I was concerned to read
the evaluators’ comments about Image Online Design’s application as compared with
its evaluation of Afilias’. I found a twisted double-standard, lack of logical reasoning
and a certain elitism to be involved. The evaluators cast serious doubts
upon IOD’s ability to register dot webs; it furthermore questions the credibility
of 20,000 dot webs having been registered. Rather than randomly and bizarrely questioning
the veracity of such statements, perhaps the evaluators should have investigated
further (the point is for applications to be intelligently reviewed, is it not?).
If there is a question of the registrations existing, it is incumbent upon the evaluators
to ask to review the evidence (e.g., the data base). Certainly, IOD is fully able
to provide registrations. It has been doing so since IANA gave it the go-ahead four
years ago. All this is easily verifiable, instead of being subject to derisive cursory
statements. A complaint is made that IOD has no experience running a larger
registry. However, it has not been given the opportunity. Such a statement implies
that TLDs should only be managed through established registries. This means that
newcomers to the field who have demonstrated some proficiency are still not within
the purview of what the evaluators consider to be acceptable. The result is either
a monopoly or a “good old boy network” that keeps out the new blood. IOD’s “several
years [sic] experience” running a registry is not for some reason considered valid
experience establishing and maintaining a data base. On the contrary, IOD’s experience
managing the 20,000 names demonstrates flexibility, innovation and chance to identify
any “bugs” in the system. Criticism is made of IOD’s system. If the above-mentioned,
easily checked material has not been checked, it is doubtful that the evaluators
have fully checked out IOD’s software and hardware. Not having visited IOD’s facility,
and not knowing the extent of its upgrades, the evaluators are not in a position
to judge its ability or inability to handle an influx of registrant requests. Their
reasoning is vague and, frankly, nonexistent. The concession that “they have demonstrated
competence in all relevant areas” seems to be a “by the way” of no importance based
on the earlier comments. The lack of consistent reasoning is apparent in
the evaluators’ complaint that IOD’s staff is also involved in other corporations.
The comments on Afilias (whose application is much more favorably reviewed) do not
take such a negative view of this intended registry's personnel being involved in
other companies. Afilias is a new company, rapidly constructed in September to request
registry status. It does not have the history of service and data base activity that
IOD offers. An honest mathematical question was raised: if Afilias is honest in its
financial projections, it would rapidly dip severely into the red. This is not a
forecast that would bode well for a stable registry. This kaleidoscope of
bizarre reasoning on the part of the evaluators continues. IOD is lambasted for not
having a second office; the Afilias address is not its own, but is within a highly-prestigious
New York legal firm. IOD’s ability to handle a large influx is questioned, despite
its well-functioning database; Afilias is praised despite its having no database.
IOD earns negative points for not having a large enough body of personnel; Afilias
has no clear personnel at all. The lack of cohesive logic goes on and on. Furthermore,
no mention at all is made of Afilias’ request for several TLDs. IOD has only asked
for one. Surely diversity in the registrars is a prime necessity to encourage competition
and service. Lastly, a post by Christopher Ambler notes the varied serious errors
made by the evaluators. Such mistakes show a blatant disregard for truth and seem
to favor a slant toward some hidden agenda. Thank you for reviewing these
comments. I trust a re-review of the applications by more careful evaluators will
allow for a more cogent appraisal, viewing the applicants regarding what they have
already demonstrated, and allowing newcomers entrance to the registry field.
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