New sTLD RFP Application


Part B. Application Form

Name and Address fields

Company/Organization Information

Company Name NetNumber, Inc.
Company Address 1 650 Suffolk Street, Suite 307
Company Address 2 N/A
Company City Lowell
Company State/Province MA
Company Postal Code 01854
Company Website Address www.netnumber.com
Company Country USA

Sponsoring Organization Information

Sponsoring Organization Name Pulver.com
Sponsoring Organization Address 1 115 Broadhollow Road, Suite 225
Sponsoring Organization Address 2 N/A
Sponsoring Organization City Melville
Sponsoring State/Province NY
Sponsoring Organization Postal Code 11747
Sponsoring Organization Country USA
Sponsoring Organization Website Address www.pulver.com


Namestrings and Conventions

First sTLD choice: .tel
Naming Conventions:
The objective of the ".tel" TLD is to enable IP Communications Service
Providers (IPCSPs) to register telephone numbers as domain names on the
Internet and to associate IP-based services with those registered telephone
numbers.  In the context of this top-level domain the string “tel” refers to
“telephone number” which is used to derive a valid domain name.  This string
adheres to RFC1034 and RFC1123 for the characters used in this name.  The name
“tel” represents an internationally acceptable well-understood acronym
identifying “telephone”.   This definition is also referenced in RFC2806
section 2.7.2 which uses the string “tel” to define the URL scheme identifying
a “telephone number” by using “tel” as the URL scheme name.  

Sub-domains of ".tel" may not be arbitrarily defined; rather they are defined
in accordance with the ITU E.164 standard.  A valid e164 domain name under the
".tel" TLD is defined as follows:

Start with a telephone number: 1-212-332-1234.

Remove all non-numeric characters: 12123321234.

Reverse the order of the number: 43212332121.

Separate by dots:

Add the sTLD:

The “.tel” Registry is responsible for enforcing these restrictions in the
registry’s zone before accepting a registration from an IP Communications
Service Provider (IPCSP).

Second sTLD choice: N/A
Naming Conventions:

Third sTLD choice: N/A
Naming Conventions:

Sponsoring Organization Structure
The Sponsoring organization for the “.tel” sTLD is Pulver.com (www.pulver.com).

Pulver.com is a private US corporation dedicated to the creation of a community
of interest focused on the advancement of the IP communications industry. 
Pulver.com ("The voice of telephony on the net") is the pre-eminent
organization for creating and fostering a global community of interest for the
IP Communications industry.  

Pulver.com, through the Pulver Report newsletter (circulation of >50,000
readers) and through regular "Voice on the Net" (VON) conference events held in
the US, Europe and Asia, will provide the ".tel" sTLD with on-going mechanisms
for open interaction with a large qualified base of IP Communications
constituents including service providers, equipment vendors, end-users, and
regulatory bodies.

For example, the Spring VON event which will be held in Santa Clara, CA March
28 – April 1st 2004 will be attended by representatives from over 1,000
organizations from 25 countries.  All of these companies have demonstrated
their willingness to invest of both the time and money necessary to actively
participate in the IP Communications industry community created by Pulver.com.

The list of participants from the IP Communications industry includes service
providers, equipment vendors, software developers, universities, regulatory
bodies, and research groups.  Outlined below is a small sampling of several
well known organizations from around the world that are sending representatives
to participate in the upcoming Spring VON event:  

3Com Corporation
Agilent Technologies
America Online
Bell Canada
British Telecom
California PUC Commissioner
Center for Democracy & Technology
Cincinnati Bell
Cisco Systems
Columbia University
Community Broadband Networks
Connexion by Boeing
Cornell University
CRTC, Canadian Federal Gov't
CrystalVoice Communications
Department of Defense
EarthLink, Inc.
Fidelity Communications
Forrester Research, Inc.
France Telecom R&D
Free World Dialup
Frontier Communications
Gartner Dataquest
GE Vendor Financial Services
General Dynamic Decision Systems
GoldStar Communications, LLC
Guadalupe Valley Telephone Cooperative, Inc.
Gulf Telecom
Harris Corporation
Hewlett Packard
Hitachi America, Ltd.
Hutchison 3G Austria
KDDI America
Korea Telecom
Level 3 Communications
Lockheed Martin
NTT East
PA Public Utility Commission
Rutgers University
San Jose Mercury
SIP Forum
Stanford University
Telefonica CTC
Telekom Austria
The Yankee Group
Time Warner Cable
University of Zurich
US Telecom Association
VOIP Americas
Yahoo! Inc.

