.org Reassignment: Commentary of the Internet Society on Final Evaluation Report

1 October 2002

ISOC Commentary on the Final ICANN Staff Evaluation Report
Regarding the .org Re-delegation
October 1, 2002

Members of the ICANN Board of Directors:

The Internet Society (ISOC) would like to thank the ICANN staff and the evaluation teams for the diligence they have shown throughout the review process. Their fair and impartial evaluations, based on the requirements set forth in the RFP, resulted in a clear recommendation.

We support the final staff evaluation report and its recommendation "that the Board reassign the .org registry to ISOC." The staff obviously believes, as we do, that ISOC's non-commercial heritage, global presence, and Internet knowledge, coupled with Afilias' technical expertise, will significantly strengthen .ORG, enabling it to deliver greater value and better performance to registrants. We believe that the plan detailed in our proposal and further explained in our responses to the Supplemental Questions merit the staff's final recommendation.

Should the ICANN Board select our proposal, we will be ready to assume responsibility for this important top-level domain when VeriSign's contract expires. The Public Interest Registry (PIR) – the proposed organization that ISOC intends to run the registry – is now being formed; and the ISOC Board is in the final stages of appointing the PIR Board. The final announcement is expected within the coming week. Afilias has begun preparations to tap its existing capacity and integrate the .ORG domain into its back-end operations. With ICANN contract negotiations completed as envisioned by October 23, and VeriSign's expected cooperation; we anticipate a smooth and timely transition process.

To assist the ICANN Board in the final decision, our comments will focus on the 11 criteria set forth in the RFP. We believe that our proposal (including the answers to the Supplemental Questions) meets or exceeds each of these criteria, provides the most balanced and realistic plan, and as such makes PIR a natural choice for the next registry operator.

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Criterion 1: Need to preserve a stable, well functioning .ORG registry

The ISOC proposal ensures the preservation of a stable, well functioning registry because it rests on two proven pillars. The first is our heritage in Internet policy and our responsible stewardship in matters dealing with the welfare of the Internet. The second is Afilias' track record of operating a large-scale registry in a responsible, stable, and reliable manner.

Policy – ISOC has a history of dedication to the Internet and has been a non--profit corporation working in the public interest for over ten years. ISOC's mission is "to assure the open development, evolution and use of the Internet for the benefit of all people throughout the world." We are the organizational home of the Internet Engineering Task Force (IETF) and other Internet related bodies, and we have a global constituency that provides a deep understanding of the policy and management issues facing TLDs across the globe. ISOC is especially well versed in the impact of the Internet on the underdeveloped, underserved, and non-commercial segments—key communities for .ORG.
Should the Board select our proposal, PIR will oversee the management of the domain. PIR will participate in ISOC's extended global network to facilitate policy and management decisions. PIR's Board of Directors will be appointed by ISOC, and its policies will be derived from ISOC's principles.

Operations – PIR's back-end service provider, Afilias, will bring stable and proven technology to .ORG. Afilias has extensive experience running an EPP-based registry, having launched .INFO. .INFO is the clear leader among the new gTLDs, with close to one million registrations as well as the most live, unique Web sites. Over the past fourteen months, Afilias has compiled a record of consistency, speed of delivery, dependable infrastructure, and well thought-out transition plans – key skills that are required to preserve the stability of .ORG during and after its transition.

Afilias' registry services are among the most stable, reliable and fast in the industry. Afilias leads NeuStar in three key areas for a stable and well-functioning registry: Speed, Availability and Update Frequency. Highlights from the performance summary are:

Afilias' speed of delivery yields faster "registration to resolution" service than NeuStar, as shown in research conducted since the proposal was submitted on June 18. Test names were registered in .INFO and .BIZ domains, and "time to resolution" was measured by checking how long it took before the name was available at all gTLD root servers. Afilias' .INFO domain names were available about two minutes after being registered at a registrar, over thrice as fast as the NeuStar-operated .BIZ domain. The results are shown below:

Sustaining the high-availability infrastructure that delivers this performance is one of the most advanced open source relational database systems, PostgreSQL. As detailed in our answer to Question 13, PostgreSQL already fully supports a 24x7, high-transaction, registry system:

1) it has scaled with .INFO from zero to nearly one million domains via its large capacity and its concurrency capability (multi-version concurrency control);

2) it provides all database functions required by .INFO (and .ORG);

3) it delivers (as evidenced above) at our service level commitments or better;

4) it benefits from broad usage (RedHat, BASF, and others) and support by a significant base of developers; and

5) it provides high data portability and standards compliance, including native JDBC/ODBC support.

