A. General Description of the Application
- TLD String(s) Requested.
General Purpose, General.
iDomains, Inc. (“iDomains”) requests 3 TLD’s with its application focused primarily on the .biz TLD. iDomains targets a broad registrant and end user base and focuses primarily on commercial uses. Accordingly, iDomains qualifies for the general purposes category and general group.
- Sponsor, Registry Operator and Subcontractor.
b. Registry Operator.
iDomains, Inc. was formed on May 19, 1998 under the laws of the Commonwealth of Pennsylvania. iDomains is a sister corporation of Domain Bank, Inc., an ICANN accredited registrar, in that both corporations are under common control. The sole shareholder of iDomains is Henry A. Lubsen, Jr. iDomains has not engaged in significant operations to date. The company was formed to provide domain name registry services as opportunities to provide such services became available. Domain Bank is a founding member of the Internet Council of Registrars ("CORE") and in August of 1999 became an ICANN accredited registrar. iDomains proposes to contract with CORE to provide back-end registry services for the .biz registry. CORE would provide the following services: (1) Domain name registry services, (2) centralized Whois and (3) third level domain registry services. In the event that a cross-registry Whois service Id develops, iDomain anticipates that CORE will be responsible for its operation with respect to the .biz registry.
CORE is a not-for-profit association organized under Swiss law, with its principal address in Geneva, Switzerland. CORE is an association in which its members have coordinated a technical framework while retaining their own marketing and customer service functions. CORE currently acts as an ICANN accredited registrar and utilizes a shared registrations system ("SRS") which allows its members to register domains under .com, .net and .org. This SRS is based on a model originally designed for use by a registry and manages over 800,000 domains.
- Registry-Registrar Model.
To help alleviate the inherent conflict in the common ownership of an accredited registrar and a registry, the owners of Domain Bank will divest at least seventy-five percent of the equity ownership of Domain Bank to one or more third parties if iDomains is awarded a registry contract. All accredited ICANN registrars will be eligible to provide registrar services in the iDomains registry. Moreover, iDomains proposes to implement a process essentially identical to the current registrant/registrar/registry relationship with regard to dealings with domain-name holders.
B. Technical Review
- Summary Description of Proposal.
iDomains proposes a general TLD dedicated to business domain names. Registrants will be filtered to ensure that they are bona fide businesses. Registry operations are outsourced to CORE. CORE projects 300,000 registrations in the first month, 2.6 million in the first year and 19 million under management by the end of year 5.
All two character sub-domain names would be reserved to the registry. Registrants would receive .biz and ..biz., where would be the country of the registrants origin. Registrants would be restricted to entities that can demonstrate, at least at some minimal level, that they are a business. For example, by providing a tax ID number.
- Support of the Business Plan by the Technical Plan.
The CORE proposal seems to meet the technical requirements in all respects.
a. Total Capacity.
System capacity estimates are based on revising the registry protocol to reduce traffic and to off-load Whois and check traffic to a separate service. Attempts will be made to reduce Whois traffic by identifying abusive requestors and excluding them. iDomains is claims that the current registry system has been tested to manage several million names. iDomains estimates that system will handle one “complex” transaction per second exclusive of Whois traffic. It is unclear precisely what a complex transaction is.
b. Projected Growth Rate.
iDomains uses a scalable approach that should be adequate to track the expected growth rate.
c. Startup Period.
iDomains will implement a batch processing, round robin scheme to provide request throttling and promote fairness during the start-up period.
d. Fault Tolerance.
Availability is provided through use of standard duplication techniques. System will provide an alternative location for SRS services. The alternate location will receive continuous updates, however, switchover apparently will take several hours.
iDomains proposes to use two sites to support the registry function, however, the switch over approach appears to require a significant period of time (hours). iDomains should consider implementing a failure approach that would allow continuous operation of registry services even in the event of a serious primary site failure.
