D13.2 Business Plan for New Registry Operations


The role of the Registry Operator is to fulfill the policies mandated by the
Sponsoring Organization  “.biz TLD Regulatory and Advisory Council” 
(henceforth in this document known as bizTRAC).


In this section D13.2 we will first give a detailed explanation of our approach and
then, in the light of this summary specifically answer the Application form
questions D13.2.1 – D.13.2.15. Our explanation section will be divided into
sections numbered D13.2.0.1, D13.2.0.2, etc. Note that throughout this
section 13.2 we will be referring to the “.biz” TLD. We are also applying under the
same Description of TLD Policies submitted with this application to manage
any or all of the following strings: “.firm”, “.ebiz”, “.real”, “.inc”, “.ebz “. It
should be understood that all of the policies to which we refer in this document
are intended to apply equally to any of these TLD strings.


D13.2.0.1 The TLD Management Group


We are proposing a Restricted TLD, managed according to the policies detailed
in the “Description of TLD Policies”. The specified policies require that each
application be thoroughly scrutinized by individuals specifically employed to
perform this function. This means that successful management of the TLD
will involve three tasks


The tasks are:


(1)   Management of Computational Operations. These operations include
actually running the registry computers, updating the registry database,
automated interaction with registrars, management of Whois and
data escrow, and so on.

(2)   Extensive manual assessment of submitted application materials to
determine whether to accept or deny a Registration Request using the
policies and procedures specified in the Description of TLD Policies.

(3)   Marketing and non technical administration


In order to successfully manage these functions we will establish a group which
we will call the “TLD Management Group” in this document and throughout
the application materials.  This section 13.2 and all sub sections will
therefore refer to the activities of the TLD Management Group unless otherwise


The first of the three tasks given above, the Management of Computational
Operations, will be outsourced to 7Ways.com and carried out as described in
section III of this document. This group, as shown, in the organizational
chart in section D13.2.0.9 will report to the TLD Management Group through
the Technical Operations Officer.


The second function, the assessment of applications, is a major role that is not
carried out to the extent that we propose by any existing registry operation.
This will be supervised by in-house staff but mainly carried out on an
outsourcing basis by major accounting, law and consulting firms as described
below in section D13.2.0.10


The development and monitoring of polices under which this group operates will
be carried out by  our Sponsoring Organization bizTRAC as described in the
Sponsoring Organization Proposal Submitted with this document.


D13.2.0.2 Summary of The New TLD


If our application is successful, our objective will be to establish the “.biz” (to be
pronounced “Dot Biz” ) top-level domain in the public mind as a prestigious
Internet designation that signifies that any company with a .biz name
extension is a “real business.”  By limiting the availability of the .biz designation,
we will also very significantly reduce the problem of  “cyberhoarders” for
genuine Internet entrepreneurs and business people.


We define cyberhoarders as those that buy up Internet names with no intention
of using them for any real business purpose. Rather, they hold the names
hostage until a genuine entrepreneur that wants the name for a legitimate
business is prepared to pay the ransom – which in most cases is many
thousands of dollars. Most “.com” names which are a single word, a recognizable
phrase in common use, or a three or four letter acronym, have been
purchased. Less than 30% point to an active web site. In other words the large
majority have been abducted by cyberhoarders.


This is a big problem for new Internet entrepreneurs. On the Internet name is
everything. In many cases the entrepreneur has no choice but to settle for a
second-best name or to pay off a cyberhoarder. The .biz designation will
give the entrepreneur an alternative.


Each application for a .biz designation will be assessed according to various
accounting and business criteria and only approved if the applicant is a real
business. The assessment criteria will probably including current revenues for an
operation that is up and running, or specifically assigned capital and a
credible business plan in the case of a start up.


We will support the “.biz” designation with an aggressive print and street billboard
advertising campaign telling people that “.biz means you are in BUSINESS!”

A real business or an entrepreneur will pay $2,000 for an approved “.biz”
designation. The business can therefore get the domain name that they want (as
long as its not owned by another real business) and the added prestige of
being a “.biz” for a less than the price of paying off a cyberhoarder.


