A. General Description of the Application
  1. TLD String(s) Requested.
    .sansansan and .three33
    .bababa and .eight88
  2. Category.
    General Purpose, General.

    Rathbawn Computers Limited (“Rathbawn”) requests a number of TLDs. Although Rathbawn’s 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 categorization. Instead, Rathbawn’s categorization is based primarily on the substance of the application which seeks TLDs targeted at the broad group of registrants and end users and focuses exclusively on commercial uses. As such, Rathbawn qualifies for the general purpose category and general group.
  3. Sponsor, Registry Operator and Subcontractor.
    a. Sponsor. Unsponsored Application.
    b. Registry Operator. Rathbawn is a newly incorporated Irish corporation, with facilities in Golden, Colorado and Canberra, Australia[2], acquired to apply to ICANN for new general TLDs. While Rathbawn has no operational history, its management, through its firm Capital Networks, has experience in registry operations through its involvement in operating the .hm registry (Heard and McDonald Islands) and as a founding member of CORE. Moreover, TotalNIC.com, a business unit of Capital Networks, is an ICANN approved registrar of domain names in .com and .net. TotalNIC.com claims to be the world's first firm to offer half price .com and .net registrations and claims to have been a price leader ever since.
    c. Subcontractor. None listed.
  4. Registry-Registrar Model.
    Registrations will be made available through all qualified ICANN approved registrars which demonstrate certain technical competence. Neither the registry nor any company in which any of its directors hold any interest will offer registration services in any of the general TLDs.

B. Technical Review
  1. Summary Description of Proposal.
    This proposal contains five essentially separate components, though all are to be handled by the same technical facilities:

    1) multiple TLDs for corporations and other incorporated businesses

    2) .wap for sites running the WAP protocol

    3) a set of pinyin versions of Chinese names for use by Chinese speakers

    4) .sex and .xxx

    5) .afr and .africa

    There are somewhat different plans, both administratively and technically, for all five different components. In common, Rathbawn will run only registry and Whois facilities (not registrars) and will seek to offer registration at very low prices.
  2. Support of the Business Plan by the Technical Plan.
    a. Total Capacity. The projected sizes of the different areas range from 200,000 to 52 million over a four year time frame. The technical plan is sufficient for the smaller ones, but may be underplanned for the larger ones, if Rathbawn is indeed that successful.
    b. Projected Growth Rate. Again, variable among the five areas. In some areas, Rathbawn projects growth rates of greater than an order of magnitude over four years. The plan does not seem to call for introduction of more DNS sites over time.
    c. Startup Period. Again, variable. For some of the domains, Rathbawn plans significant pre-start and startup activities. For others, it is basically going to just turn them on.
    d. Fault Tolerance. In some cases, Rathbawn chose not to locate servers in the geographical areas of greatest need. For instance, the Chinese TLDs do not have a DNS server in China, or even Asia. Certain kinds of faults might thus separate all servers from their most important audience.
    e. Security. Rathbawn’s use of tiered access to different servers, non-routable IP addresses to the servers, filtering through front end machines, and physical security of server locations is standard. But Rathbawn says little about the security of registrar-registry communications, and seems to rely on passwords where it could use cryptographic communications or more secure access control. Rathbawn does not discuss password selection procedures, nor the frequency with which passwords will be changed. It does not discuss logging or auditing, nor does it indicate plans for regular evaluation of system security.
  3. Summary of Relevant Experience.
    Rathbawn, through CapitalNetworks, has been a registrar for some time, and has run a very small country’s registry. It provides no details on how many names it has registered in either role. Principals have been active in design and discussion of registration issues. There is no evidence it has run any large scale data management operation at the level of some of its proposals.
  4. Apparent Implementation Risks.
    For all proposals, Rathbawn’s experience is limited, especially at high end. It may run the large registries poorly. The risk is lower for the registries that will have smaller size.

    Rathbawn’s view of security seems narrow. Its proposed security mechanisms are underspecified, leading to concerns that they will not run a sufficiently secure operation.

    For the .xxx/.sex TLDs, Rathbawn’s proposals to require participant sites to verify the age of the viewer against the prevailing laws of the viewers countries are technically difficult. It plans to rely on a database of ISP locations, presumably mapping the IP address of the viewer’s request packets to the ISP originating them. It is unclear that this information is uniformly available. Further, ISP location is often a poor match to viewer location. Almost certainly, clever use of IP address spoofing software can defeat this provision. The use of intermediate sites set up to hide the origination point of communications would also completely defeat it.

    Rathbawn plans to map the Chinese name domains into Chinese character versions of the TLDs. It claims this will be easy, but does not specify how it will be done and will need to conform to certain domain name limitations.

    The .wap domain is highly specific to the WAP protocol. If that protocol becomes eventually unpopular, the domain will be of little value, but will have to be supported indefinitely. A more technically sound approach would be to create a TLD that can register any protocol, with WAP being one of the options.

    Rathbawn suggests that the family of TLDs related to corporations is a more logical and useful way to organize commercial enterprises than .com. It provides no suggestion of how a consumer determines which of the five or ten possibilities is used by any given corporation, nor what to do if the corporation changes its form of incorporation, as apparently happens regularly.
  5. Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
    These resources seem very limited. The current company apparently has six employees, and the partners are not very large. The partners provide some level of expertise on dealing with registration issues, but not deep experience.
  6. Advancing the State of the Art.
    The Chinese TLDs will presumably lead to experience in using non-Latin characters for domain names. The .xxx TLDs will require considerable innovation to achieve what Rathbawn hopes to achieve.
  7. Other Comments.

C. Business Review
  1. Applicant’s Representations.
    Rathbawn was created by its parent, Capital Networks, specifically for the opportunity to become a new TLD registry. Its goal is to introduce a new level of price competition and mutual obligation into domain name registry service provision. Its sister company, TotalNIC.com, is an ICANN-approved registrar for .com and .net. Management of Rathbawn also designed and established the .hm registry in 1997, one of the first fully automated web-based registries. Rathbawn currently has 14 staff borrowed from Totalnic.com. The revenue model is subscription-based. Registrations will be priced at the estimated long run incremental cost of $3 per year. It will not operate as a registrar. Rathbawn has defined five target markets in its application: .xxx – 2.87 million, .llc – 19.06 million, .chinesename – 1.55 million, .wap – 1.46 million, .africa – 100,000.
  2. ICANN’s Evaluation.
    The strengths of this application lie in its management’s registry experience and its large target markets. The application has several weaknesses. The TLDs it has applied for have very different markets and issues. The application does not discuss how it will tailor its marketing to each segment, nor does it discuss any experience the company has in any of these segments. There is no critical analysis of market penetration. It may also understate the capital investment and staffing levels needed for such general demand TLDs. Without a serious discussion of its target markets and how it plans to penetrate them, this application has not demonstrated a complete and thorough understanding of the business. Overall, there are other applications in this category that are stronger from a business plan perspective.

D. Summary of Public Comments
  1. Number of Comments.
  2. Opposition to Application.
    Some of the proposed TLDs are “ridiculous.” One writer stated that it would be “patronizing and colonialist” for a company based in the U.S. and Australia to “own” a TLD referring to the African continent Another comment focused, in part, on the $50,000 application cost being prohibitively expensive for those who live in poor countries in Africa.

[1]And all other suffixes denoting incorporation or business registrations.
[2]Rathbawn will carry on business initially from the offices of TotalNIC.