Some questions were raised regarding Afilias' use of the PostgreSQL database software. Our examination of .INFO operations has shown the database's ability to successfully scale, replicate, mirror, cluster, perform application processing, and support on-line/off-line maintenance. Afilias has performed intensive load, scalability, transaction, and performance tests on its PostgreSQL database, with clear and successful results – in fact, this database has been tested to more than 5 million domain names, with sustained and heavy transaction loads, with no negative impact on performance or scalability. However, we have addressed below the questions raised in the Gartner report:

1) Gartner: "The potential difficulty of transitioning from the Oracle database used by VeriSign"

Answer: Since VeriSign currently operates a thin registry, the amount of data per name that needs to be ported is quite modest. To migrate this data, we will work with VeriSign to obtain Oracle output in a widely accepted file format (e.g. CSV, pipe-delimited, etc). Our conversion system can readily accept data in these common formats and communicates directly with PostgreSQL to insert the data. In addition, PostgreSQL has portability tools to migrate Oracle-based data.

2) Gartner: "The fact that the .ORG Registry will be the largest mission critical deployment of PostgreSQL."

Answer: As detailed in our answer to Question 13, many other organizations (including BASF, the American Chemical Society and Onvia) rely on PostgreSQL for mission critical applications. Afilias' experience ramping up .INFO to one million names coupled with their successful testing of loads well in excess of anticipated .ORG demands provide us with confidence that we can manage .ORG with the stability required.

3) Gartner: "Regarding potential issues of support as the unique demands of the .ORG registry potentially evolve PostgreSQL away from mainstream users"

Answer: Although unlikely in our judgment, it is possible that .ORG demands may require unique database modifications. As an active participant in the open source movement, Afilias will constantly monitor the evolution of both the registry and the Postgres community. Any truly unique database requirements would trigger a review of alternate solutions. Fortunately, not only do we have PostgreSQL's source code, but its data portability and standards compliance would facilitate a migration, should one be needed. Our response to Question 13 outlined such a migration plan.

We believe, as does Gartner, that the potential risk in these areas is very manageable, and we will, as any responsible registry operator would, perform the monitoring suggested.

Beyond the database, Afilias' infrastructure also includes world-class components such as services from IBM and UltraDNS, and a staff that is skilled and experienced in both data migration and ongoing operations.

Several other features of our plan deserve mention:

• Our transition plan features a unique RRP-to-EPP proxy service to ease the transition for registrars and ensure continuous service.
• Afilias has existing relationships with registrars accounting for over 99% of current .ORG registrations, providing a further measure of stability.

Our service level commitments rank at the top of the applicants – and Afilias' actual .INFO performance backs it up.

In sum, ISOC's history and leadership in the development of responsible global Internet policy combined with Afilias' excellent service and existing, scalable, infrastructure ensures that PIR will be well equipped to run a stable, well functioning .ORG registry.

Criterion 2: Ability to comply with ICANN-developed policies

ISOC has always shown itself to be responsible and to take appropriate decisions regarding the welfare of the Internet and this will be a hallmark of PIR as well. Afilias has been and will remain committed to complying with ICANN developed policies.

ISOC's knowledge of and experience in Internet policy will help guide PIR's Board and management as well as set its principles. ISOC has demonstrated support for ICANN policies in the past and we are sure this will continue.

Afilias has demonstrated compliance with ICANN policies by:

• implementing the first-ever Sunrise period which protected thousands of trademark holders;
• successfully managing the unique "sunrise challenge" process;
• conducting an equitable Land Rush 2 process, which returned over 17,000 inappropriately registered sunrise names to the public;
• immediately executing ICANN Resolution 01.92 regarding the reservation of country names in .INFO;
• implementing proven mechanisms to ensure equivalent access to the registry;
• adhering to the UDRP process;
• complying with WHOIS data access requirements, and so on.

