Response to ICANN Report on TLD Applications
PREFACE
Diebold is please to
provide the following information in response to ICANN’s “Report on TLD Applications”
(“Report”) posted to the ICANN web site, http://www.icann.org/tlds/report/, on November
10, 2000.
HISTORICAL
On October 2, 2000 Diebold Incorporated submitted a complete
application to ICANN, including information of business practice and financial natures.
Diebold requested that, due to corporate policy and potential regulatory issues,
portions of the application be treated as confidential. Diebold and ICANN could
not come to agreement as to which portions should be considered confidential within
a reasonable timeframe. As a result, Diebold withdrew those portions of the
application.
ICANN advised Diebold that the remainder of the application would
be reviewed without direct consideration of the withdrawn portions of the application.
Diebold believes ICANN has followed this advisement in good faith and has somewhat
minimized the impact of the withdrawn information in their review.
POSITION
Diebold
agrees with the general assessment of ICANN that the seven applications reviewed
in detail in the Report represent excellent candidates for the operation of new TLDs.
We further believe that Diebold represents one of the “best of the best” for reasons
that my not be entirely clear to observers who have not had the opportunity to review
more detailed information regarding our commitment to success through appropriate
financing, staffing, organization and an excellent understanding of the business
practices necessary for success.
Due to changes in the circumstances regarding
regulatory issues, we are supplying certain additional information, originally supplied
to ICANN, but withheld due to regulatory and policy considerations. From the
ICANN TLD Applications FAQ page at http://www.icann.org/tlds/tld-faqs.htm:
“Only
the following materials will be accepted after the 5:00 pm (California time) 2 October
2000 deadline: (a) notification of a material change in circumstances…”
This summary
document is an effort to provide, to ICANN and the Internet community, information
necessary to more deeply consider our application and approach.
FINANCIAL,
OPERATIONAL AND BUSINESS CONSIDERATIONS
Diebold has fully considered the capital,
staff, marketing, expense and operating costs necessary for the successful implementation
and operation of a TLD registry/registration business. Diebold is a nearly
$2 billion corporation with annual product and service R&D spending of nearly $50
million (see http://www.diebold.com/investors/default.htm for more information
on Diebold’s financial position and SEC filings). Diebold has assessed and
is budgeting for funds necessary to fully support our proposal at all projected business
levels, and has additional funds available for unforeseen contingencies.
Diebold
also has a very low debt ratio and high cash reserves in comparison to other companies
in our industry. In brief, we are committed to the operation of a new TLD registry
as a strategic part of our ongoing business operations.
Some of the costs that
might be incurred by startup organization will not be realized by Diebold:
- Diebold
has, for many years, operated a 24x7x365 award-winning multi-lingual call center
(our Customer Response Center, or CRC) capable of handling customer service calls
of many types (please see our website at http://www.diebold.com/gsseemcsol/Default.htm
and
http://www.diebold.com/products/servicesandsupport/support.htm
for more
information on our newest call center). Diebold receives tens of thousands
of voice and data calls each day to our CRC.
- Diebold operates a 24x7x365 UL-rated
Event Monitoring Center (EMC) for the real-time monitoring of status messages and
related information key to the operation of our customers’ and internal systems (see
our website at http://www.diebold.com/gsseemcsol/Default.htm for information on our
EMC and http://www.diebold.com/gsseemcsol/Default.htm for information on the types
of services already supported by these facilities).
- Diebold’s CRC and EMC facilities
are currently staffed by more than 350 full time employees ranging from call handlers
to technical support staff to senior management. A variety of disciplines are
represented, including hardware support, software support, integration support, network
and communications systems support, call dispatch and handling, problem escalation
specialists, and administrative resources. Diebold proposes additional resources
(depending on business level requirements) that will act to augment, coordinate and
manage existing resources. In addition, Diebold intends to hire additional
staff specially trained and suited to operate the proposed TLD registry. This
is additive to the staff listed in our application, many of whom are already well
versed in the nuances of our technical model.
- Diebold has the necessary existing
infrastructure to house both the systems and additional personnel necessary to support
our proposal at all levels of potential business. In addition, Diebold is prepared
to augment those significant resources with additional facilities and systems as
is necessary to run an efficient and successful registry.
MARKETING
CONSIDERATIONS
As a very successful $1.3+ billion corporation, Diebold clearly
understands the value of appropriate marketing planning and budgeting. Diebold
also understands the highly variable nature of funding requirements necessary for
marketing efforts. We have planned levels of funding and staffing for marketing
that are highly flexible and appropriate for the level of business.
Diebold
has several marketing organizations, all of which will be employed by the TLD registry
operation as necessary in their areas of principal expertise. Our Managed Services,
Professional Services, Traditional Services, Global Marketing, Direct Marketing and
Corporate Communications organizations all will be employed in various marketing
efforts for the TLD registry.
Diebold also utilizes the services of Dix
& Eaton, a highly respected marketing and public relations firm, as well as many
others outside the corporation.
TECHNICAL CONSIDERATIONS
Diebold
believes the vast majority of technical questions have been answered in our application.
Operational and planning issues related to technical capabilities are addressed elsewhere
in this document.
FIT WITHIN DIEBOLD / ORGANIZATIONAL STRUCTURE
Diebold’s
TLD Registry Operation will be an integral part of the Diebold Managed Services organization.
