GENERAL TLD POLICIES
Blueberry Hill Communications, Inc. ("Bluehill.com") will implement existing policies, procedures and practices previously developed, tested and used in connection with .com, .net, and .org to ensure a smooth, consistent and uniform introduction of service.
Based on our experience as a Registrar, we believe that the integrity of the Internet and the effectiveness of a proof-of-concept phase will be enhanced by the implementation of existing consistently applied business procedures, technical capabilities and TLD policies.
The use of existing practices and procedures, or their equivalent, for any new, open TLD is important, not just because it creates a level playing field among TLD registry services, but also because it reduces operating costs for the user and increases the time to market for new TLD services. Consequently, it allows for the proof of concept to proceed as quickly as possible with the least amount of redundant effort and unnecessary expense. This in turn permits registries and registrars to turn their attention to the critical task of attracting new users to the Internet while increasing customer satisfaction.
Basic standardization will help make Internet end users, TLD registries and TLD registrars more certain of the policies underlying all TLDs. Bluehill.com, like Network Solutions, strongly encourages diversity and creativity in many areas related to domain names, especially the addition of TLDs to the DNS. We recognize the importance of standardization in certain aspects of any maturing industry.
For this reason, Bluehill.com also encourages ICANN to ensure that the registry operators of all TLDs introduced by ICANN standardize core practices and procedures based on the current successful experience in .com, .net and .org.
We are aware that the procedures, practices and policies created in connection with .com, .net and .org are the result of the efforts and expense of many individuals over an extended period of time. The documents that embody these results have proven to be convenient, cost-effective and easy to use, important considerations for all end users, registrars and registries. In addition, the existing contractual templates used in connection with .com, .net and .org embrace standard principles of good business practice, including legally enforceable commitments by all parties.
Bluehill.com also believes that policies involving domain names must reflect a commitment to the protection of the legal rights of the parties involved, including intellectual property rights. The existing contracts do this and aim to minimize disputes, or, in the event a dispute is unavoidable, enhance their orderly and timely resolution, consistent with the facilitation of dispute resolution and law enforcement.
Adoption of these familiar practices and procedures will also result in a satisfied customer base, one not faced with the unattractive alternative of learning and adopting a completely new, untried set of procedures.
One of the reasons the existing documentation has proven effective in connection with the registration of domain names under the .com, .net and .org TLDs is the reasonableness of the principles underlying them, including service level requirements. Completion of certain customer transactions is measured each month against these thresholds, providing registrars, registries, ICANN, and other parties tracking information. We believe that all interested parties will be served fairly by an effort to continue to integrate such reasonable procedures and principles into all relevant documentation.
The ICANN Registrar Accreditation Agreement, NSI Registrar License Agreement and the ICANN-NSI Registry Agreement ("Existing Agreements"), contain terms suitably generic for use in connection with .com, .net and .org, as well as any other new, open TLD registry. We believe that the use of these current agreements will help standardize various functions and policies of TLD registry operators while supporting the development of business models that may differ from the current registry models.
Bluehill.com supports the current policy to allow all registrars to set their own prices for domain name registration services. Registrars, once introduced, should be free to bundle registrar services with other products, enhancing the possible benefits to consumers and having a positive effect on the ease of registering domain names on the average consumer. This encourages innovation, which tends to attract a greater number of participants onto the Internet and results in overall increased customer satisfaction.
A fundamental aspect of stability of the Internet is that universal and durable connectivity should be preserved so that domain name holders have reasonable assurances that their domain names will resolve to IP addresses of their host computers, even in the event of a business failure of, or other problems with, a registry or registrar.
The Existing Agreements protect consumers by setting forth standards for the protection of personal data collected by accredited registrars. They require participation by accredited registrars in a uniform dispute resolution policy, assuring fair and equitable treatment through binding arbitration by independent and international arbitral entities for disputes that arise over intellectual property and domain names.
The Existing Agreements also provide for the funding of ICANNs operations through fees collected from registries and accredited registrars. All of these structures, or their equivalents, will be employed in connection with the operation of .kids.
We have chosen to incorporate procedures and standards that have already proven successful in connection with .com, .net and .org in order to greatly reduce costs, reduce delays and start-up costs, and effectively focus, and encourage other registries to focus on developing and introducing new end-user services rather than reinventing pre-existing and proven procedures and standards.
