IATA's Response to USTAR Comment Regarding Reconsideration Request 00-9 Posted: March 14, 2001

IATA respectfully submits the following in response to ICANN's invitation to reply to the comments of Mr. Bruce Bishins of "USTAR" dated 23 February concerning IATA's pending Reconsideration Request. For the reasons set forth below, USTAR has failed to assert any valid reason for not authorising IATA to proceed with implementation of the ".travel" TLD at the earliest opportunity. Accordingly, the ICANN Reconsideration Committee should recommend the ICANN Board promptly approve the pending IATA application. IATA further understands that other concerned travel & tourism industry associations may be expressing their views on this matter directly to ICANN in the near future.

1. There clearly is an actual need for a chartered ".travel" TLD. USTAR's notion that the on-line needs of the travel industry are already being met without a chartered ".travel" TLD flies in the face of overwhelming evidence. A primary objective of a chartered ".travel" TLD is to increase security and bolster consumer trust and confidence in booking travel on-line. Largely because of the lack of such trust and confidence, only 7-8% of travel business is currently conducted over the Internet. See, e.g, Time (December 4, 2000) (there is a "continued reluctance to give credit-card information over the Internet * * * and doubts about online agents' reliability. Then too there are the horror stories about travelers who booked online but got left high, dry and broke at the airport"; "while travel is the leading segment of e-commerce, only 8% of all travel bookings are made online"); Travel Agent (Nov. 6, 2000) ("online travel represents only 7 percent of the entire travel industry, indicating room for a lot of growth"; "[m]ore profitable and complex [travel] products are still being booked offline due to clients' wariness of the Internet"); Travel Trade Gazette UK & Ireland (Feb. 12, 2001) ("consumers are still reluctant to buy package holidays over the internet. Even strong travel brands such as thomascook.com admit they face an uphill struggle trying to sell holidays costing pounds 1,000 or more. Consumers are just not ready to entrust large sums of disposable income to the internet").

2. IATA has developed equitable governance policies and procedures to fairly administer the ".travel" TLD. IATA is committed to ensuring that access to the ".travel" TLD is open to all legitimate participants in the global travel industry. IATA has no intention of exercising control over these decisions. To begin with, as IATA has made clear time and again, the ".travel" Advisory Board which will have this decision-making responsibility will be made up of representatives from all sectors of the travel industry, with no single sector (including airlines) having veto power. Moreover, IATA has no intention of developing the criteria to be used to determine whether a travel agent is entitled to receive a ".travel" TLD. Rather, IATA wants to see these decisions made by the broad-based Board which will represent the entire industry, with input from appropriate travel agent associations. Ironically, the author of the USTAR comments, Bruce Bishins, knows this because he was at the ".travel" Summit in February 2001, where this was discussed and agreed.

3. IATA's proposal for ".travel" has the support of all sectors of the global travel industry. Mr. Bishins participated in the recently held ".travel" Summit, in which over 50 representatives from the global travel community unanimously agreed to seek approval for ".travel." The official Report of the Summit, which was chaired by Senator Herman de Croo (President of the House of Representatives of Belgium, former Minister of Telecommunications and Transport, and a statesman who has long been at the forefront of the European travel industry), is attached. At the Summit's conclusion, an industry working group was formed to further develop the seven (7) agreed principles unanimously adopted at the Summit (which are set forth in the attached Report), and to provide specific recommendations to a second ".travel" Summit to be held in Montreal this May. Mr. Bishins volunteered to serve, and was readily accepted, as a founding member of this Working Group. (Given his role in this Group, there is clearly no merit to his allegation that IATA has favored ASTA - which is not a member of the Group - over ARTA, one of the organizations with which Mr. Bishins is affiliated).

4. There is Overwhelming Interest in the New ".travel" TLD. USTAR provides no empirical support for its claim that the travel industry will not embrace ".travel." By contrast, IATA's reconsideration request attaches the list of supporting comments for its proposal which demonstrates that companies, organizations and individuals - representing a total of more than one million travel professionals and businesses - whole-heartedly support the ".travel" TLD and will utilize it once it is approved and becomes operational. Moreover, many of these organisations sent representatives to Geneva, at their own expense, to participate in the recent ".travel" Summit, thus further demonstrating their interest, commitment, and support, for this initiative.

5. Mr. Bishins' attacks against IATA are groundless. Despite having accepted the invitation to attend the ".travel" Summit and having volunteered to be a founding member of the ".travel" Working Group, Mr. Bishins insists on making various groundless allegations against IATA. The "fact" is that IATA is a non-profit organization which seeks to sponsor ".travel" as a service not only to its member airlines, but to the entire travel industry and consumers of travel. IATA has acted in good faith to receive and consider all of the comments made by Mr. Bishins and others, and hopes that Mr. Bishins will eventually realize, as have so many others from throughout the global travel industry, that IATA's application for ".travel" will be of substantial benefit for the entire travel industry and the consumers which the industry serves.