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