Bluehill.com recognizes that the Uniform Dispute Resolution Policy ("UDRP"), since inception on December 1, 1999, has been effectively used to resolve more than 1700 challenges, involving approximately 3000 domain names. The UDRP is an example of an innovation that came out of the domain name registration policy-formation process. More than 1000 proceedings have been disposed of by decision, including close to 800 involving a transfer, 15 involving a cancellation and more than 200 involving a decision for the registrant.
Bluehill.com suggests balancing minimal restrictions with maximum consensus, and believes that the best practices discussed in Network Solutions September 27, 2000 White Paper, and borrowed liberally here, effectively accomplish this balance. In doing so, the integrity of the Internet is preserved and growth continues.
Further, we agree with Roger Cochetti in his paper submitted to the ICANN NAMES COUNCIL earlier this year. The paper, "How New Internet Top-Level Domains Could be Introduced Rapidly on a Sound Basis", contains several pertinent points.
In order to introduce a proof of concept with the least delay, while still assuring sound operations and stable application of established policies, Bluehill.com and ICANN would enter into a registry agreement substantially identical to that between ICANN and the current TLD registry, creating a level playing field, saving time, and assuring the application of policies that have been widely accepted within the ICANN community.
Bluehill.com proposes to adopt the language of the following documents (or similar documents that are in affect at implementation):
NSI Registrar License and Agreement
ICANN-NSI Registry Agreement
Uniform Dispute Resolution Policy
Further, we propose to adopt terms of service language that would reflect similar language set forth by Network Solutions:
Service Level Agreement as mandated by the ICANN Registry Agreement
The Uniform Dispute Resolution Policy ("UDRP") is an excellent example of the benefit of soliciting the input of a wide representation of the Internet, including the intellectual property and civil liberties communities, registrars, registries, governments, international organizations such as the World Intellectual Property Organization, and others.
Bluehill.com believes that a similar opportunity exists in connection with the introduction of .kids, and, in particular, during the start-up phase of the registration of domain names. More than at any other time, when a new, open TLD begins to accept registrations, a potential for misuse of intellectual property arises. We believe that implementation of our proposed affidavit process during the "sunrise phase" will be an effective model for use across all new TLDs.
The TLD will offer second level registration (directly under the TLD, as in registered-name .kids) in accordance with the limits imposed on the com/net/org namespace.
Supported characters will include a-z, 0-9, and the dash. The dash is allowed to be used in direct succession but is not allowed to be the first or last character of the registered second level string.
The maximum character number of the supported second level domain will be 63 characters. When the five additional characters contained in the extension (.kids) is added, the total character limit is 68 characters.
Domain names in this name space are not case sensitive. All data for domains will be stored in lowercase form. When data is supplied in uppercase it will be replaced with the lowercase version of each letter. Host registration will also be supported.
Domain-Name holders are serviced through registrars, which in turn work with the main registry. The registrys role will be bulk delegation and data management of domain registrations, registrar payments, and zone file generation to be provided to root name servers. The registry will be responsible for billing registrars and managing domain expiration at the Registry-Registrar level. In turn, the individual registrars will bill domain-holders directly, at rates they impose, as well as manage contact specific data and detailed whois daemons.
The registrar will manage the central whois server with domain / delegation details as well as primary organization information. In the event of individual registrar failure, registry will be responsible for absorbing the registrars business into other competing registries.
Standardized registrar data syntax will facilitate data escrow and speed import and integration with new registrar(s). Domain service interruption will be avoided due to the functional data required for domain resolution managed at the registry level.
Registrars will be selected by Bluehill.com under the same criteria and process currently imposed by ICANN. Our system for selection will mirror the system located at www.icann.org/registrars/accreditation.htm.
No registrars have been pre-selected. In fact, new registrars will not be selected until after 27 months of operation to ensure the registrars procedures and financial strength has been proven.
Data recorded at the registry level will be limited to associated registrar, domain name, and delegating name servers. Data beyond that is managed at the registrar level.
Data privacy at the registry level will allow the public release of the following information on a per-domain basis:
Delegating Name Server Host Names 1 + 2, 3-10 Optional
The data above also serves as the data returned for a registry whois connection.