D13.2.0.3  Allocation of SLDs under the .biz designation (All practices of the
TLD Management Group will be in accordance with the policies described in 
“Description of TLD Policies”  established and from time to time amended
by the Sponsoring Organization bizTRAC). These policies are briefly summarized in this section.


Those wanting a “biz name will have to apply.  The name will be awarded if and
only if it is determined that the applicant is a “real business.” The following is
a summary of our policies as specified in the Description of TLD Policies.


(a)   Each application will be assessed according to various simple accounting
and business criteria.

(b)   A start up operation is able to place a Reservation on a name for a limited
period of time. (see Description of TLD Policies section E16.3).

(c)   A .biz name application will only be approved if it does not infringe
trademarks of the country in which the registrant wishes to do business. If
the registrant specifies a “worldwide” market location the specified
SLD must not infringe on US or EU existing trademarks. (See
Description of TLD Policies section E5.0.3)

(d)   Each SLD applied for will be publicly posted on a Listing of Names Applied
For (see Description of TLD Policies section E5.0.4) and those
believing their Intellectual Property Rights would be infringed will be given
an opportunity to lodge protest.

(e)   Each business will only be able to purchase one “Business Name” .biz
SLD and a limited number of  “Product Line” SLDs. (See Description
of TLD Policies section E5.0.5). Business Names and Product Line
Names will be referred to in this application as Primary Names. The
fee for the registration of a Primary Name will be $2,000.

(f)     We will not sell “Substantially Similar Names” to different companies. If
you buy dogfood.biz, we will not sell dogsfood.biz or even dogs-
food.biz to anyone else. Substantially Similar names can be names which
differ from a Primary Name by a hyphen or by a regular plural or
possessive (in English or another language) of one or more of the
constituent words in the name (See Description of TLD Policies section
E5.0.5). Substantially Similar Names are referred to as Active if the
name points to the same web-site as the registrants primary name,
or inactive it the registrant registers the name to prevent other
registrants from registering or reserving the name. A Substantially Similar
name can not point to a different site than the Primary Name.

(g)   .biz names must be renewed on an annual basis. Renewal will however
be granted only if there is evidence of significant business activity
over the previous year. (See Description of TLD Policies section
E16.9, E16.10 and E16.17.1).

(h)   In the start up phase we will use a one-time special practice of a Name
Lottery to award the .biz designation to competing entities. Those
winning the Name Lottery will not be granted the automatic right to
an SLD. Rather winners will be given the right to be first in line for the
regular Application process, and may or may not be awarded the
SLD depending on the result of that process. The Name Lottery will
also be used as a de facto “sunrise period” to give priority to those
with Major Marks (defined in the Description of TLD Policies
document E11.12), existing trademarks or other prior name rights.

(i)     SLDs can only be transferred on a very limited basis if it is clear that both
the transferring business and the transferee are a real business at
the time of the transfer and that the transfer itself constitutes a
transfer of real business operations rather than just the transfer of the
domain name. (See Description of TLD Policies  Sections E16.11 and


D13.2.0.4  The Market


According to a report from Network Solutions, over 5 million .com, .org and .net
names were registered in the first quarter of 2000.  This was an increase of
446 percent over the first quarter of 1999, and of 120 percent over the
previous quarter.  Our target market segment, however, consists only of those
domain name registrations that are made with the intention of establishing a
business presence on the net.  An article released by CyberAtlas on May
17, 2000 cites a report by Access Market International (AMI) Partners and
Inc. Magazine.  The report estimated 600,000 small businesses were selling
their products and services via e-commerce sites in 1999, up from 400,000
small businesses in 1998.  The value of such transactions rose from $14
billion (1998) to $25 billion (1999), representing an increase of 79 percent.


An article released by CyberAtlas on May 31, 2000 cites a report by International
Data Corporation.  The report estimates that the number of small
businesses selling on line will rise to 2.8 million by 2003.  If we assume that small
business registrations continue to accelerate at the same rate for at least
the next five years, we can estimate that there will be at least 5 million new
small businesses selling online by the end of this period. We would also
expect at least double this number of start-up businesses to establish an
Internet presence over this period. In other words, probably less than half of
the businesses that set up a web page will ultimately successfully end up
doing business over the Internet.