Appropriateness of Sponsored TLD Community
The ".tel" sTLD will be a resource for IP Communications Service Providers
(IPCSPs) that enables the mapping of legacy telephone numbers to the Internet
address information required by IP-enabled communications applications and
services. The underlying role of the ".tel" sTLD is to facilitate the smooth
migration of communications services from the PSTN to the Internet by allowing
IPCSPs to utilize the telephone numbers that have been assigned to them or to
their subscribers as a resource for addressing IP-based communications

In the context of the “.tel” sTLD, an IP Communications Service Provider
(IPCSP) is defined as any entity that provides IP-based communications services
to individual subscribers.  Examples include enterprises, universities,
government agencies, as well as incumbent and emerging IP-based communications
service providers. 

The requirement for the “.tel” sTLD existed in October 2000 when Pulver.com and
NetNumber, Inc. first submitted an application for the “.tel” TLD, and the need
is even more apparent today.  Outlined below is a list of representatives from
the IP Communications community who are prepared to act as references
supporting both the need for the “.tel” TLD as well as supporting Pulver.com as
the sponsor of the “.tel” TLD for the benefit of the IPCSP community. 

Chief Technology Officer
Alcatel Mobile Communications Group

Bryan Wiener
Net2Phone Global Services

Bill Jarvis
President and CEO
GoBeam, Inc.

Alain Fernando-Santana
NetCentrex Inc.

Ofer Gneezy 
President and CEO

Bryan R. Martin
Chairman & CEO
8x8, Inc.

Jerry Knight
Accessline Communications

Brian J. Allain
Ranch Networks

Louie Holmes
TelCel Communications Inc.

Marc J. Zionts
Excel Switching Corporation

R.J. Auburn
Voxeo Corporation

Dennis M. Maloney
Vice President
Solus Communications

Eric Burger
Chief Technology Officer
SnowShore Networks, Inc.

Jerry Knight
AccessLine Communications

Paul Gregory
NuCall Communications Inc.

Afaque Ahmed
FoneBooth Networks Inc.

Brett Shockley
Spanlink Communications

Brian O'Neill
BaseVoice LLC

Dror Mei-Tal
Global Telecom Brokers

Alexander L. Wolf
Chief Operating Officer

Saied Kazemi
Millenigence, Inc.

Ralph Hayon
Natural Wireless

Jill D Smith
President and CEO
eDial, Inc

Mark Bruk
Xten Networks, Inc.

Sridhar Ramachandran 
NexTone Communications

Andy Voss
President & CEO
Sansay, Inc. 

Craig Walker
President and CEO
Dialpad Communications, Inc.

Harry M. Taxin
President & CEO
MegaPath Networks Inc.

R. Brough Turner
Sr. VP & Chief Technology Officer
NMS Communications

Brian McClintock
Executive Vice President and COO
New Global Telecom, Inc.

Michael Camp
VocalData Inc.

Jim Brown
Dictronics, Inc.

Pulver.com provides a highly effective infrastructure for sharing information
with IP Communications industry participants on a global basis.  Pulver.com
provides the IP Communications industry with forums, discussion lists,
scheduled industry events and ad hoc meetings to deal with any number of issues
facing the industry.    
Pulver.com has the unique ability to ensure global participation from
appropriate industry representatives for discussion of ".tel" policy issues.  

Newsletter support:  The Pulver Report is published and distributed via e-mail
to over 50,000 Internet-Telephony industry participants with over 30% per cent
international readers.  The Pulver Report will provide a public forum for
communication of ".tel" policy issues across a broad spectrum of industry
participants on a monthly basis.

