A. General Description of the Application
- TLD String(s) Requested.
General Purpose, General.
Name.Space, Inc. (“Name.Space”) requests 118 TLDs in its application. Although the Name.Space application contains a number of requested TLD’s which, taken alone, may qualify for different categories and/or groups, there is no primary, identifiable TLD which allows for such a categorization. Instead, Name.Space’s categorization is based primarily on the substance of the application which seeks unrestricted TLDs targeted to a broad group of registrants and end users focusing exclusively on commercial uses. As such, Name.Space qualifies for the general purpose category and general group.
- Sponsor, Registry Operator and Subcontractor.
b. Registry Operator.
Name.Space, was founded in 1996 to publish and provide registry services for new general TLDs, including .art, .cam, .design, .gallery, .music, .news, .shop, .sports and .sex. Name.Space’s principal business address is in New York, New York. Names.Space is currently acting as a wholesale provider of new and emerging general TLDs by providing registry service to registrar resellers at wholesale rates. Name.Space claims to have selected, established, published and be presently operating over 540 new general TLDs. Name.Space also claims to serve small e-commerce businesses by providing custom, secure DNS services, web presence, and secure and conventional e-mail services.
- Registry-Registrar Model.
Name.Space intends to form relationships with all interested, existing ICANN accredited registrars to resell new general TLD’s published and operated by Name.Space as they do with NSI and .com, .org and .net domains. In addition, Name.Space intends to develop a network of global affiliates, partners and resellers to provide services licensed under the Name.Space brand as well as customer-branded services in which Name.Space provides the technology back-end capabilities under a customer’s brand.
B. Technical Review
- Summary Description of Proposal.
This proposal would add approximately 100 new general TLDs, possibly more. Names could be reserved at the SLD level. In effect, some SLDs currently being operated by Name.space would be elevated to general TLD status.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
Capacity estimates are based on unspecified benchmarking that indicate that the system can handle 100 transactions per second. No actual estimates of expected peak rates are provided. There is no breakdown of expected transaction rates by service.
Although Name.Space currently runs a registry-like service and a name server network, very little information is provided on how the current system would be scaled to accommodate the anticipated load.
b. Projected Growth Rate.
The projected growth rate is indicated indirectly based on estimated revenue from name registration. The expected registration rate would equal or exceed one million names per quarter. This appears to be a substantial increase from current operations based on renewal registrations in the 1000s of names per quarter.
c. Startup Period.
The initial startup registration is expected to be as high as one million names in the first month. Even this may be low if all TLDs were granted at one time.
d. Fault Tolerance.
Whois functions will be performed by the registrars, therefore, the integrity and availability of the Whois data will derive from the capabilities of the individual registrars.
Name.Space basic approach is based on a single geographical location with internal redundancy. Internal redundancy is basic off the shelf variety (e.g. RAID, hot swapping of units). Plans for geographical dispersion are formative. Non-critical services, like Whois, are restarted manually. It is intended that critical services would be redundantly located, but the update and restart plan needs to be clarified.
Data recovery procedures are basically manual and implemented using very basic tools. A more automated data recovery approach would be desirable.
Security is based on using public key encryption methodology between registrars and registry. Other aspects of transaction security are based on off the shelf tools. Physical security is common commercial grade. The basic security philosophy is that all data transmitted or sent off site would be encrypted.
- Summary of Relevant Experience.
Name.Space claims to operate 540 general TLDs using proprietary software. The application suggests that the primary technical staff currently serve as contractors but will be made permanent employees in the event that the proposed general TLDs are agreed to by ICANN.
- Apparent Implementation Risks.
It appears that the protocol between the registrar and the registry will be a private protocol. As currently stated in the application, the protocol is in narrative form. This protocol would need to be completely defined, tested and deployed. It appears to be different from the current registrar/registry protocol. The technical plan is rudimentary and does not relate how operational structure would be integrated with reliability and redundancy requirements.
Scaling from the present system to the reliable, high performance system required to support the projected demand is not clearly delineated. Scaling plans are incomplete with respect to staffing, development, facilities and performance estimation. Moving from an assumed level of a few thousand names under management to the projected initial level of one million names under management would require a very steep ramp up. This is likely to be very different from the current primary business of Name.Space which is SLD management, hosting and web design.
The leadership team has limited experience. What experience it does have is limited to systems of a modest scale. Scaling to the larger and more robust systems required to handle the anticipated load will require a stronger technical team and stronger technical management.
Adding so many TLDs at one time might lead to a “land rush” of unprecedented size. This would need to be very carefully controlled if it is not to have short-term destabilizing effects.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
Experience level of the team is modest, although it has experience in operating an SLD that would have some of the characteristics of its proposed TLDs. Plans do not indicate how the current system would be scaled to that envisioned to handled the increased traffic of the proposal. The underlying assumption is that the scaling process will be straightforward.
- Advancing the State of the Art.
The technical proposal would immediately add about 100 new domain names that would be used in an unrestricted manner.
- Other Comments.
C. Business Review
- Applicant’s Representations.
Name.Space was founded in 1996 to publish and provide registry services for new generic top level domains such as .art, .cam, .design, .gallery, .music, .news, .shop, .sports, .sex, and others, to open the domain name market to competition and diversity. Name.Space has selected and presently operates over 540 new general TLDs. For its current operations, Name.Space has three full and part time contractors in addition to the founder.
The revenue model is subscription based. It includes a wholesale price of $6 and a retail price of $30 per domain name. Name.Space is proposing to offer registry and registrar services. This company will require $150,000 by the end of the year 2000 to ramp up the operation and to begin to accommodate resellers. Name.Space believes that revenues from existing sales will be strong enough in the next quarter to minimize the need to borrow any additional capital. The application further states that Name.Space may enter into negotiations with other investors but that has not been determined at this time and that it is highly confident that it can raise sufficient capital once its gTLDs are activated globally. Over the next 12 to 18 months the company will seek additional capital in the range of $2.5 to $5 million.
- ICANN’s Evaluation.
The strength of this application lies in the existence of registry/registrar experience. The weaknesses of this application includes: (1) a weak marketing plan, (2) a lack of sufficiently planned financing and (3) lack of sufficiently planned human resources to meet demand. Further, this application only contained a one-year pro-forma financial statement. Overall, this application is not as strong as other applications in its category from a business plan perspective.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
Support was expressed for the proposed “.shop” TLD in particular (mostly in quite similar postings).
Name.space is a “stable” company and “understand the goal of [the] internet”.
One commentator registered support from both Name.Space and IOD: “Should ICANN award any of name.space’s TLDs to other applicants I think [it] would be an injustice and would warrant litigation since the TLDs are effective and resolve on an alternative root like many others. This is a question of infringing on intellectual property and ICANN should be careful not to fragment the web.”
Another commentator supported “.games” because “use of the internet for entertainment is obviously widespread.”
- Opposition to Application.
ads is already owned by the country of Andorra.
Complaints were registered that some of the proposed TLD names were confusing
application failed to comply with the ICANN guidelines.
One commentator wrote opposing the “.market” TLD and instead suggested “public utility portals” should be created that would allow participants in various markets to enter into paperless contracts.
“I think ICANN would be making a mistake by legitimizing the work that name.space has done as equal to an actual TLD. While their service is obviously very useful to many who, to date have not been able to get exactly what they need for their name, to hold them up as ‘already serving as a registry’ would be an exaggeration both technically and in principle.”