A. General Description of the Application
  1. TLD String(s) Requested.
  2. Category.
    New Services, Telephony., LLC (“”) requests the .tel TLD to assign domain names as simple number strings which correspond to the Public Switched Telephone Network (“PSTN”) telephone numbers. Generally, the purpose is to provide a way to link a phone number with an arbitrary IP address.’s telephony service is generally not available on the DNS. Accordingly, qualifies for the new service category, telephone-related group.
  3. Sponsor, Registry Operator and Subcontractor.
    a. Sponsor. is a for-profit limited liability company, organized under the laws of the state of California with its principal place of business in Rancho Santa Fe, California. is intended to be supervised by a non-profit company called Tel Oversight Board ("TOB"). The basic function of is to market the new domain name and license registrars to sell these names to individual registrants. It is intended to have the exclusive right to register domain names using the .tel TLD., however, is intended to operate under the oversight of both ICANN and the TOB pursuant to a master agreement into which all parties would enter. It is intended that the TOB be an independent board with up to 15 members including at least (1) three people who have a strong background in the formation and development of the Internet, (2) three people chosen to represent the user community, (3) three people who have a background in international law, international economic development or international relations and (4) three people chosen because of their exceptional background in serving the public interest either in the public sector or in the non-profit community.
    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 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.
    c. Subcontractor. None listed.
  4. Registry-Registrar Model. intends to deal with only ICANN-accredited registrars.

B. Technical Review
  1. Summary Description of Proposal. proposes to provide only SLDs in the form of telephone numbers (i.e. number strings). The numbers would be translated to an IP address that would point to the owner’s web site. This approach is intended to allow users to locate web sites by making use of telephone information resources. The proposal does not envision reserving the name space for voice enabled devices.
  2. Support of the Business Plan by the Technical Plan.
    a. Total Capacity. The data base is projected to handle around 230 transactions per second. The anticipated registration rate is about 50,000 registrations per month. This seems adequate given the specialized nature of the domain.
    b. Projected Growth Rate. There were details provided, but it is expected to be modest based on the intended usage. It should be noted that the proposal does not necessarily envision that the name would actually be used to activate a voice enabled device. Rather it is a kind of cross reference mechanism.
    c. Startup Period. Startup problems are not expected because the SLDs are numerical.
    d. Fault Tolerance. Equipment is co-located in Exodus managed sites. This approach make geographic separation straight forward. Onsite inventories of spares are maintained for repair. Redundancy is based on clusters of servers fed by load balancers. Registry data bases are replicated on a dynamic basis allowing immediate switch over to an operating data base. Registry data base will be mirrored at a remote location. The remote location will operate as a warm back up to the primary site. DNS servers are located world wide.
    e. Security. Good. The use of Exodus Communications offers strong physical security measures. Some issues of security are a little under specified, 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. The proposal would benefit from inclusion of details on how audit trails would be performed to track changes to the registrar database. For example, it would be useful to track changes in registration.
  3. Summary of Relevant Experience.
    Tucows has experience in all phases of Internet operation. This includes providing registry and registrar services since 1997. Current staffing levels of technical, operations and administrative personnel is good.
  4. Apparent Implementation Risks.
    It is unclear what the Whois load will be. The sizing of the Whois function seems somewhat small compared to the basic service capability. Many experienced applicants indicate that the Whois load is comparable to the name service load due to attempted data mining operations.
  5. Available of Human, Operational and Technical Resources to Cope with Unexpected Events.’s plan considers the use of redundancy in maintaining system operation. Code supported by the system is open source with internal modifications. This would imply familiarity with the code and its modification. Physical security is provided by Exodus, an experienced provider of secured facilities.
  6. Advancing the State of the Art. plans to make use of current registry protocol, but also will develop an enhanced protocol based on XML. Zone maps will be updated at five minute intervals.
  7. Other Comments.
    The proposal probably avoids many cyber-squatting and claim jumping issues because the SLDs would simply be numbers. It is possible that if the space became even modestly popular that some number hijacking would occur. proposes to conduct periodic, random comparison of the data base with actual telephone numbers and their owners. Some people move rather frequently, tracking the move would require action by the telephone owner. proposes that about 20% of revenue be dedicated to promoting training and Internet connectivity in less developed countries.

    Implementation is based on the use of open source systems. Overall architecture appears to be internally developed.

C. Business Review
  1. Applicant’s Representations. was created for the purpose of sponsoring the .tel TLD. It has no operational history or capital, but the application includes two non-firm letters of commitment for $10 million each. The organization will be represented by those active in Internet policy issues and those sensitive to user needs. The application has proposed using telephone numbers as one’s address because this, an internationally common language, would eliminate cyber-squatting. This TLD would be available to all businesses, individuals and organizations.

    Tucows is a leading distributor of e-business services and applications on the Internet. It is an ICANN-accredited registrar and operates Tucows SRS, a source of wholesale domain name registrations. The company also provides ancillary services related to domain name registration. It currently has 234 employees. Tucows had revenues of $1.5 million for the three-month period ended March 31, 2000 and total assets of $32.5 million at that date.

    The revenue model includes a $3,000 one-time license fee for registrars. Registrars will be charged $6 annually per registration. The target market is a broad range of individuals, businesses, and organizations throughout the world. The application predicts that there will be 360 million Internet users by 2003.
  2. ICANN’s Evaluation.
    The strengths of this application lie in Tucows’ relevant experience. The main weakness is the lack of market research supporting the assertion that a number-based domain name system would benefit international communities. In addition, the application lacks a detailed marketing and promotional strategy and does not adequately address the buyer values. Overall, there are other applications in this category that are stronger from a business plan perspective.

D. Summary of Public Comments
  1. Number of Comments.
  2. Support for the Application.
    “I've looked at some of the applications for new TLDs - most are practically useless. The idea, however, has great merit in that it's simple and practical. All of the problems about who gets what are solved. The idea of using an existing identifying system is wonderful - it's practical and international, and what's more is available to any individual. With the proper guardian procedures in place (they're not hard), it has the added advantage of guaranteeing a meaningful domain name for everyone.”

    “With, the search process will be significantly more efficient and 100% effective since a simple telephone no may serve as a unique business ID.”
  3. Opposition to Application.
    One commentator worried that the proposal would be “a service of unlimited legal conflicts.”