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Username: ebroitman
Date/Time: Fri, October 27, 2000 at 4:00 PM GMT
Browser: Microsoft Internet Explorer V5.0 using Windows 98
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Subject: Response to Professor Chander regarding professional restricted TLDs


      RegistryPro has noted with interest the concerns raised by Professor Anupam Chander regarding dotlaw’s bid for a .law TLD.   Comments such as Professor Chander’s are important to a full analysis of the potential new registries.  Since RegistryPro has proposed .pro, a TLD that would similarly serve lawyers and other professionals, we appreciate the opportunity afforded by the public comment period to explain RegistryPro’s policies.

Consistent with its mission, ICANN has stated that selections of new TLDs and new registries will be made to:  maintain the Internet’s stability; evaluate the “proof of concept” in introducing new TLDs; enhance competition; enhance the utility of the domain name system; meet unmet needs; and enhance the diversity of the DNS.   RegistryPro strove to meet those goals with its bid for .pro, a top-level domain extension exclusively for accredited professionals. 

If the bid were accepted by ICANN, RegistryPro would create sub-domain strings tailored to specific professions, such as doctors, lawyers and accountants.  The .pro TLD would help consumers to more effectively locate qualified professionals on the Internet, provide an exclusive name space for professionals, and multiply the volume of available domain names. 
· For example, a licensed medical doctor would be eligible to register, to let users all over the world know that he is credentialed in his field. 
· At the same time, a licensed attorney could register, allowing two professionals to distinguish themselves while both having a .pro designation. 
· Furthermore, .pro would be available to professional companies and associations, which can register on .pro and leverage the new extensions to enhance their member services.

RegistryPro’s model would promote competition and transparency, preserve the professional nature of the TLD, help protect intellectual property, enhance the global nature of the domain name system, and ensure stability:

Promote Competition and Transparency:
o RegistryPro has proposed increased services at a competitive registration price – it would charge a single fee – no more than the $6.00 charged for .com registrations. 
o RegistryPro would provide a level playing field to all ICANN-accredited registrars – promoting competition at registrar and registry level, which ultimately benefits the professionals.
o RegistryPro’s shareholders, and Virtual Internet, would donate a margin of their registry profit after recouping investment costs, in order to increase competition and create a level playing field.
o RegistryPro would establish an Advisory Board of independent experts who will ensure both transparency and the development and implementation of policies and procedures that reflect the requirements of ICANN and the customer.

Preserve the Professional Nature of .pro Registrants:
o The RegistryPro bid proposes that the .pro extension be initially subdivided into, and (and similar prefix reflecting the accounting abbreviation most relevant to the country in question), targeting the legal, medical and accounting professions.  These comprise over 65% of all professionals worldwide. 
o The targeted, qualification-based roll out of .pro would protects the integrity of the domain name system. 
o RegistryPro proposes an initial menu of qualifications for each subdomain, which would be broad enough to reflect the various professional credentials of jurisdictions around the world, while strict enough to preserve .pro’s restricted standing.
o To help ensure that .pro domain names are only issued to credentialed professionals, RegistryPro would require its registrars to collect evidence of the credentials, such as a bar certificate or membership to a professional association.  
o Professional associations would be invited to join RegistryPro’s independent Advisory Board, which would help craft and continuously improve the qualification criteria. 

Protect Intellectual Property. In addition to preserving the professional restrictions, RegistryPro would help protect intellectual property by providing:
o Registered trademark owners with a pre-registration period, and
o The tools to effectively search for, and stop, cyber squatters.

Accommodate the International Nature of the TLD:
o The Ireland-based RegistryPro, with facilities around the world and 24/7 customer service, would respond to the needs of the global market. 
o Disputes would be referred to globally diversified independent arbitrators, based on the UDRP model.
o Initial marketing efforts would concentrate on Japan, the UK, and the US, but the TLD would be open to professionals around the world.

Ensure Stable and Enhanced Technology:
o RegistryPro would provide increased reliability, real time registration, and enhanced capability.  While current TLD registration systems typically feature a waiting period, a site registered on RegistryPro could show up on the web as soon as a name is registered.  Additionally, there would not be “down times” in the technology supporting the domain names – as there is today. 
o RegistryPro would offer a centralized database, which among other benefits, helps to protect domain names in case of registrant failure.
o RegistryPro partners have the resources and the proven track record to ensure stability and build a truly competitive registry that responds to customers’ and registrars’ needs.

RegistryPro believes that its proposal addresses the issues raised by Professor Chander in the comment on .law.   In contrast to Dr. Chander’s monopoly and pricing concerns, the .pro TLD would be available to all qualified applicants, through all ICANN-accredited registrars. Since RegistryPro would offer a single low price to all registrars, the competitive registrar environment should result in savings passed on to professionals.  With regard to Dr. Chander’s comment about holding back certain domain names, RegistryPro would not make any such decision unilaterally.  Instead, RegistryPro would achieve a balance between protecting intellectual property and meeting consumer demand by carving out a pre-registration sunrise period and providing enhanced tools to search for cyber squatters.  Similarly, RegistryPro does not claim any authority to “allocate” domain names.  Domain names would be registered on demand from professionals and professional organizations.  In fact, RegistryPro strives to serve a globally diverse market, as described above. Finally, RegistryPro is committed to working with ICANN, professional associations, and other ICANN constituencies to ensure that the .pro policies and restrictions achieve the goals in the new TLD process and respond to the needs of the professional communities.

In conclusion, RegistryPro appreciates the guidance for new TLDs provided by comments such as Professor Chander’s, and we are available to respond to any questions about the RegistryPro proposal.


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