" model, national PSTN regulatory agencies are placed in a position to grant incumbent PTT's exclusive control over the provisioning of ENUM services for the telephone numbers that fall under their control.   

     - A recent Internet-Draft presented to the ENUM working group clearly articulates this as a viable implementation scenario under

(b) Incumbent PTT's can be expected to use the power that may be granted to them under the "" model to control, protect and limit the provisioning of ENUM services by ISP's, ASP's, and other emerging IP-Communications service providers.  As a result:

     - New IP-Communications entrants are likely to encounter roadblocks in registering ENUM addresses for services that compete with incumbent PTT's around the world.  This should be no surprise to anyone.  Given power, any company will act in its best interest to limit competition. 

     - Incumbent PTT's with exclusive control of ENUM services will have an incentive to set prices high enough to discourage competition from emerging IP-Communications providers that will need access to the "" ENUM services.  (i.e.: Unified messaging ASP's, IP-Telephony ASP's, etc.)

What is the ".tel" proposal for addressing these concerns about ""?

     Give the Internet community the ability to decide between ".tel" and "" after fully exploring the tradeoffs of the two implementations.  How can this outcome be achieved?  If ICANN takes this opportunity to award a ".tel" TLD, then the Internet community will be put in a position to determine which solution best meets the industry's long-term interests.  If ICANN misses this opportunity to approve one of the three pending ".tel" applications, then control over global ENUM services will be distributed to 240+ national PSTN regulatory bodies without the benefit of appropriate public review of the decision.

Outlined below is an issue-by-issue summary of the competing visions:

Technical Standard:

    ".tel":  IETF-ENUM compliant.

    ""  IETF-ENUM compliant.

     ".tel":  Derives authority from ICANN

     "":  Derives authority from ITU         

Policy Control & Oversight:

     ".tel":  ICANN and ITAB define policies on a global basis ensuring end-user control over ENUM registration.

     ""  240+ PSTN regulatory bodies set policies on a country-by-country basis.

Market Focus:   

     ".tel":  Clearly focused on meeting the needs of the emerging IP-Communications industry.

     "":  Mixes the competing interests of PTT's and the IP-Communications industry.

Registration  Model:

     ".tel":  Guarantees open and fair competition for ENUM registration services on a global basis.

     "":  Allows each national PSTN regulatory body to determine if competition will be supported.

Incumbent PTT's Role:

     ".tel":  Guarantees that incumbent PTT's can choose to provide ENUM services without blocking open competition.

     "":  Allows PSTN regulatory bodies to award exclusive ENUM registration rights to incumbent PTT's.

Subscriber Choice:

     ".tel":  Guarantees end-user control over registration of ENUM services.

     "":  Allows each national regulatory body to decide if choice will be supported.

Internet community benefits: 

Regardless of which implementation wins in the end, the best interests of the  Internet community will be served by allowing the issues to be evaluated by the market over a reasonable period of time.  If ICANN approves one of the three pending ".tel" applications then the opportunity will exist for an open and fair review of the merits of each solution.  If ICANN does not select one of the ".tel" applications for a new TLD then "" will proceed without debate.  No decision by ICANN at this time is in effect a final decision to select "" before the issue can be reviewed in a public forum.   


- Let the ICANN TLD definition process work.

- Let competition and the market process work.

- The Internet community will be the winner. 



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