BLUEBERRY HILL COMMUNICATIONS, INC.

1. TLD String(s) Requested.

   .kids

2. Category.

   General Purpose, Restricted Content.
   
   Blueberry Hill Communications, Inc. (“Blueberry Hill”) requests the .kids TLD. The application implicitly attempts to restrict content across the TLD and targets a more restricted group of registrants. The targeted end user base, kids and their families, is very broad. Accordingly, Blueberry Hill qualifies for the general purpose category and restricted content group.

3. Sponsor, Registry Operator and Subcontractor.

   a. Sponsor. Unsponsored Application.

   b. Registry Operator. Blueberry Hill was established on November 6, 1998 under the laws of the state of California. Blueberry Hill claims to serve over 50,000 domain users in 100 countries worldwide. Operations include development, support, customer service and billing for all currently offered services (UNIX/NT Web Hosting, Dedicated Linux/UNIX/NT Servers, Name Server Host Registration and DNS Zone Access Accounts, and Domain Name Registration). Blueberry Hill claims its core capabilities to include: (1) hosting and domain registrar services, (2) web based customer service, (3) order fulfillment and billing systems and (4) technical automation and extensive up-stream systems integration. Blueberry Hill has entered into a letter of intent with Neustar, Inc. ("Neustar") and/or JVTeam, LLC (“JVTeam”) for data support.

   c. Subcontractor. JVTeam is a newly formed limited liability company, organized under the laws of the State of Delaware. JVTeam’s parent companies are Neustar and Melbourne IT, Ltd. (“Melbourne”). Melbourne was founded in 1996 as a wholly owned subsidiary of the University of Melbourne. In 1999 Melbourne became a publicly traded company listed on the Australian Stock Exchange. Melbourne's products and services include: (1) domain name registration, maintenance and related service and products, (2) advanced telecommunications services and products, (3) an incubator program and (4) research and development. Melbourne’s principal place of business is Melbourne, Australia. NeuStar was originally founded in 1996 as an independent communications industry services business unit within Lockheed Martin. NeuStar designed, built and continues to manage one of the largest databases in the world and now serves as the North American Numbering Plan Administrator. It operates the telephone numbering registry for the North American Numbering Plan as a Public numbering resource. NeuStar is also the Local Number Portability Administrator for the US and Canada, operating the routing registry, the Number Portability Administration Center Service Management System for North America. NeuStar’s principal place of business is Washington, DC.

4. Registry-Registrar Model.

   Registrars are intended to be selected by Blueberry Hill under the same criteria and process currently imposed by ICANN.

1. Summary Description of Proposal.

   Blueberry Hill proposes a gTLD for all things kids related. They project startup in the July 2001 quarter with 120,000 registrations, a peak of around 1 million registrations per month in the next three quarters, then a steady demand of 400,000 registrations per month. JVTeam is proposed as a subcontractor, with in-house development of the registry as an alternate plan. Note that no contractual agreement exists between the proposed subcontractors and Blueberry Hill.

2. Support of the Business Plan by the Technical Plan.

   Based on other proposals it seems likely that JVTeam would propose an adequate technical plan, so the following notes refer to Blueberry Hill’s in-house capabilities. Since no contract exists between Blueberry Hill and the contractor, it is unclear whether the proposed payments (still subject to negotiation) between Blueberry Hill and the contractors will support the contractor’s technical infrastructure. It is unclear what the actual commitment of JVTeam is.

   a. Total Capacity. The technical plan identifies the number and types of systems to be used in very general terms. Apparently the intent is to develop a proprietary solution using MySQL and PERL, probably on a Linux or other Unix platform. The plan does not describe how this approach specifically supports the projected 12 million domain registry. Conventional wisdom is that a PERL/MySQL platform is not well suited to a high availability, high performance application that will evolve for many years. Although the proposal alludes to the use of a clustered model for the various services, no details are given.

   b. Projected Growth Rate. The technical plan does not describe the mechanisms planned for dealing with the very rapid growth projected in the business plan other than to state that multiple machines can be used for many aspects of the system, such as database serving.

   c. Startup Period. No technical mechanisms are specifically proposed to deal with the land rush period. Note that the peak rate during the land rush period is about 2.5 times higher than steady state.

   d. Fault Tolerance. The application specifies two database servers and a mechanism for recovery in the event that one fails. DNS root servers are expected to be distributed geographically, and there is a provision for recovery of failed systems to remote servers.

   e. Security. Typical and adequate physical security mechanisms are proposed. Reasonable systems security measures are discussed, including use of SSH and SSL. The proposal is somewhat short on the details of some of the security measures, making it hard to evaluate their likely strength.

3. Summary of Relevant Experience.

   Blueberry Hill provides domain registration, web hosting services and related software products. The current domain registration interface uses Melbourne IT as a registrar. Blueberry Hill appears to have a special competence with MySQL/Perl based systems. Although certain proprietary development projects are cited as evidence of large-scale systems design experience, the projects described would seem to be much smaller than developing and operating the infrastructure for a TLD of the size projected. JVTeam’s experience would appear to be adequate.

4. Apparent Implementation Risks.

   While it is possible to build elegant, extensible systems on Perl, such systems often are very difficult to enhance. The applicant did not provide a detailed plan for the development and deployment of the Registry operation. Given that the applicant’s relevant technical experience is as an ISP and reseller of domain registration services, more concrete evidence of technical mastery of the problem would be desirable.
   
   The proposal would have been enhanced if more attention had been paid to availability and scalability issues. These are difficult to engineer in after the system is in production.

5. Available of Human, Operational and Technical Resources to Cope with Unexpected Events.

   The applicant asserts extensive in-house technical resources. No resumes are provided which would be evidence of particular competence in operating a gTLD or debugging a large scale distributed system. JVTeam appears to have adequate technical resources.

6. Advancing the State of the Art.

   The design and implementation of a new proprietary registry system might develop new approaches to solving existing problems.

7. Other Comments.

   None.

1. Applicant’s Representations.

   Blueberry Hill provides its customers hosting and domain registrar services. It serves over 50,000 domain users in 100 countries worldwide. The company currently has 20 employees. Its mission is to promote and provide a safe, healthy and secure cyberspace environment for kids while preserving the stability of and promoting competition within the Internet. The target market for .kids is any company, organization or individual that considers kids, and by association their parents, a viable audience.
   
   The revenue model is subscription based with a registry price of $500 per domain for the first quarter, $79 per contract for the next two years and $35 thereafter. The company will contribute $100 per contract during the sunrise period and $9 per contract during the remainder of phase one to charitable organizations. The registrations will be offered with a term of one to ten years. The company’s projected market share is 30 percent of all new registrations with a total of 12.66 million registrations through April 2005. Management expects an 80 percent renewal rate.

2. ICANN’s Evaluation.

   The strength of this application lies within the proposed target market with its vision of providing a place for children on the Internet. Further, this application has provided a phased marketing plan targeting specific segments of the population. The weakness of this application is that there are no restrictions on who or what can be registered on the .kids domain site. It would only take a few inappropriate sites to destroy the child-oriented nature of the TLD. Further, it is unclear whether there is a solid commitment from the subcontractor. Overall, there are other applications in this category that are stronger.

1. Number of Comments.

   6

2. Opposition to Application.

   The .kids proposal would not rely on objective criteria for categorizing content and thus the registry would be able to restrict content based on its value judgments. (The same comment was posted for other .kids proposals)

3. Substantive Comments and/or Questions.

   Other comments focused on certain generic points that any .kids proposal should address.