We also expect that many new larger businesses as well and  existing
businesses will buy .biz domains.


D13.2.0.5 Marketing the .biz Top Level Domain



Our marketing objective is to sign up at least 10,000 .biz names within the first
year of operations after a start-up period of six months. We will achieve this
through a combination of brand development advertising strategic
partnerships, viral marketing and other promotional strategies.


Brand Development Advertising

We will develop brand awareness through an aggressive print and street
billboard advertising campaign telling people that “.biz means you are in
BUSINESS!”.  We will also place Internet banner advertising on selected
business oriented web sites. We estimate that we can effectively pursue this
campaign for a cost of approximately $5,000,000 per year.


Strategic Partnerships

We will aim to form strategic partnerships with several top registrars. We have
already had extensive discussions with Bulkregister.com and
Alldomains.com. We will also aim to form relationships with those sites that are
not actually registrars but direct business to registrars such as
DomainRegister.com or MyDomain.com or even a major ISP such as Earthlink.
We will offer to pay these partners $100 for each .biz registration that we
obtain by referral from their site This is considerably higher than the fees
paid to registrars for registering .com names. We therefore expect the
cooperation of these businesses and believe that our relationships with them will
greatly assist us in marketing and promoting the .biz TLD.

We will also aim to form a relationship, possibly by giving up some company
equity, with one of the major Internet portals or search engines with the aim of
promoting the .biz designation.


We will aim to form strategic partnerships with newspapers and magazines and
“web publications” which will offer first year free subscriptions or services to
.biz designation companies.  Among others we will target traditional
business print publications such as the Wall Street Journal, Business Week and
Forbes Magazine.


Finally we will aim to form strategic partnerships with third party providers such
as accounting firms to provide services to .biz members.  For example, we
could aim to find an accounting firm that would prepare tax returns for .biz
companies for significantly reduced costs, say for $150, for the first year.
The accounting firm might be prepared to do this in order to capture .biz
customers. Generally second tier or third tier accounting firms charge $300 -
$500 for small business tax accounts. We could possibly subsidize some of
their costs from our sign up charges. We could then modify our advertising
campaign to publicize: “Guess who’s getting their taxes done for $150? -
.biz means you are in business!”


Viral Marketing

We will pay a $100 commission to any .biz business who is quoted as a “referring
business” by someone signing up for a new .biz name. If someone
successfully refers six other businesses we will refund their entire sign-up cost.


Other Promotional Strategies

We will spend $200,000 on public relations in our first year of operations. Our
objective will be to maximize favorable coverage of the .biz domain on all
branches of the media. We will also aggressively promote the .biz top-level
domain to all of the search engines and browser companies with the
objective of persuading them to give high priority on their search lists to .biz
designation companies.


D13.2.0.6 Competition

As a result of this application process and subsequent open calls for those
wishing to manage new TLDs, it is possible that many new TLDs will be created.
Discussions by the ICANN Working Group C has estimated that ultimately
more than 100 new TLDs may be added.  “.flowers”,  “.cars”, “.news” and
“.paper” are given, among others, as examples of the of new TLDs which
might be created. We expect ICANN this application process to result in the
issue of 6-10 new TLDs this year and probably a similar number next year.
We do not believe that the issuance of new open TLD designations will
solve the problem of cyberhoarders for the following reasons:

(1)   There will be relatively few good names within each new designation and
these will once again be purchased by cybersquatters. (eg.
flowers.flowers, prettyflowers.flowers, roses.flowers and blooms.flowers
will be purchased by someone within a few minutes of the launch of a
“.flowers” TLD.

(2)   If the new designations become popular, the fact that there are relatively
few good names in each one will tend to even further inflate the
prices of these names in the secondary market. “cars.cars” and
“wines.wines”, for example, will probably change hands for very high


We also believe that there will be many businesses that will want a general
designation rather than one of the more product specific new TLDs. In addition
we expect that there will be a gradual introduction of new TLDs. It is likely
therefore that for the next couple of years at least there will be many
business areas that are not covered by the new designations.


