Reconsideration Request 00-16
Received: 16 March 2001

Note: The following letter was physically handed to ICANN staff during the Melbourne meetings. The letter is being treated as a clarification of Telnic's original reconsideration request.

Mr.Hans Kraaijenbrink
Chairman of Reconsideration Committee
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292
United States of America
13th March 2001

Dear Mr Kraaijenbrink,

RE Reconsideration Appeal

We would like to thank you and your fellow Directors Messrs. Cerf, Blokzijl and Schink for taking time out of you busy schedules to meet with us and listen to the issues relating to our gTLD application. We believe that there exists substantial factual information contained in the attachment to this letter which may not have been clearly communicated or was not fully understood at the time of the original resolution 00.89 of 16th November 2000. Telnic has been damaged by being denied the opportunity to operate a .tel TLD registry.

We have taken the opportunity to summarise the key points in this letter but if you have any questions or concerns please do not hesitate to contact us.

1) Background

TelNIC Limited originated the .tel concept as a new and distinct top-level domain to fill a need for voice-driven IP communications. The concept is simple: it is to use the descriptive power of words rather than numbers for individuals and corporations to contact each other. In effect, this is extending the application envelope of DNS. So put simply, instead of dialling:

(00) 44 (0) 870 599 6699 for Hertz you could "dial" hertz.tel

Alternatively, instead of 020 7273 4567 for John Kent you could also "dial" johnkent@home.uk.tel

In the same way that an ever larger number of individuals and corporations have personalised e-mail addresses, so under the .tel proposals individuals and corporations could have personalised "for life" .tel addresses which would allow the burgeoning VoIP industry to really flourish. It would also allow them to change IP addresses without losing their individualised .tel names.

TelNIC's proposal is unique - we envisage a service providing a uniform naming infrastructure for PC-to-PC and future IP telephony services (e.g. UMTS). This will provide the ability to use a domain-name representation as an identifier, and allow for the possibility of many new applications.

2) What .Tel Means

TelNIC - in common with several others proposing a .tel infrastructure - envisage the use of .tel namespace as a convergence point, a marrying of technologies. However, we foresee a new type of addressing, one geared towards the growing VoIP market. We propose the convergence of domain names and the Internet naming system into telephony, allowing telephony users to make use of the same types of text-string-based DNS names from which today's Internet users benefit.

Our vision of this integration applies to various scenarios and market segments. It includes PC-based VoIP clients as well as future IP devices such as those currently under development and coming to market. It provides a natural extension to direct client-to-client communications and corporate users, as well as those users connected/connecting via a media gateway or proxy. It will, of course, prominently feature G3 mobile networks and telco infrastructure integration.

TelNIC's .tel will provide a stable, well-managed, and highly-structured TLD for the provision of DNS. That DNS has different sets of users, and different approaches to meeting those needs:

End users using PCs and IP-enabled telephony devices will be provided with low-maintenance DNS services for their needs and a registration service with features targeted at ease of use.

Corporations will be able to host and manage DNS in a way that allows them to move their infrastructure to VoIP and VoIP-enabled gateways, and provide subdomains.

The Internet will benefit from a single-response TLD architecture that attempts to answer most queries with a single response.

Telcos and ISPs will benefit from a local-response platform that they can incorporate and embed into their delivery platforms.

Regarding the ITU letter in response to ICANN, we feel strongly and wish to emphasise that TelNIC's .tel can co-exist with ENUM. Acceptance of our proposal does not mean that ENUM is in any way made less effective, or more importantly, less critical. The TelNIC proposals explicitly removes any possible conflict with ENUM.

TelNIC will also ensure that there can be no conflicts with any of the issues around E.164 ENUM by imposing restrictions and permanent quarantining of all-digit .tel domains. This is to again ensure that there is no confusion or conflict:

           All-digit strings will be permanently embargoed.

           Broad terms and conditions and safeguards will be implemented covering any abuses that could possibly lead to any PSTN confusion, conflict or similarity.

           Measured use of numbers might be permissible where there is no direct, marginal, implied or similar confusions/conflicts with PSTN codes or numbers - and where digits form an incidental part of a text string (e.g. johnsmith11.tel).

The only exception might relate to issues such as emergency calling, and potential future requirements for call-location to determine an exact place a caller is making an emergency mobile call from. However these latter points are not seen as being relevant for many years to come simply because .tel will sit alongside existing PSTN services where these requirements are already being met.

3) Reasons for reconsideration

1)          There are clear and substantive grounds that there should be a sub-division of the "Telephony Category" to importantly distinguish between number-based applications and solely text-based applications. This essential "Telephony - Text Based Addressing" sub-division should be tightly restricted to text-based applications. We feel that ICANN has not considered this important sub-division of the Telephony Category.

2)          The interjection of the ITU and the issues of ENUM were central to deciding that Telnic's proposal should not proceed. Our proposal is not ENUM related.

To ensure the clarity of our position, the TelNIC .tel proposal:

        Does not represent a naming system which applies to PSTN users.

        Does not represent, in any way, a mechanism for providing domain names that look like PSTN numbers.

        Does not represent a mechanism which provides for PSTN-addressable VoIP numbers.

        Does not conflict with E.164 proposals; it complements them.

        Does not mandate a specific protocol.

Further, we uniquely provide a new application of DNS (without unnecessary extension of DNS) on the Internet, and we meet a real need.

Again, it is important, and fundamental, in light of the impasse created by the ITU issues, to re-emphasize the need to distinguish between actual number-based proposals and text-based proposals.

It is our belief that these important factors have not been fully taken into account and considered by ICANN in its appraisal of Telnic's .tel proposal.

4) Action Requested

Further to the above grounds for reconsideration, our request for action is uncomplicated and compelling. TelNIC therefore request:

1)       To be classified in a "Telephony - Text Based Addressing" sub-division of the stipulated "Telephony Category". This "Telephony - Text Based Addressing" sub-division is an essential, appropriate, and necessary structuring.

2)       That our .tel application is reviewed in the context that we do not impinge, in any respect, the stated issues concerning ENUM or telephony numbering conflicts. As mentioned, our organisation will ensure that all safeguards are in place to completely avoid any actual or perceived conflicts.

3)       That we want to be reviewed for an immediate grant of a TLD.

5) Conclusion

We believe that there are compelling reasons to create this TLD now, and that it provides clear benefit to consumers, both individual and corporate. We believe that it creates a wealth of new business opportunities for registrars, telecommunications companies, and third-party service providers, and have outlined just a few of those ideas in both our presentations and our ancillary project document (as attached and to be posted on telnic.org). We feel that the benefits apply both to PC and Internet telephony users, as well as providing a platform for powerful new services for all communication service users.

The growth of VoIP and the lead times involved in designing the architecture for VoIP platforms and the next generation of mobile networks, such as UMTS, point to the importance of granting .tel as a part of the current process.

It would surely be in the interests of ICANN to recognise and bring any new or potential addressing developments in the mobile Internet into the ICANN fold. We believe that TelNIC's .tel initiative offers such an opportunity.

We urge ICANN to modify the terms of resolution 00.89 to include .tel and Telnic.

We look forward to the advice and assistance of ICANN, its membership, and the public at large with the evolution of our proposal into a living TLD.

Yours sincerely

Alan Price


Telnic Limited. 8 Wilfred Street, London SW1E 6PL. United Kingdom.

Tel: + 44 (20) 7828 0000 Fax: + 44 (20) 7828 0000

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