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Username: JohnR
Date/Time: Wed, March 14, 2001 at 3:27 AM GMT
Browser: Netscape Communicator V4.75 using Windows 98
Score: 5
Subject: Petition ICANN speaks for fairness rather than its relationship with Verisgn!


        Dear Sir or Madam:

It is pity for other registrars to see that Verisign plays a dual role in the domain industry, i.e., as both registrar and registry.  Because of this particular situation, the competition is never fair.  In my view, other registrars stand at a lower level because they have to
get approved by the “big brother” registrar Network Solutions.  It is a pity.  As a result, this arrangement has caused damage to other registrars and registrants as well because Network Solutions has all kinds of advantages over other registrars.  One damage is the domain hoarding by Network Solutions.  Because Network Solutions has a
double-edged sword (registry and registrar), they do not have to pay a dime to keep the expired domain names.  Because the expired domain names have not been released for the public to register, the interest of consumers and other registrars has been significantly damaged.

We, a domain reseller, have always heard people’s complaint about the service of Network Solutions including its domain  hoarding.  It is very surprising to hear ICANN’s claim that it has not received many complaints about the practice of Network Solutions.

The government wanted to break Network Solutions’ role as both registry and registrar based on the belief that the separation is the basis for a fair competition among the registrars.  It seems to me that the reason the government has not broken Network Solutions at its first attempt because it will need to take some time and administrative process to smoothly break it up. This fairness can only be realized when the registry has been separated from the registrar. 

We believe the competition among the registrars is still unfair.  ICANN cited the domain share as the evidence to support its arguement that the competition is good enough that no separation of the registry and the registrar is necessary.  While we acknowledge that there is some severe competition among the registrars, we have to emphasize that the fact that the share of Network Solutions has shrunken does not mean the competition is fair.  The share distribution change is only an incitation of competition.  It does not necessarily mean this competition is fair.   The fairness can only achieved by the separation of the registry and the registrar.  Without the separation, Verisign can use the $6.00 domain fee from other registrars to support its competition with the other registrars. Or without paying a fee, hoarding expired domain names so that other registrars can not register them for their clients.

We do not think ICANN has offered sufficient evidence or even explanation to support its argument that the separation is not necessary.  As a domain reseller with ample experience dealing with registrants, we strongly believe that the fairness of competition among the registrars has not been achieved.  Verisign must separate its dual function in order to maximally secure a real fair competition.

On the other hand, we do not see any potential damage to the Internet community could be caused by this separation. The big loss for Verisign, though, is that it can no longer use the domain fee to support its competition with its rivals.

We petition ICANN speaks for fairness 

John Robert
Director, Business Communication
Marsgerm Technologies, Inc.  

Note: anyone who is interested in sending a comment or petition to iCANN or the Department of Commerce, feel free to use the content of this petition if deemed to be useful.


Link: Domain Manual

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