C30. One of ICANN's core principles is the encouragement
of competition in the provision of registration services at both the registry
and registrar levels. Promotion of that principle will be a criterion.
As one illustration of this criterion, a major purpose of the reassignment
of the .org registry is to diversify the provision of registry services
by placing the .org registry under different operation than the .com and
.net registries. Consideration will be given to the extent to which proposed
arrangements are consistent with this purpose. As another illustration,
applicants are encouraged to refrain from prohibiting non-affiliated providers
of backend services from offering their services in connection with other
applications. This section of the .org Proposal concerns the effect on
competition of the selection of a successor registry operator.
Neither The .Org Foundation nor eNom have any relationship to the current .org registry (an therefore to the current .com and .net registries) beyond the fact Verisign is a supplier, as a registry, for domain names in those TLDs to eNom, a registrar. No board members, shareholders or employees of either The .org Foundation or eNom are also board members, shareholders or employees of Verisign or any of Verisign's subsidiaries or related companies.
C31. Give your analysis of how selecting your application
would affect competition in the provision of registration services at
both the registry and registrar level.
Give your analysis of how selecting your application would affect competition in the provision of registration services at both the registry and registrar level.
Registry level:
Competition would increase at the registry level.
Price influence on registry competition.
One reason competition will increase may be due to the fact that the registration fee ($4.95) to registrars is lower than the fee for all other gTLDs and most other ccTLDs or large SLD registries. Though our analysis shows that many registrars will not pass this savings along to registrants, especially in low volumes, it may cause some registrants to give up names in other TLDs and switch to the .org TLD, it may cause them to register new names in .org instead of elsewhere.
Service influence on registry competition.
After the transition the registry will remain unrestricted. So,many registrants, for example, European non-profits who may be ineligible to register names in restricted TLDs (like .us or .biz), may choose .org instead.
Other services such as the ability to vote to help decide policy, and grant-receiving eligibility (from the matching fund) for .org registrants may also cause registrants to choose the .org TLD over the competing registries.
Likewise, real-time zone updates, may induce registrars to register names in .org because changing name server information will take place much faster. A registrant will be instantly gratified when, immediately after registering a name, it is delegated and useful.
Limited marketing may help persuade non-profits who don't have a .org domain or who have a domain at another registry, decide that the .org TLD is a more appropriate TLD for them.
Increasing Registry Service Supply influence on registry competition.
Since eNom is a new entrant to supplying TLD registry services, and is not prohibited from offering this service to other TLD registries, the competition amongst the existing suppliers such as GNR, Verisign, Afilias, and NeuLevel/NeuStar will increase and there will be a corresponding increase in the pressure to lower prices for providing this service to existing and future TLD registry managers/operators. Besides pressure to decrease the price, another outcome may be in the pressure to increase the service, such as providing real-time DNS, or switching to an EPP model, for the TLD registrants these companies ultimately serve.
Other registry services offered via RFP process.
If the Foundation decides to offer other services, it will do so via an open RFP processes whereby other 3rd parties can compete to offer the best new service at the lowest price. The contract with the initial registry service provider precludes them from offering any other registry related services to the Foundation; therefore, they will not be able to use their advantage as the initial service provider to the Foundation in any RFP competition to offer additional services. They are required to cooperate with the additional service provider to provide the additional service (e.g., to allow access to the whois database, if the new service needs such access). This process should insure that the Foundation offers the new service to the registrars (or others) at a price close to the at-cost price.
Registrar level:
Competition would increase at the registrar level.
Free Transfers influence on registrar competition.
After the transition to EPP, registrar-to-registrar transfers will be at no cost, and will not add a year to the registration period. This will remove a slight bias (by registrants) against transfer because the registrant has to spend money now to transfer versus sometime in the future. They usually wait to the last minute before expiration to transfer, which sometimes causes difficulties. Transfers are the basis for competition. Free and easy and simple transfers can only increase fair competition.
Smaller registrars near the brink financially will be more easily and cheaply able to combine and consolidate their operations so as to be more efficient and better able to compete.
The "registrar as a registry" issue.
eNom will commit to become de-accredited as a .org registrant and therefore will not be able to register names in .org as a registrar. This will help assure equal registry access to all registrars, remove a conflict of interest and minimize the slightly negative affect on competition that a registrar acting as a registry in the same TLD will provide. Nevertheless, profits obtained from the .org registry service, if any, can be used to benefit eNom as it competes with other registrars to register names in other TLDs such as .com, in much the same way as an Afilias membership benefits those registrars that are members and not the registrars that are not Afilias members. Or the Melbourne IT participation with NueStar benefits Melbourne IT. Our belief is that this advantage is slight, especially since eNom has only 3% of the market in the .com TLD. And the benefit of adding an additional, experienced, registry service provider to the competitive registry services pool outweighs this slight negative.
Additional Registry Services provides opportunity for registrars to differentiate.
The additional registry service, specifically, the polling mechanism and the self-identification mechanism, not only differentiates the .org registry from the other registries, it will also provide opportunities for registrars to differentiate among themselves by either choosing to implement the service or not. Registrants may well transfer their registration to registrars that choose to offer these additional services.
C32. State whether the applicant or any entity identified
in item C13 operates a DNS registry having more than
500,000 registered names and, if so, provide details.
No, neither entity operates a registry, though eNom is the registrar-of-record for over 1 million names in a number of TLDs and does provide DNS services for about 1.6 million host records (sub-domains under about 600,000 of the 1 million names registered).
C33. Describe in detail all affiliations, including
direct or indirect ownership and contractual arrangements (including letters
of intent) for the past, present, or future provision of registry services,
between (a) the applicant or any entity identified in item
C13 and (b) any operator of a DNS registry having more than 500,000
registered names.
Although eNom has participated in the domain name space for many years as a competitive registrar, and before that as a DNS service provider, it aspires to be a new entrant to the competition amongst TLD registry service providers. eNom has been a member of CORE since late 1999, but for the past few years has not been an active member.
eNom is not participating in any other registry (such as Afilias, which is a registrar member organization), and is not currently performing any TLD registry functions. However, in the fall of 2002, it will be performing as a registry for a few SLDs by releasing an RRP interface allowing other registrars to register names as sub domains in these selected second level domains for which eNom is the registrant.
eNom participated as a large part of the ".one" gTLD proposal submitted to ICANN in 2000. The proposed TLD was not granted.
No employees, board members, stockholders, or affiliates of eNom or the Foundation are members of ICANN's board or staff or are affiliated with any registry or other registrar. eNom has just two individual shareholders (Paul Stahura and Jim Beaver) who hold 100% of the shares of eNom via a holding company.
No employees, board members, or stockholders of eNom or the Foundation have served on the board or staff of ICANN or any of ICANN's support organizations, for example on the DNSO names council. Members of the eNom staff have participated in almost all the ICANN meetings.
eNom, as part of it's proposal to perform the registry services for the ".co" ccTLD obtained an LOI from Verisign in Nov 2001. The proposal was not ultimately accepted by the ".co" manager and a final agreement was not reached. The LOI has since expired.
C34. Intentionally omitted.
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