In addition, Afilias is deeply involved in the development of various ICANN policies, including:

• helping write the Redemption Grace Period policy for domain names;
• formulating policy for WHOIS data accuracy, consistency, uniformity and access;
• creating policy for domain name transfers; and
• devising plans for validated transfers of domain names using EPP Authorization codes

Afilias' staff is involved in various key policy-making bodies, including the:

• DNS Security and Stability Committee;
• DNSO WHOIS Task Force (gTLD registry representative);
• DNSO Deletes Issues Working Group;
• DNSO Transfers Task Force (consultancy);
• IETF Provreg Working Group; and
• DNSO gTLD Registry Constituency.

ICANN's General Counsel, in the final report, noted that Afilias has consistently demonstrated its ability to comply with ICANN-developed policies.

In addition, Afilias employs a Compliance Officer whose responsibilities include ensuring that the registry provides equivalent access to registrars, monitoring potential conflicts of interest, OCI (Organizational Conflict of Interest) training, and confidentiality training.

In summary, both ISOC and Afilias are committed to complying with ICANN developed policies.

Criterion 3: Enhancement of competition for registration services

Awarding the .ORG registry to ISOC will enhance competition for registration services in three respects:

1. A new registry – the Public Interest Registry – will be created, adding another gTLD registry company to the existing eight.
2. A stronger back-end provider – Providing back-end services for .ORG will add to Afilias' 3% market share, making it a more credible registry competitor.
3. A stronger domain – ISOC's proposal will effectively differentiate .ORG, enabling it to flourish through its provision of superior products and services and, we believe, will help set the standard for other registries.

As our proposal states, PIR will be a legal entity separate from ISOC. PIR will negotiate the registry management agreement with ICANN, will carry out the registry functions, and will be a self-sufficient organization with no financial dependence on ISOC. Afilias will provide interim financing. Our plans for formalizing PIR are nearly complete, including seating the Board, and we will be prepared to complete negotiations with ICANN in the timeframe allotted, should the ICANN Board approve our proposal.

ISOC itself is a strong organization that will be a positive steward for PIR and .ORG. As a non-profit, member-funded organization, ISOC deals with the same challenges and variables that most non-profits face from time to time. ISOC has made various moves recently that have significantly strengthened our financial footing, enabling us to steadily improve over the last two years and gaining us thousands of new members. Over the ten years of our incorporated existence, ISOC has weathered a number of challenges and always emerges a stronger and more productive organization.

Afilias will become stronger as well. Through its arrangement with ISOC (and ultimately, PIR), Afilias will leverage a higher percentage of its existing capacity, enabling it to operate more efficiently. This, in turn, will provide Afilias with the resources needed to more effectively compete with other providers (including NeuStar, which, when .US is added, has more names in its registries than Afilias), thus enhancing competition.

Most importantly, .ORG itself will gain strength behind the marketing plan in our proposal. This plan distinguishes .ORG as the Internet home of non-commercial organizations by focusing on educating and evangelizing .ORG and instituting programs in the likeness of ISOC's current training activities.

In summary, ISOC's proposal enhances competition by introducing a new player, strengthening a growing provider, and investing in the .ORG brand.

Criterion 4: Differentiation of the .ORG TLD

To differentiate .ORG and drive growth of the domain, we have proposed an integrated marketing and public relations program that will create a sustainable competitive advantage for .ORG. It will help .ORG achieve its potential as the home for non-commercial entities on the Internet, while respecting its legacy as an open and unrestricted TLD.

Based on our market research, we have developed a program that combines: 1) public relations activities that educate non-commercial organizations; and 2) global sales and marketing support for the distribution channel (registrars and resellers).

This is similar to the approach used by Afilias to develop .INFO: first to generate registrations (now nearly 1 million); then to stimulate deployment of live sites (over 250,000); and finally to encourage use of .INFO addresses by registrants in their advertising (e.g. mta.info in New York). In fact, research shows that .INFO has close to 67% active sites (nearly 40% of which appear to be unique to .INFO), while .COM and .BIZ have approximately 65% and 59% respectively.

