Executive Summary

We are pleased to have been recognized by the Preliminary Report as one of the top three contenders to be the successor to the current .org registry operator, and we thank the evaluation teams and the ICANN Staff for their hard work.

We disagree, however, with the conclusion of the report that the Internet Society ("ISOC") is the most qualified operator to run the new .org registry. Our careful review of the report reveals serious problems with the methodology used in certain evaluations, the consistency of the criteria applied to all 11 applications, the effort to translate scores on individual criteria into a single grade, and other important aspects of the evaluation process thus far. For example:

• One of the most important criteria for running a successful registry is financial stability and viability. This is particularly relevant to an industry that has been plagued by serious financial problems during the past two years. Candidates' financial wherewithal and experience in managing a budget were never examined in detail by the report. The financial problems of both ISOC and NeuStar have been documented and need to be evaluated in consideration of their ability to operate .org.
  
  
• Although we are generally pleased with the report by Gartner, there are certain procedural and substantive issues that may have led to inconsistent results and flawed scoring. In particular, Gartner's publication of an analytical report on NeuStar in the middle of the .org application process ("NeuStar: One of the Best Kept-Secrets in Telecom," by David Fraley, 06 May 2002, available on www.gartner.com) raises questions whether its more extensive knowledge of NeuStar's systems may have given that bidder an unfair advantage.
  
  
• Since the CIO Team did not provide much detail as to its methodology or findings, we question the reliability of its process and the weight attributed to its determination.
  
  
• While we appreciate the voluntary efforts of the NCDNHC team, aspects of its report concern us. Its methodology for measuring the level of public support was flawed. Also, the report contains inconsistencies in evaluation of the 11 applicants and mathematical errors.

Inasmuch as the report constitutes only Phase I of the evaluation process, these problems can be remedied before ICANN Staff issues its final report on 5 September 2002 (Phase II) and the ICANN Board makes its decision at the end of September (Phase III). As these flaws and errors are corrected, it will become even clearer that Global Name Registry is the best-qualified candidate:

• Sound Financial Condition: Among the top three contenders identified in the report, we are unique in having a sound financial track record. Our backers include the Carlyle Group, which manages more than $14 billion in assets worldwide. Unlike ISOC, we would not be dependent upon delivery of the VeriSign endowment. (Although if one of our non-profit affiliates were deemed eligible for the funds, we would expand our outreach to more local communities in Latin America, Africa and Asia.)
  
  
• Outstanding, Demonstrated Technical Capability & Compliance with Standards: We own and operate a state-of-the-art registry system that has been built in-house and designed to serve 50 million domain names and thousands of registrars:
  
  
  • Unlike ISOC/Afilias, we have built and operate a registry infrastructure that does not rely solely on an outsourced partner for its operations.
    
    
  • We will operate the .org registry using hardware and proprietary software, which - unlike Afilias' - is compliant with key IETF RFCs and has enough capacity to run the entire .com/.net/.org DNS and Whois systems.
    
    
• Smooth Transition by 31 December 2002: Our technical team's experience working with VeriSign (including providing VeriSign with software developed by Global Name Registry's own technical team as the foundation for technical cooperation) could be the critical factor in a successful transition.
  
  
• Responsiveness to the Non-Commercial Community: Global Name Registry is committed to developing .org as the "Community Capital," while exceeding current service standards and lowering the registry price - two critical factors the ICANN Board has emphasised. Our .orgcentre and the Causeway Community Foundation will be a large part of our marketing campaign designed to respond specifically to the community's needs. These initiatives will be undertaken in close consultation and cooperation with the .org Steering Committee. Our proposal means reinvesting revenues from .org back into the community, rather than simply supporting a narrower set of interests (e.g., ISOC) or increasing corporate earnings (e.g., NeuStar).
  
  
• Global Outreach: We will leverage our relationship with the International Federation of Red Cross and Red Crescent Societies (the "Red Cross") to maximize our global outreach and to bring the resources of the .orgcentre and the Causeway Community Foundation to local communities worldwide.
  
  
• Significant Enhancement of Competition: Selecting Global Name Registry as the .org operator will create the first European super-registry and significantly enhance competition in the registry services industry.

In order to ensure a fair evaluation process and a credible outcome, we therefore request that the final report:

• Fully incorporate the concerns described in our comment, including correcting tabulation errors and re-scoring or invalidating scores that cannot be substantiated or that result from inconsistent application of the criteria; and
  
  
• Include all of the information that the Board will require to make a fully informed decision in the interests of the 2.3-million .org registrants and the broader ICANN community, particularly on the financial stability and viability of the top three contenders.

Introduction

We have read the Preliminary Staff Report on Evaluation of the Proposals regarding Reassignment of the .Org Registry (the "Preliminary Report") and are pleased to have been recognized by ICANN Staff as one of the top three contenders to be the successor to the current .org registry operator. We know that the evaluation teams faced a tremendous challenge in digesting and analysing the bids within a short timeframe, and we commend them for their efforts and continued commitment to the process.

We want to thank the ICANN Staff, the Non-Commercial Domain Name Holders Constituency (the "NCDNHC"), Gartner, Inc. ("Gartner") and the Academic CIO Team (the "CIO Team") for their efforts, with special gratitude to those who volunteered their time. We commend the ICANN Staff in particular for its commitment to overseeing the application process in as fair, impartial, open and transparent a manner process as possible.

We appreciate the evaluation teams' recognition of the strengths of Global Name Registry as both a registry operator and as a visionary for the .org namespace. Gartner selected Global Name Registry as one of the top three applicants on technical excellence, and indicated that we stand first among all applicants with respect to our ability to support, function in, and adapt to protocol changes in SRS. This is one of the most important components of transitioning the .org registry from a thin registry accessed through RRP to a thick registry accessed through EPP. The NCDNHC applauded Global Name Registry's vision statement, including our explicit recognition of the diversity of .org, and our development of a "clear brand identity" based on creating "Community Capital".

