A. General Description of the Application
1. TLD String(s) Requested. .pro
2. Category. General Purpose, Restricted Commercial. RegistryPro Ltd. ("RegistryPro") requests the .pro TLD. The application targets a limited registrant base (professionals worldwide) and a broad end user group. Accordingly, RegistryPro qualifies for the general purpose category and restricted commercial group.
3. Sponsor, Registry Operator and Subcontractor.
a. Sponsor. Unsponsored Application.
b. Registry Operator. RegistryPro was incorporated in Ireland on February 14, 2000 with its principal place of business in Dublin, Ireland. RegistryPro is wholly owned by Register.com and Virtual Internet. Register.com and Virtual Internet have entered into a formal arrangement with Baltimore Technologies to bring additional technology skills and capacity to RegistryPro. RegistyPro claims that an equity stake for Baltimore Technologies in RegistyPro is under discussion. Register.com is one of the initial five testbed registrars selected by ICANN to register general TLDs. In June 1999, Register.com commenced online registration as an ICANN accredited registrar of .com, .net and .org domains. Register.com also claims to process domain name registrations in over 160 country code TLDs. Virtual Internet provides Internet domain name registration, e-mail, website hosting and electronic commerce services that enable business to be undertaken on-line. In addition, Virtual Internet provides Internet brand and trademark protection services to monitor the use and abuse of customers' brands and trademarks on-line. Baltimore Technologies claims to be an international provider of information security products and services that enable companies, government agencies and other organizations to conduct secure communications and transactions over computer networks and the Internet.
c. Subcontractor. None.
4. Registry-Registrar Model. RegistryPro intends that domain name holders will deal with registrars. RegistyPro intends that all ICANN accredited registrars that agree to the .pro TLD policies will qualify to become a .pro registrar.
B. Technical Review
1. Summary Description of Proposal. RegistryPro would control the SLDs which would be assigned to represent groups of professionals (e.g. doctor, lawyer, etc.). There would be strict registration requirements so that registrants would need to prove that they were accredited in the particular SLD. This accreditation information would be available in the data base for public review. Initially registration would be limited to certain large industrialized countries that have in place strong, reliable and somewhat conforming professional accreditation processes. After gaining experience, RegistryPro would extend services to counties with different professional accreditation models.
2. Support of the Business Plan by the Technical Plan.
a. Total Capacity. Capacity of the system has been sized for 2000 transactions per second. Based on the configurations provided, the design should be more than adequate. Storage capacity seems more than adequate, even considering the thick registry requirements for storing accreditation information (possibly images). System description and plans explicitly address scaling.
b. Projected Growth Rate. Applicant assumes that the initial surge will be for about 1million names followed by about 90,000 registrations per month. System capacity exceeds this expectation by a substantial margin. The system is sized to reach the 5 million name level before major extensions are required.
c. Startup Period. During the "land rush" period, RegistryPro proposes to use a batch registration technique with random selection. This approach stabilizes demand and promotes fairness.
d. Fault Tolerance. Registry facilities will be located in two geographically separated sites. One site will be the primary site handling all traffic the other site will be secondary. The primary center has complete duplication of all critical elements, while the secondary center has somewhat less internal duplication. Although the secondary center is less robust, it is still very adequate with respect to redundancy. During operation, the SRS function will be operated so that the active database continuously replicated on a back up server, allowing for near instantaneous transfer of authority. The plan also includes a standby server that receives frequent periodic updates in case of failure of the active/back up system.
DNS servers use newly developed propriety software, but will include standard BIND as a backup. These servers will be updated on a daily basis (following current practice). Overall the redundancy plan seems more than adequate.
