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Username: NetNumber
Date/Time: Sun, November 12, 2000 at 11:38 PM GMT
Browser: Microsoft Internet Explorer V5.0 using Windows 95
Score: 5
Subject: Pulver/Peek/Marschel ".tel" Response To ICANN Report

Message:
 

 
        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
       
     
     

 


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