The following is written in response to the “business elements” of the ICANN
staff report on the Affinity/bizTRAC proposal.Firstly, we thank the staff and
note that they expressed no major reservations on our proposal in either the business
or the technical aspects of our plan.
1. The Benefit of Creating a TLD Free of
Speculation
We believe, however, that the staff review may not have fully considered
the major benefit of our proposed TLD. Very simply, the primary objective of the
proposed TLD is to create a name space where domain name hoarding and speculation
do not occur. By achieving this in our TLD, we also expect to very significantly
reduce these harmful practices throughout the Internet.
We maintain that “name
scarcity”, which apparently is such a problem, is almost completely a result of “name
hoarding” practices and frivolous registrations. After all approximately 80% of registered
SLDs do not point to an active web site. (We define “frivolous registrations” as
those which are made with no real intent of being actively used). This results in
a situation where it is very difficult for a real business to establish a powerful
presence on the net without paying ransom to a cybersquatters, or a name hoarder.
Often this cost will be 10s or 100s of thousands of dollars. The experience of the
average registrant is *not* paying $35 and getting the name they want. Rather most
end up settling for a second best name or paying off a speculator.
If approved,
our strict front end screening practices would create a haven free of name hoarding
and speculation. All names in the TLD would cost $2,000. Because we would register
far fewer names than an unrestricted domain, we believe that this would ensure that
a new business would always be able to obtain a powerful name under our TLD. This
in turn would mean that there would be very little incentive for registrants to buy
any high priced names in the secondary market for names in .com or other TLDs – effectively
our proposal would cap the price of the majority of secondary market sales across
all TLDs at $2,000. Thus name speculators would be deprived of the opportunity of
a “big score” and, we believe most would simply throw in the towel. In other words
we believe that if approved our proposal would significantly reduce the practices
of domain name hoarding and speculation across all TLDs.
2. bizTRAC
The staff
report states “bizTRAC barely exists, and thus little experience resides there”.
We concede that bizTRAC is a new entity which is being built specifically to represent
constituency interests in managing the TLD. However at the time of application we
already had the CEO of a major registrar (BulkRegister.com) on the board, and 5 other
individuals with extensive business, intellectual property, consumer rights, and
general legal experience. Since submitting the proposal, the Confederation of British
Industry (the major British business association) has stated in their note on this
notice board that they envisage providing a representative to the board if we are
awarded the TLD. Professor Graciela Chichilnisky of Columbia University has also
agreed to serve. Graciela Chichilnisky has held the UNESCO chair in Mathematics and
Economics at Columbia University since 1995 as well as many other prestigious government
and academic appointments.
It is also our intention that we will add representatives
from the business and IPC constituencies of the DNSO and to make full efforts to
ensure that bizTRAC will as effectively as possible represent the interests of all
constituencies effected by our operation.
3. Possibility of not meeting projections
The
staff report states that “If few businesses chose to register, the registry might
be under-funded for its requirements”. We believe that it is very unlikely that our
initial projections will not be met and exceeded. Based on a reassessment and on
new information we believe our initial projections of 10,000 names in the first year
to have been very conservative. The new information is that dotTV, has apparently
registered 100,000 names since May, many at a price of over $1,000. Making an exact
estimate is of course impossible, but we belive it is very unlikely that we will
not register at least the numbers projected. Note however, that our capital is sufficient
if we register half this number. In our proposal we also show a “minimum maintenance
scenario” which would allow us to maintain operations so as to serve existing customers
with as few as 400 registrations per year.
4. Scalability of 7Ways Operation.
The
partners of 7Ways have long experience in the technical field and extensive contacts
world wide. The directors confirm that they believe that it would be easy for them
to rapidly expand their operation. In addition Affinity has a large technical staff
which could be temporarily be diverted to assisting 7Ways in the case of a faster
than projected need for expansion.
5. Possibility of Accepting .inc TLD string
We
confirm that we would be happy to accept the .inc string if it were offered to us.
“.inc” of course implies “incorporated”. That is, it implies the existence of a real
business – which is exactly the idea of our TLD. We therefore believe, on further
consideration, that our concept would work as well, or nearly as well with
the .inc string as it would with .biz.
6. Other areas of flexibility in our proposal
We
initially intended to start operations with only 2 registrars for an initial 6 month
test period. On further consideration we would be prepared to open up registration
to all ICANN registrars either after a 2 month test period, or even at once as specified
by ICANN.