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Keep Competition for Registry Services

  • To: <settlement-comments@xxxxxxxxx>
  • Subject: Keep Competition for Registry Services
  • From: "Tony Farrow" <tony@xxxxxxxx>
  • Date: Wed, 7 Dec 2005 23:15:49 -0500

December 7, 2005


Mr. Paul Twomey

President and CEO

Internet Corporation for Assigned Names and Numbers

4676 Admiralty Way, Suite 330

Marina del Rey, CA 90292-6601



Dear Paul:


I am writing this letter in response to your call for comments from the
internet community on the proposed .com Registry Agreement with VeriSign.
As you are aware Pool.COM is focused on the secondary market for domain


I attended the ICANN meeting in Vancouver and was present for many of the
discussions on the subject of the proposed .com deal.  In the time I have
been paying close attention to ICANN proceedings, I do not believe I have
ever heard the community in as much agreement as it is on this deal.  


You heard what I heard.  The new registry agreement must not be approved.
In fact, it ought to be set aside and the current contract allowed to run
its course, and then re-bid competitively.


Of particular interest to me are the changes it would bring to the process
of creating new registry services.  This proposed .com agreement prevents
community input into new registry services; the agreement creates a
work-around for government oversight of these registry services and allows
VeriSign expansion into what are now highly competitive markets.  In the
secondary market alone, companies like Enom, SnapNames and Pool.com make it
a vibrant and competitive marketplace.


It is clear that at the onset of both the internet and ICANN the focus was
on new domain names and a policy process to help expand global access to the
internet.  Much like the housing market in most countries (certainly here in
Canada and in the U.S.), the secondary market has surpassed the economic
activity of the primary market.


I believe this is what is driving VeriSign to use its club of litigation to
get terms in this proposal that would monopolize a market it never saw.
Other companies, including Pool.COM, realized this opportunity and created
new secondary market services.  Today these companies compete at prices and
service levels that only result from competition.  


I want to be responsive to your call for specific recommendations, too.  


First, let me start by saying ICANN needs to balance the commercial
interests of all participants within the internet not just one party, namely


Second, registry services must result from the policy development process
within ICANN not from a single organization's product roadmap.


Third, recognize that .com, of all registries, occupies a unique market
position and should have greater scrutiny, not less, on the expansion of
those registry services.  


We at Pool.COM are not afraid of competition.  We live it everyday competing
for both customers and partners.  Competition ensures that we provide
satisfactory levels of service and return to our partners.


By bundling the settlement of litigation, the renewal of the .com contract
and new registry services together you are allowing VeriSign to run
secondary market service exclusively.  Today this service is being run
competitively by four or more suppliers.  The proposed .com settlement
agreement demonstrates that ICANN believes the secondary market service is
required but the service should not be a competitive one.  


Just one run by VeriSign.




Tony Farrow




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