Data privacy at the registrar level will allow public release of the following information in addition to the data provided at the registry level:
Administrative, Billing and Technical Contacts:
Data beyond the scope of the data listed above will be managed in a secure and confidential manner, to avoid release of payment method, status, and other specifics.
Data escrow will be managed at the registry level, to ensure registrars do not cross reference data managed by another registrar. When a domain name is transferred from one registrar to another all public data will pass through the registry to the new registrar. The domain-holder will provide the new registrar with confidential data such as payment details and domain management access provisions.
SSL will be used when appropriate throughout the registration process. Operating under this model, Bluehill.com has never experienced unauthorized transmission of sensitive data.
Billing and Collection
Billing and collection will be managed by the existing Bluehill.com system utilizing an automated order system via Cybercash. Charging an order is completely automated. Funds are directly placed into a Merchant account. Customer information is secured in a separate database for protection.
We do not foresee any changes necessary to our current system in order to handle additional registrations. However, during our sunrise period, a database of those requesting a domain name will be created and maintained. At the end of the period there will be a one-time, automated charge and database addition for all successful registrations.
Bluehill.com will outsource all collection activities to Commercial Recovery Corporation. This will alleviate additional demand on the existing system due to charge backs, disputes, and collection activity.
Commercial Recovery Corporation
9298 Central Avenue NE
Minneapolis, MN 55434
II. REGISTRATION POLICIES DURING START-UP PERIOD
In introducing new TLDs, care should be taken to ensure that the rights of third parties are appropriately protected. Bluehill.com proposes that during the first 90 days applications will be accepted from those who believe they have a legal right to their name with a .kids extension. Examples may include: Disney.kids, Fox.kids, Oracle.kids, AOL.kids etc.
During this "sunrise" phase we will accept application from those that complete an affidavit under the penalty of perjury that they have a right to their name.
Bluehill.com is including a draft affidavit (Attachment A) that can be used in connection with the registration of domain names by companies that own established, well known, or famous trademarks during the initial phase of operation. The draft affidavit is geared towards large corporations such as Xerox, Kodak and Microsoft.
Bluehill.com has been advised by counsel that while this affidavit could also be used for companies that have legitimate trademark rights that co-exist with similar marks used by other companies, it may not provide sufficient evidence of such companies senior rights to register their trademarks as domain names. According to counsel, the affidavit in those situations could serve as evidence that such a company can assert a legitimate or plausible competing claim to the domain name (as opposed to a cybersquatter).
The draft affidavit is based on the bulk of provisions upon principles and the type of evidence that many countries generally request and/or rely on to evaluate the degree to which they will afford protection for an arguably well known trademark in their country, even if the trademark owner has made limited use of the mark in the particular country at issue.
With this as the premise of the draft affidavit, we hope ICAAN will view it as consistent with how many other countries with modern trademark laws approach issues that are similar, although in a different context.
The draft affidavit also contemplates asking the signer to attest to such information as sales volume and advertising expenditures. Obviously, some companies might consider this information confidential and would be reluctant to provide it, and as such, this may be something that requires modification in the final form.
Along with the affidavit, we propose a two-year, non-refundable registration fee of $500 during the "sunrise" period. There will be no limit on the number of applications or names that may be registered.
The higher registration price during the "sunrise" period will cover the cost of the affidavit program while meeting ICANN's objectives to minimize disputes and help identify where conflicts may exist. The affidavit process will also give legitimate stakeholders an opportunity to reserve their names without competing with the masses.
Bluehill.com believes that this higher fee will provide for a self-funding registry operation, allowing those that profit most from the introduction of the .kids TLD to assist in the funding of its early development. In addition, the sunrise registration will serve as an early indication of demand in order to insure all the necessary systems are in place to meet resource needs going forward.
Once affidavits are received they will be entered and cross checked in an automated database. Those that have multiple claims will be notified to follow a modified ICANN dispute resolution policy that will afford the resolution of a name not yet registered. Bluehill.com will "lock the name down" until the matter is resolved under this modified dispute policy.
We suggest that ICANN consider this slight modification of the UDRP only during the proposed "sunrise" phase.
Applications with no conflicts will be registered without prejudice. If future conflicts are discovered after the "sunrise" phase the ICANN dispute policy is in order. The affidavit may also be useful in the arbitration process.
