A. General Description of the Application
- TLD String(s) Requested.
General Purpose, General.
NeuStar, Inc (“NeuStar”) requests several TLDs which are unrestricted. NeuStar targets the broadest possible registrant base and end user group with almost exclusive focus on commercial uses. As such, NeuStar qualifies for the general purpose category and general group.
- Sponsor, Registry Operator and Subcontractor.
b. Registry Operator.
By correspondence on November 8, 2000, Neustar informed ICANN it would not subcontract its registry operations to JVTeam. Neustar’s decision not to subcontract to JVTeam arises from potential non-compete issues between Melbourne IT (joint partner in JVTeam) and Afilias. NeuStar, a Delaware Corporation, was originally founded in 1996 as an independent communications industry services business unit within Lockheed Martin. NeuStar designed, built and continues to manage one of the largest databases in the world and now serves as the North American Numbering Plan Administrator. It operates the telephone numbering registry for the North American Numbering Plan as a Public numbering resource. NeuStar is also the Local Number Portability Administrator for the US and Canada, operating the routing registry, the Number Portability Administration Center Service Management System for North America. NeuStar’s principal place of business is in Washington, D.C.
- Registry-Registrar Model.
JVTeam intends to follow the existing guideline for registry/registrar relations established by ICANN for the .com, .net and .org registry.
B. Technical Review
- Summary Description of Proposal.
The proposed TLD is .web. It will be a competitor to the .com TLD. The TLD will be unsponsored and unrestricted. Registrations will be made only at the second level.
Note: this proposal is very similar to the JVTeam (.per) and JVTeam (.biz) proposals that have been submitted on behalf of JVTeam. JVTeam is a joint venture of NeuStar and Melbourne IT. As the two JVTeam proposals are so similar to this one, the assumption that Melbourne IT was a full participant in the development of this proposal also. However, it is our current understanding that Melbourne IT is no longer a contractually committed subcontractor on this proposal. On this basis the proposal has been evaluated (to the extent possible) as a proposal only from NeuStar. We are assuming that the system design expressed in the proposal would remain unchanged. We have, however, attempted to consider the proposal as it stands, but deducting the potential contributions of Melbourne in terms of resources and already developed software.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
The business plan assumes that several million names will be registered. Capacity is based on a distributed server system modeled after previous experience with providing data base services for the North American Numbering Plan and telephone customer/provider assignment. The build plan is based on providing three times the projected steady state load. NeuStar has estimated many aspects of capacity requirements and has designed the system to support the first two years of operation. NeuStar has a target of 1000 tps for SRS.
The fault tolerance model is based on using two co-active, geographically dispersed centers each capable of handling the peak load. Therefore, normally the system is operating at 50% capacity. It was not clear whether the proposed facilities were Neustar or Melbourne IT.
b. Projected Growth Rate.
Growth rates are based on surveys and models driven by the survey results. The estimated rate is about 2.5 million names per year. The proposed system is well configured to support this load.
c. Startup Period.
Special provisions to process registrar requests in bulk during a startup period. Bulk processing will be used to provide fairness to registrars. This scheme will effectively select names for registration randomly from registrars. The new registry protocol (XRP) would not be used until after the start-up phase. There will be a pre-registration period where trademark holders may provisionally claim names related to their trademarks. The combination of a relatively low volume re-registration period, batch processing and preservation of current RRP should enhance start-up stability. Careful design of the start-up batch mechanism will be required to anticipate potential misbehavior by registrars during a “land rush”. As XRP is proprietary to Melbourne IT, it was not clear that Neustar has access to either the software or its design.
d. Fault Tolerance.
Fault tolerance is based on using redundancy. Physical redundancy is based on using two or more geographically isolated sites. Communications between sites are duplicated and systems within each site are duplicated. Provisions include capability to maintain system operation and performance even with the complete loss of one site.
Geographical redundancy is based on two registry sites and possibly two additional name server sites. Two of the required sites are already in existence and operating in essentially the same manner as the proposed registry and name server sites.
The two data centers will cross replicate critical databases in real time. The proposal does not make entirely clear if both data centers will be simultaneously live for update or in a master/backup configuration. In addition, conventional off-site back up will be used.
The system will use automated tracking of component status with the intention of detecting problems before they occur.
System measures are based on using end-to-end encryption techniques using off-the-shelf and proprietary origin. NeuStar appears to use current techniques for both physical and transactional security. The billing and collection system is based on password protection, rather than more advanced techniques. Similarly, remote administrative access to the data centers will be authenticated with passwords, rather than more advanced techniques, such as certificates. Security appears adequate.
- Summary of Relevant Experience.