Existing managed services within the group include:
- Advisor: Diebold’s
ATM event monitoring service (see http://www.diebold.com/gsseemcsol/ATMStatusMonitoring.htm)
- Alarm
Monitoring: Diebold’s security and alarm monitoring service (see http://www.diebold.com/gsseemcsol/AlarmMonitoring.htm)
- Electronic
Lock Monitoring: Monitoring of electronically controlled access locks (see
http://www.diebold.com/gsseemcsol/ElectronicLock.htm)
- RemoteLink: Our
unique subscription-based content delivery system for delivery of screen and other
content to ATMs and similar devices (see http://www.diebold.com/gsseemcsol/RemoteLink.htm)
- Cash
Management: Our service for the monitoring of cash levels at cash dispensing
devices
- SERAS: Services Electronic Reporting Access System – Our industry-first
system for secure web access to information related to Diebold managed services (see
http://seras.diebold.net).
Diebold envisions our TLD Registry operation
as an integral, intuitive and logical extension of our existing Managed Services
businesses, as well as a new initiative for the company in line with our strategy
to expand our technology-based services capabilities.
We believe our experience
with highly detailed, technical services operation uniquely suits us as a potential
new TLD registry/registrar. Few, if any, of the other TLD applicants can demonstrate
the successful deployment of such a variety of high-end managed services.
SPECIFIC
ISSUES RAISED IN THE REPORT
Diebold understands the concerns expressed
in the Report. Without appropriate information, it can be difficult to assess
whether an organization has the wherewithal to enter into a business model for operation
of a new TLD registry. While we believe this document should answer many of
the issues raised, there are specific questions posed by the Report we will address
here.
- ISSUE: “the Diebold proposal, when compared with the other
proposals in this group, provided virtually no information about the organization
that would actually operate the registry. Specifically, the proposal lacked information
on how the Diebold technical team would be staffed, resumes of the principal managers,
where registry operation would fit in the Diebold organization, and how additional
software would be provided.”
- RESPONSE: We believe many of the staffing
and organizational positioning issues have been addressed elsewhere in this document.
There are still several unanswered questions, however.
o Resumes of principal
managers – This information will be forwarded forthwith and for immediate public
review.
o Additional software – Diebold expects to continue to develop its registry/
registration management system with in-house resources (200+ software engineers available
within the company, 6 dedicated to the registry/registration management system).
Diebold has also employed, as needed, contract programmers for this and many other
projects. In addition, Diebold will use, where appropriate, existing/packaged
software products for incorporation in the overall system. Diebold has also
anticipated the need for “emergency” resources as necessary to support a “start-up”
operation, and has budgeted and contracted accordingly.
- ISSUE: “The
business/financial team concluded that Diebold's application did not include a thorough
analysis of the target market or a detailed marketing plan. The application did not
provide a sufficient rationale for the estimated demand or the resources to meet
that demand. Without such details, Diebold's application was not complete enough
to demonstrate an understanding of what is involved in operating a registry business.”
- RESPONSE:
There are really two aspects to the issues raised above: Target Market and Marketing
Plan.
o Target Market: Diebold has extensive and lengthy experience doing
business with the financial, retail and campus (colleges and universities) markets.
Our strength clearly lies in these markets, although we have significant business
in other markets as well. Diebold certainly envisions leveraging this experience,
without throttling a new TLD’s potential by forcing our view on the world.
Diebold has stated that we believe in an organic model of growth of the DNS space.
Therefore, we have no one specific target market. Our registry model will succeed
regardless of our own utility within it. While this allows for a great deal
of leeway in the acceptance of registrations, we believe that is its greatest strength.
Diebold believes that markets will choose the TLDs where they feel their interests
are best served. Diebold intends to “open up a market” for the organic organization
of affinity groups within TLD’s. As stated in our application, a TLD such as
“.secure”, for example, would provide a natural migration point for several different
business models:
§ Security alarm monitoring over the Internet
§ Security product
sales over the Internet
§ Secure financial transaction over the Internet
§ VPN
services over the Internet
o Comment: An observation was made toward another
applicant that their concept was sound, but they proposed use of a proprietary technology,
rendering the application perhaps inappropriate. Diebold wishes to define potential,
not method, and avoid such a potentially negative view. The history of the
Internet shows that this organic model succeeds, because it allows for an open approach
to solution definition.
o Market Planning: Diebold has prepared several marketing
scenarios to address the potential for differing levels of competition. For
example, our proposed “.global” TLD could have many uses, including competition and
relief for “.com”, “.net” and other general use TLDs that might be approved by ICANN.
Depending on the competition, and the acceptance of our TLDs “.cash” and “.secure”,
the marketing approach we actually take could vary quite widely. For budgetary
planning purposes, we have assumed the highest level of competition (acceptance of
10 or more general use TLDs in addition to restricted use TLDs).
SUMMARY
Diebold
believes our application, with the additional information provided herein, provides
a complete and appropriate application for a new TLD registry. Our history
of success, technical expertise and formidable resources offer the highest opportunity
for success. We look forward to working with ICANN and the Internet community
to extend the DNS space in a reasonable and responsible manner.
Regards,
Gene
Marsh
Senior Manager, Services Development
Diebold Incorporated
marshm@diebold.com
330-498-2670