Public Meetings:  Coinciding with Pulver.com hosted events, such as VON (which
occurs in the US, Europe and Asia on a regular basis), Pulver.com will provide
a regular forum for open discussion of ".tel" policy issues to promote and
advance the ".tel" TLD as a tool in the continued development of IP
Communications services.

Openness and Tansparency
Pulver.com will define policies and procedures for the “.tel” sTLD in an open
and transparent manner through procedures designed to ensure fairness.


No later than five (5) days after each meeting during which policies and
procedures relating to the operation of the “.tel” sTLD are discussed, any
actions taken by Pulver.com shall be made publicly available in a report
published in the English language and displayed on a publicly-accessible
website under www.pulver.com.  


Pulver.com shall post on the web site www.pulver.com a calendar of scheduled
meetings for the upcoming year during which “.tel” policy issues shall be
discussed in a public forum along with an agenda for each meeting.

Initial Directors, Officers, and Other Staff
Pulver.com will establish an 11 member Board of Directors (“Board”) with
delegated policy making authority, under a legal structure acceptable to ICANN,
to guide the ongoing development of the “.tel” sTLD.  The Board will include
two permanent members, one nominated by Pulver.com as the Sponsor of the “.tel”
TLD and one nominated by the Registry operator, initially NetNumber, Inc.  The
remaining 9 rotating members will be made up of business, technical, and policy
making leaders from within the IP Communications industry.  The initial
representatives nominated by Pulver.com and NetNumber, Inc. are as follows: 

Jeff Pulver: Jeff is the founder and President/CEO of Pulver.com, which
produces the Voice on the Net (VON) conferences, builds Internet communities,
and tests innovations in Internet technology. A pioneer in the field of IP
(Internet Protocol) Telephony, Mr. Pulver has been tracking enabling and
emerging net technologies since 1994 and is one of the world's leading experts
on up-and-coming communication technology and their effect on business
communications. He moderates the Voice on the Net and other mailing lists;
publishes the Pulver Report, which is read by over 50,000 people; and maintains
the pulver.com website, which is a meeting place and comprehensive source of
information on the convergence of Internet and Telecom. 

Douglas J. Ranalli:  Douglas is the Founder and Chief Strategy Officer of
NetNumber, Inc.   Mr. Ranalli is a seasoned leader and entrepreneur with
experience in three high-growth start-ups.  Prior to founding NetNumber, Mr.
Ranalli was the founder and CEO of Fax International, Inc. an early entrant
into the international fax over IP business that reached #20 on the INC 500
list of fastest growing private companies in the US in 1997.  Prior to Fax
International, Mr. Ranalli founded a publication for college students called
DORM magazine while attending Cornell University as an undergraduate
engineering student.  Under Doug’s leadership, DORM grew to a controlled
circulation of 1.2 million before being sold to Time Inc. in 1987.  Mr. Ranalli
is the holder of multiple communications related patents and is the subject of
a case study developed by the Harvard Business School entitled "Fax
International Japan" which is utilized by a variety of MBA programs around the
world.   Mr. Ranalli holds degrees in Industrial Engineering (BS) from Cornell
University and an MBA from the Harvard Business School.

Selection of Directors, Officers, Members, Staff
The 9 rotating members of the “.tel” Board shall be divided, as nearly as
possible, into three equal groups.  The term of the original Board members
shall be determined by lot with one-third (1/3) of the members serving for one
year, one-third (1/3) of the members serving for two years and one-third (1/3)
of the members serving for three years.  Thereafter, Board members shall serve
a term of three years and until their respective successors are named. Each
term shall begin and conclude following the appropriate annual meeting.  A
Board member shall not serve consecutive, full three (3) year terms, A Board
member may serve one (1) full three (3) year term and then seek office again
after at least one (1) year has expired and the next year’s Board positions are
available.  However, when a Board member is elected due to a vacancy in the
Board, the member may seek a consecutive full term of three years since the
first term was not a full, three (3) year term.

