A. General Description of the Application
- TLD String(s) Requested.
New Services, Telephony Related.
The Internet Telephony Addressing Board (“iTAB”) requests the .tel TLD for a restricted domain to allow for the identification of voice-enabled Internet devices using the DNS as a lookup facility. iTab’s proposed use of the .tel TLD mimics the database. This type of service is generally not available on the DNS today and qualifies iTab for the new services category, telephony-related group.
- Sponsor, Registry Operator and Subcontractor.
Sponsorship for the .tel TLD is intended to be provided by Pulver.com and iTAB operating as co-sponsors. iTAB is a non-profit Delaware corporation, intended to be the policy making body for the .tel TLD. iTAB was created to provide .tel with an independent policy-making body comprised of noted business and technical leaders from within the Internet Telephony industry. Pulver.com will provide iTAB with an on-going forum for public discussion of .tel policy issues with a broad global audience of Internet-Telephony participants. Pulver.com claims to be the pre-eminent organization for creating and fostering a global community of interest for the Internet-Telephony industry. Pulver.com, through the Pulver Report newsletter and through regular "Voice on the Net" conference events held in the U.S., Europe and Asia, will provide iTAB with on-going mechanisms for open interaction with a large qualified base of Internet-Telephony constituents.
b. Registry Operator.
NetNumber.com, Inc. ("NetNumber") is a Delaware corporation founded in August 1998 with headquarters in Lowell, MA and is engaged in the business of providing global Internet directory services. NetNumber currently provides two Internet directory services: (1) Global Internet-Telephony Directory ("GITD") and (2) Virtual Private LDAP Directory ("VPD"). The GITD is a combination DNS and LDAP directory service that translates telephone numbers into Internet addresses in support of all forms of Internet-Telephony applications. The VPD is an outsourced LDAP directory infrastructure that application vendors can utilize to share directory information across distributed applications.
NetNumber utilizes extensive subcontracting services in two areas of registry operations: (1) asset hosting and (2) first line technical operations. The .tel registry operating plan calls for establishing operational support relationships with four key vendors: (1) EMC Corporation, (2) Exodus Communications, (3) Level3 Communications and (4) WorldCom Communications. Of these four key vendors, NetNumber has had the EMC relationship in operation since March 2000. NetNumber utilizes the following contract services from the EMC Internet Services Group: (1) asset leasing, (2) asset hosting, (3) redundant power systems, (4) redundant data network systems, (5) redundant Internet connectivity services, (6) 24x7 DBA services, (7) 24x7 facility management services and (8) 24x7 first line technical support services.
- Registry-Registrar Model.
Domain name holders will be required to deal directly with registrars and not with the registry.
B. Technical Review
- Summary Description of Proposal.
iTAB proposes a restricted domain. Sub-domains will be assigned according to a strict protocol that successively divides the domain a digit at a time until a unique one to one correspondence is made between the sub-domain name and telephone number. At this point additional name sub-division may occur. There is to be no block registration of numbers (e.g., country codes, area codes or exchanges).
Application section E.22 provides a number of examples of the use of the number mapping service. The proposal envisions that an assigned number would be directly associated with a voice enabled device and with the registrants own telephone number. In fact, one could only register a number if they had actual control over the corresponding telephone number. This service would be in direct competition with the number mapping service.
- Support of the Business Plan by the Technical Plan.
a. Total Capacity.
Capacity is projected at 16000 queries per second. Systems have been sized so that load will not exceed 60% of capacity. Performance has been benchmarked using an internal model of the proposed system. Demand estimates are based on 50 queries per day per number (i.e. name).
b. Projected Growth Rate.
iTAB expects to register about 500,000 names in the first year of operation.
c. Startup Period.
iTAB envisions no particular problems with the startup period because the registration is only for numbers. Furthermore, the registrant must have current control over the number being registered. It is not clear how this could be verified in practice.
d. Fault Tolerance.
NetNumber proposes to have at least three geographically distributed sites. Within the sites, systems will cluster based with full duplication. Two registry sites will be run with data replication, thus providing for a geographically dispersed storage of critical data.
Physical security will be based on using Exodus maintained facilities for the remote systems. Data and transaction security is based on state of the art encryption techniques. Sites are protected by off-the-shelf firewall systems.
- Summary of Relevant Experience.
The applicant already operates a telephone number to URL translation service. The size of the current registry operation is not detailed in the proposal. Team members of NetNumber were formerly associated with Unifi, an Internet Fax service provider.
- Apparent Implementation Risks.
Although the proposal seems complete, it is unclear what the precise level of applicants current experience is with respect to registry operation.
Recruiting of technical staff in the tight Boston job market will be required if growth outpaces the current projection.
- Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
The applicant’s current operating situation seems to be a complete version of what would be expected if applicant were assigned to a TLD. The applicant has planned the proposed system in considerable detail and has provided performance bench marking based on actual testing.
The applicant’s level of current staffing seems adequate to meet the immediate requirements of operation.
- Advancing the State of the Art.
The applicant proposes to offer bulk access to zone files on a contract basis.
The applicant proposes to administer zone files incrementally.
- Other Comments.
This proposal would compete directly with the telephone number translation system. This system would be controlled by current telephone service providers and related regulatory bodies.
C. Business Review
- Applicant’s Representations.
iTAB is a newly formed organization created to be the sponsor for the .tel TLD. The board is represented by communication service providers, technology vendors, and software developers. It will receive revenue from the registry operator to fund its operations. Pulver.com is the co-sponsoring organization that will provide iTAB with on-going mechanisms for open interaction with a large qualified base Internet-telephony constituents.
NetNumber currently provides two Internet directory services related to Internet-telephony. Other management experience includes the construction of a global, secure Internet backbone infrastructure for carrying international fax traffic. NetNumber’s mission is to provide secure, reliable, independent, network-based directory services to facilitate the smooth convergence of global communications services between the Public Switched Telephone Network and the emerging Internet-telephony industry. The company currently has 21 employees. NetNumber has yet to receive any revenues and had $7.0 million in net assets at June 30, 2000.
The revenue model consists of a $6 annual registration fee. The target market is any current telephone number subscriber (individual, corporation, or service provider) who wants to register a telephone number and associated Internet addresses on the Internet. The application cites projections of over 60 million IP-voice end points by the end of 2005.
- ICANN’s Evaluation.
The strengths of the application lie in its thorough business plan. The weaknesses lie in the timing of the marketplaces’ migration to Internet telephony and the amount of additional capital needed that has yet to be received by NetNumber. NetNumber lost $2.5 million in the first six months of 2000, and only has $7.0 million in net assets remaining. From a business plan perspective, this is a stronger application.
D. Summary of Public Comments
- Number of Comments.
- Support for the Application.
“As an active member of the Internet Community and as an Executive Vice President - COO of an Applications Service Provider I'm always interested in a fair, competitive environment for technology services. It is my belief that the approval of the NetNumber.com and Pulver.com application, the Peek/Pulver/Marschel application, for the .tel TLD would provide the best environment for competition by insuring market access by subscribers to the registration of telephone numbers for IP telephony. I recommend that you approve this application.”
- Substantive Comments and/or Questions.
“Regardless of which implementation wins in the end, the best interests of the Internet community will be served by allowing the issues to be evaluated by the market over a reasonable period of time. If ICANN approves one of the three pending ‘.tel’ applications then the opportunity will exist for an open and fair review of the merits of each solution. If ICANN does not select one of the ‘.tel’ applications for a new TLD then ‘e164.arpa’ will proceed without debate. No decision by ICANN at this time is in effect a final decision to select ‘e164.arpa’ before the issue can be reviewed in a public forum.”