.KIDS DOMAINS, INC.
A. General Description of the Application
- TLD String(s) Requested.
General Purpose, Restricted Content.
.KIDS Domains, Inc. (“.KIDS Domains”) requests the .kids TLD. The application explicitly attempts to restrict content across the TLD and targets a more restricted group of registrants. The targeted end user base, kids and their families, is very broad. Accordingly .KIDS Domains qualifies for the general purpose category and restricted content group.
- Sponsor, Registry Operator and Subcontractor.
.KIDS Domains is a for-profit C- Corporation organized in the State of California. .KIDS Domains is being formed for the purpose of applying for, sponsoring and acting as administrator for the proposed new TLD .kids. Subsequent to the application process, .KIDS Domains will have a seven member Board of Directors that will oversee the business aspects of .KIDS Domains. Directors' duties will include steering .KIDS Domains and facilitating the establishment of initial protocol and procedure for the administration of the new TLD.
.KIDS Domains will also establish a Content Policy Board, formed independently of the Board of Directors. The duties of the Content Policy Board will include: (1) facilitation of the establishment of a standardized policy on content suitability, (2) facilitation of the processes and procedures for the enforcement of the .kids policy on the websites using .kids domain addresses, (3) oversight and administration of the .kids auditing system and (4) oversight of the High Risk Group Self Regulatory Commission. The High Risk Group Self-Regulatory Commission will be made up of .kids domain name registrants who are categorized as "High Risk" and will work to determine definitions for content that is harmful and inappropriate to minors. The .KIDS Content Policy Board will oversee the establishment and ongoing administration of the .KIDS Annual Audit process, an annual audit of content and suitability.
b. Registry Operator.
Tucows, Inc. ("Tucows") was formed in 1994 and incorporated on May 1, 1999 in the state of Delaware with its principal office in Toronto, Ontario. Tucows describes itself as a leading distributor of e-business services and applications on the Internet and to have a network of more than 4,000 Internet service providers, Web hosting companies and domain name resellers in more than 100 countries around the world. Tucows further purports that its website offers over 30,000 software titles in libraries located around the world, providing users with fast local downloads. Tucows is an ICANN accredited registrar and claims to be a leading provider of wholesale domain name registrations and related services.
- Registry-Registrar Model.
Because .KIDS Domains will be a restricted TLD, .KIDS Domains does not intend to allow other registrars to register domain names in the .kids TLD.
B. Technical Review
- Summary Description of Proposal.
The proposal calls for the creation of a .kids TLD to support an area of the Internet that is designed for children. This TLD will have restricted access to name creation. Kids Domain will require/perform ongoing auditing of content and links on sites with .kids names. The registry would only accept registrations from its own registrar, to provide strong assurances of properly audited name creations. The registry and registrar will be run by Tucows Inc.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
Not clear that they are prepared for the load that will eventually result, if successful. It’s possible that they are, but not enough detail to be certain. There are some concerns about their ability to handle peak loads.
b. Projected Growth Rate.
They expect to grow to 2.5 million domain names in 2 years.
c. Startup Period.
They provide a very detailed plan on how to deal with many startup problems. This plan is designed primarily to deal with non-technical issues of starting up, but some of the strategies they employ are likely to have beneficial technical effects at startup time, too.
d. Fault Tolerance.
Tucows will use Exodus Communications to run their hardware. The plan calls for duplicate registries in widely separated locations, and even more DNS servers in even more locations. The details of how mirroring is done between the locations are sketchy, but Tucows has experience with mirroring software. Backup procedures and data escrow seems solid. The Whois service is maintained in its authoritative version at a single site, but portions of the service are also stored at registry sites. Failure of the central Whois service would thus be at least partially masked while it was being restored. The centralized Whois service uses replicated hardware for higher fault tolerance.
The use of Exodus Communications offers strong physical security measures. Some issues of security are a little underspecified, such as the password procedures used and whether links between sites are properly secure. Issues of securing the connections between the mirrored facilities should be more completely discussed. There is no discussion of logging and monitoring facilities for security purposes, nor of periodic security reviews of the system.
- Summary of Relevant Experience.
The technical experience is entirely concentrated in Tucows. The employees of Kids Domain itself have little or no relevant experience. The experience at Tucows is relevant. Tucows has served as a registrar, and has developed registry software that others at least propose to use. Tucows has run a fictional TLD to test their software, which has successfully handled something like 200,000 registrations.
- Apparent Implementation Risks.
Tucows has no actual experience running a live registry. The architecture does not make a very clean separation between the registry and registrar software, which could lead to problems if the TLD ever allows external registrars to communicate to the registry. There is, in particular, no specification of how a registrar outside of their administrative and physical domain might properly and safely interoperate with the registry service. The proposal describes no specifics to allow that mode of operation, but suggests it might be done in the future.
