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VGRS Analysis of Comments on WLS Proposal

20 March 2002

The following analysis is provided by VeriSign Global Registry Services regarding feedback received about the VGRS Wait Listing Service (WLS) proposal. The analysis is organized as follows:

1. General analysis
2. Analysis of registrar comments
3. Analysis of registrant comments
4. Analysis of other comments

1. General Analysis

Prior to analyzing comments received in response to the request for WLS proposal feedback, it is first essential to understand why VGRS solicited comments from the community: to obtain feedback from registry customers (registrars), registrar customers (registrants and potential registrants) and other interested parties to determine whether there was sufficient interest in the proposed WLS. Rather than focusing on every point in the comments received, the primary focus of this analysis is to determine whether there is sufficient interest to warrant going forward with the offering.

Feedback during a joint meeting of registries and registrars at ICANN's just-concluded Accra meeting helped VGRS understand that it had not been fully successful in clearly communicating the purpose of requesting feedback. Consequently, many concluded that the purpose was to initiate a consensus process-which it was not. In the future, when discussion is requested about potential new registry services, it will be important to more explicitly explain the purpose for soliciting feedback.

In the case of the WLS proposal, feedback was specifically requested because VGRS wanted to determine whether sufficient marketplace interest existed for such an offering and, if so, what issues should be considered. A fundamental assumption was that the WLS would not be successful if there was insufficient interest by VGRS customers (registrars). After a few months of discussion about what was then referred to as a "parallel registry" service, and prior to the ICANN meetings in Marina del Rey in November 2001, VGRS concluded there was not yet sufficient interest in the WLS concept at that time and sought an opportunity in which to vet this idea further with registrars. Then, following a request for a proposal from the DNSO Registrars Constituency at Marina del Rey, the initial WLS proposal was provided in December 2001. Feedback was received and a revised proposal was provided in late January 2002.

This analysis primarily focuses on comments received in response to the revised proposal and, in some cases, incorporates other related feedback received. In the case of the revised proposal, comments specifically submitted to the wls@verisign.com address can be found at http://www.verisign-grs.com/wls.html. Other WLS documents, including the initial and revised proposals and responses to questions asked about the initial proposal, can be found at the same URL. The deadline for comments was 7 March 2002. In the case of registrar comments, an exception was made because of the importance of their input.

2. Analysis of Registrar Comments

It should be noted that VGRS considers comments by registrars to be of primary importance because they are direct customers of VGRS and the ones who will implement the WLS as a product. Two sets of consolidated comments were received from registrars, as were several individual registrar submissions. One set of consolidated comments was submitted by a group of registrars in favor of the WLS; another was from the Registrars Constituency, which adopted the formal position of being opposed to the WLS.

Looking at all registrar submissions together and considering that there are 171 ICANN-accredited registrars and 99 active .com/.net/.org registrars, only a small percentage of registrar companies submitted comments. On the other hand, looking at the size of registrars as measured by the number of registrations represented, feedback was inclusive of a significant majority of the registration services market.

For the purposes of this document, VGRS lists results using both methods.

As can be seen by the data below, counting each registrar equally, a small majority of registrars who submitted comments opposed the WLS. But when registrar size is considered, the registrars representing a majority of the marketplace support the offering of a WLS 12-month trial. The data provided below is based on VGRS registration data as of 28 February 2002 and on comments received at the wls@verisign.com address.

  # Of unique ICANN accredited registrars %
In favor 14* 42.4%
Opposed 19 ** 57.6%
Total   33  

* Registrars in favor include: BulkRegister.com, China DNS, DomainSite.com, Galcomm.com, GoDaddy.com, Melbourne IT, Namebay (Monaco), NameEngine, NameSecure, NameScout, NameSystem, Neteka, Network Solutions, Register.It, SiteName and SRS Plus. Registrars.com was not included in the count because its registrations were transferred to Network Solutions at the end of February. NameEngine and NameSecure were not counted as separate registrars because they are owned by VeriSign, Inc.

** From Registrar Constituency comments.

Considering the above registrars, as well as those who did not vote in the Registrars Constituency vote and did not submit individual comments, and analyzing them in light of the size of the registrar relative to number of registrations in the SRS as of 28 February 2002, the results are:

% in favor:   57.5%
% opposed:   17.8%
% no vote or abstain:   24.7%

In light of the above results, VGRS has concluded that the domain name market place contains more than sufficient interest in the WLS offering to warrant going forward with a 12-month trial as proposed. It was understood from the beginning that some registrars might not be interested in participating in the WLS. It is entirely at the discretion of registrars whether or not they choose to participate.

3. Analysis of Registrant Comments

Registrant feedback was received primarily from one constituency in the DNSO and the DNSO General Assembly (GA), as well as from a few individuals. The Intellectual Property Constituency submitted comments in response to the original proposal and their comments were incorporated in the revised proposal; no additional feedback was received from that constituency after the revised proposal.

The GA feedback appears to be written by one GA participant with endorsements from several other GA participants; however, the participant neither included specific data in this regard nor answered the questions regarding representativeness, as requested by VGRS. Based on monitoring of the GA list, it is estimated that fewer than 10 people specifically endorsed the proposal on the list. If the results of a separate list poll were included, it is possible that this number would increase but it is not clear whether some individuals participated in both efforts. Regardless, even if the number of individual WLS opponents was as high as 20 or 30, this number is a very small percentage of GA members and is a miniscule subset of the total number of domain name holders and potential registrants. No comments or questions were offered by members of the audience at the public GA meeting in Accra, after a brief explanation of the WLS proposal was presented.

One of the complaints submitted was that some current businesses might go out of business if the WLS is implemented. Apparently these businesses rely heavily on the rapid registration of just-deleted names and believe that their businesses will be undermined by the WLS. As has been fully explained repeatedly elsewhere, it is far from clear that this is the case, but even if it is, VGRS believes that the overwhelming majority of consumers, for whom practical access to domain name registrations being deleted remains unaddressed, will enjoy a far better experience when the WLS is offered at the registry level. Moreover, even though VGRS has committed to continue supporting the current batch delete process, we believe that it is unreasonably cost-inefficient and therefore hard to justify batch deletes from a business point of view; consequently, it is also hard to justify support for business models that rely so heavily on such an approach.

VGRS recognizes the difficulty obtaining meaningful feedback from individuals in the very large Internet community. Market data demonstrates that the existing level of consumer interest in a registrar-based wait listing service is already high, even though such a service provides a lower probability of successful domain name registration acquisition than will the VGRS WLS. This actual market experience with customer demand is one indicator of market demand. But ultimately, the best measurement of consumer interest will be actual market data accrued during the 12-month WLS test period.

4. Analysis of Other Comments

No comments were received at the wls@verisign.com address from any DNSO constituency other than from the Registrars Constituency. Because VGRS is a member of the gTLD Registry Constituency, it is known that the gTLD Registry Constituency has taken a position that registries should be able to offer new services without the necessity of an ICANN consensus process. Appendix G in the unsponsored registry agreements specifically allows for this possibility.

Next Steps

VGRS has submitted a request to ICANN for an amendment to Appendix G of the .com and .net registry agreements to add pricing for the WLS for a 12-month trial period.

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