TelNIC Limited: .telReview
& Report on TLD Applicant Response
To: The Directors of ICANN
Re: .TEL proposal
from TelNIC Ltd.
Date: November 14th 2000
Dear Members of the ICANN Board,
During
the past few years, TelNIC has endeavored to create, test and develop a powerful
new concept that will revolutionise the whole Internet-telephony industry.
In a
nutshell, this concept is to create a new telephone addressing system based on words
and names instead of numbers. TelNIC’s objective is to allow for identification of
voice–enabled Internet devices through the DNS, i.e. in order to call John Smith
in the UK, a caller would simply enter john.smith.uk.tel instead of having to dial
a traditional telephone number for John Smith, such as +44 20 7498 7257.
The need
and power of this new addressing system is obvious and your staff has explicitly
recognised that out of the four proposals in the telephony related group “the TelNIC
proposal is the strongest in meeting unmet needs.”
After reviewing in detail the
comments set out in the staff report we were extremely surprised that your staff
recommended that ICANN should not take TelNIC’s application to the next stage of
active discussion.
Indeed, we believe that your staff report has not revealed any
major flaws in our proposal which would justify such a recommendation, so the proposal
may have been shelved for other unspecified reasons.
ICANN staff have outlined
certain criticisms or cautions which are set out and answered thus:-
1 The concerns
raised and caution urged by the ITU, counsel against establishing a telephony-related
TLD until further study and consensus-building within the Internet and telephony
technical communities.
2 Each of the four proposals appears not to have adequately
addressed requirements for stable, authoritative coordination with the PSTN numbering
system, particularly when dynamic-routing considerations are taken into account.
3 Moreover,
if a TLD were established in which the service available at URLs was defined by the
TLD rather than the prefix, this would likely increase confusion regarding URL naming
conventions.
4 The technical team stated that “TelNIC’s application was roughly
adequate to the stated tasks, although somewhat under-specified in some areas.”
5 The
strengths of this application lie in TelNIC’s financing, the large potential market,
and experience in registrar operations. The weaknesses relate to the lack of
a quantitative market analysis and support of demand assumptions. Overall, there
are other applications in this category that are stronger from a business plan perspective.
The
first three criticisms were applied to all four applicants in the telephony group
but we consider they do not impact upon us in view of the unique word-only basis
of our application. The last two criticisms pinpoint minor weaknesses in our proposal
which can be easily remedied.
1.0 Response to Point 1
"The concerns raised and
caution urged by the ITU, counsel against establishing a telephony-related TLD until
(after) further study and consensus-building within the Internet and telephony technical
communities."
1.1 Our analysis should be read against the background that all the
other applications in the telephony group all involve exclusively numbers and we
therefore feel extremely confident that our word/name approach is unaffected by the
ITU letter submitted to ICANN by the ITU on 1 November 2000 (the “Letter”).
1.2 In essence, ITU’s recommendation to ICANN is that it would be “…premature
for ICANN to grant any E.164-related TLD application …”. The ITU only takes
on a “coordinating role” regarding numbering assignment which should be contrasted
with administration and operation of the network infrastructure.
1.3 The
success of the Internet is due largely to its accessibility and facilitation.
The Internet allows access by a wide variety of hosts due to the numerous protocols
available to the Internet community, and these protocols allow disparate machines
to communicate over a disparate network. The ITU wants the development of a
global numbering/addressing scheme to accommodate PSTN and IP-based networks before
telephony-related TLDs are issued. However, as advocated by the ITU itself,
there is a convergence of networks that allow one network to be integrated with any
other network. The use of IP and this ability to integrate with existing networks
allows for the global integration of voice, video and data facilities.
1.4 The
TelNIC .TEL TLD concept relies on existing IP technology in that it allows for DNS
look up to enable the IP-enabled device to make and receive the call. This
means that fundamentally TelNIC does not use E.164 numbers in its domain names and
therefore TelNIC’s application should not be affected by the ITU recommendation or
be subject to the telecommunications regulatory regime. Accordingly, TelNIC’s .TEL
TLD application should fall under the remit of ICANN.
1.5 TelNIC agrees
that the regulatory aspect of the Internet should be managed in a transparent way
that ensures that domain names and addressing systems are maintained on an equitable
basis, to facilitate the protection of intellectual property rights and to promote
a fair competitive environment. However, the development of the Internet is largely
driven by private initiative and is, of course, market led. The development of IP-based
networks and the growth of the IP environment will not stop simply because ICANN
does not issue telephony-related TLDs.
1.6 Another argument raised by ITU
in its Letter is that it may not benefit the Internet community to allocate certain
TLD’s at this time. The ITU do not argue this point persuasively and TelNIC
would assert that it is in the interests of the Internet community to issue additional
TLD’s at this time because it will lead to increased TLD availability and a better
choice for individuals and businesses.
1.7 It is also worth noting
that theoretically any domain name could be used for the purposes suggested by TelNIC.
The extension .TEL we believe is just the most appropriate description to use.
However, if any domain name could be used for packet switching and telephone routing,
what is to prevent the ITU demanding an effective veto and/or control of the entire
Domain Name System so as to dominate such domain names?