It is uncertain whether their architecture will be up to peak demands for registrations. The proposal claims that several servers each capable of handling 286 registrations per second will handle peak capacity adequately, and, since more servers can be added, the system can be expanded as necessary.
The unique value of the .kids domain lies in meeting parents’ expectations that it will be a safe area of the Internet for their children. The proposal provides very little technical support for meeting this goal, and it is unclear if the proposers understand the magnitude of the task of auditing 2.5 million names/web sites and handling complaints.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
Surprises unrelated to the special mission of the .kids TLD can probably be handled with the available resources. Since Tucows has not run a production TLD before, there is some risk that they lack some skills required, but their experience with registrars and registry software is comforting.
The XML-based registration protocol they propose to use is apparently largely untested. While they will also support RRP, it is possible that the inclusion of the experimental protocol will lead to problems.
There is little reason to believe that the applicant currently has the resources necessary to deal with surprises directly related to the purpose of .kids. It’s similarly unclear whether they understand what is and is not possible in the Internet to deal with surprises at this level, related to the semantics of their TLD.
- Advancing the State of the Art.
The plan calls for use of an incremental zone map update procedure. It also introduces a new registration protocol based on XML. The startup period contains some good, novel ideas for handling initial load.
- Other Comments.
C. Business Review
- Applicant’s Representations.
.KIDS Domains was organized for the purpose of applying for, sponsoring and acting as administrator for the proposed new top level domain “.kids.” The company has a funding commitment from ZA Associates for $10 million contingent upon the approval of this application.
Tucows, Inc. was originally founded as a distributor of software on the Internet and also offers Internet users software reviews, a rating system and editorial resources. The company is an ICANN accredited registrar and operates the Open SRS, which is a source of wholesale domain names. Tucows has over 200 employees.
.KIDS Domains’ vision is twofold: (1) to serve as the platform through which businesses can effectively and appropriately reach online the most educated, enlightened, and successful young generation in history; and (2) to ensure that this platform remains safe for children, and trustworthy for the concerned parents, grandparents and guardians of those children – all of whom stand torn between the wealth of constructive knowledge available to kids online and the tremendous amount of inappropriate content readily available.
The revenue model for the sponsor includes: (1) $19 per year for personal use, (2) $39 per year for businesses intending to use their site for business purposes, (3) $99 for businesses intending to provide links to other sites with no more than 200,000 page views per month and (4) between $150 and $2,500 for businesses intending to provide links to other sites with more than 200,000 page view per month. For the $19 and $39 per year sites, self audits will be required. Portal site owners are required to submit to an annual audit administered by a .KIDS Domains accredited auditing firm.
The revenue model at the registry level is $4 for each of the first 250,000 domain names registered and $3 for each name thereafter. Additionally, Tucows will receive $50,000 initially and $5,000 per month from the sponsor. The total registrations for Tucows will range from 810,000 in year one to 3.9 million in year four at the 50 percent confidence level. Outside registrars will not be utilized, but may be considered once controls are established and stabilized.
- ICANN’s Evaluation.
The strength of this application includes (1) a narrow focus on particular market including specific goals, (2) a plan to control content through audits and (3) sufficient capitalization. The weakness of this application lies in its lack of a detailed marketing plan. The company has stated it has engaged another company to direct its marketing but has not provided the specifics of the plan. Overall, if this company can adequately control the content, this would be an adequate business plan given the category from a business perspective. Because of the effort and related financing necessary to control content to matters appropriate for children, this is the strongest application in this area.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
Positive comments focused on the potential of the proposal to help protect children from harmful on-line content. Also viewed as a plus was the proposal’s separation of content policy decisions from business decisions.
“I have a 12 year old grandson who uses our computer for his homework. Even with my supervision we have stumbled upon some undesirable web sites while trying to find information. I would appreciate a controlled method for him to obtain the information without being exposed to adult subjects. I think this is an idea whose time has come.
“I believe the .KIDS proposal that would screen material and give parents like us a safe top level domain to direct our children to is an excellent idea and I support it.”
- Opposition to Application.
Concerns were expressed that the proposal was too focused on commerce and not enough on allowing young people to create their own, non-commercial online communities.
Writers also were concerned that young people themselves would not be adequately involved in the design and operation of the .kids TLD.
Another concern was that voluntary separation of content on the web could eventually turn into forced separation and restrictions on free speech.
- Substantive Comments and/or Questions.
“The .KIDS domain should only be granted if it is restricted. The reason that a .KIDS domain should exist is to provide our kids with a safe environment in which to discover the Internet on their own. Since it is difficult for parents to continually monitor what sites our children visit on the Internet, restriction gives them freedom with set boundaries. Not restricting the domain is akin to letting children who don’t know how to swim play around the pool without adult supervision. Do we want to let our child drown in a sea of undesirable and polluted sites because we forget to put a latch on the gate. .KIDS domain is the latch that we need.”