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Background Paper:
RegistryPro Request to Offer Second Level Registrations

Posted: 26 October 2003


Background Paper: RegistryPro Request to Offer Second Level Registrations

On the agenda for the 31 October 2003 Board meeting is the proposal by RegistryPro, Inc. (the ICANN-designated operator of the .PRO registry) to begin offering domain registration services at the second level in addition to the current offering of .pro registrations at the profession-specific third-level (these are currently law.pro, med.pro, and cpa.pro).

The proposal is submitted in accordance with the provisions in the Registry Agreement between ICANN and RegistryPro, Section 2.6 of Appendix L, which, after written ICANN approval, allows for implementation of second level registration under .pro.

The Registry Agreement between RegistryPro and ICANN was signed in May 2002. RegistryPro is currently preparing to publicly launch the .pro registration process.

On 6 August 2003, ICANN received a request from RegistryPro, Inc. which plans to launch registrations of second level domains (SLD). The request seeks the revision of the appendices to the .pro Registry Agreement to provide for it to offer two types of second level registrations directly under the .pro top-level domain (TLD).

In the first case, registrants that provide multiple services and meet the requirements for two professions or more can register directly under .pro that is such as companyname.pro, instead of for example companyname.med.pro and companyname.law.pro.

In the second case, any professional that meets the requirements for one of the professions specific third level names, a redirecting service to the third-level name will be offered. Such as for example companyname.pro will redirect to companyname.law.pro for a company offering legal services.

The RegistryPro SLD Proposal

RegistryPro proposes to offer SLD registrations in addition to the current profession-specific third level domain registrations in the .PRO name space.

The proposed SLD registrations would be offered only through ICANN-accredited registrars. In summary, the SLD registration offering proposed by RegistryPro would operate as follows:

“1) Where registrants provide multiple professional services and meet two or more eligibility requirements. Examples of organizations that would qualify are accounting firms (providing both legal and accounting services such as …), financial service providers (offering accounting and legal advice, such as …), and

2) Where any professional meets the .PRO requirements RegistryPro would like to offer them the ability to register on the second-level, with a redirect to the third-level professional designator that corresponds to their professional area. For example, a lawyer or law firm could register for johnsmith.pro in addition to johnsmith.law.pro. The second-level name would be redirected to a corresponding third-level designator... Thus, RegistryPro would offer URL and email redirect service. RegistryPro would charge an additional fee for the re-direct services for users opting to register on the second-level.”

Further, the RegistryPro proposal specifies that the registrants would be required to meet all of the registration requirements set forth in Appendix L in both of the above cases.

To implement the proposal contractually, amendments to several appendices will be required. The most significant amendments required are to Appendices F, G and L.

Considerations in Evaluating the Proposed Amendments

While registration under the .PRO domain space is generally restricted to third-level domain names, the .PRO Registry Agreement does provide for future allowance of second-level registrations under Section 2.6 of Appendix L:

2.6 Possible Future Allowance of Second-Level Registrations. Some registrants (particularly professionals in some jurisdictions that do not semantically correspond to the designated PS-SLD abbreviations) may prefer to use a domain name that has only two levels (www.xxx.pro rather than www.xxx.law.pro). In the future, the Registry operator may propose to give .pro registrants the option of registering for two-level domain names directly in the .PRO TLD (subject to the list of restricted domain names in Appendices K and X and in compliance with the registration policies, processes and requirements in this Appendix L and Appendices J and M); these domain names would be distinguished by professional category by being directly routed to matching Registered Names in the applicable PS-SLD. Any proposal by the Registry operator under this Subsection 2.6 must be made in writing to ICANN and will be subject to ICANN's written approval. In determining whether to give approval, ICANN will consider any recommendations of the Advisory Board as contemplated in Subsection 6.1.2.4 of this Appendix L. If ICANN does not act on a proposal within ninety days, it will report in writing to the Registry operator on the status of its consideration.

RegistryPro has consulted with its Advisory Board, which as contemplated by the .PRO Registry Agreement is composed of representatives of professional associations that are representative of the legal, medical, and accountancy professions (the subjects of the First-Phase Profession-Specific-SLDs to be offered by RegistryPro). The Advisory Board has provided a statement of support for the RegistryPro proposal which indicates the support for the proposal.

The Board has noted in resolution 02.100, where ICANN is evaluating significant registry changes,

"ICANN should act in a way that promotes consumer choice and innovative services while ensuring that registry operations are conducted in a manner that does not harm the legitimate interests of consumers or others."

If no legitimate interest appears in danger of being harmed, then the request for modification of the agreement is considered under a streamlined procedure. If, however, there are specific reasons to conclude that the legitimate interests of others are likely to be harmed, this suggests that the contractual revision may involve a change in policy to be considered through the formal policy-development process. It is important to note that the .PRO request differs from the previous but similar .NAME request, since the request to offer second level registrations is contemplated in the .PRO Registry Agreement at Section 2.6 of Appendix L as set out above. The .NAME Registry Agreement did not contemplate a second level registration, and was accordingly subject to an additional level of review.

The RegistryPRO proposal to offer SLD registrations does not appear likely to harm anyone's legitimate interests. In fact, this statement is enforced by the unanimous support from the RegistryPRO Advisory Board, and further RegistryPRO have consulted those registrars currently intending to offer the .pro TLD, and have received positive feedback from these parties as well.

Registration of SLD .PRO names will be in addition to the professions-specific third level names, and will only be available through ICANN accredited registrars, and thereby promoting registrar-level competition as well as allowing for more diverse and clearer consumer choice in the .pro name space.


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