ICM REGISTRY, INC.

1. TLD String(s) Requested.

   .kids .xxx

2. Category.

   General Purpose. Restricted Content.
   
   ICM Registry, Inc. (“ICM Registry”) requests the .xxx and .kids TLDs as an integrated solution for improving child safety on the Internet. ICM Registry implicitly attempts to restrict content across both TLDs and targets a narrower registrant group. The targeted end user group is larger than the other applications in this group. Accordingly, ICM Registry qualifies for the general purpose category and restricted content group.

3. Sponsor, Registry Operator and Subcontractor.

   a. Sponsor. Unsponsored Application.

   b. Registry Operator. ICM Registry was incorporated under the laws of the state of Delaware on June 28, 1999, with its principal address in Toronto, Ontario, Canada. It is wholly owned by Chestermere Investments Ltd. ("CIL"). CIL is a privately held investment holding company owned and operated by the Hendeles family. ICM Registry was founded to own and operate .xxx as a for-profit, unsponsored, chartered TLD registry. ICM Registry also intends to operate .kids as a non-profit, unsponsored chartered TLD for charity. ICM Registry is run by Jason Hendeles. From 1995-1998, Mr. Hendeles acted as senior business architect and founder to several Internet and telecommunications companies, including Skyscape Communications, Inc., the National Moving Network and the Digital Broadcasting Network. Mr. Hendeles is also a founder and owner of A Technology Company, Inc., an ICANN accredited registrar. All ICANN accredited registrars will be eligible to provide registrar services if they demonstrate technical requirements. Domain name holders will deal directly with an ICANN accredited registrar rather than the registry except in certain limited circumstances. ICM Registry has reached an agreement with The .TV Corporation International ("dotTV") to provide a stable and high quality infrastructure for its registry. ICM Registry has also reached an agreement with VeriSign Global Registry Services Division ("VeriSign") to provide a data backup and escrow service should ICM Registry suffer irrecoverable data loss or financial penury. VeriSign will also provide the registry service infrastructure for the proposed .kids domain. Finally, ICM Registry has selected DMR Consulting Group Inc. ("DMR") to assist in the startup of ICM Registry and supplement a transition management team.

   c. Subcontractor. dotTV is the exclusive worldwide registry for second-level domain names in the .tv TLD through an agreement with the Country of Tuvalu. VeriSign has been the provider of .com, .net and .org domain names since 1991 when Network Solutions Inc. ("NSI") began providing the service. In August of 1999 the Network Solutions Registry began operations as a separate business unit of NSI. In June 2000, VerSign acquired NSI and renamed the Registry division, VeriSign Global Registry Services. VeriSign provides back-end domain name addressing, resolution and distribution services for ICANN registrars. VeriSign claims to be currently serving over 60 production ICANN accredited registrars and over 60 pre-production ICANN registrars. DMR claims to be a leading international provider of management consulting and information technology services to businesses and public enterprises, with more than 60 offices in the United States, Canada, Europe and Asia-Pacific. DMR claims to be known for providing integrated business and IT solutions that enable clients to improve their competitive position, market share and productivity.

4. Registry-Registrar Model.

   All ICANN accredited registrars will be eligible to provide registrar services if they demonstrate technical requirements. Domain name holders will deal directly with an ICANN accredited registrar rather than the registry except in certain limited circumstances.

1. Summary Description of Proposal.

   ICM Registry requests the .xxx and .kids domains. They claim creating both domains is an integrated solution to improving the child-safety of the Internet, providing both a kids-only area of the network and shifting clearly adult content to a readily identified part of the network. Both domains will have policies that all registrants must agree to, and policies for removing those who do not comply. The proposal contains highly detailed plans for handling pre-registrations, trademark issues, and requests for the same domain name. dotTV would run the .xxx registry, while VeriSign would run .kids.