DNS availability - 99.99% (one year basis)
RS availability - 99.99%
Whois availability - 99.99%
e. Security. RegistryPro proposes a range of security measures. Link security will be maintained through the use of encryption, authentication and IP filtering. These techniques will be combined to enhance registrar/registry link security. Additionally, RegistryPro proposes to use digital signatures to validate registry objects, an approach that seems prudent given that the public is relying on the evidence of accreditation. As presented in the plan, the security approach is based on a layered analysis of possible threats and remediation using state of the art and off the shelf tools. The security plan appears to be well thought out and sufficient for the intended registry use.
3. Summary of Relevant Experience. RegistryPro would be a newly formed company drawing on the resources of several committed joint venture partners. These partners have significant experience in providing registrar services worldwide. In addition, the partners have extensive database and telecommunication's skills. The joint venture partners are committed to providing the technical personnel required for success and have also demonstrated a good track record in hiring.
4. Apparent Implementation Risks.
The plan depends upon using four subcontractors. Providing architecture
and coordination service across the subcontractors may be difficult.
However, the experience of the identified technical and management
team seems adequate to meet this risk.
The plan calls for the development of new code and registry/registrar model. The plan did not appear to include a test bed arrangement to allow registrars to develop code to interface to the extended RRP. Such a test bed should be viewed as a necessary provision.
5. Availability of Human, Operational, and Technical Resources to Cope with Unexpected Events. RegistryPro has significant experience in the development of large systems and has a large pool of talent to draw upon.
RegistryPro's plan is well thought out and supports the business plan. With respect to fault tolerance the plan compares very well with the plans of applicants proposing to provide much larger general registry service (i.e., .com competitors).
6. Advancing the State of the Art.
RegistryPro would employ a "thick" registry model. Such
a model is important because RegistryPro anticipates maintaining
a significant amount of data at the registry. This data would
be used to profile the registrant's professional credentials and
would form the basis for enhanced Whois and directory services.
The proposed model would include extensibility based on the use
of XML. RegistryPro proposes to follow the outline of the current
general RRP draft proposal.
Registrant explicitly plans to track the development of multi-lingual naming standards within the IETF Internationalized Domain Names (IDN) group and to provide internal support as necessary.
RegistryPro proposes near instantaneous update of zone files, additionally a back up system based on the current BIND mechanism will be maintained as a hedge against software failures.
7. Other Comments. None.
C. Business Review
1. Applicant's Representations. RegistryPro is a joint venture between Register.com and Virtual Internet created specifically for this TLD application. Register.com was one of the five initial ICANN accredited registrars and also processes domain names for country code TLDs. Virtual Internet provides domain name registration, e-mail, website hosting, and e-commerce services. Virtual Internet also provides brand and trademark protection services. Register.com held cash and cash equivalent of $148 million at June 30, 2000. Virtual Internet held cash balances of $32.5 million at July 31, 2000. Register.com has 217 employees and Virtual Internet has 145 employees.
The subscription-based revenue model includes a $6 annual registration fee. Ancillary services will also be provided, but RegistryPro will not be a registrar. The application defines its target market as all professionals worldwide, estimated at 29.5 million. However, it will initially limit its marketing activities to the 6.8 million doctors, lawyers, and accountants in the United States, United Kingdom, and Japan. Accountants compromise 41% of the target market.
2. ICANN's Evaluation. The strengths of this application lie in its partners' experience in Internet and registry operations. It has two primary weakness or concerns. First, there is a significant possibility that much of its target market may be practicing in connection with a firm and hence may not be interested in participating in this offering. For example, many CPAs are not practicing public accountants but rather professionals within a corporation. These professionals will not have a driving need for the service. Second, an approximate $7 million cash shortfall in the first year which may not be fully committed. The joint venture partners have stated that they have sufficient funds internally. Further, the partners have failed to specify details for external auditing. Overall, this application is better conceived from a business perspective than the other applications in this same category, but as shown above, there are some concerns.
D. Summary of Public Comments
1. Number of Comments. 4
2. Support for the Application. "By
providing a domain for health professionals, RegistryPro can offer
consumers an easier way to navigate the Internet and find a healthcare
provider that best meets their needs."