We believe the strong language and high price of "sunrise" registration are likely to discourage abusive registration practices. Those with legitimate claims will be willing to pay for the convenience of not having to fight to register their name or engage in costly and lengthy dispute resolutions.
The affidavit includes explicit language contained in recent and applicable trademark and anti-cybersquatting legislation such as:
Bluehill.com will reserve 50% of the "sunrise" registration fee for a legal defense fund to respond to potential challenges. Another 30% will be allocated to start up expenses. The remaining 20% will be allocated to organizations working to provide a safe, healthy and secure Internet environment for kids and toward worldwide programs for children. The 20% will be distributed as follows:
Ten percent of gross revenues generated during the 90-day "sunrise" registration period and $4.50 of registration fees generated during the first two years of the contract to fund ongoing efforts to provide a safe, healthy and secure Internet for kids. These funds would be distributed through an ICAAN established Foundation or other suitable existing umbrella charitable organization to existing programs and organizations seeking to resolve issues related to safe, secure access to the Internet for kids.
To further promote the safety and security of kids worldwide and support the TLD brand, Bluehill.com will dedicate an additional ten percent of gross revenue raised in the "sunrise" registration period and $4.50 of each registration fee during the first two years of the contract to a worldwide childrens organization such as UNICEF.
For more than 53 years UNICEF has been helping governments, communities and families make the world a better place for children. Part of the United Nations system, UNICEF has an enviable mandate and mission, to advocate for children's rights and help meet their needs.
Bluehill.com believes the dedication of a significant percentage of gross proceeds for these purposes will provide positive momentum toward solutions to existing issues of concern for child safety as well as a unique positive motivation for participation in the program.
Services and Pricing
The following products and services will be offered during the term of contract:
Enhanced registration sunrise period
(0-90 days) $500
2 years registration
Domain name registration (4 27 months)
2 years registration
Direct domain name registration (28
48 months) $35
1 year registration
Registrations through competing registrars $8 -$34
Value added products:
Kids email $5/yr
Kids portal $3/yr
Kids forwarding $3/yr
Kids pointing $2/yr
Value added bundle $11/yr
III. REGISTRATION RESTRICTIONS
This unrestricted proposal is based on the overall philosophy that Internet effectiveness is adversely affected by centralized censorship. We believe a restricted TLD with predetermined parameters of censorship will not survive.
We also hold that the concept of restricted TLDs as it relates to .kids lends itself to potentially long and difficult legal battles regarding freedom of speech and the use of the Internet.
We believe technological advancements will continue to offer expansive answers to questions regarding of access and content. These advancements will have the added benefit of being "bottom up" rather than "top down" solutions that reduce litigation pressures and increase the potential effectiveness of self-regulation.
IV. CONTEXT OF THE TLD WITHIN THE DNS
Benefits of the TLD
The Bluehill.com application is based on a subcontractor model with no need to capitalize or duplicate infrastructure. Bidding between existing infrastructure providers will lead to lower costs and greater innovation while creating a model for increased competition.
The Internet is a distributed, decentralized and powerful global communications network that is a challenging and unique resource to regulate and control. Shared global responsibilities, as well as existing laws and regulations, are many times inadequate in providing assurance that children and families can enjoy the promise and potential of a safe, healthy and secure Internet experience.
By the age of 12, most children are free to log onto the Internet with little or no parental supervision, according to a national study of families with Internet access. The study, conducted by Greenfield Online, found that 75 percent of parents in online households allow their children to surf the Web in their home.
Greenfield's research also found that while most families take a strict approach to monitoring the Internet access for children under the age of 11, once they reach age 12, most are allowed to go online whenever they feel like it. In families with kids under age 11, 85 percent of parents oversee each and every click. But among families with children age 16, only 5 percent of parents take steps toward monitoring online activities. And despite the availability of Internet filtering software and parental control services, only 20 percent of parents use these tools to control what kids are doing online, according to Greenfield.
There is active and ongoing international debate about whom should make decisions concerning Internet content. Worldwide governments, educators, researchers, organizations and industry partners are actively examining issues related to access and content regulation. We believe decisions regarding content are best left in the hands of these international experts and propose no duplicative process. Rather, we believe the introduction of .kids can stimulate and focus the discussions and attention in one place.
Currently, inadequate funding coupled with the broad and expansive nature of existing TLD names are barriers to effective solutions regarding content. The establishment of .kids will address both of those barriers.