For these reasons, we believe that “.biz” names restricted to those who are
actually in business, and sold at a price of $2,000 will be an attractive alternative
to many businesses.


No other existing top-level domain says “business” like .biz. No other top-level
domain is currently restricted to those actually doing business on the
Internet. If we manage to obtain the rights to manage the .biz TLD, we will have
created a service which is very valuable to the worldwide business
community and which we believe will create a very powerful market presence.


D13.2.0.7 Business Risks

The greatest challenges that we will face, once we have obtained the rights to
manage the “.biz” TLD, is that of building the brand image of the “.biz” Top
Level Domain. We feel we can do this successfully because (a) “.biz” will
offers a low price alternative to paying off a cybersquatters. (b) It fills a gap
in the market (i.e. a top level domain for real businesses) (c) we will pursue
an aggressive advertising campaign (d) We will find web based strategic
partners that will assist us in marketing this idea.


As stated above, this and subsequent application procedures will result in the
launch of a number of new top-level domains. This may reduce the pressure
on available names and therefore reduce the demand for our heavily
promoted .biz designation. We expect however that if the new designations show
signs of becoming popular, once again cybersquatters will jump in and
quickly buy up the most desirable properties.


D13.2.0.8 Management Team

The Management team of the TLD Management Group currently consists of the
three principals these are Phil Berent, and Josh Kyle and Margot Lee.


Phil Berent has 15 years experience in the financial industry as a quantitative
analyst and derivative specialist. Mr. Berent is the is the originator of the .biz
idea to create a restricted TLD available only to companies that are actively
in business. Prior to launching this project Mr. Berent was President of
Berent Capital, a money management firm managing a $600 million interest rate
swap portfolio for European institutional clients. Mr. Berent Established the
firm, raised start-up capital and marketed world wide to institutional
investors. He was also responsible for developing the firm’s investment
philosophy and technology.   Mr. Berent also lectures on derivatives. (Lecturing
assignments have included the executive programs of Carnegie Mellon and
Lausanne University in Switzerland). Before founding Berent Capital he
worked for Merrill Lynch as a Director in the fixed income derivative area. In
this role he ran structuring and marketing teams in Frankfurt and New York
and played a large part in building that firms derivative structuring and
distribution capability in Europe and the Middle East. During this employment he
was a frequent contributor to the firm’s internal publications and wrote
papers covering various areas of financial quantitative research. His final title
was that of Director.  Mr. Berent obtained an MBA from Columbia University
in 1986 with a concentration in Finance and Management Science.


Mr. Berent will be Head of the TLD Management Group.


Josh Kyle has 13 years experience as a senior executive in management of
several companies including start-up operations.  He has special expertise
in business enterprises with international interests in the fields of insurance,
venture capital, manufacturing and real estate.  Most recently, he was CEO
of Film Bond International, a division of Frontier Insurance marketing
completion bonding to the film industry. In this position he developed, staffed and
oversaw marketing and operating plans.  Previously, he served as Vice
President for a venture capital firm, Credit China Corp “CCC” focused on Asian
investments. In this capacity he carried out, investment evaluation,
preparation of business plans, and oversaw the due diligence process for
numerous projects. Prior to this role Mr. Kyle was the co-founder of World Impact
Trading Corporation, a US-China manufacturing organization, where he
served as CEO for six years from 1989 to 1996.  During this period he
succeeded in raising annual revenues from $60,000 to $6,000,000.


As an undergraduate, Mr. Kyle attended Yale University, and TSOA New York
University for film.  He obtained an MBA from Columbia University in 1994
with a concentration in management.  He has dual US-UK citizenship and
speaks Mandarin Chinese.


Mr. Kyle will be head of Administrative operations for the TLD Management



Margot Lee brings a diverse background in marketing, finance, media, and 
technology to the TLD Management Group.  After working on the trading floors of
JP Morgan and Merrill Lynch, Margot created Vox Populi Communications,
a financial and business development consulting firm for new media
companies.  In 1998, she became a producer and Field Host for MoneyHunt, a
national Public Television program spotlighting the country’s hottest
entrepreneurs.  As Senior Programming Producer at HBO’s Volume.com, she
oversees the creative operations and strategy for the content/community
portal for urban youth online.


