A. General Description of the Application
- TLD String(s) Requested.
General Purpose, Restricted Commercial
dotLaw requests the .law TLD. The application targets a limited registrant base defined exclusively by the registrants affiliation with the legal market. The targeted end user group is large. Accordingly, dotLaw qualifies for the general purpose category and restricted commercial group.
- Sponsor, Registry Operator and Subcontractor.
dotLaw is in the process of being registered as a Delaware for-profit corporation. The initial shareholders of dotLaw will be W. McKay Henderson, James D Fonger, MD and dotMD, Inc. ("dotMD"). Mr. Henderson is a partner in PricewaterhouseCoopers' Financial Advisory Services and is the National Director of the Health Care Fraud and Abuse Investigations Practice. Dr. Fonger has been a practicing cardio thoracic surgeon and claims to have been actively involved in a number of Internet projects as they relate to medicine. This includes the development of a real time Internet based registry for cardiac surgery that collected data worldwide to a single server as it was created. For a discussion of dotMD, see below.
b. Registry Operator.
DotMD, Inc. (“dotMD”) claims to have demonstrated competence in the TLD domain administration through the following: (1) its 25 year contractual relationship with the country of Moldova to manage the ccTLD, .md., (2) the operation of www.register.md (a URL registration site for the ccTLD .md), (3) the development of web site solutions for individual and group practice physicians and (4) the construction of a MetaDirectory which aggregates medical resources around health conditions. To assure security of sensitive date, dotMD has secured a relationship with what they claim to be a top-tier hosting facility, Exodus Communications ("Exodus").
Exodus was founded in 1994 and currently offers a range of Internet services including: (1) complex web hosting, (2) Internet connectivity, (3) Internet technologies and collaborative managed services, (4) Exodus professional services and (4) Arca Systems security services.
- Registry-Registrar Model.
dotLaw plans to utilize only ICANN accredited registrars in connection with registering domain names in the new TLD.
B. Technical Review
- Summary Description of Proposal.
TLD will be .law. This will be a restricted domain reserved for members of the legal profession who can demonstrate that they are practicing members of the legal profession and/or provide services directly to the profession. Some SLDs and 3rdLDs would be assigned for special purposes (keyword, location etc.). The sub-domain structure is not currently fully defined, but would be defined before the TLD is opened. Investigation may be required to determine if licensing verification can be carried out properly for countries other than the US and Europe.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
Total names under management is expected to be several hundred thousand based on the estimated number of attorneys and law firms world wide. This is a volume 10 to 20 times the current dotMD registration, thus the scaling is significant. Registry would also provide web hosting and registration.
b. Projected Growth Rate.
Growth rate projections are modest and can be accomplished through standard means.
c. Startup Period.
Startup surge is expected to be modest because the domain is restricted to applicants that can prove their affiliation with the legal profession.
d. Fault Tolerance.
The system appears to located at a single site. Basic fault tolerance is based on duplication of the servers at that site. There are three other sites that provide name service. Geographical duplication of the primary site would be a worthwhile enhancement if this application is accepted.
Physical security is based on using Exodus facilities for servers. System security is based on off-the shelf hardware and software. Some system security monitoring is provided by Exodus.
- Summary of Relevant Experience.
Registry operator is currently operating the ccTLD .md, which has been overlaid to be a medical services area. There are currently about 10,000 names under management.
- Apparent Implementation Risks.
Applicant would need to scale by a factor of 10 to 20 to meet the projected demand. The current system is rather modest is size and capability, so scaling gracefully may be problematic. Currently the system is based on custom software; it is unclear from the description if this would scale appropriately. However, the design group presumably has intimate knowledge of the software and the ability to respond to problems.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
Current registry and registration software for .MD is custom and has been developed by dotMD and Exodus software engineers. The proposed system would be developed by the same group, so their current experience with the code could be useful in addressing unusual situations.
- Advancing the State of the Art.
Plan would provide a modest sized small domain that would be tightly restricted. All aspects of the plan are of very modest scale.
- Other Comments.
C. Business Review
- Applicant’s Representations.
DotLaw is a recently formed organization for the purpose of establishing the new top-level domain of .law. The two founders of this organization are a partner in the professional services firm, PriceWaterhouseCoopers, and a cardio thoracic surgeon who has had involvement with dotMD. The purpose of this top-level domain is to develop and manage a general TLD for the legal profession and its support community. This domain would provide easier access to individuals seeking legal advice and greater ease of marketing for those individuals that were within the legal community.
DotMD is proposes to act as the operating registry. This organization has a 25-year contractual relationship with the country of Moldova to manage the ccTLD, .md, around health conditions. As of October 2000, there are over 10,000 active, registered domains in .md excluding the Moldova registrations.
The application will be targeted to the legal community at large including law students, court reporters, bar associations and individuals seeking legal representation and research. The application also states that there are approximately 1.0 and 2.5 million lawyers in the United States and internationally, respectively. The registry fee is $100 per domain name and $450 for domain name with enhanced legal specific web page development services. A driver of the model assumptions is the experience of dotMD, Inc.
- ICANN’s Evaluation.
The strength of this application lies in its very focused community. The weaknesses lie in the generally weak treatment of the marketing plan. The application includes generalities, but not enough specifics. The pro-forma financial statements are not included in the application. Overall, there are other applications that are stronger in this category from a business plan perspective.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
The proposed TLD would be an “incredible resource for the legal community and the public.”
“As a member of the national media, I found the presentation of the site engaging, useful and an attractive forum for discussion and contact.”
“This will be of great assistance to both professionals, and the general public as well.”
“It seems an appropriate way for the legal community to make themselves more identifiable on the web, and provides easier access for people worldwide to find the information they are seeking.”
“Will lead to better informed consumers.”
“It will make it much easier to find and disseminate legal information online.”
“It will provide a reliable source for the dissemination of legal information and be valuable for both the legal profession and the general consumer.”
- Opposition to Application.
The rules proposed by Dotlaw, Inc. “seem designed to maximize Dotlaw’s financial gain from the monopoly on the distribution of domain names.”
The registry would have too much discretionary control over pricing of domain names.
One commentator saw a problem with the fact that a .law name holder must maintain a .law logo link.
It is unlikely that U.S. and non-U.S. bar associations would agree that Dotlaw, Inc. should be vested with the authority to allocate names.
At least one commentator did not want to see any “restriction or constriction of access, use, or implementation of any aspect of law.”
Some concern was expressed as to Dotlaw, Inc.’s partnering with DotMD, a medical organization, to run the TLD.