The education component of PIR's proposal will create a sustainable competitive advantage for .ORG by establishing a clear and compelling positioning that leverages both ISOC and .ORG's noncommercial heritage, and sets .ORG apart from other TLDs. ISOC's long history of running effective training programs will be used to its full advantage to support the .ORG community.

The sales and marketing component focuses on registrars. The program is specifically designed to expand .ORG globally, as close to 70% of current .ORG registrations are in the US. Our proposed channel programs, including the .ORG Marketing Fund, will improve the penetration of .ORG among non-commercial entities and market the domain in a responsible and appropriate manner. Our partner Afilias has effectively run such programs for .INFO.

Our proposal also details our intent to minimize speculative or defensive registrations by focusing our outreach on a limited target: non-commercial entities not yet on the Internet.

Moreover, we have proposed a wide array of innovative registry services (both free and low-cost). These include an .ORG directory, ORGRing linking to related sites, ORGWatch domain monitoring, ORGLock hijacking protection, and privacy protection products.

Through the proposed education and marketing activities and the addition of new services, we believe PIR will differentiate the .ORG TLD in an effective and highly responsible manner.

Criterion 5: Inclusion of mechanisms for promoting the registry's operation in a manner that is responsive to the needs, concerns, and views of the non-commercial Internet user community.

We believe strongly that the voice of the non-commercial community is critical to the long-term success of .ORG. ISOC's global membership and heritage and PIR's non-profit status will ensure the registry remains sensitive to non-commercial concerns. Should the ICANN Board select ISOC's proposal, PIR will execute extensive plans to ensure that this voice is heard. These include:

• The .ORG Advisory Council, which will serve as an ombudsman-type resource for management as it seeks to incorporate community input for important decisions. The Council will be made up of leadership from the broad spectrum of the non-commercial world.
  
  
• Web-based input mechanisms, including polling, discussion forums, and more, which will both help keep the community informed and provide it a means of commenting on initiatives.
  
  
• PIR's marketing program, which incorporates "good works" such as non-profit outreach programs, will provide education and training on how to better leverage the Internet. In some cases, PIR will adapt ISOC's proven workshop programs, enabling PIR's outreach to commence without a lengthy startup period. Some of these existing programs are detailed in our bid.

ISOC's global membership encompasses a broad, diverse, and international constituency. This is illustrated by its 10,000 individual members, who are distributed around the world as follows: 33% Europe; 35% North America; 17% Asia-Pacific; and 15% from Africa, Latin America, and elsewhere. ISOC's chapters, organizational members, and board are also broadly distributed.

In summary, through its ISOC roots, PIR will have the benefit of established and well-recognized mechanisms for responding to and supporting non-commercial Internet users, and intends to properly fund these mechanisms as set forth in our proposal. These mechanisms will be supplemented with a special .ORG Advisory Council, Web-based input mechanisms for interested parties, and an open and inclusive approach. Our proposal has also received broad support from .ORG registrants and organizations (See Criterion 6 below).

Criterion 6: Level of support for the proposal from .org registrants.

ISOC has received more than 600 letters of support, from 85 countries – global representation unmatched by any other bidder. ISOC was the only bidder to be awarded a "high" geographic diversity score in the NCDNHC evaluation report.

While many of the support letters come from ISOC members, more than a third have also come from non-ISOC associations, institutions, and individual .ORG registrants from around the globe, such as those from the Research Libraries Group, EDUCAUSE and INSEAD. Since filing our proposal we have also received support from many .ORG registrants such as The British Computer Society (www.bcs.org).

As the NCDNHC report correctly pointed out, ISOC's endorsement letters supported ISOC as a bidder and the ISOC proposal in its entirety rather than isolated portions of it.

Criterion 7: The type, quality, and cost of the registry services proposed.

PIR will provide high-quality, reasonably priced services to both .ORG registrants and registrars. Once transitioned, .ORG will operate as a "thick" registry based on EPP, providing all of the core registry functions needed to support a TLD consistent with ICANN requirements.