Vacancies in the Board of Directors may be filled by a majority of the
remaining Directors then in office, though less than a quorum.  Each Director
elected shall hold office until his or her successor is elected.  A vacancy or
vacancies shall be deemed to exist (i) in the case of the death, resignation or
removal of any Director, or (ii) if the authorized number of Directors is
increased without election of the additional Directors so provided for, or
(iii) in case of failure at any time to elect the full number of authorized
Directors, or (iv) if any Director fails to attend three (3) consecutive
meetings of the Board without a reasonable excuse.  If any Director tenders his
or her resignation to the Board of Directors, then the Board shall have the
power to elect a successor to take office at such time as the resignation shall
become effective.  No reduction in the number of Directors shall have the
effect of removing any Director prior to the expiration of his term of office.

Board members will receive no compensation and will be required to cover their
own costs associated with participation in “.tel” sTLD public meetings.

Meetings and Communication
Bi-Monthly Newsletter:  Pulver.com will dedicate a section of the bi-monthly
Pulver Report to the communication of current issues relating to the
operation of the “.tel” sTLD.  The Pulver Report is published and distributed
via e-mail to over 50,000 IP Communications industry participants with over 30%
per cent international readers.  Interested parties may subscribe to the Pulver
Report at no cost via the Internet at http://www.pulver.com/reports/subsc.html.

Regular Public Meetings:  Coinciding with Pulver.com hosted events, such as
VON (which occurs in the US, Europe and Asia on a regular basis),
Pulver.com will provide meeting facilities to enable the “.tel” Board to
communicate directly with the IP Communications industry in an open and public
forum.  For example, the calendar of appropriate Pulver.com events for 2004 is
as follows: 

March 28 - April 1st - Spring 2004 VON Conference & Expo , Santa Clara, CA 

June 7-10 - VON Europe 2004 Conference & Expo, London, UK 

June 22-23 - SIP Summit 2004, Chicago, IL 

Oct 18-21 - Fall 2004 Conference & Expo, Boston, MA

Fiscal Information
Pulver.com is a New York State S corporation that encompasses several areas of
activity including: Pulver.com Enterprises, Consulting, Conferences,
VON-events, and VON-Europe.  Fiscal information for these various groups is as

Annual Revenue:  	$5.5 million
Annual Expenses: 	$4.1 million
Employees: 		30
Paid in Capital:	$6.3 million

Indemnification from Liability
No director, officer or employee of Pulver.com or NetNumber, Inc. shall be
liable for debts, liabilities or obligations arising out of the operation of
the “.tel” sTLD.

Proposed Extent of Policy-Making Authority
Scope of authority sought

Pulver.com seeks authority from ICANN to create, maintain, and monitor three
specific policies that are directly tied to the unique utility of “.tel” within
the IP Communications industry.  

Naming Policy:  Policy that defines the unique characteristics of a valid
domain name under the “.tel” sTLD as summarized in the Naming Conventions
section of this application.

Registration Validation Policy:  Policy that limits registrants to IP
Communications Service Providers (IPCSPs) who are registering names on behalf
of individual subscribers who have been assigned control over the E.164 numbers
being registered as names under the “.tel”. sTLD. 

Conflict Resolution Policy:  Policy that defines the mechanism by which two or
more IPCSPs resolve a conflict over which IPCSP actually represents the
individual subscriber consumer or enterprise) who has been assigned an E.164
number that is being registered within the “.tel” sTLD. 

Reasons/justifications for seeking authority

The policies Pulver.com seeks authority over are the core policies that define
the utilization of ".tel" as a shared resource for bridging the addressing gap
between legacy telephone numbers and emerging standards of the IP
communications industry.  

Guaranteeing policies in the Interest of the Internet at large

All policies related to the operation of the “.tel” TLD will be under the
control of the “.tel” Board.  Furthermore, all policy issues related to the
“.tel” TLD will be discussed in an open forum sponsored by Pulver.com as
described above in “Meetings and Communication”.  The ongoing decision by
thousands of IP Communications companies to actively participate in the
community of interest created by Pulver.com is in itself evidence of the trust
the industry places in Pulver.com’s ability to advance the best interests of
the IP Communications industry.        

Variation from existing ICANN policies at opening of TLD

Other than the “.tel” specific policies outlined above, no variation from
existing ICANN policies is envisioned.