We respectfully disagree, however, with the suggestion in the Preliminary Report that the new .org registry operator should be the Internet Society ("ISOC"). Our careful review of each of the reports underlying the Preliminary Report, and the Preliminary Report itself, reveals serious problems with the methodology used in certain evaluations, the consistency of the criteria applied to all 11 applications, the effort to translate scores on individual criteria into a single grade for an "Evaluation Summary", and other important aspects of the evaluation process thus far. Inasmuch as the Preliminary Report constitutes only Phase I of the evaluation process, these problems can be remedied before the ICANN Staff issues its final report on 5 September 2002 (Phase II) or the ICANN Board subsequently makes its decision at the end of September (Phase III).

Comment

It is vital that by the end of September the ICANN Board has before it for consideration all the information it needs to select the candidate most qualified - in every critical respect - to operate the new .org registry. We therefore request that ICANN Staff will, before issuing its final report for the Board's review:

• Fully incorporate this comment on the Preliminary Report, including correcting tabulation errors and either re-scoring or invalidating scores that cannot be substantiated or that result from inconsistent application of the criteria.

• Add to its final report all of the information that the Board will require to make a fully informed decision in the interests of the 2.3 million .org registrants and the broader ICANN community, particularly on the financial stability and viability of the top three contenders.

We recognize that a numerical evaluation process, with identified flaws corrected, may be the only way to narrow a competitive field of 11 candidates to a few top candidates. It may not, however, be the best way to differentiate among the top three: ISOC/Afilias, NeuStar and Global Name Registry. The combination of the (1) varying importance of the criteria developed by ICANN, (2) inherently subjective nature of their application, and (3) slight differences in scoring (e.g., Gartner gave overall scores of 3.65 to ISOC and 3.64 to Global Name Registry, a difference of only .01), does not establish a reliable method for discerning and weighing important differences among the top three applicants. We respectfully submit that the most useful way - and, really, the only way - to prepare the Board for its decision is to provide clearer, more comprehensive information on each of the top three candidates.

This comment (1) describes why Global Name Registry remains the candidate all around best qualified to be the new .org operator; (2) identifies material flaws and misinformation in, and omissions from, the Preliminary Report that must be corrected before the final report is issued on 5 September 2002; and (3) recommends additional information the Staff should present to the Board in its final report.

Global Name Registry's Qualifications

We believe that we are the candidate most qualified to assume full operation of the .org registry on 1 January 2003 because we represent the "best of the breed" overall. We say this without any slight to the other candidates. On the contrary, we have a healthy respect for our competitors, and nothing in this comment is intended to undermine that. At the same time, the need to make the final report accurate and complete in certain fundamental respects puts pressure on us to highlight the differences among the three of us for the benefit of the Board. When it is time for the Board to make the final decision and can choose only one winner, the following strengths will distinguish Global Name Registry from the other top contenders:

• Sound Financial State: .org is too important a top-level domain to award to any entity that is not clearly - on its own - financially stable and viable. We are backed strongly by the Carlyle Group which manages more than $14 billion in assets worldwide and has been an enthusiastic supporter of our operations. In light of the serious financial problems that ISOC (see http://www.isoc.org/isoc/general/trustees/mtg25.shtml) and NeuStar (see "NeuStar Slashes Staff Again", TechNews.com, 23 May 2002 at http://www.washingtonpost.com/ac2/wp-dyn?pagename=article&node=&contentId=A3429-2002May10¬Found=true) have had during the past year, and as recently as a few months ago, we are clearly the most financially secure top contender. The problems facing ISOC and NeuStar could impact negatively on their ability to transition and operate .org, in both the short- and long-term. Unlike ISOC, we are not dependent upon receipt of the VeriSign endowment (although if one of our non-profit affiliates is deemed eligible for the funds, those funds would be used to expand outreach to local communities in Latin America, Africa and Asia).

• Outstanding, Demonstrated Technical Capability & Compliance with Standards: The .org domain space, containing approximately 2.3 million registrants, is too important to entrust to any entity that has not operated a top-level domain, or even to an entity that does not have a track record of technical excellence. We own and operate a state-of-the-art registry system that has been built in-house and designed to serve 50 million domain names and thousands of registrars. Our technical capability and commitment to excellence provide a solid foundation onto which we will safely transition and operate the .org registry:

  • Unlike ISOC/Afilias, Global Name Registry has built and operates a registry infrastructure that does not rely solely on an outsourced partner for operations of its data centre, DNS, Whois or MX services.

  • Global Name Registry's decision to purchase certain SRS services from VeriSign to provide for additional stability and redundancy during the .name start-up period has given us unique familiarity with the incumbent operator's technical teams and systems. VeriSign will not, however, play any role whatsoever in the operation of .org.

  • Global Name Registry will operate the .org registry using its proven, internally designed and developed hardware and software, which - unlike Afilias's - is compliant with key IETF RFCs and has enough capacity to run the entire .com/.net/.org DNS and Whois systems.

• Smooth Transition by 31 December 2002: There is no room for error on this tight schedule. The Global Name Registry technical team's experience working with VeriSign (including providing VeriSign with software developed by Global Name Registry's own technical team as the foundation for technical cooperation) could be the critical factor in a successful transition. We fear that some applicants may have underestimated the complexity of the .org transition and made unrealistic promises. We have carefully evaluated, and are ready to execute, every element critical to a seamless transition.

• Responsiveness to the Non-Commercial Community: Global Name Registry is committed to developing .org as the "Community Capital", while exceeding current service standards and lowering the registry price. The .orgcentre - a success-centre for non-commercial entities - will be an open resource centre available exclusively for the benefit of the .org community and will continuously assess its changing needs and interests. The Causeway Community Foundation will be available to fund hundreds of projects that the .org community believes can benefit the broader Internet community. Both entities - which will re-invest revenues from .org back into the non-commercial community, rather than supporting a narrow set of interests or solely increasing corporate earnings - will be a large part of our marketing campaign designed to respond specifically to the community's needs. All of these efforts will be undertaken in close consultation and cooperation with the .org Steering Committee, consisting of the leadership of the NCDNHC and Global Name Registry.