Afilias registry services performance has been demonstrated to be superior to that of many other providers (See Criterion 1 above).

In addition to excellent delivery of core registry services, PIR plans to strengthen .ORG by introducing many enhanced services designed exclusively for non-commercial organizations. These include:

• ORGWatch: Allows monitoring of a .ORG domain name, or a keyword and the domains associated with the keywords.
• ORGLock: Provides registrants with the ability to prevent modifications, transfers, or deletions of domain names without their explicit permission.
• ORGSearch: Allows organizations to submit their sites to a wide variety of search engines and can be jointly marketed through the registrar channel.
• ORGCloak: Offered in conjunction with registrars, it allows organizations to protect portions of their WHOIS information from the general public.
• ORGSure: A certification service to be provided in conjunction with registrars, for registered non-commercial organizations, so that they can display an "official .ORG site" logo and be listed for free in an official .ORG directory.

PIR will also maintain the current .ORG registration price at US$6.00, which has proven affordable to existing .ORG registrants. Further, we believe that a lower price at the registry level would not be reflected in the retail price.

• While .INFO, .BIZ, and .NAME domain names cost registrars less than .COM, .NET, and .ORG domain names, many registrars offer all of these TLDs for the same retail (per-year) price.
• In fact, some registrars offer the cheaper .INFO, .BIZ, and .NAME domains for HIGHER retail prices than .COM, .NET, and .ORG registrations.
• Registrars currently offer .COM, .NET, and .ORG domain names at retail prices ranging from about US$8.00 to US$35.00 per year – a wide range. The existence of sub-$10 registration places .ORG within the reach of every non-commercial organization.

With more than 150 ICANN-approved registrars in existence, market forces will continue to ensure that any organization that wants a .ORG name will be able to afford it.

In sum, we have proposed to improve core services and add new services while maintaining .ORG's base price at US$6. This will add value, especially for non-commercial registrants.

Criterion 8: Ability and commitment to support, function in, and adapt protocol changes in the shared registry system.

ISOC itself is involved in the standards-setting process and provides the organizational home for standards setting efforts. Afilias has significant experience with the new EPP protocol and is an active participant in the various industry groups that determine the evolution of standards. Both ISOC and Afilias share a commitment to open standards. PIR's policies with respect to this issue will be guided by ISOC's mission, which is "to assure the open development, evolution, and use of the Internet for the benefit of all people throughout the world."

This commitment is illustrated by plans in our proposal to: 1) improve the speed, reliability, and security of .ORG's DNS services; and 2) launch .ORG with the most recent and current version of EPP.

In addition, Afilias has recently launched an open EPP sandbox to help registrars migrate to EPP. This sandbox supports EPP v.2, .4, and .6, and will be upgraded as new versions are proposed.

As leaders in their respective areas, both ISOC and Afilias share a commitment and the ability to support, function in and adapt to protocol changes in the shared registry system.

Criterion 9: Transition Considerations

ISOC's proposal outlines a competent and stable transition plan that will ensure a smooth migration from VeriSign. It taps Afilias' existing capacity and uses a unique concept to ease the changeover.

ISOC's proposed transition plan features a unique RRP-to-EPP proxy service that will limit downtime and the effect of the transition on registrars. This service would act as a temporary interface for the completion of the migration. The proxy service would be phased out in favor of direct EPP connectivity following the migration of the registry, while allowing adequate time for registrars to transition their current .ORG customer data into a system compatible with Afilias' EPP registry.

Afilias has demonstrated experience in technical support, registrar problem resolution and registrar outreach – including a trouble free launch and execution of the LandRush 2 program in July 2002.

This plan, coupled with Afilias' close relationships with registrars responsible for over 99% of .ORG registrations, prompted Gartner to laud our plan as "very well thought out" with a "good set of metrics for ICANN to evaluate transition."

Our proposal, relying on Afilias' expertise, has outlined a realistic transition plan that will ensure the smooth and stable transition of the .ORG registry.

Criterion 10: Ability to meet and commitment to comply with the qualification and use requirements of the VeriSign endowment and proposed use of the endowment.