Policy-Making Process
With respect to any policies that are being considered by the “.tel” Board for
adoption that substantially affect the operation of the ".tel" TLD, including
the imposition of any fees or charges, the Board will:

(i)	provide public notice on the www.pulver.com web site explaining what
policies are being considered for adoption and why;

(ii)	actively seek input from related industry groups early in the policy
making process;

(iii)	provide a reasonable opportunity for parties to comment on the adoption
of the proposed policies, and to see the comments of others; and

(iv)	hold a public forum at which the proposed policy would be discussed.

After voting on any policy, the Board will publish in the meeting minutes the
reasons for any action taken, the vote of each Director voting on the action,
and the separate statement of any Director desiring publication of such a

A. Add new value to the Internet name space
Industry Background:

The global communications industry is moving at remarkable speed to embrace the
new world of Internet Protocol (IP) technology. Underlying economics and the
growing demand for data services dictate that networks like the Internet,
corporate intranets, and managed extranets will be the telecommunications
networks of the future. 

Standard communications devices like telephones, fax machines, and voicemail
systems are quickly becoming IP-enabled devices that connect to both the
existing telephone network and to data networks like the Internet.  As
IP-enabled communications devices begin to proliferate around the world, a
requirement has emerged to integrate the existing addressing scheme of the
legacy Public Switched Telephone Network (PSTN) with the emerging addressing
schemes of the Internet-Telephony industry.  In short, a requirement exists for
a directory service that will translate existing legacy telephone numbers into
Internet addresses

The underlying need for the ".tel" TLD can be summarized as follows: 

An enormous global investment has been made in training end-users all over the
world to use standard legacy telephone numbers to place calls, send faxes,
leave voicemail messages, etc. Unfortunately, IP networks like the Internet,
corporate intranets, and managed extranets don't work off of telephone number
addressing. Instead, IP networks work off of IP addressing, SMTP addressing,
URL's and other non-telephone number formats. 

The ".tel" TLD will provide a smooth migration of legacy telephone numbers over
to the new world of Internet protocol networks.  The smooth transition enabled
by the ".tel" TLD is the ability to link telephone numbers to Internet
addresses for IP-enabled communications devices so that end-users can continue
to use telephone numbers as a common addressing mechanism for both PTSN and
Internet services.

Enterprise IP-PBX example:

IP-enabled PBX (Private Branch Exchange) systems are telephone systems that
have the ability to connect calls over both the PSTN and data networks like the
public Internet.  Major suppliers of IP-PBX systems include 3Com, Cisco,
Nortel, Lucent, Ericsson, etc.  One of the goals of IP-PBX systems is to
provide "least cost routing" for every call placed by an end-user.  In the
Internet-Telephony world, the true least cost route comes from setting up a
call "end-to-end" over the public Internet.  The process starts with an
end-user picking up a phone and dialing a telephone number.  The IP-PBX looks
at the number and tries to make a least cost routing decision.  The least cost
option is to connect the call over the Internet.  The higher-cost back up is to
send the call out over the existing telephone network (PSTN).  In order to send
a call out over the Internet the IP-PBX needs to check a global directory to
determine if the telephone number can be translated into an Internet address
for an IP-PBX or IP-phone at the distant end. 

The ".tel" TLD is the top-tier of a globally distributed directory solution
that enables IP Communications Service Providers (IPCSPs) to register the phone
numbers of their individual or enterprise subscribers on the Internet and
associate those phone numbers with any number of IP-enabled communications
devices (phone, fax, e-mail, PDA, etc.) or services.  Early deployments of
IP-communications systems avoided the address translation problem being
addressed by the ".tel" TLD by limiting the scope of IP-telephony solutions to
just internal corporate communications.  By limiting the scope of the solution,
each IP-PBX could be programmed with up-to-date Internet address information
for every end-user inside a given company.  This "closed user group" solution
has been an important first step for the emerging Internet-Telephony industry
but it is breaking down as users try to expand the IP-telephony model beyond a
small user group.  

As a next step in the evolution of the IP Communications industry, an industry
sponsored and supported directory infrastructure is a requirement.

B. Protect the rights of others
Outlined below is a summary of the initial registration policies that will be
proposed to the “.tel” Board for public review if the “.tel” sTLD application
is approved.   

