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Username: Chalandon
Date/Time: Tue, November 14, 2000 at 12:54 AM GMT
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Subject: .TEL RESPONSE OF TELNIC TO ICANN EVALUATION REPORT

Message:
 

 
       
      TelNIC Limited:  .tel

Review & 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


 


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