The ICANN review team has done an admirable job of reviewing
the Telephony related TLD applications. Having said this, the recommendation
to not select a ".tel" application at this time fails to address a well-defined,
pressing and unmet need of the emerging Internet-Telephony industry. Outlined
below is a review of the specific concerns raised in the ICANN report as they relate
to the Pulver/Peek/Marschel ".tel" application, including a clarification of the
unmet need of the Internet-Telephony industry: From the report: "Each
of the four proposals appears not to have adequately addressed requirements for stable,
authoritative coordination with the PSTN numbering system…"
Pulver/Peek/Marschel
Response: The Pulver/Peek/Marschel “.tel” TLD proposal fully supports the ITU
and each country’s authority to create, distribute and assign e164 numbers to PSTN
subscribers. Building from this foundation, the Pulver/Peek/Marschel application
clearly articulates that registrations under the ".tel" TLD can only be made by valid
PSTN e164 telephone number subscribers. As such, there is perfect coordination
between the PSTN numbering system and the ".tel" Registry. Furthermore, the
application articulates several policies including a Registration Validation Policy
and a Conflict Resolution Policy that act specifically to guarantee perfect alignment.
From the report: "Another unusual technical requirement for these proposed
services is the ability to manage dynamic mapping requirements in the DNS…….It is
not clear from the proposals how even simple issues such as call forwarding would
be handled."
Pulver/Peek/Marschel Response: The Pulver/Peek/Marschel proposal
defines that the ".tel" TLD will be operated according to the technology standard
defined under IETF-ENUM RFC 2916. The current position of the industry on this
issue is unambiguous: Dynamic updates of end-user information for mobility,
presence or other issues will not occur in the top-tier or top-level of an ENUM system.
The ICANN analysis team has highlighted an important industry issue, but it is clear
that this issue does not apply to the operation of a top-level domain under the IETF-ENUM
standard. As such, the issue of dynamic updates within the ".tel" TLD does
not apply to the Pulver/Peek/Marschel ENUM compliant ".tel" TLD application.
From
the report: "If a TLD were established in which the service available at URL's
was defined by the TLD rather than the prefix, this would likely increase confusion
regarding URL naming conventions."
Pulver/Peek/Marschel Response: We agree
with the statement from the ICANN team but conclude that this does not apply to the
Pulver/Peek/Marschel application. This comment appears to apply directly to
the Number.tel application that proposes to allow browser based input of URL's which
include both a telephone number and the ".tel" string. (http://12125551234.tel)
By comparison, the ENUM standard adopted by the Pulver/Peek/Marschel ".tel" TLD does
not provide for using an e164 domain name in the form of a URL. Furthermore,
as ICANN points out, ENUM services are intended for use by communications systems
and not by individuals operating from a browser interface. As such there is
no room for confusion on this point in an ENUM compliant system as described in the
Pulver/Peek/Marschel ".tel" TLD application.
From the report: Finally,
the evaluation team concludes that none of the telephony applications should be selected
at this time in part because of “the concerns raised and caution urged by the ITU
counsel against establishing a telephony-related TLD until further study and consensus-building
within the Internet and telephony technical communities is completed”.
Pulver/Peek/Marschel
Response: Herein lies the key issue. ICANN is aware that the ITU has
taken action to validate "the official" implementation of ENUM services under the
"e164.arpa" domain based on following the existing control policies of the PSTN.
Given this situation, the unmet need of the emerging Internet-Telephony industry
addressed by the Pulver/Peek/Marschel ".tel" TLD can be summarized as follows:
ENUM
has been accepted as an Internet-Telephony directory standard.
The ITU has selected
"e164.arpa" as the TLD for the officially approved, standard implementation of ENUM
services.
"e164.arpa" follows the existing control policies of the PSTN and its
incumbent PTT's.
The long-term interests of the existing PSTN structure and the
emerging Internet-Telephony industry are not perfectly aligned. Very specifically,
the "e164.arpa" model of delegating control of ENUM services to 200+ national PSTN
regulatory bodies is not perfectly aligned with the best interests of the emerging
Internet-Telephony industry.
The Internet-Telephony industry has a valid
and unmet requirement for an alternative implementation of ENUM services under an
approved TLD based on policies that reflect the best interests of the emerging industry
rather than the existing PTSN.
The ITU has done its job of advancing the
interests of the PSTN by selecting “e164.arpa” as the official domain for the delivery
of ENUM services. We ask that the ICANN Board take appropriate action to advance
the best interests of the emerging Internet-Telephony industry by approving the Pulver/Peek/Marschel
".tel" TLD to create effective competition for "e164.arpa".
Sincerely,
Douglas
J. Ranalli
Founder & Chief Strategy Officer
Glenn Marschel
Chief Executive
Officer
NetNumber.com