• Global Outreach: We will leverage our relationship with the International Federation of Red Cross and Red Crescent Societies (the "Red Cross") to maximize our global outreach and to bring the resources of the .orgcentre and the Causeway Community Foundation to local communities worldwide. Red Cross presence in more than 180 countries and its 92 million volunteers worldwide provide a strong foundation to expand use of the .org namespace. Through its global footprint, the .orgcentre's tools, and the Causeway Community Foundation's resources, we can reach a broader section of the Internet community.

• Significant Enhancement of Competition: Selecting Global Name Registry as the .org operator will create the first European super-registry and significantly enhance competition in the registry services industry. Global Name Registry currently runs only one top-level domain and would therefore be able to focus our full attention and resources on the operation of the two registries. NeuStar and Afilias, on the other hand, already each operate two other top-level domains; indeed, awarding it to either of them could make it harder to justify the decision to require the incumbent to divest its third registry.

Flaws in the Evaluation Process and Preliminary Report

Gartner, Inc.

We are generally pleased with the report by Gartner, a well-respected organization that brings a level of experience to the process that cannot be replicated. Its evaluation was supported by detailed illustrations of the underlying objectives and methodology. Nonetheless, there are certain procedural and substantive issues that may have led to inconsistent results and flawed scoring, including Gartner's previous knowledge of the systems of at least one of the bidders, and inconsistent application of several criteria and their components.

Previous Familiarity with NeuStar Systems

We believe in Gartner's integrity as an industry analyst. We were surprised, however, to learn that it published an analytical report on NeuStar in the middle of the .org application process (see "NeuStar: One of the Best Kept-Secrets in Telecom", by David Fraley, 06 May 2002, available on www.gartner.com). It is now clear that Gartner had significant knowledge with respect to NeuStar's systems before evaluating its bid. This raises two issues:

• There should have been disclosure prior to Gartner's evaluation of any bid, and acknowledgment in the Preliminary Report that Gartner had already conducted an in-depth analysis on NeuStar. This is particularly important in light of the fact that Gartner awarded NeuStar the highest score of any bidder, including Global Name Registry and ISOC/Afilias.

• There is no way to determine whether Gartner's pre-existing knowledge of NeuStar's technical systems, rather than the contents of its .org bid, benefited NeuStar's application or adversely affected other bidders. However, Gartner's previous knowledge of NeuStar's systems may have given NeuStar an unfair advantage over its competitors because Gartner would have been able to fill in any gaps in NeuStar's application.

We reiterate our belief that Gartner likely entered this process with the intent to conduct a thoroughly impartial and objective evaluation. However, it is entirely possible that Gartner's pre-existing knowledge of the NeuStar systems swayed its analysis of the NeuStar bid. In light of this uncertainty, it cannot be said unequivocally that this part of the evaluation process was altogether fair.

Consistency of Criteria

With respect to consistency, using two separate teams to evaluate the 11 applications led to several deficiencies. Gartner raised certain issues with the Global Name Registry bid, in comparison to the ISOC/Afilias and NeuStar bids, with respect to Criterion 1 (stability of .org registry), Criterion 7 (the type/quality/cost of registry services proposed) and Criterion 11 (completeness of proposals). Clarifying these issues will demonstrate that Global Name Registry possesses equal, if not better, experience and capabilities.

Criterion 1: Stability of the .Org Registry - Capacity

Global Name Registry understands the overriding importance of preserving the stability of the Internet. In the .org context, this requires a system that is technically sound with high quality services that meet the needs of .org registrants. Relevant to this context is a discussion of the details of an applicant's DNS platform, which is extremely important to a well-functioning .org namespace and must operate flawlessly.

Gartner has stated that the Global Name Registry "proposal included no discussion of capacity, volume or response time" of our DNS platform. The team, however, overlooked the full description contained in the application (Response C17.10 "Peak Capacities"). Because the system underlying this description comprises an integral part of the DNS platform, this oversight appears to have materially and adversely affected Global Name Registry's performance on Criterion 1.

In fact, Global Name Registry provided a more detailed description of our capacity, volume and response time than did either ISOC/Afilias or NeuStar. Our discussion includes performance graphs per single server, per cluster and across the entire Global Name Registry network. It further describes, in detail, zone-loading times, memory and disk space usage plotted against different zone sizes. This is a painstakingly detailed description of capacity, not only for the current zone size of .org, but also for other operational conditions. In this respect, Global Name Registry's proposal demonstrated better experience with capacity than either ISOC/Afilias or NeuStar.

In evaluating the capabilities of each of the top contenders, it is important to note that VeriSign receives more than 6 billion DNS queries per day, equal to roughly 70,000 queries per second (see http://www.verisign-grs.com/mdns/ha/haDatasheet.pdf, http://www.nwfusion.com/news/2002/0306verisign.html, and http://www-1.ibm.com/servers/eserver/pseries/news/pressreleases/2000/apr/network_solutions.html). This equates to approximately 7,000 queries per second for .org alone, and peak demand is likely to be 200-300% higher than this average query rate.

Global Name Registry currently operates, and would operate .org, with a documented capacity of 32,000 queries per DNS cluster alone (see C17.10), or almost 200,000 queries per second across its six clusters and entire DNS network. This far exceeds the peak demand for .org and provides a stable environment that currently has sufficient capacity to account for growth in the future. Furthermore, this solution uses BIND and is fully compliant with all relevant specifications (see C17.12).

Gartner appears to have overlooked that ISOC/Afilias and NeuStar failed to meet these criteria. Afilias states that its DNS network (outsourced to UltraDNS) can handle 10,000 queries per second, while NeuStar asserts a peak DNS capacity of 5,000 queries per second. Clearly, both fall short of the peak demand for .org. Additionally, because Afilias's 100% outsourced provider, UltraDNS, also provides its services to several companies other than Afilias, its actual capacity available for .org may be even lower than 10,000.