1.8 It may be perceived
in the marketplace that the ITU’s concern stems from the capability of the TelNIC
concept of being able to supply users with an Internet–communication address for
life that can be used to make a call anywhere in the world, where the maximum call-cost
is at the local rate. Accordingly, the implications of .TEL and a mature Internet-communications
industry could be far-reaching on the billing structure and revenue streams of the
ultimate constituents represented by the ITU. Even if there is a move to levy charges
or exercise control more familiar to traditional telecommunications industry, ICANN
should not use the inevitable convergence and progress of technology, on the recommendation
of the ITU, as a reason to suppress the innovation of the Internet. As technologies
continue to converge and blur the already indistinct boundaries, the pressure to
deregulate and simplify the global regulation of telephony and Internet integration
will increase.
1.9 Although TelNIC welcomes open, healthy debate, and cooperation
on the formulation of Internet-communications policies and planning, it is in the
interests of the Internet community as a whole to come of age and take proactive
initiatives to push frontiers, and not be reactive to preserve old-orders that have
other agendas. This is particularly so when it comes to the incumbent telecommunications
industry, the DNS and Internet-communications. If the ITU’s case is of concern, and
there is a need for special frameworks, then there is sufficient room for an alternative
and distinctly separate TLD solution that is specific to PSTN: .PSTN?
2.0 Response
to Point 2
"Each of the four proposals appears not to have adequately addressed
requirements for stable, authoritative coordination with the PSTN numbering system,
particularly when dynamic-routing considerations are taken into account."
2.1 We
have not addressed the requirements for stable authoritative co-ordination with the
PSTN numbering system because we are working to the imminent IP future that is beyond
the PSTN system and numbering conventions. This all IP communications world, that
is happening now is one which has been fundamentally recognised by the ITU itself.
Therefore the crux of our proposal is that we are not dependent on the PSTN numbering
system; in fact ultimately the opposite is true.
2.2 It is also noted in the report
that TelNIC’s application does not specifically renounce the future use of numbers
as SLD strings. We believe that our proposal is clearly a word based system
and we are therefore happy to consider and are willing to discuss any solution to
avoid compromising the E.164 numbering system.
3.0 Response to Point 3
"Moreover,
if a TLD were established in which the service available at URLs was defined by the
TLD rather than the prefix, this would likely increase confusion regarding URL naming
conventions."
3.1 TelNIC believes there is very limited relevance to its proposal
of any argument that the standard conventions [RFC 2806] which designates the word
“tel” at the beginning, as against the proposed [TLD .TEL] at the end of the URL
will hamper consumer acceptance.
3.2 The dimension of the market for Internet-communications
that TelNIC will develop is so wide, so innovative, and so multi-faceted that it
demands its own TLD, rather than a prefix tel://ICANN.org system that is an adjunct
and after-thought to an existing structure. We have progressed from the basic and
one-dimensional Internet-communications time that the RFC2806 accommodates, and the
time is now right for a dedicated Internet-communications TLD that expands and enhances
the DNS. The creation of a TLD is a necessary pre-requisite for the many services
which will follow from the introduction of a dedicated word-based addressing format.
3.3 TelNIC
sees the vision of a truly diverse Internet-communications future that is using DNS
in very creative and clever ways to create interactive voice-driven services. There
are many considerations along this road, and it needs to be approached in a sophisticated
and well-structured manner. This can only happen along lines similar to those we
propose.
3.4 RFC2806 is adhered to and used very little, and it does not satisfy
innovation or the huge potential growth of Internet-communications. However there
is no reason why RFC2806 cannot quite satisfactorily remain intact for the foreseeable
future until its probable disappearance from use altogether. In any event even before
critical mass is achieved, the greater likelihood is of the introduction of an alternative,
namely the entry of the domain name only and the use of a .tel icon to trigger the
call – thereby removing the need for either prefix or suffix.
4.0 Response
to Point 4
The technical team stated that “TelNIC’s application was roughly adequate
to the stated tasks, although somewhat under-specified in some areas.”
4.1 TelNIC
has worked with a number of well established institutions, including Ericsson, Oracle,
Planet Online and the Defence Evaluation and Research Agency (DERA) of the UK Ministry
of Defence – all leaders in their respective fields.
4.2 Ericsson – a world
leader in communication and especially mobile infrastructure - carried out “proof
of concept” certification for the immensely progressive Internet-enabled UMTS environment
with DERA, thus demonstrating that the simple entry of “johnsmith.tel” into a UMTS
device would successfully result in connection to John Smith on his UMTS mobile phone.
We draw your attention to the Ericsson letter which accompanied our application.
4.3 TelNIC
has been found by ICANN to be well financed and we naturally welcome a discussion
to iron out any substantiated technical deficiencies. These will be addressed and
resolved immediately and our investors have indicated that they will make available
any additional funds which may be required in this connection. Fixed IP to IP – an
ever-expanding market – must be the staple diet for TelNIC’s registry in the early
days. The evaluation team comments that “mobility may require much more frequent
SRS and DNS updates”. These are amongst the issues which TelNIC has flagged and is
already working on – hence the importance of working with a world leader such as
Ericsson - but the fact that future (even imminent) new systems may not yet have
been totally architectured should surely not preclude the issue of a TLD to deal
with today’s environment. The TLD will simply provide a small but vital piece of
information to the software and hardware manufacturers and their designs will doubtless
reflect the most practical solutions for the particular tasks in hand. This is quite
fairly reflected in the findings under “Stability”. The endless value added services
– such as call forwarding – will not be handled by either registry or registrar –
but by ITSP’s which will host subscriber’s domains.
