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Username: Formal response
Date/Time: Mon, November 13, 2000 at 7:34 PM GMT
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Subject: Abacus' formal response to ICANN staff report

Message:
 

 
TO: ICANN
NEW TLDs division

By e-mail
By certified mail

November, 13-th, 2000

RE:  Abacus America, Inc.
Application for new TLD Registry operations for
.biz; .cool; .fam; .inc; .xxx

Response to ICANN staff report http://www.icann.com/tlds/report/biz1.html


A. General

We believe that a part of our application was NOT properly classified. The statement that “… its application focused primarily on the .biz TLD “  is simply not true. Throughout the application, we paid equal attention to all names.  It was only because we listed these names alphabetically that .biz became the first name on the list. While we definitely support .biz, we believe that the four (4) other names proposed by Abacus are equally strong. Our belief is supported by the independent poll conducted by MSNBC, where four (4) out of five (5) of our names are listed in the top 10 names voted upon by thousands of participants.

We request hereby that our application be reviewed again.  Moreover, we ask that our proposed TLD .fam be included in the “personal” group where it belongs and that .xxx is included in the “restricted content” group where it belongs.


B. Technical

We are stunned by the fact that Abacus – the only applicant among 44 who offers a live working prototype of the full TLD Registry system http://rodopi.abac.net is so strongly undervalued from a technology standpoint. We believe that this is a misunderstanding and we will gladly provide further information about how our systems will scale and perform under load. Furthermore, we are applying for five (5) domains which generate 32 possible combinations of approved TLDs  and 96 total possible combinations at 10% 50% and 90% level of confidence. Obviously there is no way for one system to fit all these possible combinations, which vary in size. We described the basics in our proposals, whereby additional power could always be added to our basic solution. The selected operational systems UNIX for DNS and MS 2000 Data Center for back office operations are both scalable and cluster able. Furthermore, we conducted significant testing in our own labs and our engineers came to the conclusion that the systems proposed by us will match and outperform our business proposal and will scale upwards well beyond that. We will gladly open our labs to ICANN’s advisors to re-confirm our conclusions. One of the reasons our systems perform so well is the hardware implementation of SSL protocols.

We take the technology very seriously and that is why we prepared an itemized response to all technical issues.

a. Total Capacity.  “The equipment appears less well configured than other proposals for similar TLDs”

Response:
Unlike the configurations proposed by other TLD applicants, our configuration was tested in the prototype environment and under simulated load. Our tests showed that the DNS servers could handle a load much higher than the average load on the current root DNS servers for .com, .net and .org TLDs. The described servers configuration can handle a load higher than the load projected in the business plan. Nonetheless, we are able to upgrade the system if and when needed since scalability and cluster ability are built-in our proposed OS. Also, our configuration includes hardware SSL implementation, which will result in much better performance compared to RRP systems with software SSL implementations running on similar servers. We will gladly share our testing model and results with ICANN’s technical experts.

b. Projected Growth Rate.  “The machine architecture described in the technical plan does not appear to be designed to scale up rapidly.  The architecture described relies on individual dual processor systems running Microsoft Windows 2000.  Preferable choices are clustered systems or hosting on a platform that scales to larger configurations through simple substitution of other computers.”

Response:
Latest performance tests show that Microsoft SQL Server 2000 outperforms all other database solutions, including Oracle (see http://tpc.org). Microsoft Windows 2000 Datacenter scales up to 32 CPUs, 64 GB memory, and a 4-node clustering and load balancing solution and this offers more than enough scalability for the database servers. The Rodopi R architecture allows for an unlimited number of RRP servers working simultaneously with the database, so additional RRP servers can be added at any time. The Whois server can also scale to a 4-node clustering solution.

c. Startup Period.  “The technical plan projects 10,000 registrations on the first day, 100,000 in the first week, 1 million in the first month and 3 million in the first quarter.  Were the applicant to be granted all of the TLDs being requested, the land rush period is likely to see far higher volumes than these.  The systems do not appear to be sufficient to handle the startup period.”

Response:
The numbers described in the business plan are not the technical limitations of the proposed systems. We estimate that the servers described in our proposal can handle at least 1 million registrations for the first 2 hours (150 registrations per second). Again, this estimate is supported by extensive lab tests under simulated load. We will gladly share our test model and results with ICANN’s technical experts.

d. Fault Tolerance. “The fault tolerance strategy for all machines except root DNS servers is to keep spare machines hot.  The fail over strategy was not described.  There was no provision for a second geographic location for servers other than DNS servers.”

Response:
We will replicate the main registry location at all locations originally described as DNS locations. Each location will be able to take over registry operations at any time. All changes in the registry database will be mirrored by the Rodopi servers at all locations. This mirroring technology is currently in use by the “Rodopi Roaming Club” to synchronize roaming accounts and usage data between more than 600 Internet Service Providers.