Inappropriate or questionable content for children is easily accessible among the millions of existing web pages online. The recent Child Online Privacy Protection Act (COPPA) report, issued after public input and hearings, cited statistics that revealed "almost 70 percent of traffic on the Web is adult oriented material" and that very little is done, by parents or other sources, to protect children from what may be inappropriate content online.
In spite of best efforts to educate and inform parents and children about safeguards, it is impossible to identify and locate all of the possible sites with questionable motives or apply any standard code of ethics across the DNS.
The US governments initial "hands-off" approach to online privacy and access issues recently morphed into a legislative fix mode with the Child Online Protection Act. Enforcement provisions of the Act have never been enforced due to litigation sparked by the ACLU and others on First Amendment grounds.
The European Union is also working to adopt some sort of "code" or standard that would hold up under legal scrutiny. Progress is slow and the introduction of TLD .kids should not wait for the eventual solutions.
While we do not propose to join the ongoing debate on access and content, our proposal does propose to foster, encourage and augment existing funding for potential solutions via the dedication of a portion of total fees to ongoing efforts to resolve issues related to content and access for kids.
There are many international Internet industry, non-profit and governmental organizations working to encourage cooperation between relevant industry sectors, public awareness, media education, self-regulation, etc. Examples include: Congressional Internet Caucus and Advisory Committee; Childnet International; The Internet Education Foundation; GetNetWise; The European Commission; Childrens Online Privacy Commission; US Center for Advanced Technology in Education; Bertelsmann Foundation; Information Society Promotion Office.
The .kids proposal provides a segmented product that the marketplace will naturally rally around to "do the right thing", given its inherent promotional advantages for users, its natural market segmentation opportunities, its funding for policy development and UNICEF and the public and media attention the introduction of a .kids will generate.
Community and market served
Practically speaking, every market and community in the world is a potential target for TLD .kids. The TLD .kids will serve corporate, social and philanthropic organizations worldwide.
Recent estimates put current .com registrations near 20 million. According to search engine Yahoo, there are 1209 categories, 3641 sites and 480,000 web pages with kid content. AltaVista cites 6,761,780 web pages. Google references nearly 16 million sites. The true market is somewhere in the middle, but difficult to project.
According to a recent Jupiter Communications survey, the U.S. Online population at the end of 2000 is estimated at 14 million kids age 2 - 12 years old and 13 million teens age 13 - 18, representing 40 percent of America's kids.
The number of Internet users under the age of 16 will surpass 77 million by the year 2005, according to Computer Economics.
Earlier this year, NOP Research found that one in three children ages 6-16 in the UK have used the Net, with another 1.8 million getting on this year. The number of Internet users in the Asia Pacific area will increase nearly fourfold from 2001 to 2005.
|Source: Computer Economics|
The market clearly exists for a TLD designation .kids.
Corporations seeking to target information or products to kids will benefit from the niche opportunity .kids presents. Non-profit organizations and social groups would benefit from the opportunity to present educational, informational, and targeted messages. Kids themselves would be drawn to a single TLD designated just for them. Parents would find it far easier to manage their responsibilities with a designated TLD.
Meeting presently unmet needs
There is currently no clearly defined space for children and kid content online. Kids directories are few in number and difficult to access. Bluehill.com believes the introduction of .kids will provide a unique niche for content and improve access. The search for relevant information would be narrowed significantly resulting in quicker, easier access.
The lack of a code of ethics or effective screening mechanism to protect kids from inappropriate content is an ongoing problem. We believe the creation of a centralized online repository for "all things kids" will provide a new beginning and a new challenge for international governments, corporations and populations to build a safe, secure Internet environment for kids from the ground up. The existing competitive marketplace environment is the proper vehicle for that construction, not a regulated environment. In other words, the introduction of .kids can be used to create the opportunities, provide positive incentives, align the interests and let the marketplace work.
The establishment of .kids will not create new problems as to access and content, those problems already exist, but rather .kids will provide the motivation and incentives to focus international attention and public and private resources on solutions.
The proposed TLD .kids will be distinguishable from existing and potential new TLDs due to the unique blending of social and economic interests proposed. This TLD will distinguish itself as a self-supporting entity independent of the volume of registrations. In other words, whether one or one million .kids names are registered the financial model we propose will maintain its integrity.