A graduate of the University of Virginia, Margot was an Echols Scholar and
received a BS degree in Finance with extensive coursework in French. She was
featured in Doing It For Ourselves: Success Stories of African-American
Women in Business
(Berkeley Books, 1996) and in 1997 completed the
Chartered Financial Analyst (CFA) series of examinations.


She currently serves on the Board of Directors of The Learning Project, a non-
profit organization dedicated to creating and managing outstanding public
schools in low-income areas, and is on the board of the John A. Reisenbach
Charter School, the very first charter school approved to operate in New
York State.  She is also a competitive triathlete and cyclist.


Ms. Lee will be Head of Marketing for the TLD management group.


D13.2.0.9 Organizational Structure and Staffing


The chart below illustrates the structure that would be required in the first year to
achieve all of the development and administrative objectives of the TLD
Management Group described above for systems, marketing, and business
development. We also expect to retain two contract programmers on a full
time basis over the first year. Further hires would probably be necessary
after the end of one year.






Phil Berent, Head of TLD Management Group:

Develops and maintains the vision of the group. Represents TLD Management
Group on board of Sponsoring Organization bizTRAC. Establishes
relationships with strategic partners including domain name registrars, ISPs, and
third-party service providers. Develops relationships with external providers
to whom much of the work of assessing registration applications will be
outsourced. Works with Head of Operations to develop policy proposals to the
Sponsoring Organization bizTRAC for amendments to procedures for
assessing and processing applications for .biz registrations. Recruits other
members of team.


Josh Kyle, Head of Operations:

Works with Head of TLD Management Group to develop procedures for
assessing and processing applications for .biz registrations. Oversees
development of the “.biz” web site. Oversees development of registrations team
and customer Service function.


Margot Lee, Director of Marketing:

Works with each of our strategic partners to develop a marketing approach.
Works with advertising agencies contractors to develop advertising campaign.
Develops relationships and joint marketing approaches with those that
might provide services to .biz designation businesses.


Group Finance Officer:

Directs financial affairs of TLD Management Group. In charge of determining
group’s financing requirements and managing the group’s investments.
Prepares financial analysis of operations for guidance of management. Directs
preparation of budgets and financial forecasts. Arranges for audits of
group’s accounts.


Manager of Human Resources and Administration

Develops policies for Human Resources and administrative issues. Reports
directly to Head of TLD Management Group.


Chief Web-Site Programmer

Works under direction of Head of Operations to develop .biz Registry web site
and software necessary for the domain name registration process.


Head of Registrations

Responsible for overseeing the application process for every applicant for a .biz
domain name registration. Will work extensively with external service
providers to ensure that registrations are quickly and effectively processed.


Head of Customer Support

Responsible for implementing telephone and e-mail customer support for TLD
Management Group. Will work extensively with the Head of Registrations.


Technical Operations Officer

Will provide liaison between the management of the TLD Management Group 
and 7Ways.com who will manage technical operations of the registry as
described in section III of this document.


D13. Building the Management Team


In the first year we need to hire 15 people for the TLD Management Group.
Affinity Internet has effectively built a team of approximately 150 people since of
October of last year when the company was formed. We will use the same
methods and resources that we used for this effort to build the team of the
TLD Management Group. We employ one full time recruiter who will direct
her efforts to find and screen individuals able to fulfill the required functions.
We have also used good relationships with Corn Ferry International and
Heidrich and Struggles.


The Corporation will be an equal opportunity employer, seeking qualified
individuals that represent the interests of its broad diversity of customers.  As an
employer the Corporation will honor all legal obligations arising from
legislation and regulation at the federal and state levels.  Compensation of Staff
will be negotiated with each individual.  All compensation packages will be
designed to comply with relevant state and federal legislation.


D13.2.0.10 Outsourcing of Computational Operations to 7Ways.com


The establishment and installation of computer systems, the running of those
systems and all computational aspects of the running and maintenance of
the Registry will be run by 7ways.com.

7Ways.com will be paid a fee of a royalty of 5% of revenues in return for
providing this service. Contracts between us and 7ways are currently in
preparation but have not as yet been signed.