(1) Registrants in the “.tel” sTLD will be restricted to IP Communications
Service Providers (IPCSPs) who are providing IP-based communications services
to individual or enterprise subscribers who have been assigned day-to-day
control over the E.164 telephone numbers being registered in the “.tel” sTLD.

(2) Registrants (IPCSPs) will be required to sign a registration agreement
verifying that each E.164 number used to derive a registered domain under the
“.tel” sTLD is under the day-to-day control of an individual or enterprise
subscriber receiving services from the Registrant IPCSP. 

(3) Registrants will be required to provide a deposit fee as defined by the
“.tel” Board to cover any costs associated with implementing the “.tel”
Conflict Resolution Process operated by NetNumber, Inc. as the initial Registry
operator of the “.tel’ sTLD. 

(4) The WHOIS database for the “.tel” sTLD will identify the name of the IPCSP
responsible for the registration of a given domain name.  For privacy purposes,
no WHOIS information will be provided regarding the identity of the underlying
individual receiving communications services from the IPCSP.  

(5) The Conflict Resolution Process implemented by the “.tel” Registry will
provide an online mechanism allowing any individual, enterprise or service
provider to claim day-to-day control over an E.164 number registered in the
“.tel” domain and challenge the validity of an existing registration.  All
costs associated with resolving the conflict over the determination of who has
day-to-day control over a given E.164 number shall be born by the entity
(challenger or current registrant) found to be in error.

C. Assurance of charter-compliant registrations and avoidance of abusive registration practices
The core registration restrictions outlined in section B above provide for
protection against abusive registration practices.  Any individual, enterprise
or service provider with effective day-to-day control over a given E.164 number
can utilize the “.tel” Conflict Resolution Process to force an existing
registration to be deleted or modified based on demonstrating day-to-day
control over a given E.164 number.  Furthermore, no costs shall be incurred by
any individual, enterprise or service provider who makes a valid claim against
an IPCSP for registering an E.164 number incorrectly.

D. Assurance of adequate dispute-resolution mechanisms
Given the proposed “.tel” Conflict Resolution Process described in section B
above, applicants assume that the ICANN Uniform Dispute Resolution Policy will
only be used to resolve conflicts within the “.tel” sTLD in extreme situations
and only as a last resort.  Since it is only possible for one individual or
enterprise subscriber to actually have “day-to-day” control over any one E.164
telephone number at a given time, disputes should be resolved quickly. 
Determining who has rights for a “.tel” domain name becomes a process of
determining who has “day-to-day” control over the E.164 number that was used to
derive the “.tel” domain name.

Defining “day-to-day" control is described as follows:

E.164 numbers (telephone numbers) are allocated to service providers using
nationally delegated organizations which follow a structure defined by the ITU
(International Telecommunications Union).  A service provider assigns out
telephone numbers when a subscriber requests telephone service.  As service
providers assign these E.164 telephone numbers the “day-to-day” control passes
from the service provider to the individual subscriber or enterprise entity
that has requested service.  It is these subscribers or enterprise entities
that decide what services they would like enabled for their E.164 telephone
number(s).  Multiple sources of number assignment documentation exist that can
be used to resolve conflict over control of a given E.164 number.

E. Provision of ICANN-policy compliant WHOIS service
Given the unique nature of the “.tel” sTLD, Applicant’s propose that the
Registry operator provide a publicly available Whois database service on behalf
of all ".tel" Registrars as a common component of the Registry service.  

Applicants propose to limit the information provided in the common Whois
database to the name and contact information of the Registrant (IPCSP) that
registered a given domain name.  Limiting Registrants to IPCSPs (versus
individual subscribers) dramatically reduces the complexity associated with
maintaining accurate Whois data. 

For individual privacy purposes, Applicants propose to avoid providing any
information regarding the identity of the underling individual communications
service subscriber who has been assigned day-to-day control over the registered
E.164 number.  

Applicants are prepared to work with ICANN to modify the above Whois policies
to comply with emerging ICANN privacy policies in this area.

© 2004 The Internet Corporation for Assigned Names and Numbers