Criterion 7: Type/Quality/Cost of Registry Services

The ICANN Board unanimously expressed its view on the type, quality and cost of registry services proposed during its meeting in Ghana in March 2002. Vint Cerf stated, with no objection from the rest of the ICANN Board, that:

"the organization be focused on making the operation safe, secure, efficient and inexpensive as possible [emphasis added]" (see Real-Time Captioning of ICANN Board Meeting in Accra, Ghana, Afternoon Session, 14 March 2002).

"A significant consideration will be the price at which the proposal commits to provide initial and renewal registrations and other registry services" (see Criteria for Assessing Proposals).

It is unclear, however, the extent to which Gartner actually weighed proposed pricing in its evaluation, if at all. The Gartner analysis does not mention how proposed price reductions affected a bidder's performance, which strongly suggests that pricing did not receive the significant consideration intended by the ICANN Staff and Board relative to other criteria.

Pricing is in fact an important criterion that distinguishes us from ISOC and NeuStar because our proposed average prices differ significantly: US$6 (ISOC), US$5 (NeuStar) and US$4.51 (Global Name Registry). Indeed, our proposal on pricing is far more aggressive than our competitors - up to 40% discount based on volume and duration. Because affordability is so important, and it was the intent of the ICANN Board that the new operator reduce the registry price, this omission is material and therefore renders evaluation of Criterion 7 incomplete under the standards established by ICANN.

Outsourcing

Gartner has taken issue with the fact that the .name registry is "partly outsourced" and that we run a "mirrored registry". In fact, the .name registry has been largely developed and deployed using software created by Global Name Registry and hardware designed by our Operations Team. Global Name Registry currently operates both the main site and disaster recovery site described in the .org application, which currently run 100% of the Whois and MX capacity and 60% of the DNS capacity (approximately 120,000 queries per second - more capacity than ISOC/Afilias and NeuStar put together) for .name. The main site includes a full database set and business logic. The only component that Global Name Registry does not operate is the EPP front-end, the front-end, however, is comprised of software we developed internally and have shared with other registries (e.g., Afilias uses our EPP client software).

The EPP frontend is the only real addition that would be required for the Global Name Registry .name system to encompass full SRS capability. Rather than diminish our experience, this minimal outsourcing gives us knowledge of VeriSign's systems that will facilitate a smooth transition. Further, to the extent outsourcing is a concern, it is important to note that Afilias has proposed to outsource its system for .org to IBM on a much more comprehensive basis than the Global Name Registry arrangement for .name.

Experience

While we acknowledge that we have operated a top-level domain for a slightly shorter period than either Afilias or NeuStar, the differential is a matter of only three months. It is simply wrong to conclude that Global Name Registry is less competent on this basis. Rather, attention should be paid to the substance of the operation of the registries, as well as to previous experience that any of these bidders had prior to operation of their respective generic top-level domains.

In particular, Global Name Registry significantly outperformed both Afilias and NeuStar during our respective start-up phases. Global Name Registry has experienced 100% uptime on all services during our start-up and operations. Our registration processes proceeded without incident, in particular, with no technical or legal issues. In contrast, during the land rush phase of the .info rollout, Afilias experienced a number of procedural and policy problems that were described as an "abomination" by one of its directors (see ".Info Chief Quits in Protest over Sunrise Period" at http://news.zdnet.co.uk/story/0,,t269-s2094819,00.html). As a result, Afilias was required to resort to challenging its own registrations. During the .biz land rush process, NeuStar faced serious criticism for its lottery system and ultimately lost a lawsuit claiming that its registration process constituted an illegal lottery under the laws of California (see "NeuStar: America's New VeriSign?" at http://www.internetnews.com/dev-news/article.php/10_913441).

As further evidence of our experience, the same core team that currently comprises Global Name Registry successfully operated a personalized email communications system that grew to more than 1.5 million users within one year. While operating such system is not identical to running a generic top-level domain registry, there are many similarities that give Global Name Registry significant operational experience perfectly applicable in the registry context. These similarities include:

• Online transaction system with high volumes: The email system, like a registry, was a high-volume transaction system that supported more than 1 million users within one year, and more than 1.5 million at its peak, with 35 million page views a month. This translates into almost 1.2 billion transactions per month.

• Design: Like a registry SRS, the system was comprised of a three-layer structure where each layer was designed to individually scale.

• Security: Despite daily DOS attacks and attempted security breaches, the system was never compromised due to its numerous firewall layers, IDS systems and state of the art security.

• Scalability: Like a registry, the system was built to accommodate more than 100 million users and billions of transactions per month.

Size of Registry

Gartner cites the size of the .name registry as indicative of less experience. Unfortunately, this statistic overlooks the fact that:

• Whether a registry system includes 1,000 objects, 150,000 objects, or 2 million objects, the experience of the operator is rather a function of how the scalability strategy has been implemented, not of how many objects have been inserted. For example, it is easy to design and insert an Excel spreadsheet that contains 10,000 data elements and scales to 65,000 elements; however, it is much more difficult to design and insert 10,000 data elements into a system designed to meet the needs of 50 million objects.

• Global Name Registry has built a system that is capable of hosting more than 50 million domain names.

• Our performance record is unmatched by any other generic top-level domain operator.

• We have proven the registry's security and stability through virtually flawless operation and our 100% uptime on key registry components, such as DNS, Whois and MX services.

Backup Data Centres

Gartner has indicated that the Global Name Registry bid contains little to no information on the disaster recovery site. The bid does, in fact, include significant detail, as follows:

• Response C17.1 (for "Disaster Recovery" see pages 33, 62, 75, 98, and 116-117; for "Offsite Logging" see pages 6, 8, 27, 31, 38, and 97-98).

• Response C17.3 (includes a figure discussing how replication occurs between the data centres).

• Response C17.2-16 (for "Disaster Recovery", including the disaster recovery site, see pages 2, 6, 24, 37, 153, 160-162, 166, 170-176 and 181).

In contrast, the ISOC/Afilias bid provided little detail on their fail-over data centre. As an example, the data replication method does not seem to be discussed, which could mean that they rely on anything from synchronous mirroring to physical transport of a database dump in the case of main data centre failure.

