The time is long overdue for the introduction of a personal name registry, and on
the surface this appears to be a well implemented solution. Closer inspection
of the application reveals some curiously high costs from supplying organisations
and raises the question on the relationships that they may have with the applicants.
During the first year, over $20,000,000 is spent on hardware and software.
In the first quarter $5,700,000 is being spent on software development, and $3,500,000
on hardware, although no specific details could be identified as to who these suppliers
were, nor what was being acquired for this very considerable sum of money.
first year there are 87 employees, who cost a total of $8,800,000 - this is probably
the most highly resourced registry of all the applications.
There is no information
on capital provision, where this will be raised from, and what it will cost..
Furthermore, the cash requirement using the best scenario is $31,000,000 (in the
worst demand situation it rises to £52,000,000), which can only start to be repaid
during the third year of operation. After fours years, there is only a 50%
cover on the repayment stream - no details on cost of capital could be found in the
pro-forma financials. This would be a highly speculative investment under these
terms which would not be favourably received by most investors.
The pricing structure
also seems to be deliberately set up to favour large holders of domain names by providing
them with advantageous pricing, the determinants being both the number of domains
held in .per and in other domains. No mechanism is detailed on how this would
be verified. Neither of these mechanisms helps to provide a level and equal
playing field for all registrars.
The concept that users will update their WHOIS
information every 90 days is probably optimistic, although the process of using a
reminder might be usefully adopted by other applicants.
However, the measures that
have been set in terms of identifying and measuring the successful introduction are
a useful concept that should be adopted by any successful applicant.