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

   a. Total Capacity. They estimate that .xxx will grow to around 500,000 names in four years. dotTV is likely to be able to handle this volume without trouble. There appear to be no estimates on the projected size of .kids. VeriSign would handle the registry for .kids. This organization is clearly qualified.

   b. Projected Growth Rate. The growth rate for .xxx assumes a quick startup and reasonable later growth. There appear to be no estimates on the growth rate of .kids.

   c. Startup Period. The proposal includes unusually careful startup procedures to deal with trademarks and other disputes. The technical facilities specifically designed to handle startup issues seem reasonable.

   d. Fault Tolerance. For dotTV the architectural diagrams suggest reasonable redundancy in the data centers, and they offer a very wide geographic spread of registry servers and especially DNS servers. VeriSign fault tolerance is completely acceptable for the purposes of the .kids registry.

   e. Security. The discussions of security for the dotTV proposal is so limited that it is difficult to assess electronic security for .xxx. Physical security by Exodus Communications should be adequate. VeriSign security is adequate for the operation for .kids.

3. Summary of Relevant Experience.

   ICM Registry is a new company with little experience. Most technical issues will be handled by dotTV (for .xxx) and Verisign (for .kids). dotTV runs the .tv registry, which contains 100,000 names. This is the same order of magnitude as the expected traffic for .xxx. VeriSign has extensive experience operating both large and small registries.

4. Apparent Implementation Risks.

   As noted above, it is difficult to assess the security proposed for the .xxx TLD. It can be difficult to add security after a design is complete.
   
   The Content Auditing Service is new technology. Few details are provided about its operation, and it may be difficult to implement in practice.

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

   ICM believes that additional human resources will be available from its consulting company partner, DMR consulting. Incremental resources specifically for .xxx are the responsibility of dotTV. Incremental resources specifically for .kids are the responsibility of VeriSign. These organizations appear to have skilled personnel available in the event of surprises.

6. Advancing the State of the Art.

   There is an underdeveloped set of ideas on using filtering in conjunction with these domains, possibly at the DNS level.

7. Other Comments.

   The level of thinking about the startup period is impressive.

1. Applicant’s Representations.

   ICM Registry is a new entity created for the purpose of the new TLD application. Management has relevant Internet experience, including operating an ICANN-accredited registrar, computer consulting, and Internet and ICANN leadership groups. ICM Registry currently has two full-time managers, with four others from Canadian consulting firm DMR Consulting. CIL, parent of ICM Registry, had year-end revenues and net assets of $1.2 million and $33.5 million, respectively, at September 30, 1999.
   
   ICM Registry’s revenue model includes a $28 annual registration fee, name auction fees, banner advertising, intellectual property protection services, and other ancillary services. The target market for the adult-oriented TLD is existing and future adult entertainment web sites. The application states there are 300,000 adult-oriented websites.

2. ICANN’s Evaluation.

   The strengths of this application lie in its well-developed marketing strategy for the adult segment, the potentially large size of the target market, strong financial support, intellectual property expertise, and technical partnerships with leaders in the registry/registrar business. The weaknesses may be the lack of a detailed plan to ramp up employee staffing/training needs and the ability to move existing adult sites from their current position to the new adult TLD. Overall, this is a stronger application from a business perspective given its category.

1. Number of Comments.

   40

2. Support for the Application.

   The proposal helps address the problem of children having easy access to adult content on the internet.
   
   The proposal “shows a good deal of forethought as to how the internet can grow in a more logical and articulate way.”
   
   The proposal will aid in organizing content on the web and make it easier to navigate the web.
   
   The proposal will categorize content, not segregate it.

3. Opposition to Application.

   Some concern was expressed regarding Network Solutions’ involvement with the proposal.
   
   According to comments, the proposal really attempts to reap a profit from .xxx and stave off criticism by establishing .kids.
   
   The focus of the proposal is too heavily weighted toward .xxx and not enough attention is paid to .kids.
   
   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. (Same comment posted for other .kids proposals).
   
   Some commentators expressed the concern that porn and child-friendly content TLDs simply should not be awarded to the same entity. “XXX profit machines can exist exclusive of the kids sites. Why must the two be mounted on the same TLD?”