In conclusion, with respect to Criteria 7, the Gartner report should have better reflected that the experience of Global Name Registry is actually superior to that of ISOC. While ISOC may be doing a fine job of developing educational tools and fostering development of Internet standards, the group itself has no experience in operating a registry. Furthermore, ISOC (or its nominee), although the proposed registry operator of record, would be so far removed from the operation of the registry that little knowledge, if any, about technical operations would be possessed by the operator. To remedy its marked lack of experience in operating a registry, ISOC has teamed with Afilias. Afilias, in turn, plans to contract its key operations to IBM and UltraDNS. It must be noted that these steps would constitute a much higher percentage of outsourcing for .org than Global Name Registry's current arrangement for .name.

Criterion 11 (Completeness of Proposal)

We believe that this Criterion (completeness of proposal) has been misinterpreted by Gartner. As stated in the Criteria, a complete proposal must, among other aspects, reflect "a thorough understanding of what is involved", have "procured firm commitments for all necessary resources" and have "formulated sound plans for executing the proposal".

Global Name Registry's description of our experience in building a state of the art registry, of how we would approach the .org transition, and of our extensive implementation plan, demonstrate that we have met these requirements. Moreover, we appear to be the only top contender in sound financial shape, with blue chip investors committed to protecting our integrity and reliability. With strong support from the Carlyle Group, which manages assets in excess of US$14 billion worldwide, for our efforts on both .name and potentially .org, we are confident of our ability to fully support both registries. The Global Name Registry team is thoroughly staffed to meet the various challenges of running a registry, with wide-ranging capabilities in development, operations, marketing, business development, public relations, policy, legal, registrar relations, human resources, finance, and internal technical support.

ISOC, in contrast, faces serious financial hurdles that raise questions about its stability and viability, and its experience in budget management. The minutes of ISOC's December 2001 Board Meeting indicate that:

"Revenues have exceeded expenses in 2000 and 2001, reducing our negative net worth to about $500K by end of year 2001... this has severely limited our capacity to develop new initiatives in the education and policy domains. The society has been operating with a very low amount of available cash, sometimes not much more than two weeks."

"We observe that the current model of individual members and chapters is not working, and that we need to change it. Even with the recommended budget, we will still get a negative set worth of a couple $100K at the end of the year..."

"We loose [sic] 65% of our members every year, which means that we are finding 4500 new members every year. but we cannot keep them. Many chapters are not very active; the chapter council never took off the ground. Membership has been stagnant for years and is now decreasing." (See http://www.isoc.org/isoc/general/trustees/mtg25.shtml.)

If ISOC had trouble matching revenues and expense during the high-tech boom years, the question of how ISOC, if selected, would now fund the transition, start up and operation of the .org registry is even more compelling. Cash reserves of two weeks or less, or even a "surplus of US$152,382" (see "Internet Society Statement in Response to Questions Regarding the Preliminary Recommendation to Award the .Org Registry to ISOC" at http://www.isoc.org/dotorg/icann-response.shtml), may be sufficient for a non-profit organization, but this level of funding is entirely unacceptable for operation of a world-class registry that contains 2.3 million names and the potential to grow much larger.

In addition, ISOC's proposed operator, Public Interest Registry ("PIR"), has not been formed, does not have a management team and lacks infrastructure (e.g., PIR has established no articles of association, no bylaws, no directors and no staff). In light of the financial status and the corporate issues facing ISOC/PIR, proper interpretation and application of Criterion 11 would have rendered the ISOC proposal materially incomplete.

We also question the financial position of NeuStar. In May 2002, approximately one month after it was awarded the contract for .us, the company conducted its fourth lay-off, cutting an additional 16% of its workforce (see "NeuStar Slashes Staff Again", TechNews.com, 23 May 2002 at http://www.washingtonpost.com/ac2/wp-dyn?pagename=article&node=&contentId=A3429-2002May10¬Found=true).

Given uncertainty surrounding actual delivery, and timing, of the VeriSign endowment (assuming it will be delivered), the ICANN Board should select an applicant that is not dependent upon endowment funds. Moreover, in light of the extremely short timeframe in which the .org transition must be planned and executed, there should be particular emphasis on the actual ability of the successor to execute the proposal, not only whether the proposal is itself complete. It is unclear whether ICANN Staff has yet evaluated either of these important factors in drafting its Preliminary Report. When they are given the weight they deserve, it will be clear that our financial stability and fully implemented corporate structure make Global Name Registry the safer choice.

Consistency - Issues Overlooked in Other Bids

In addition to overlooking, or perhaps not fully understanding, certain issues presented in the Global Name Registry bid, Gartner seems to have failed to spot problems and omissions in other bids. These include DNS capacity (mentioned above), database documentation and compliance with specifications. A review of these inconsistencies should lead Gartner to conclude that the marks for other bids were higher than they should have been. Because these aspects of registry operations are integral parts of a successful registry, this information should be presented to the ICANN Board.

Documentation of Database

The successor operator of the .org registry should possess clear and specific documentation of its database, which Global Name Registry provides in Response C17.3. In contrast, the database documentation of ISOC is thin. This may be due to Afilias seeming to rely on a non-commercial PostgreSQL database, and the subsequent lack of available testing tools and competent personnel. It is not stated which database is being used (but one could be led to infer PostgreSQL), nor is it at all documented how the database(s) (if there are several) would interact, replicate or mirror. Database competence is crucial for a registry operator, whose main tasks include full control over the authoritative database for any top-level domain.

Compliance with Specifications

As required by ICANN, the successor operator of the .org registry should ensure full compliance with specifications, including "compliance with at least the following RFCs: 954, 1034, 1035, 1101, 2181, 2182".

ISOC has not answered the RFP Question C17.12 appropriately. In fact, ISOC indicates that it is compliant with a completely different set of RFCs ("2453, 2080, 2328, 2460, 2373, 2463, 2464, 2236, 1812, 1771"), notwithstanding the fact that these RFCs have little or nothing to do with the question. Thus, its solutions are not compliant with the IETF standards and could risk endangering the security and stability of the Internet.

