It's clear by the review of the Image Online Design Inc.(IOD)
registration application that ICANN is unfairly prejudiced against small business
and instead favors maintaining more of a monopoly of TLD registrations for big business.
Big is not always better, and this is especially true in the computer industry, where
small innovative businesses have built and advanced technology and the construction
of internet. IOD has a registry already up and running, and has 4 years
of experience doing so. I visited their site, and their registry system seems streamlined,
efficient, reliable, professional and attractive. This speaks volumes to their
ability to run a viable, large-scale TLD registrar. The fact that they have
not pre-emptively burdened their resources by hiring extra personnel prematurely
is more a sign of conservative judgement and prudence than inability and inexperience.
It is easy to hire qualified technical talent, especially when you have a promising
company like IOD. I don't think they should be discriminated against or penalized
for their better judgment in keeping initial costs down.
IOD's perseverance
in developing and maintaining their registry in the face of many obstacles over the
past four years speaks to their dedication, determination, and commitment in providing
a valuable service to the internet community, and promoting free-commerce in the
face of an existing monopoly. I don't believe their desire to introduce other
registration operators after the first year is unreasonable. In fact, the gradual
introduction and integration of new registry operators seems more of a practical
consideration (especially in a smaller business). It would make the .web TLD
available to consumers sooner, and enable the company to integrate and test the addition
of other registry operators in a more reliable manner that would be less prone to
technical errors when done deliberately--without unreasonable pressure to get the
work done. This sort of arrangement was obviously accorded to Network Solutions
early on, I don't see that it is unreasonable to allow for a similar arrangement
for other TLD registrars.
The pricing structure seems to be based on what is currently
the going rate for the other TLD registrations, perhaps adjusted slightly upward
on the wholesale end to compensate for development and startup costs. I suspect that
the pricing will change to reflect the market demand, and competition. ICANN
could obviously have some input in making recommendations about the pricing structure,
and what would be deemed fair for the service. I don't think that IOD's application
should be disregarded simply because their initial pricing model seems high.
This sort of thing seems easily adjustable, and I think ICANN could talk to IOD about
the pricing structure to effect a change if necessary or desirable.
IOD is an existing
small business, and to pre-emptively cut the legs out from under them by awarding
.web to another registry could be deemed an unfair practice, akin to the alleged
monopolistic practices of Microsoft in trying to steal away the markets from other
smaller software development companies. I don't think ICANN can expect to get
away with ruining a legitimate small business like IOD, and not provide some sort
of compensation or accomodation to IOD and their existing registrants. I expect
there will be lawsuits if ICANN tries to award .web to another company, and justifiably
so. I also suspect the FTC would have something to say about the matter.
This is not a simple matter, and should not be treated lightly.
ICANN needs to
consider the .web award more carefully, with respect for the history and work that
IOD has already invested in this venture, and the authority under which it was previously
established. ICANN should be more respectful of the abilities of small business,
since it is small business innovation that built this country, and the internet.
The other applicants that have applied for .web have also requested other TLDs which
would be more than suitable, and there would be no loss in NOT awarding these competitors
the .web registry, especially since they have no preexisting claim or vested interest
in it.
It would be unethical, unfair, and impractical to award the .web registry
to any company other than IOD.
Sincerely,
K. Hollyday
prashanti@earthlink.net