Thanks to this note Dada S.p.A and its partner Register.it
wants to reply to the judgment expressed by the evaluation team published on the
Internet site www.icann.org/tlds/report , so how it has been specified into the summary
of application of Design Architettura Digitale Analogico S.p.A., and regarding its
application for the assignment of a new TLD denominated .PID. The evaluation team
has enclosed the proposal regarding the DADA's TLD inside the group "new services",
and then it has noticed that (www.icann.org/tlds/report/report-iiib3-09nov00.htm):
" The technical team concluded that DADA SpA's application did not demonstrate realistic
technical and operational plans. The applicant has not demonstrated that it has the
relevant technical expertise and the proposed technical plan did not support the
proposed business plan in the several areas, including under-specification of fault
tolerance and security." Faced to this kind of judgment, DADA and Register.it
confirms the validity of its .PID project for the assignment of a new TLD on Internet.
All the accusations of technical incapacity promoted against DADA and its project
are obviously offensive and above all those accusations are heavily affected by commission's
evaluation errors.
As a matter of fact:
1) The evaluation team has badly examinated
DADA's application. Following there are few examples:
ICANN request
D13.1.7.
Staff/employees. Current staff size, demonstrated ability to expand employee base,
hiring policy, employee training, space for additional staff
DADA reply
D13.1.7
Please see Part I - Information on DADA of "Prospectus relating to the admission
to the Italian New Market and the public offer for the sale and subscription of the
ordinary shares of DADA.
Into the part number 1.6 of DADA's informative prospectus
is clearly indicated that at the date of May 31, 2000, Dada had eighty-seven (87)
employees (today DADA has one hundred and forty (140) employees).
ICANN request
D15.1. Detailed description of the registry operator's technical capabilities
DADA reply
D15.1. The technical staff is formed by a group of 20 programmers
and 10 system-analysts and software engineers. Moreover, a group of 10 system integrator
is concerning about internet connectivity and the monitoring of the network."
On
the contrary the commission affirms (into the Business Review, section c, of the
Application Summary) DADA has only five (5) employees.
And more:
ICANN request
D8.
Registry operator's total revenue (in US dollars) in the last-ended fiscal year.
DADA
reply
D8. December 31, 1999 (12 months) 4.335.775 USD, June 30, 2000 (6 months)
6.474.419 USD
On the contrary the commission affirms (into the Business Review,
section c, of the Application Summary) that DADA at June 30, 2000, "had six-month
revenues and net assets of approximately 13.9 million Lira and 169 million Lira,
respectively".
It is a serious mistake that had heavy repercussions on DADA valuation,
and this fact demonstrate how the commission evaluation of DADA proposal has been
superficial and insufficient. It is not possible to consider that a society listed
to the Italian New Market could have just a half-year turnover of 13.9 millions of
lira ad just five (5) employees.
2) Probably because of a quick check of DADA
proposal, there is another heavy mistake that injure the credibility of commission
judgment: in fact the DADA project has been enclosed into the New Services- Message
Routing Group instead of General-Purpose TLDs - Personal Group. Actually DADA proposal
aimed to obtain the assignment of the new TLD denominated .PID (Permanent Identification
Domain or Personal Identification Domain) to move to the market of all human beings
that want to be identified on the Internet by a unique internet address. So, made
clear this point, the development of .PID as a tool of connection between different
communication system was only one of the many potentialities of DADA system, but
it was not the core value proposition. Considering these facts, DADA right to be
enclosed into the General-Purpose TLDs - Personal Group is clearly evident. There
are many and many similarities between DADA proposal and the other proposals enclosed
into this category (for further details see also: http://www.permanentidentifier.com/personal-use.htm).
The
category error has been evident and it has compromised DADA work: in fact DADA proposal
has been estimated with different parameters because of the wrong category. The category
error has brought to unfit parameters for a right valuation because those parameters
where good for a different hypothesis: the negative judgment on DADA proposal comes
from this error.
There for, WE ARE ASKING DADA PROPOSAL TO BE ENCLOSED INTO THE
PERSONAL GROUP ANS RE-ASSESSED AGAIN.
3) Moreover, the enclosing of DADA application
into the Personal Group category would have a positive effect on DADA capability
to become Registry of the new .PID domain. Actually, the negative judgment of the
evaluation team on DADA application has been basically based on technical motives.
Well, DADA S.p.A. is a Registrar since Semptember 21, 1999, and it has been regularly
approved by ICANN for the .com, .net, .org, TLDs. As a Registrar, DADA has to guarantee
a complete technical reliability. All those technical requirements that DADA has
and that ICANN approved, were totally ignored by the evaluation team. ICANN never
disputed the lack of those requirements to DADA: this fact demonstrate DADA has all
the technical reliability to support the new TLD proposal. Further, we enclose DADA
technical department paper about your comments on application: we give You some annotations
to valuate the critics over the letter B. of the technical Review of the Summary
of Application of DADA S.p.A (for further details see also: http://www.permanentidentifier.com/technical-addendum.htm.
In conclusion, You have to notice that all these information should have been
be requested to DADA by the Commission before to be published on Internet. This way
of doing has been adopted in many cases like: da recuperare sul web, nella parte
delle valutazioni dei domini personali
This different way of proceeding damaged
DADA interest under different ways. In particular, all the critics have unfairly
denied to DADA the possession of the fundamental requirement to be Registry. These
unfair accusations produce a damage to DADA, therefore we have alerted our lawyers
to verify the opportunity for a legal action.
In the meanwhile, DADA S.p.A. and
Register.it formally asks ICANN to:
- Remove immediately the web pages (www.icann.org/tlds/report/report-iiib3-09nov00.htm)
where are enclosed all the wrong judgments of DADA application.
- Enclose its application into the Personal Group,
- To proceed with a brand new control of the application