3. Apparent Implementation Risks. “The proposed Registry software, Rodopi R, has not been deployed in a production environment. The infrastructure appears to be undersized for the land rush period, and the architecture does not appear to allow for easy scaling up.”

Response:
At present, the only registry with software deployed in registry production environment is Network Solutions. Rodopi R is based on the commercial product Rodopi, which is used by more than 600 Internet Service Providers and Telcos. The Rodopi DN and Pirin software products are based on Rodopi as well, and are currently used commercially by one Registrar and hundreds of Resellers. Abacus America, Inc. is the only new TLD Registry who offered a working prototype (http://rodopi.abac.net ), based on a commercial grade product.

C. Business review.

We were similarly surprised by the Staff Report’s comments about Abacus not having the marketing expertise or understanding of the markets.

First of all Abacus generates over $10 million in annual revenues. Such a figure could not be achieved without significant understanding of our markets and a great deal of marketing expertise. Our marketing budget is close to $2 million. We have prepared several business plans lately for variety of reasons and we know that short business plans are more valued than long ones.  It was for this reason alone that we avoided stating obvious truths and “reinventing the wheel” about Marketing in our TLD application.

Second, Abacus was the ONLY applicant having to have been able to predict four (4) proposed TLDs which ended up within the top 10 list in the independent poll by MSNBC.  That prediction was made after extensive market research (see Abacus’ TLD Application, whereby we stated, in part, that the reason for selecting each TLD proposed was because of our own market research.

As of Oct, 12, 2000, the tally by MSNBC was as follows (current results at: http://www.msnbc.com/modules/surveys/domainname.asp ):


1. .xxx (1783 votes)    proposed by Abacus
2. .web (1668 votes)
3. .sex (1281 votes)
4. .biz (1115 votes)      proposed by Abacus
5. .inc (997 votes)         proposed by Abacus
6. .kids (947 votes)
7. .news (825 votes)
8. .fam (594 votes)        proposed by Abacus
9. .shop (536 votes)
10. .info (471 votes)


No other applicant came close to predicting the demand for registrations in any way that approached Abacus’ market research. The closest applicant had only two (2) domains in the top 10 list. Results such as this serve as independent verification of Abacus’ knowledge of the markets, the segments we are serving and the general marketing principles.

Third. Abacus’ entire business model is 100% focused on the Internet. It sleeps, eats and breaths Internet. What better way of knowing Internet trends, markets and segments than the real day to day hands on experience that comes with this kind of access and exposure to the daily needs of Internet users?

Fourth. Abacus has experienced strong growth of over 100% per year for the last 3 years. Such growth cannot happen without clear business and marketing vision.

Respectfully, Abacus therefore disagrees with the characterization of its marketing and business abilities.  Nonetheless, Abacus is committed to working with ICANN in every way to satisfy ICANN that it will, in fact, provide lasting security and stability if it is chosen as a Registry.

D. Comparison with other applications.

.biz

iDomains –  only 4 employees; does not have history and experience; controversial issues including some ICANN activists, who are personally involved and CORE, involved with this application as a subcontractor as well as a principal in other applications. Abacus’ application is definitely much stronger in regard to the technological and business experience and capabilities.

JVTeam –  It seems they are not a team anymore. It is official now that NeuStar and Melbourn IT split due to conflict of interest, because Melbourn is involved in competing application. With the team falling apart, NeuStar does not have relevant technological experience and technological back up.
With all due respect to the financial power of Martin-Marietta and the general experience of NeuStar, Abacus has much more relevant experience and working technology, which makes it a better candidate.

KDD – Financially strong applicant and adds geographical diversity too. The most serious of its problems is that it is partnering with NSI, thus reinforcing NSI’s monopoly in TLD markets. Abacus’ application is better because it does further add to the problems of this monopoly. Many postings in the public forums show how sensitive the people are about monopolies. ICANN was created to break the monopolies, not to reinforce them.

.fam

Abacus is the only applicant for this domain name listed #8 in the top 10 list by MSNBC.

.cool

Abacus is the only applicant for this popular name among the young generation.  The comments in the first ICANN public forum bear this out.

.xxx  .inc

We reserve the right to analyze the competition on those domains when the names are approved by ICANN.

E. Conclusion

As shown above, most of the comments evaluating Abacus’ application can be addressed by further submissions to ICANN.  If there are other portions of the application which did not reflect these points, Abacus is eager to augment any of those sections to the satisfaction of ICANN. We will cooperate with ICANN by providing further evidence if and when needed.

Abacus has spent the last two years in preparation for successfully managing  new TLDs. We  created strong technology and have built our business model around the Internet and providing service to the Internet community.  Abacus wants to do everything in its power to demonstrate that it is the best choice for the TLDs which it has proposed.

We are looking forward to working with ICANN to establish reliable and stable Registry operations.

Sincerely,

Ivan Vachovsky,
CEO
Abacus America, Inc.

     
     

 

Link: Abacus' technology for Registry operations


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