BIZ REGULATORY AND ADVISORY COUNCIL / AFFINITY INTERNET, INC.
A. General Description of the Application
- TLD String(s) Requested.
General Purpose, General.
The biz Regulatory and Advisory Council ("bizTRAC") requested 5 TLDs with its application focused primarily on the .biz TLD. Accordingly, bizTRAC qualifies for the general purpose category and general group because .biz is a generally unrestricted TLD targeting a broad registrant and end user base. Furthermore, bizTRAC’s entire application is focused on primarily commercial uses.
- Sponsor, Registry Operator and Subcontractor.
bizTRAC is a non-profit LLC formed under the laws of the state of New York. The stated purpose of bizTRAC is "to provide a regulatory and advisory body where the unique concerns and opinions of the stakeholders of the .biz TLD can be translated into policy to support .biz as a TLD for operating businesses." The Board of Directors will consist of 15 to 31 members. The Board will follow guidelines encouraging representation by the major constituencies served, including at least: (1) two Board members from groups representing trademark and intellectual property organizations, (2) two board members from chambers of commerce, (3) two board members representing better business bureaus (or other self-regulated bodies), (4) two board members representing consumer protection groups, (5) two board members representing business and trade associations and (6) two board members representing registrars.
b. Registry Operator.
Affinity Internet, Inc. ("Affinity") was founded in 1999 for the purpose of establishing a dominant web-hosting platform for small and medium size businesses. Soon after organization and initial capitalization, Affinity acquired three operating companies that form the core of its present revenue stream: Affinity Web Hosting, Inc, ProWebSite and Dynatek Info World, Inc. (d/b/a Sitehosting.net). Through these operating companies, Affinity has been operating since 1996 and claims to offer small and medium sized businesses a full suite of web-hosting and web-related infrastructure services, including e-commerce solutions. Affinity claims to have more than 35,000 customer accounts. While marketing and pricing of the .biz TLD will be carried out by Affinity, all technical management of the registry operations will be outsourced to 7Ways.com, Inc.
7Ways.com, Inc. (“7Ways”), created in June 1998 and located in Sophia Antipolis, France, purports to specialize in Internet engineering and security. 7Ways is an ICANN accredited registrar and a member of CORE.
- Registry-Registrar Model.
For a period of four months, Affinity and one other registrar will provide registrar services. After the initial start-up period, bizTRAC aims to add one registrar per month over the next six months. Only ICANN accredited registrars will be eligible to become a registrar for the TLD.
B. Technical Review
- Summary Description of Proposal.
The proposers suggest a .biz TLD to serve as a more regulated name environment than .com. They will only accept registrations from legitimate businesses, and will ensure that trademark violations, cyberhoarding, and improper registration of substantially similar names are not permitted. All issues but high level policy will be handled by Affinity Internet Inc. In turn, Affinity subcontracts to 7Ways for management of the actual facilities.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
Due to the stringent requirements for getting into the registry, the total capacity is fairly modest, in the high tens to low hundreds of thousands of domains. The technical plan seems adequate for that level, though it fails to specify the types of machines used, so it is difficult to assess if it would operate well at high capacity.
b. Projected Growth Rate.
The growth rate is not dramatic, and the system should be capable of handling these rates. Given their lack of specificity in their hardware and architecture, it is impossible to assess if it will scale far beyond their plans, should they prove extremely popular.
c. Startup Period.
The proposers will have a six month pre-start period to set up names for early adopters and to work out trademark and other legal issues. The resources available are reasonable for handling the startup traffic.
d. Fault Tolerance.
Good in some ways, but underspecified. They do not give details on the kinds of machines to be used as servers, though they do discuss replication of core components of the system. They do not specify that the main registry site and the mirror site will be in widely different locations, which would be highly preferable.
Solid. 7Ways has strong security experience and is using reasonable tools and methods.
- Summary of Relevant Experience.
bizTRAC itself barely exists, and thus little experience resides there. Affinity’s experience is largely with running web sites. 7Ways has good experience in Internet naming. They are an official registrar, they have ties to CORE, they have developed registry software meeting CORE specifications, and they have tested their registry software up to 1,000,000 entries. They do not list live experience running a registry.
- Apparent Implementation Risks.
The lack of specificity in the hardware to be used leaves some doubt about whether it is powerful enough and fault tolerant enough. The more popular the service proved, the greater the risk that the system design would be inadequate.
The validation step is a major bottleneck, and might significantly slow down registrations. Since they apparently plan to do all issues of validation (determining reality of the applicant, checking for substantially similar names, etc.) with human assistance, there are no technical risks here.
The registration fee is very high. If few businesses choose to register, the registry might be underfunded for its requirements.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
There is little information provided in the proposal to answer this question. Basically, the technical expertise is in 7 Ways. The materials 7Ways provides do not give sufficient details to assess organizational scalability.
- Advancing the State of the Art.
The technical plan really does not advance the state of the art. The unique aspects of this proposal are non-technical.
- Other Comments.
C. Business Review
- Applicant’s Representations.
bizTRAC was formed specifically to sponsor the .biz TLD. It will consist of 15-31 members, and its mission is to provide a regulatory and advisory body for the stakeholders of .biz. It has no past operations and the registry operator will provide its initial capital of $300,000. Its ongoing source of revenue will be from registrations.
Affinity currently offers web-hosting and related infrastructure services to small and medium sized business. Its mission is to guide small and medium sized businesses seeking to build a successful e-Business. The company was founded in 1999, but through its acquired companies it has been operating since 1996. Affinity currently has 150 employees in the United States.
The target market for the .biz TLD is small businesses. The application includes estimates that five million new small businesses will be selling online within five years. The revenue model includes a $2,000 registration fee with $150 annual renewal fees. Nominal fees will be charged to reserve substantially similar names that point to a primary site or block others from reserving them. For this fee, Internet users will be provided some assurance that the registrants in this TLD will be quality businesses.
- ICANN’s Evaluation.
The strengths of this application lie in its large potential market and the company’s Internet experience. It also provides a different type of business model in that users of the site will be provided additional assurances. The weaknesses include the lack of a detailed marketing plan, and minimal support for revenue model assumptions. Overall, there are other applications in this TLD category that are stronger from a business perspective.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
A high cost of entry, as Affinity proposes, will eliminate non-serious applicants and help prevent hoarding of domain names.
“This proposal is the only “.biz” proposal which is really different. This should be tried to see how pre-screening works.”
“I think $2,000 is a good price to charge because it will eliminate non-serious applicants. Renewal is only $150. This is not a lot of money for a real business, or even someone starting a business, to pay. It is less than what is charged by people who want to auction names. Also this would give prestige to a company using .biz.”
- Opposition to Application.
Certain commentators expressed concern that the TLD is designed only for large companies and will discriminate against small businesses;
Others expressed concern regarding the dangers of the “name lottery”; and. biz would, according to a commentator, create confusion with .bz (generic comment made about all .biz applications).
“We find that this proposal falls far short of the proposed “proof of concept” RFP. ...The string proposed is far too broad & encompassing for the pricing restrictions indicated ($2,000). This discriminates significantly against small business (especially in emerging global economies). The concept of a “Name Lottery” as proposed in this application is repugnant and without merit in this process.”
“I would never provide personal address, bank information or anything of that nature in order to register a domain name. $2000 for a business domain is excessive and ridiculous. ... this policy is unworkable and much too restrictive for such a category of TLD. A better string would be BIG biz... as you will essentially eliminate most small businesses.”
- Substantive Comments and/or Questions.
“This is a very well thought-out proposal which will help small business people with the problem of name hoarding. As far as I can tell, none of the other proposal address this problem.”