|VI.||ENHANCEMENT OF COMPETITION|
One of ICANN's core principles is the encouragement
of competition in the provision of registration services at both the registry
and registrar levels. Promotion of that principle will be a criterion.
As one illustration of this criterion, a major purpose of the reassignment
of the .org registry is to diversify the provision of registry services
by placing the .org registry under different operation than the .com and
.net registries. Consideration will be given to the extent to which proposed
arrangements are consistent with this purpose. As another illustration,
applicants are encouraged to refrain from prohibiting
|C31.||Give your analysis of how selecting your application would affect competition in the provision of registration services at both the registry and registrar level.|
NeuStar was created with the goal of providing advanced registry services in a neutral and even-handed manner to promote competition, and has played a significant role in advancing competition in both the Internet and telecommunications industries.
Promotion of competition is at the core of NeuStar’s mission—administering services in an even-handed manner to provide a level playing field for all possible participants, large or small, established entities or new entrants. The NeuStar application for .org demonstrates how we are uniquely positioned to maximize competition at both the registry and registrar level. The selection of NeuStar to operate the .org registry will best foster competition because of the following attributes:
Trusted, neutral third-party model
Registrar ownership model—The Registrar ownership model in which the registry is owned and operated by a single registrar may create certain operational efficiencies. However, this approach has the following disadvantages in terms of promoting competition:
Consortium model—The Consortium model, in which a number of registrars own an entity that operates the registry, does provide a means of pooling common interests and funds for registry operations. However, this model also is not optimal in terms of fostering competition for the following reasons:
Neutral third-party model—In the neutral, third-party model, the registry operator does not operate as a registrar and therefore it does not offer any services that compete with the registrars. The neutral, third-party model is the optimal model for promoting competition for the following reasons:
NeuStar’s legacy in both its telecommunications and Internet registry business, which has proven successful in competitive markets, is that of a trusted, neutral third-party. We therefore, do not and will not accept .org registrations directly from registrants. By maintaining NeuStar’s focus on providing registry services to registrars, rather than competing directly with them, the registrar community is effectively served in a manner that supports fair and open competition.
of Conduct ensuring competitive neutrality
NeuStar’s proposed Code of Conduct for .org also includes stringent operating requirements specifically targeted at the promotion of competition. For additional details on the Code of Conduct see Proposal Section C21.
Experience promoting competition
In the telecommunications industry, NeuStar played a central role in establishing competition in North America. Our Local Number Portability business serves over 3,000 telecommunications service providers in that market, enabling users to change their provider while retaining their existing telephone number. Number portability is considered one of the most important factors in bringing about competition, since users generally will not change providers if they have to change their telephone numbers. In our role as the North American Numbering Plan Administrator (NANPA) and the administrator for the European Telephony Numbering Space (ETNS), NeuStar allocates numbering resources in a competitively neutral manner to service providers in both the North American and European markets.
Diverse and inclusive .org Global Policy Council
NeuStar’s proposed .org Global Policy Council (GPC) provides a framework for geographically diverse representation by ALL sectors of the noncommercial community. The GPC structure also includes a free membership organization with mechanisms to support feedback to the council. NeuStar’s inclusive approach ensures that no single segment of the noncommercial community has disproportionate control of what .org is and what it becomes, thus providing a superior model for ensuring effective competition (See Proposal Section C35 for additional detail).
No conflicting gTLD
The TLDs currently supported by the NeuStar registry (.biz and .us) are specifically focused on the global business community and the United States markets. NeuStar does not currently operate a gTLD that would be attractive to the global noncommercial community. In selecting NeuStar to operate the .org registry, ICANN will be diversifying the number of registries serving the noncommercial community and thus supporting robust competition at the registry level.
NeuStar’s success marketing the .biz gTLD to a specific targeted
No affiliation with incumbent operator
NeuStar has no affiliation with the .com and .net registry operator – directly or indirectly with the registry, its parent, or any of its company affiliates. Thus, a selection of NeuStar as the successor registry operator of .org, mitigates this risk and supports the stated goals of ICANN.
Ensuring the long-term viability of the competitive registry
NeuStar has established a price and pricing structure (for more detail, please see Proposal Section C26) that represents a significant discount from the current market rate for .org. In the interest of promoting fair competition, the proposed pricing and payment terms for all registry services will be available on an equal basis to all ICANN accredited registrars. Despite the reduction in price, NeuStar’s proposed service levels (See Proposal Section C28) represent an improvement in those currently in place with the current .org registry operator.
State whether the applicant or any entity identified
in item C13 operates
a DNS registry having more than 500,000 registered names and, if so, provide
NeuStar has a legacy of operating mission – critical public resources for over six years, recently expanding the breadth of services to the management of an Internet registry with over 800,000 domain names.
NeuStar Registry Service’s currently administers two TLDs – the .biz registry, an intended-use domain for commercial entities, and the .us country code domain. The .biz Internet registry launched in September of 2001, and has grown to over 620,000 registered names. We have utilized that same platform to seamlessly transition and operationalize the .us country code TLD in the first half of this year. The .us registry has over 240,000 names under registration.
NeuStar was selected by ICANN to establish and operate the .biz registry in November 2000. The .biz Internet registry launched in the fall of 2001 and began its live registration of domain names in November of the same year. Like .org, the .biz TLD is not generic—it has an intended user base. For .biz, that intended use is serving global commercial needs, it does not compete in any way with .org. The fact that .biz compliments rather than conflicts with .org means that NeuStar will focus marketing to the global noncommercial community solely on the .org TLD
In October 2001, NeuStar was selected by the United States Department of Commerce to transition management of the .us country code from VeriSign, enhance the name space and implement a competitive registration model. Within a month of selection, we seamlessly transitioned the existing registry, one that was comprised of a complex, hierarchical compilation of domain names. Just three months later, a sunrise period was executed, and over 10,000 trademarks were registered. In April 2002, the .us registry went ‘live’ for the public, accepting near real-time registrations—over 100,000 in the first day without service disruption or degradation of any kind.
|C33.||Describe in detail all affiliations, including direct or indirect ownership and contractual arrangements (including letters of intent) for the past, present, or future provision of registry services, between (a) the applicant or any entity identified in item C13 and (b) any operator of a DNS registry having more than 500,000 registered names.|
As previously indicated, NeuStar will perform all functions associated with registry services and is not affiliated with any registry managing over 500,000 names. There are no other dependencies or obligations that are outside of the control of NeuStar, as was the case with the smooth transition of .us from VeriSign, we will directly perform all registry services thereby mitigating the significant inherent risk associated with managing multiple partners and subcontractors and ensuring the a zero-impact transition and ongoing stability of the .org TLD.