NeuStar has experience in operating a registry-like service related to numbering and tracking in the telephone industry. One would expect that the availability and service level requirements on such a “registry” exceed what would be required of a large TLD. The number plan data base requirements probably exceed those of a TLD by an order of magnitude. Security issues related to telephone number plan administration are probably comparable. NeuStar claims that their current systems process 10s of millions of transactions per day.
- Apparent Implementation Risks.
The NeuStar (.web) plan will need to be staffed from NeuStar’s technical and management resource pool and will need to grow into an organization of comparable size. Significant new recruiting may be required.
It is unclear from the proposal if NeuStar will develop the SRS function or if that was to be brought to the venture from Melbourne IT (at least a base to work from). Without this code base there may be a longer development and testing period that the proposal is based on.
Use of a new registry protocol (XML) will require cooperation between the TLD provider and the registrars.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
The response to anomalies is based on prior experience in supporting large databases and large name registry operations. Experience includes releasing and tracking changes to large software systems. Even without the participation of Melbourne, the designated NeuStar technical team seems well qualified to carry out the technical plan. Recruiting in the Washington D.C. area may be difficult, but the area does include a relatively large pool of qualified people.
The plan exhibits excellent attention to detail and covers all aspects of large system development and deployment. NeuStar has relevant experience in constructing and operating a system that is very similar to a registry. NeuStar is experienced in meeting strict service level agreements.
- Advancing the State of the Art.
The core of the proposal depends upon the use of a new registry protocol (XPL) that would provide a distributed general TLD registry capability. The new registry protocol would be open and would be migrated to standard status. The proposal envisions the addition of many more general TLDs in the near future. The proposal also proposes the “fat” registry model.
The basic implementation plan is to make the registry services more robust and the registrar services simpler. The reliance on the registry service to maintain all information will provide experience with a different approach to this problem.
The plan envisions fast update to zone files and Whois database, using the XML and high-performance server architecture. The proposal claims to significantly reduce domain-name update time from stated current time of 24-48 hours to less than one hour. The process is based on sending smaller zone file updates more frequently to the name servers using a “diff” approach.
The proposal envisions that the registry will contain the Whois database, but that the individual registrars will provide the front-end for access to the database so that they can “brand” it. The approach is based on an XML-defined approach that would become a standard. The registrars would be capable of adding additional information to the Whois data base (possibly for a fee).
- Other Comments.
Proposal depends upon maintaining name translation table in RAM at each server. Although large, the size is manageable. It is assumed that only the basic translation table would be in this table. This mechanism is part of the efficiency basis of proposed scheme.
NeuStar plans to utilize pre-registration mechanism to allow reservation of names with intellectual property implications. The technique allows interested parties the option of demarcating their potential intellectual property and then receiving notification of potential conflicts. Effort required in this area is not definitively sized. This approach is based on notification rather than on outright reservation by a potential intellectual property holder thus placing the responsibility for defending the intellectual property on the property owner.
The predicted Whois query rate would be on the order of one or two queries per day per name. This rate could be even higher if the Whois data base is enhanced to include more interesting data related to businesses (like SIC codes or directory keywords).
The registry will build a special laboratory to act as a test bed for registrars and the extended registration protocol.
C. Business Review
- Applicant’s Representations.
NeuStar has stated that it is the sole applicant for the .web proposal. It has also stated that it would be its preference to implement and operate the domain with full support from JVTeam, if awarded the .web TLD. Subsequent correspondence indicates that Melbourne IT, the other partner of JVTeam has withdrawn from this application.
NeuStar offers regulated services and deregulated commercial services. NeuStar operates the telephone numbering registry for the North American Numbering Plan and serves as the Local Number Portability Administrator.
The revenue model is subscription based. The annual price will vary from a high of $5.30 to a low of $3.75, including discounts, depending upon the volume of registrations. Neustar is expecting demand at the 50 percent confidence interval of 2.3 and 11.1 million registrations for the years one and four respectively. The company also expects to employ 122 employees by the end of year four.
- ICANN’s Evaluation.
This application has many strengths. It contains a thorough assessment of the market, including primary market research. The target market and marketing plan is well laid out and includes a discussion of the early adopters, followers and laggers. Further, the estimated demand and required resources are thoroughly expanded. The company is currently planning on investing significant sums. This is due in part to the forecasted losses in the early periods. Overall, this application is a stronger application in this category from a business perspective. However, it has been made weaker since the withdrawal of Melbourne IT as a partner.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
NeuStar’s charges for registry services are reasonable.
NeuStar and Melbourne are “recognized players” and have “vast experience in the domain registration business.”
Neustar did not accept speculative pre-registrations.
- Opposition to Application.
Worries were expressed regarding the possibility that some companies may be trying to turn a quick profit on TLDs
Some worries were also expressed regarding the financial capacity of at least one of the entities standing behind the application.