COMMERCIAL CONNECT, LLC

1. TLD String(s) Requested.

   .mall
   .shop
   .svc

2. Category.

   General Purpose, General.
   
   Commercial Connect, LLC (“Commercial Connect”) requests 3 TLDs which focus on broad commercial applications. Although not as wide open and unrestricted as the .biz TLD, the .mall, .shop and .svc TLD’s are generally unrestricted and focus primarily on a large registrant base and broad end user group. Accordingly, Commercial Connect qualifies for the general purpose category, general group.

3. Sponsor, Registry Operator and Subcontractor.

   a. Sponsor. Unsponsored Application.

   b. Registry Operator. Commercial Connect is a startup top level domain name registry formed by a partnership of Computer Analytical Systems, Inc. ("CAS") and Simon Property Group, L.P. ("Simon"). CAS d/b/a CAS-Com Internet Services, Inc. is an Internet Services Provider and CAS d/b/a CASDNS, Inc. is an accredited ICANN TLD Registrar. Simon Property Group, Inc. is the largest publicly traded retain real estate company in North America. Simon is a corporation with global geographic presence in business and commerce with unlimited technical and financial resources, and vast experience in electronic commerce and aggressive business management.

   c. Subcontractor. None.

4. Registry-Registrar Model.

   Commercial Connect intends to use ICANN accredited registrars for registration.

1. Summary Description of Proposal.

   Entry to the SLD would be restricted so that .shop would be reserved for fixed site commercial enterprises, .svc for those that deliver services and .mall for collections of shops.

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

   a. Total Capacity. The capacity of the hardware specified seems adequate to the requirements. There is less information in the proposal on the software and distributed systems aspects of handling the capacity, thus those issues are harder to judge.

   b. Projected Growth Rate. The registry is expected to grow to several million names within a small number of years.

   c. Startup Period. During the sunrise period the system will undergo capacity testing using artificial load generation. If deficiencies were uncovered they would need to be remedied within this one month period. Startup period will consist of an initial 60 day period where trademark owners may register names, followed by a 30 day test period. The expectation is that the registry will take in about 500,000 names in the first quarter of operation.

   d. Fault Tolerance. Redundancy will be provided by five geographically separated sites. Three will provide registry and name service, while two additional sites will provide name service. WAN interconnection will be physically redundant. Plan calls for using physically distributed servers. Details of maintaining consistency between servers is not provided. Similarly the details of redundant operation, failure detection and recovery are not covered in detail.

   e. Security. Security is based primarily on physical security and password restricted access to the system. The details are insufficiently specified to offer strong judgments on the likelihood of their adequacy. The proposal does not discuss logging, auditing, and ongoing security reviews of the system.

3. Summary of Relevant Experience.

   Technical experience derives from two sources. One is operation as a registrar and the other is in providing corporate IT services to a very large real estate company that owns shopping malls. The applicants technical team is currently designing systems to provide Internet connectivity and services to the tenants of its shopping malls. The registrar currently has about 30,000 names under management.

4. Apparent Implementation Risks.

   Applicants have some experience in providing reliable service and in particular services related to registrar operation. This experience would need to be scaled considerably to build a system that would handle the anticipated traffic. The applicant would need to scale by a factor of at least 10 to meet the projected name management requirements. In addition the applicant would need to develop highly reliable registry and name server capabilities.
   
   The application appears to lack a solid capacity model, with estimates of average and peak transaction rates. The initial hardware configuration is minimal considering the possibility of heavy traffic from a successful offering. The applicant would be required to scale quickly if the capacity were found to be inadequate. The proposed 30 day test period should help to mitigate risk in this area. Additional system analysis of the expected load and system capacity would benefit the design.
   
   The applicant’s technical organization would be very small initially, consisting of only two programmers and a network administrator. Using some staff from associated companies might mitigate this risk.

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

   The applicant’s technical team has two years of experience as registrar. Some experience with operating a world-wide corporate network will provide a cushion in the event of the unexpected. The plan also envisions a 30 day test period once the trademark names are in place in the system.

6. Advancing the State of the Art.

   The technical plan is straightforward. It will be unlikely to advance the state of the technical art except to the extent that a new, specialized and restricted TLD is established.

7. Other Comments.

   System will make use of the current registry protocol, but envisions extension to provide registry storage of critical registrar data.
   
   The application is very heavily weighted toward the detailed hardware requirements with relatively sparse information related to the software components and the development of any special purpose software or the integration of the system.

1. Applicant’s Representations.

   Commercial Connect is a joint venture between Simon and CAS. CAS currently provides registrar services and is an Internet service provider and has four employees. Simon has pledged all necessary financial backing for the operation of Commercial Connect. Simon had cash and cash equivalent of $143 million at June 30, 2000. Simon had cash and cash equivalents of $143 million at June 30, 2000.
   
   The subscription-based revenue model includes a $6 annual registration fee. Commercial Connect will not provide registrar services but will utilize existing ICANN accredited registrars. The target market for the proposed TLDs is all e-commerce companies currently doing business on the web, and all other retail product and service providers looking to enter the Internet sales market.

2. ICANN’s Evaluation.

   The strengths of this application lie in the financial backing of one joint venture partner and the registry experience of the other partner. The application does discuss some high-level marketing and market acceptance issues, but it does not include a quantitative analysis of the target market, nor a detailed marketing plan. Another weaknesses is that there is minimal support for market penetration. Overall, this application is not as strong as other applications in its category from a business perspective.

1. Number of Comments.

   23

2. Support for the Application.

   “.Shop” will help alleviate some of the limitations of the .com TLD.
   
   It would be “ideal,” as one comment put it, to have e-commerce sites grouped under a single TLD.
   
   Another comment expressed support for CASDNS and its management team.

3. Opposition to Application.

   One commentator wrote that the application lacks “concrete information” and specified in some detail other technical defects in the application.