Moreover, according to its bid, ISOC "will be serviced entirely through one of the world's leading DNS providers, UltraDNS", which uses "its own proprietary database". ISOC's reliance on this singular DNS provider carries significant risk for two reasons:

• From an operational point of view, reliance on only one DNS provider may lead to fragmentation of the Internet.

• The use of proprietary DNS software and non-compliance with standards (as stated in C17.12, but inconsistent with the statement from C17.4) carries with it an unknown set of vulnerabilities, possible stability problems and security breaches.

Academic CIO Team

The CIO Team was not asked to provide detailed analyses or justifications for its findings and thus provided a summary categorization of its analysis in a three-page report. With little information available on how it compiled its rankings, we find it difficult to comment with specificity on the reliability of its assessments. We can, however, make two general comments regarding process and weight.

Process

We question whether (1) the level of assurance of the understanding of key aspects of the registry services industry was adequate; and (2) it is possible for any group of individuals, no matter how intelligent or diligent, to meaningfully digest comprehensive responses to roughly 53 questions on technical capability within 11 different applications over a limited one and a half day period.

It is impossible to discern from the short report how the team developed a common understanding of "the domain name system, the functions of registries and registrars and an understanding of the RFP process", or managed to carefully review 11 complex applications during this short period. With all due respect to a team comprised of highly educated and well-respected individuals in the information technology industry, the answers provided by Global Name Registry alone to ICANN's 53 technical questions tallied roughly 350 pages (with the entire application totalling approximately 900 pages). If we multiply this number by 11 applications, it would seem almost impossible to be able to fully review, debate, research and resolve any differences.

Weight

Because of the unclear methodology and short time frame for the CIO Team evaluation, we are quite concerned that the Preliminary Report tabulations (Table 2) appear to give the CIO Team report the same weight as the far more detailed reports by Gartner and the NCDNHC. The stated purpose in asking the CIO Team to review the applications was to serve as a check of reasonableness on the Gartner report, and not to serve as an independent basis of evaluation. It should therefore be used in the Preliminary Report only to decide whether or not the Gartner evaluation is "in the ballpark". It should not, particularly in light of the process concerns described above, be used as an independent basis for ranking the applicants in Table 2.

NCDNHC

• The methodology of measuring the level of public support for specific bidders, and the tabulation of that information, were flawed.

• The evaluation of different sections of each bid by separate teams led to the inconsistent application of several criteria.

• Mathematical errors have been found in the derived rankings (notwithstanding concerns about the underlying methodology and consistency).

It has come to light that there were differences among members of the NCDNHC team, and that not all agreed with the approaches taken. We recognize that had there been more time to try to resolve these differences, some - and perhaps all - of the problems we identify below could have been remedied or avoided.

Criterion 6: Public Support

ICANN's Statement of Criteria acknowledged at the outset that Criterion 6 (Public Support) would raise "significant difficulties in ascertaining the level of support for particular .org proposals" (see Criteria for Assessing Proposals). In the NCDNHC report, Milton Mueller acknowledges that:

"Assessing endorsements as a proxy for 'the level of public support' is an inexact process" (see NCDNHC report Annex 2).

It is indeed troubling that the NCDNHC team did not simply attempt to describe the different kinds and number of letters of support that came in for each applicant. Instead, the team tried to devise a system for weighing and counting each letter that turned out to be seriously flawed. This mistake was compounded by the inappropriate weight that was given - perhaps inadvertently - to these scores in the overall rankings.

As Thomas Roessler, President of the ICANN General Assembly (no affiliation with Global Name Registry), wrote to Milton Mueller, a member of the NCDNHC team, on 21 August:

"But as the different approaches and results you guys have produced indicate, these differences were hard to quantify - certainly harder than the differences in other areas of the report. Ultimately, you don't even know what you are comparing: Are you ultimately comparing the efforts made by applicants? Are you comparing the success of similar-size efforts? The numbers you generate that way are necessarily weak. Weaker than the ones from the other parts of the report.

That's why I maintain that it is an extremely bad idea to combine the scores across categories."

The NCDNHC report acknowledges uncertainty about how to count dozens of letters from members of ISOC. While in the end it decided to try and count "ISOC support" as one letter, that decision was inconsistent with the decision to exclude letters from groups with whom other bidders had a relationship, such as the Red Cross's letter of support for Global Name Registry. For the scoring decisions to be consistent, either both, or neither, of the ISOC and Red Cross letters should have been counted.

The issue of trying to determine whether any letters of support for ISOC were from non-members was also mishandled. The NCDNHC team admitted that it had no way to tell whether a letter was from an ISOC member or non-member. As Milton Mueller acknowledged to Thomas Roessler:

"What we can't tell from the evidence is whether the people who added their name to the Class B list were ISOC members or not" (See http://www.icann-ncc.org/pipermail/discuss/2002-August/002730.html.)

As a result, the team arbitrarily decided that "100" of the letters would be deemed to be from non-ISOC members. Under the methodology adopted by the team, each of these letters was counted as 1/5 of a letter from a .org registrant, thereby giving ISOC an extra 20 points that were critical to its overall ranking.

The NCDNHC report also admits qualms about the dozens of letters of support that NeuStar solicited, most of which were form letters that indicated no specific support for that bidder. Rather, the letters indicated that, if NeuStar won, the signatories would want to be part of the advisory process.

For all of these reasons, the only accurate method of evaluating Criterion 6 - within the available timeframe and budget - is to describe the letters of support in terms of bidder, type and number, and then let the ICANN Board draw its own conclusions. To do otherwise is to provide scores and overall rankings that do not reflect the level of support in the .org community, and that skew evaluation of other criteria within the NCDNHC mandate, as well as across the other evaluations. As Milton Mueller wrote:

"The only objective method would be to spend several million dollars and a year to conduct global surveys of non-commercial .org users based on statistically representative samples. Most of whom would be unaware of the whole process of .org reassignment." (See http://www.icann-ncc.org/pipermail/discuss/2002-August/002729.html.)