5.0 Response
to Point 5
"The strengths of this application lie in TelNIC’s financing, the large
potential market, and experience in registrar operations. The weaknesses relate
to the lack of a quantitative market analysis and support of demand assumptions.
Overall, there are other applications in this category that are stronger from a business
plan perspective."
5.1 We do not understand the comment relating, “to lack of quantitative
market analysis and support of demand assumptions”. By definition we are talking
about a market, which is currently small but growing quickly and as described in
the sentence before as having “a large potential.” We had considered this point in
some detail and came to the conclusion that the market for the service we are trying
to provide is indeed large and our assumptions for the take up in our models would
be met.
5.2 In our research we found that when the proposition was put to
private individuals the potential take up at the pricing levels we are suggesting
surpassed all expectations. We believe that the least of our concerns is the
level of demand. It should be borne in mind that the TelNIC application greatly simplifies
addressing structures and gives the customers control over their telephony addresses
as well as the ability to retain those addresses if they change their telecom supplier.
Our system will also enable users to choose which package of services to purchase
from which supplier without the restrictions which currently tie consumers into particular
suppliers. The interest of the Community its serves cannot therefore be lightly bypassed.
5.3 Even
if the take up was weak initially you will see we have sufficient capital (and more
could be made available) to ride out slow market demand. A further comment
in this vein in the report was that “ usefulness of the service depends upon the
presence of a significant number of voice enabled systems that could place and answer
calls.” The answer to this point is of course – yes certainly, but software
implementations will fix this and we believe software developers will be queuing
up to resolve this situation rapidly. Much progress will be made to advance upon
the systems available today.
5.4 Thirty of the world’s largest companies, including
Internet based ones, have expressed to Telnic a serious interest in using their names
and brand names followed by the suffix .tel and many of them see the enormous additional
benefits of mapping their staff worldwide for telephony with the format of employee-name.tel
or company-name.tel (i.e john.smith.hertz.tel). We will be pleased to show ICANN
this list during discussions.
In view of the above we believe that it would not
be fair to disqualify our application on these grounds without giving us the opportunity
to explain, discuss and remedy.
6.0 Conclusion
6.1 In order for the Internet
to optimise the current opportunities and the role it has to play in voice-driven
communications, it is essential that a new really user-friendly TLD dedicated to
voice-driven communications is issued now.
6.2 TelNIC Ltd. acknowledges the basis
of concern as detailed in the Review Recommendation; however we strongly recommend
that the two issues of a DNS based solution for Internet-communications, and that
of a PSTN based solution are not confused and should be clearly separated out. This
will allow ITU centred debate to take place on PSTN matters, whilst letting the forces
of the Internet (and .TEL) take their own more vigorous and forward-looking course.
6.3 TelNIC
believes that the expressed ITU factors should not prevent the development of exciting
new Internet-communications - and the starting of a dedicated new TLD that positively
exploits DNS. Historically innovation and progress in the telecommunications industry
has been slow and unresponsive. Compared with traditional telecommunications and
their regulatory mechanisms the Internet moves at a remarkable and commendable speed.
The ITU expresses great concern in stating that the “E.164 international public telecommunication
plan is a politically significant numbering resource with direct implications of
national sovereignty.” TelNIC’s response to ICANN is to reiterate that its proposal
is clearly a word based system and therefore does not compromise the E.164 numbering
system.
6.4 The issuing of a .TEL domain-name addressing structure will
be a defining moment for Internet-communications and it will represent a maturing
of this exciting new Internet industry. Also importantly, it will define an independence
and separate identity from traditional telecommunications.
6.5 ICANN has found
no critical flaws with our concept – only certain weaknesses which can readily be
remedied given the resources at our disposal.
TelNIC should be given
the opportunity to actively discuss with ICANN the best resolution of any deficiencies
which ICANN has highlighted and TelNIC’s investors will provide any additional funds
beyond the substantial resources already outlined.
We respectfully ask ICANN
to strongly consider these crucial points and issues and discuss with TelNIC ways
to move ahead with the development of a dedicated Internet-communications based TLD
on the DNS lines we propose.
We believe that the interest of the Internet Community
and ICANN are best served from the speedy introduction of a user-friendly and customer
driven addressing architecture for IP based communications. Therefore, we urge ICANN
to act upon this timely opportunity to reach out and expand the scope of the Internet
to users all over the world in this exciting new arena.
Yours sincerely,
TelNIC
Limited Board
Contact points:
Alan Price Martin Augier Fabien Chalandon
Director Director Director
Tel: +44 207 776 52 21 Tel: +331 47
03 3424
price@telnic.org augier@telnic.org fc@telnic.org