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Username: ebroitman
Date/Time: Mon, November 13, 2000 at 7:48 PM GMT
Browser: AOL Browser V4.0 using Windows 98
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Subject: RegistryPro Response to ICANN initial evaluation

Message:
 

 
        Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina Del Rey, CA  90292

We appreciate the positive review of RegistryPro’s application and having been rated foremost among the restricted commercial group.   We are grateful for the opportunity to address the two issues raised by ICANN’s review team.

Funding – Response to Issue 1:

RegistryPro commits to fully fund the $30 million that it has estimated it will need to run the new registry for the first two years.

· RegistryPro will commit $10 million in the event ICANN grants the right to operate the .pro registry.

· The additional $20 million will be provided by a combination of internal and third party funding.  (See below)

· If market conditions prove unfavorable for private third party funding, Register.com will fund any budget shortfall.  The result, regardless, will be to meet the goals of achieving and sustaining the technological standards, robust operations and marketing outreach, as agreed with ICANN.

· Register.com is prepared, at the request of ICANN, to place funds in an escrow account or post a Letter of Credit to guarantee this commitment.

· Should the partners of RegistryPro elect to seek third party funding following a registry grant, such funding would represent a minority interest in RegistryPro, and the current RegistryPro partners would retain a majority interest in the registry.  It is anticipated that RegistryPro will seek to raise $15-$30 million in additional funding from one or more of the following sources:

Technology Partners (as indicated in our application,        Baltimore Technologies has expressed a strong desire to make an equity investment)
Venture Capital Firms
Investment Banking Firms (Please see Legg Mason letter attached to our earlier answer)
Strategic Partners


Market Size and Penetration – Response to Issue 2:

RegistryPro believes strongly that the market for .pro is substantial enough to support a robust registry, and that our operational spending will justify a solid return on investment.

· As outlined in RegistryPro’s application, the .pro TLD market totals approximately 29.5 million and is anticipated to grow at 5% per annum.

· Attorneys, physicians and accountants (the initial subdomains chosen), represent 65% of all professionals worldwide. 

· For each of the three professions we have set forth, the total number of professionals in the United States, United Kingdom and Japan:

2.4 million attorneys,
1.9 million physicians, and
2.8 million accountants.

· Moreover, with ICANN’s approval, after the initial .pro testbed, we would plan to scale the .pro TLD to additional professionals, such as architects and engineers. 

· The evaluation suggests that a large number of lawyers and accountants may work for large firms, leading to an assumption that the overall market for RegistryPro would be small.  With close scrutiny, we respectfully submit that ICANN will find that the potential market for .pro is quite robust.

        For example with regard to attorneys, market data shows that a vast majority work in solo practices or in small firms.  As the American Bar Association has stated, 47% of all private practitioners in the U.S. are in solo practice, and another 22% are in firms of under 10 attorneys.  Therefore, 69% of all private practitioners in the United States represent RegistryPro's key target market in the .law.pro space.  

Similarly, according to Inc. Magazine, 450,000 accountants in the U.S. alone are sole practitioners or are employed by small firms.  RegistryPro believes that this entire group represents a core market in the United States.

Finally although the ICANN evaluators did not question the .med market, we reaffirm that physicians are likely to register their own domain names because most doctors have independent patient outreach, rather than being represented through their respective practice groups or hospital affiliations.  As evidence of the medical profession’s initial acceptance of this business proposition, please refer to the letters of support from the American Psychological Association and the National Mental Health Association.


Conclusion:

RegistryPro believes strongly that its market demand assumptions are credible.   RegistryPro has committed the funds to tap this market and to sustain a robust, innovative, and competitive registry, in furtherance of ICANN’s goals and objectives.

Sincerely,

RegistryPro
       
     
     

 


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