Inconsistent Criteria

Our review of the NCDNHC report has brought to light inconsistencies in the application of Criteria 4 and 5. In particular, with respect to Differentiation, NCDNHC seemed to have overlooked portions of the Global Name Registry bid that they recognized in other bids, such as our .orgcentre and Causeway Community Foundation, both of which benefit the .org and Internet communities, while differentiating the .org space as a place for non-commercial activities. The NCDNHC also seemed to have overlooked our discussion of cooperative marketing. With respect to Responsiveness, it seems that the NCDNHC similarly awarded other bidders points, while neglecting similar discussions in our bid as well as misunderstanding the purpose and composition of one of our important initiatives, the .org Steering Committee.

Criterion 4: Differentiation

Global Name Registry received two 0s under the category of Differentiation, one for Innovation and the other for Registrars. Because our application contained a comprehensive discussion of elements of our .org vision that addressed both issues, the basis for these determinations is unclear. In addition, we believe that the 4 we received on Positioning should be reconsidered. Either the NCDNHC mis-scored the Global Name Registry bid in the context of these categories, or it mistakenly overlooked key descriptions contained in our application.

Innovation: While the NCDNHC team recognized the pledge by Global Name Registry to commit up to 15% of its .org revenues to programs benefiting the .org and Internet communities, there seemed to be no further investigation of this commitment. We believe, and have received feedback from various members of the non-commercial community within ICANN, that our concept for the .orgcentre and the Causeway Community Foundation are uniquely innovative. In particular, the services of an open resource centre which provides .org registrants with various tools, training and support as to how to develop their presence online have been very well-received by various members of the NCDNHC. The .orgcentre and the Causeway Community Foundation - a fund that will be available to financially support potentially hundreds of projects every year that would grow the .org community and the benefit the broader Internet community - were fully described in Response C38.3 of our bid.

In addition, while the NCDNHC seemed to overlook a key aspect of Global Name Registry's innovative commitments - our cooperative marketing program - it looked favourably upon other applications that contained the same concept. Both Unity and SWITCH received points for their cooperative marketing plan concept where they committed to a specific program, a cooperative advertising program, a registrar relations department and a road show for education of registrars. All of these concepts were described equally in the Global Name Registry bid in Response 38.5.7A.

Registrars: As a registry operator for a currently existing and operational registry, we do not understand the basis for the 0 we received for our understanding of the challenges of leveraging registrar relationships. In fact, on page 15 of its report, NCDNHC states:

"[T]he Committee recognizes that GNR provides such expertise [technology and communications networks] through its relationships with global registrars."

The .name registry has supported more than 60 registrars that sell .name products to end-users. We understand the importance of incentivising registrars to sell our products, and we have established and described, in Response C38.5.7A, our commitment to developing marketing materials and toolkits for .org. To date, we have developed extensive marketing programs and tools to attract end-users because .name is uniquely a space for individuals, an audience to whom registrars have not historically marketed. We live and die by the success of our registrars, and this is a key message in our .org application (see Response C17.11, Customer Service).

Positioning: Although NCDNHC has indicated very clearly that the Global Name Registry bid included a clear brand identity, it appears that our marketing and positioning initiatives were not given fair consideration. Moreover, the NCDNHC team should not discount or underestimate our relationship with the Red Cross. The Red Cross remains committed to helping Global Name Registry build the vision for .org by ensuring that its corporate partners re-energize their .org registrations to focus on their community involvement.

Criterion 5: Responsiveness

There are several procedural issues with respect to the NCDNHC's evaluation of the applications for Responsiveness. First, in addition to the miscalculation of final scores, which clearly and adversely affected Global Name Registry's rank in this regard, in its analysis of this Criterion 5, the NCDNHC awarded 6s to some bidders. There is, however, no mention of a seven-point scale (0-6), which raises the question of whether the team inadvertently applied it only to certain applications.

Second, we believe that if NCDNHC had thoroughly understood the structure of the .org Steering Committee, it would have made a more favourable determination regarding Input/Governance and Services Targeted at Community. Not only does Global Name Registry seek input from the non-commercial community through the .org Steering Committee, but Global Name Registry has developed two separate initiatives, the .orgcentre and the Causeway Community Foundation, specifically designed with the concept of both continuous input and service in mind.

Unfortunately, the NCDNHC group evaluating our bid did not appear to understand the .org Steering Committee concept, described in Response C35(4). Global Name Registry will not have the right to hand pick its members. Rather, as we thought we made clear, the Steering Committee will be comprised of the leadership of the NCDNHC (or whatever successor group emerges from ICANN reform):

"The OSC [.org Steering Committee] will include the leadership of the ICANN's non-commercial constituency and the .org registry, as well as from the .orgcentre and the Causeway Community Foundation... The OSC will be the first liaison mechanism of its kind to be created directly between a registry and the ICANN community... We believe that creation of the OSC is preferable to establishment of a Policy or Advisory Council for several reasons. Done properly, setting up a new council would likely involve complex procedures for selecting and voting upon the members. (see Global Name Registry bid, Response C35(4))"

We believe that this structure would be better than one created solely by Global Name Registry since the individuals participating in the NCDNHC are the most informed and committed to addressing the issues facing the non-commercial community on the Internet. We devised this mechanism in order to ensure accountability by Global Name Registry to the non-commercial community. While as a technical or legal matter the registry operator might be free to reject such guidance, we are well aware that it would be foolish and short-sighted to risk doing so.

Tabulation Errors

As Thomas Roessler and Alexander Svensson pointed out to the NCDNHC team:

"The table on page 14 (responsiveness and governance rankings) is inconsistent in itself. GNR's score should be 27.75 (instead of 26.75, thereby placing GNR on rank 1, ahead of unity with 27.25), while ISOC's score should be 23.25 (instead of 21.75; no ranking changes caused)."