Security will be provided through the use of off-the-shelf tools. Physical security follows standard approaches. Particular attention has been paid to providing secure linkages between various parts of the system through the use of encryption and certification techniques.
- Summary of Relevant Experience.
IDomains is a spinoff from Domain Bank, an established ICANN accredited registrar. While this Domain Bank is small, it appears to have extensive experience with registration operations. CORE has extensive experience in registry operations.
The experience base of the applicant and subcontractors appears to be excellent based on the development and testing of registry systems. The registry protocol specification, for example, makes clear that iDomains and CORE have the technical capability to develop or extend the required systems. CORE’s current technical staff is relatively small and significant expansion and hiring will be required to meet the demands of constructing and operating the large registry proposed.
- Apparent Implementation Risks.
The qualification of prospective registrants appeared to be labor intensive and subjective. Automating the process may be difficult. The staffing plan does not seem to support a manual process.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
iDomains is projected to have a small technical staff, relying on CORE for technical matters related to the registry. CORE itself has only a small staff, but asserts that it has a call on the technical resources of its member companies. CORE currently manages approximately 800,000 names for its members.
CORE will provide test services for Whois and for registrars so that systems may be debugged without impacting the normal operations.
- Advancing the State of the Art.
CORE would enhance the RRP to provide for a “thick” registry leading to a centralized Whois. Whois services would be extended to allow for subscription based access. This might be important in a commercial domain environment because businesses may wish to make additional information available in the Whois data base so that external directory type services could locate and present this information. Plans also include certain registrant directed audit trails and logging. For example, notification if the Whois data is modified.
iDomains would require that registrants be engaged in commercial activities only, the intention being to exclude personal activities. To enforce this, registrants would provide a tax ID number for presentation in the Whois response. There is no mention of technical means to verify such numbers.
- Other Comments.
iDomains proposes to restrict the namespace in certain ways, which may be difficult to explain to prospective registrants and registrars. Technical implementation should not be difficult, however.
C. Business Review
- Applicant’s Representations.
iDomains was formed on May 19, 1998. Its sister corporation is Domain Bank, an accredited registrar. Both companies are under common control. The application states that iDomains realizes the inherent conflict in ICANN authorizing an accredited registrar to register domain names in a registry where the majority owner of such registry is an affiliate of the registrar. It states that such a conflict is irresolvable by use of “Chinese Walls” and that if awarded a registry contract pursuant to this application, it would divest at least 75 percent of the equity ownership and management control of Domain Bank to one or more third parties. Domain Bank presently employs 15 individuals. iDomains has selected CORE to operate the back-end registry services for the new general TLD.
The revenue model is a subscription model with a registry price of $5.45 per year with an average 75 percent renewal rate. The expected total registration in year one and four are 1.1 million and 12.0 million, respectively. By year four, iDomains expects to employ 35 people.
- ICANN’s Evaluation.
The strengths of this application include (1) its experience as a registrar, (2) its strong focus on marketing expenditures in the early years, (3) its involvement of CORE as a back-end subcontractor. The weakness of this application is in the lower expected initial capitalization. If new registrations do not occur as planned, the venture may have liquidity issues. Overall, this is a stronger application in its category from a business perspective.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
“iDomains, Inc., they have some good broad appeal extensions, i.e., .biz, .ebiz, and .ecom. These are also narrow enough [business] to prevent a monopolistic strangle-hold on competition?”
“I must say that the application for iDomains is one of the more well thought out plans. The business model is well thought out and the management team has experience to handle this task. If I were making the decision I would rule for a .biz for a limited domain and iDomains would be awarded the contract.”
- Opposition to Application.
Two comments claim that .biz is already in existence. Both of these comments support IOD’s .web application.
“The introduction of a “.biz” or “.ebiz” TLD would create substantial confusion among Internet users and also interfere with the “.bz” ccTLD and the existing rights of the country of Belize due to similar sound and the likely meanings under which each TLD would be marketed. The country of Belize has recently licensed its ccTLD for marketing domain names to businesses.”