ISOC is both able and fully committed to complying with the requirements of the endowment, as noted in the General Counsel's report. While the endowment is not required for PIR to successfully transition .ORG, it will accelerate PIR's reinvigoration of the domain.

ISOC has proposed that the endowment be dedicated primarily to expanding PIR's outreach to non-commercial organizations. This includes extending the development and deployment of workshop programs, ensuring the reliability of core SRS services, and accelerating the availability of the new services mentioned in Criterion 7 above.

These workshop programs will include expanded and tailored versions of the proven ISOC-modeled workshops, Internet Fiestas, and conferences. To build awareness, we would enlarge core education, marketing and PR activities to reach more non-commercials sooner.

In addition, we would invest a portion of the endowment in accelerating the availability of new .ORG services (mentioned above) designed to help organizations develop their visibility, give donors peace of mind, and connect people to communities. While these products are part of the ongoing plan, endowment funds would provide immediate resources to initiate development and get these into the market more quickly.

These efforts have the dual benefits of helping these organizations better utilize the Internet and more fully support their own missions. And, they will address the goals of the endowment, since: 1) PIR will be a non-profit organization; and 2) these activities are future operating costs of the registry.

In sum, while receipt of the endowment is not necessary to support PIR's assumption of responsibility for .ORG, it would help expand PIR's outreach to the non-commercial community and introduce new services faster.

Criterion 11: The completeness of the proposals submitted and the extent to which they demonstrate realistic plans and sound analysis.

We believe that the plans outlined in our proposal are realistic and sound, and we stand ready to execute.

If ISOC's bid is chosen, the Public Interest Registry (PIR) will manage the .ORG registry. ISOC is in the process of establishing PIR as a non-profit company. The ISOC Board has the responsibility of appointing the PIR Board. PIR's board will have seven seats, with the members serving staggered terms. ISOC has publicly called for nominations to PIR's board, and expects to finalize the Board in the coming week. We fully expect this to be finished in time to complete contract negotiations with ICANN by the 23rd of October.

With regard to the ICANN staff report concerning structural separation between ISOC and PIR, ISOC has initiated the process of incorporating as a non-profit corporation in the United States in the state of Pennsylvania and intends to fully comply with Title 15 Pa.C.S.5551 and other applicable laws.

In addition to the Board, PIR will have an Advisory Council composed of leaders from key non-commercial groups from across the world to provide advice to .ORG management on policy and other issues, as well as to ensure a vehicle for broad participation from the non-commercial community. We feel the task of constituting this council is best left to PIR's board, and hence will not address it at this time. It will be, however, one of their most important priorities.

Regarding back-end registry operations, Afilias currently supports most of .ORG's registrars, and has existing capacity to operate .ORG today. Afilias has made significant progress developing its proprietary RRP-to-EPP proxy service to ensure readiness, our bid be selected.

ISOC and Afilias have already begun designing more meticulous project plans, detailing many of the tasks required to cut-over the registry by the deadline.

We are confident in our ability to work closely with ICANN to complete contract negotiations, and with VeriSign Registry (VGRS) to manage the data migration and transition tasks. We fully anticipate that ICANN and VGRS will cooperate in providing us information on, among other areas: registry data, zone file publication, nameservers, open .ORG trouble tickets, ongoing .ORG domain disputes, services the VeriSign registry currently offers to .ORG registrants and registrars and the attendant contracts.

We feel strongly that our proposal is complete and provides a realistic plan.

* * *

In conclusion, ISOC is honored to be recommended and we believe our proposal meets or exceeds all of the criteria set forth by the Board in the RFP. We believe our proposal provides a competent and realistic transition plan that will result in a stable migration for .ORG, as well as a stable long term management that delivers superior value to registrants.

While we are highly energized and ready to start immediately, we understand the challenge implicit in the redelegation of a domain of the size and importance of .ORG. Of all the gTLDs, .ORG carries the largest commitment to the public trust, and the closest kinship with the registrant base. If selected, we will undertake this challenge responsibly and dedicate ourselves fully to the successful transition.

Thank you again for the confidence you have shown in ISOC and Afilias.

Sincerely,

Lynn St. Amour
President & CEO
The Internet Society

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