Moreover, Thomas Roessler states:

"By merely averaging ranks, small differences in the originating scores (possibly caused by minor errors - the mistake in GNR's score corresponds to an error of about 3.5%!) are exaggerated in the end result... "

Clearly, errors such as these, while inadvertent, are far from trivial. They require either re-tabulation or invalidation of the scores at issue.

General Counsel's Report

• While we have experience in operating a RRP gateway, neither Afilias nor NeuStar currently operates, or has operated, a RRP gateway that can be used for .org.

• .org will require changes to existing EPP gateways by all applicants, including Global Name Registry, ISOC/Afilias and NeuStar.

• Those applicants that have proposed a RRP/EPP solution (including Global Name Registry and ISOC/Afilias) will have to develop such a solution, which does not currently exist within any registry system.

• Adding .org to any registry system will result in changes to a multitude of subsystems, including database schemas, authentication and validation procedures, billing systems, and Whois.

• Global Name Registry has proven and documented its ability to adapt to new protocols, additionally having already developed technology solutions to support the operation by Afilias in the operation of .info (EPP client in C++).

Furthermore, Global Name Registry owns and operates a state-of-the-art registry system that has been built in-house and designed to serve 50 million domain names and thousands of registrars. The fact that Global Name Registry worked with VeriSign to provide certain SRS services for .name to provide for additional stability and redundancy during the start-up period does not in any way make our experience less formidable than the other operators. In fact, it enhances it and provides even greater depth to our registry knowledge and SRS experience. We now have a unique familiarity with VeriSign's technical teams and systems, which will be vital in successfully transitioning the .org registry. As noted above, Global Name Registry will not rely on the incumbent for any part of the .org operation.

We fully understand that providing near real-time capabilities can be quite demanding. Internally, Global Name Registry has put in place rigorous operational procedures, change control management, and performance standards to ensure that its currently 100% operational near real-time capabilities for DNS, Whois and MX are world-class and operate safely and smoothly on the Internet, even during the crucial start-up period.

Criterion 10: VeriSign Endowment

The General Counsel's report calls into question Global Name Registry's eligibility for the VeriSign endowment, and suggests that it would "somewhat reduce the attractiveness" of our proposal (although have no effect on pricing). It is important to correct two misperceptions: (1) we have never suggested that Global Name Registry itself qualifies for the endowment, and (2) the endowment will have no impact on our ability to fulfil all of the commitments in our proposal.

With respect to eligibility, we have said that we believe the non-profit status of the .orgcentre and/or the Causeway Community Foundation will make one, or both, entities eligible for the endowment.

With respect to uses of the endowment, we have made it clear that the current business model for .org does not depend on the VeriSign endowment. Rather, revenues from .org registrations will be sufficient to support fully funded and extensive operations of the .orgcentre and the Causeway Community Foundation. The additional funds provided by the endowment would only be solicited from ICANN on a matching basis to provide additional support to our non-profit partners to provide additional resources to .org and Internet communities, such as by opening regional .orgcentres in Latin America, Africa and Asia. The matching funds basis was suggested to accord ICANN additional security and control over the appropriate uses of the endowment.

Moreover, to be entirely fair, there should be no qualitative difference between a candidate that seeks the funds on behalf of a non-profit affiliate (Global Name Registry), and one who does not seek the funds at all (e.g., NeuStar), as long as neither is dependent upon the funds for start-up or operating costs.

Conclusion

It is vital that the ICANN Board have all the information relevant to its .org decision before it. We hope that our detailed public comment will help ICANN Staff provide the Board with such a report. At a minimum, the Preliminary Report should be revised to include:

• A critical assessment of the financial stability and viability of the three top candidates - ISOC, NeuStar and Global Name Registry;
  
  
• A fuller discussion of the most important criteria, particularly respective technical experience and pricing models; and
  
  
• An acknowledgment of the shortcomings of key parts of each evaluation teams' report that results in either re-scoring these elements or invalidating scores that were based on inaccurate or incomplete information.

When this information is included in the final report, the advantages of choosing Global Name Registry, and the drawbacks of selecting another top contender, should be clear:

• Among the top three contenders identified in the report, we are unique in having a sound financial track record, while the financial problems of both ISOC and NeuStar have been documented. Given uncertainty surrounding actual delivery of the VeriSign endowment, the ICANN Board should not select an applicant, like ISOC, that is dependent upon the funds. (But it can select a candidate like Global Name Registry, whose non-profit affiliates could be eligible to use the funds to enhance existing offerings.)
  
  
• While ISOC may be doing a fine job of developing educational tools and fostering development of Internet standards, in addition to its financial problems it does not have any experience in operating a registry. Although ISOC would be the registry operator of record, it would be so far removed from the operation of the registry that little knowledge, if any, about the technical operations would reside with the operator. To mitigate its lack of registry experience, ISOC has teamed with Afilias. But Afilias, in turn, plans to subcontract its key operations to IBM and UltraDNS.
  
  
• While NeuStar has direct experience operating a registry, it too is facing financial uncertainty, as evidenced by a series of lay-offs this year. And awarding a third top-level domain to NeuStar would not be as pro-competitive as selecting Global Name Registry, which operates only one other TLD and would devote its full energy and resources to just .name and .org. Moreover, as reflected in the NCDNCH report, NeuStar does not appear to have a firm sense of what it will give back to the community, or how it will work with .org registrants to build a namespace that is attractive and meaningful. While there is a synergy in the same registry operating .name (geared to individuals) and .org (focused on communities of individuals and organizations), it is not the case with respect to ".biz and .org."
  
• Pricing is a key criterion that distinguishes us from ISOC and NeuStar. Because affordability is so important, we adopted an aggressive pricing policy of up to a 40% discount (US$4.51) based on volume and duration. In comparison, ISOC would charge a flat rate of US$6 and NeuStar would charge a flat rate of US$5.

As we have demonstrated in our .org proposal and emphasised in this comment, we believe that Global Name Registry's financial stability and established corporate structure, coupled with our vision for creating .org as the "Community Capital" and our position as one of the strongest technology providers, makes us the best choice to replace VeriSign as operator of the .org registry.