D13.2.0.11 Outsourcing of Application Processing and Trade Mark Searches


We believe that each registration will take average of somewhere between 1 and
2 hours of work. This work will involve the analysis of the firm’s bank and
other financial statements, auditor’s reports, and trademark registration
certificates. In many cases it will involve interacting with the Applicant to request
further appropriate information such as invoices or receipts. The individuals
assigned to this task therefore need to possess intelligence, initiative and
good analytical and communication skills. We envisage that in the first year
of Registrations, (the first 18 months of overall operations) we will register
somewhere between 10,000 and 50,000 SLDs.  This will therefore require
somewhere between 5 and 52 people working full time to process
applications. As we grow, we will certainly aim to do more and more of this work
in house. Initially, however, we will outsource much of this work to major
accounting and legal firms. We expect to pay fees of approximately $150
per hour.


We are currently in discussions with Cap Gemini Ernst and Young about either
providing these services or assisting us to find appropriate providers.


In order to ensure consistency, one of the first tasks of the Head of Operations
will be to work with the Head of Registrations to prepare a comprehensive
procedures manual which will be used by both internal and external staff in
processing applications.


Trade mark searches will also be outsourced. We are currently in discussions
with Net Names based in the United Kingdom, who are experts in this area,
about fulfilling this function for us.


D13.2.0.12 Full Listing of Service to be Provided and Pricing of Each


Details of each of the services provided are given in the accompanying document
“Description of TLD Policies”.  Our role as the Registry Operator is to fulfill
and implement these policies. A listing of the services and the pricing of
each service is given in section E9 of this document. This section is
reproduced here – all references in this section refer to sections in the
Description of TLD Policies:


Section E9 Description of TLD Policies  (Reproduced):


The following services will be offered under the New TLD:

(1)   Registration:  Price for application $2,000.  Full fee retained if application
is successful. $1,500 returned if application is unsuccessful. (see
section E16.3)

(2)   Registration of Substantially Similar Names. Price per SLD $25 if the SLD 
points to the registrars primary site or $5 if the registrar just wishes to
block others from  registering or reserving the Substantially Similar
Name. (see section E16.5)

(3)   Renewal: Price for annual renewal $150 for primary name. Substantially
Similar Names are renewed at the initial purchase cost ($5 or $25)
(see section E16.9)

(4)   Registration Transfer: If a Registration Transfer is approved the charge
will be $2,500. If Registration Transfer is rejected $1,500 of the fee
will be returned.

(5)   SLD Reservation: SLDs can be reserved for a period of 6 months at a cost
of $500. At the end of this period the reservation can be renewed
for$500 for an additional 3 months. If the Reservation is not
converted to a Registration these fees are forfeit. If the Registration is
converted $350 of each Reservation fee is allowable towards the
Registration application fee. (see section E16.14 (11))

(6)   Initial Lottery Entrance Fee: This fee is $100 per lottery entry which is
returned in full at the end of the 60 day lottery period to losers.  The fee is
allowable against the cost of Reservation or Registration application
to winners of the lottery. If a lottery winner does not exercise their
right to file an application for Registration or Reservation within 1
week of winning the lottery the $100 lottery entrance fee is forfeited.
(see section E11.2)

(7)   Waiting List Fee: Those wishing to join the Waiting List for and SLD pay a
fee of $20. If another party registers the name, the fee is returned in
full. The Waiting List fee is allowable against the fees for Reservation
or Registration for those reaching the top of the list. If a company
reaching the top of the Waiting List fails to apply for Registration or
Reservation of the SLD within one week then the Waiting List fee is
forfeited (see section E16.4 ).

(8)   Appeal fees:  An Applicant can appeal if an Application for Registration is
rejected. If the appeal is rejected, $1,250 of the application fee is
returned. This compares to an amount of $1,500 that would be
returned of the application fee of a rejected Application if the Applicant did
not appeal. Therefore, there is an additional charge of $250 for filing
and losing an appeal. (see section E16.16)


End of Description of TLD Policies (Reproduced).


In addition to the services above we will also provide Registrar Services as
described in E4.1 of the Description of TLD Policies document.  We will make no
explicit charge for registration services.