TLD .kids declares its target and content simply in its name. The universality of the term "kids" will ease its introduction into the existing domain name system and provide an enormous opportunity for narrowcasting information and products. Corporate buy in will be enhanced by the attractiveness of the target audience.
TLD .kids is instantly recognizable as a domain name for children and childrens issues. It will allow segmentation of content and stimulate the addition of directories that will improve access.
The .kids registry will include a number of enhanced features including an expansion of database management to include multiple listings of domain names, real time reservations and name availability information, and more accurate customer information via the updating of root servers twice each day.
What about the potential for inappropriate content?
Currently, efforts to protect young people from objectionable content on the Internet are, at best, marginally successful. By all accounts, existing governmental efforts to "childproof the net" have failed.
The Children's Online Privacy Protection Act recently enacted by Congress is languishing and under legal challenge. "Getnetwise.com" the industry's recent attempt to regulate the internet by providing parents with a centralized website replete with information regarding safety for children on the net as well as over 80 different software tools for parents to protect their children online is too little too late. The new TLD .kids will provide for a new opportunity, a virgin cyberspace arena, to implement and evaluate future mechanisms to protect children from inappropriate content.
V. VALUE OF THE PROPOSAL AS A PROOF OF CONCEPT
There are a number of concepts that may be tested by evaluation of the introduction of this TLD.
There are likely to be numerous new TLDs in the future that pose similar questions regarding access and content. Bluehill.com proposes using the introduction of the TLD .kids to generate ongoing funding in support of research, policy, content self-regulation, and other issues in support of the protection of children. If this funding concept generates sufficient funding and existing efforts are sufficiently motivated new energy toward technological and ideological solutions will result. These new solutions can be applied uniformly across new TLDs at introduction.
The unique nature of the proposed affidavit registration will attract holders of copyright, trademark and other intellectual property in order to protect their existing rights. Bluehill.com hopes to stimulate large corporate registrations to build a strong base of sites targeting kids with appropriate information first, thus deterring potentially inappropriate registrations and weeding out cybersquatters.
The affidavit process itself is a valuable model for testing a means of reducing the number of disputes and eventual lawsuits.
The cost-plus financial model Bluehill.com proposes reduces the risk of registry failure. Virtually no new capital infrastructure is required at start up. Bluehill.com can easily accommodate start up registrations within existing business operations. Subcontractors will be added as needed to accommodate additional volume.
Using the sunrise period to forecast demand, adding subcontractors as need dictates, and adding services as the model progresses preserves capital, allows the addition and deletion of services as demand and technology dictate,
And stimulates innovation while extending the product life cycle of TLDs.
Bluehill.com is aware of prior recommendations resulting from the InterNIC review process and agrees that the formation of an ongoing Advisory Panel of outside experts to critically monitor the experience of new TLDs is in the best interest of preserving the integrity of the Internet.
Bluehill.com will collect and report data to support a third party review, including at least the following:
Interruptions in service
Active websites versus registrations
New product introduction
Proliferation of directories
Number of registries available
Number of disputes in process and resolved
Training and education of target audiences
Bluehill.com will also perform a rigorous self-evaluation against the satisfactory performance of all services specified in the ICAAN agreement granted for the .kids TLD.
Our goal is to provide and promote .kids as a community of common affinity. Bluehill.com recognizes that its role will be one of responsible stewardship, protecting the overall stability of the Internet while providing motivation and funding toward the creation of a secure, safe and healthy cyberspace environment for kids worldwide.
The Bluehill.com model builds upon the successes of the past, proposes innovative new policy directives, and demonstrates strong capabilities for success.
We believe the critical elements of our proposal a self-funded registry operation, low capital requirements, stimulation for competition, affidavit-based sunrise registration period, funding for worldwide kids charities and Internet content solutions, redundant systems and monitoring provisions, comprehensive international marketing program, and intensive technical and customer satisfaction based evaluation provisions provide a blueprint for success while minimizing risks and maximizing opportunities.
Bluehill.com has demonstrated an ability to provide the infrastructure necessary to implement the proposed concept rapidly and with a high level of confidence. We believe the implementation and testing of our proposed model will provide ICAAN with valuable information on which to base future decisions related to the granting of new TLDs.
The Bluehill.com team appreciates the opportunity to be considered in this process and stands ready to meet the challenge.