|
Section VI Enhancement Of Competition
Executive Summary
ICANN has succeeded in introducing competition in the registrar market.
However, in the gTLD registry space, VeriSign still maintains a 95% market
share, with .ORG declining under its stewardship. While competition is
important, stability is paramount. To guarantee a stable and smooth transition,
the new .ORG registry operator must have demonstrated experience maintaining
a shared registry system containing at least 500,000 domain names under
management. ISOC believes that Afilias is the optimal registry infrastructure
provider to guarantee stability, while simultaneously enhancing competition
in the registry marketplace. Further, the ISOC proposal provides competitive
marketing for .ORG to restore its vitality.
Overview: ISOC applauds and supports ICANN's efforts to diversify
the provision of registry services by selecting a new registry operator
for the .ORG TLD. ISOC and PIR believe that this objective is consistent
with the policy statements made by the U.S. Department of Commerce in
its 1998 White Paper, "Management of Internet Names and Addresses."
Specifically, the U.S. government's position was that "competitive
systems generally result in greater innovation, consumer choice, and satisfaction
in the long run" and that the "pressure of competition is likely
to be the most effective means of discouraging registries from acting
monopolistically." (See Docket Number 980212036-8146-02; http://www.ntia.doc.gov/ntiahome/domainname/6_5_98dns.htm)
To date, ICANN has succeeded in introducing meaningful competition in
the registrar marketplace. Whereas less than three years ago VeriSign,
formerly Network Solutions Inc., sponsored 100% of the domain names registered
in the generic top-level domains, now VeriSign sponsors less than 36%.
Figure 56
Source: SnapNames State of the Domain April 2002
However, despite the introduction of competitive registry services as
part of the ICANN TLD proof of concept, VeriSign still dominates gTLD
registry services, holding a 95% market share.
Figure 57
Source SnapNames State of the Domain April 2002
Back to top
C30. Instructions
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.
Back to top
C31. Analysis of the Effect
on Competition
Give your analysis of how selecting your application
would effect competition in the provision of registration services at
both the registry and registrar level.
|
A. Enhancement of
Competition Registry Level
When ISOC began evaluating the opportunities associated with becoming
the registry operator of the .ORG TLD, it understood the necessity
to balance the needs of increasing competition at the registry level
while maintaining the stability of the .ORG registry for the benefit
of the MORE THAN two million registrants. Based upon the importance
that the ICANN Board placed on operational stability during its
recent meeting in Accra, ISOC realized that it would need to partner
with an established back-end registry infrastructure provider in
order to maximize its opportunity to become the .ORG registry operator.
ISOC believes that the 500,000-domain name benchmark referenced
in C32 provides an excellent measurement for the ability of a registry
operator to guarantee a stable transition from the current registry
operator. To identify a suitable back-end registry infrastructure
to partner with, ISOC identified those TLDs with over 500,000 domain
names under management:
Figure 58
Registries With Over 500,000 Names Under
Management
Then ISOC analyzed the following factors for each of the above
registry operators: 1) whether each shared registry system was established
and robust, 2) the registry protocol each uses, and 3) each registry
operator's relationship with ICANN-accredited registrars. The chart
below summarizes some of the factors considered in our evaluation
process.
Figure 59
Evaluation Factors
After balancing the needs of increasing competition
at the registry level while maintaining the stability of the .ORG
registry, ISOC felt that Afilias was uniquely qualified to provide
the registry infrastructure in its bid for the .ORG re-delegation.
As the registry operator for .INFO, the first and
most popular of the seven proof-of-concept registry operators selected
by ICANN, Afilias currently has over 805,000 domain names under
management. In addition to .INFO, Afilias provides registry services
to support the .VC (St. Vincent and the Grenadines) ccTLD and is
an affiliate of AusRegistry Pty. Ltd., the registry operator for
the COM.AU, NET.AU, ASN.AU, ID.AU, and ORG.AU second-level domains.
Afilias has a diverse multinational presence (offices
in Ireland, the United States, Canada, and the UK) and has demonstrated
the ability to resolve complex policy issues (.INFO country names
and inappropriately registered Sunrise names). It has a stable EPP
registry implementation that is capable of supporting a RRP protocol
during transition as required by the ICANN contract; and has demonstrated
experience in transitioning a TLD between registry operators.
Afilias has also successfully demonstrated a robust
EPP protocol that has processed over 20,000 intra-registrar transfers.
In enhancing competition at the registrar level, it is critical
that a registry be able to support domain name portability between
registrars. This level of domain name portability is unmatched in
any of the other proof of concept registry providers to date.
Another factor in ISOC's selection of Afilias is that
it strengthens a currently small but promising back-end registry
services provider ensuring the continued availability of a realistic
alternative to VeriSign. Although ICANN succeeded in introducing
competition into the marketplace by accrediting a large number of
registrars, market conditions suggest that are likely to be far
fewer viable registry infrastructure providers. ISOC believes that
given this reality, competition and stability is best served at
the registry level by selecting a small but established registry
service provider with an proven record of maintaining over a half
a million names, as opposed to supporting a registry infrastructure
provider with less proven accomplishments.
Back to top
B. Enhancement
of Competition Registrar Level
Given the need to provide a stable
transition for .ORG registrants, the following statistics reinforce
the likelihood that Afilias will be able to provide registrars with
a seamless transition for their registrants.
Out of the 102 registrars authorized by VeriSign to provide .COM,
.ORG, and .NET registrations, the great majority are already Afilias-authorized,
which means they have passed Afilias' rigorous operational testing
and engineering (OT&E) process and have proved their ability
to use the EPP protocol. More importantly, over 99.2 percent
of the current .ORG domain names are sponsored by a registrar that
is already Afilias-authorized. The overwhelming majority of .ORG
names are with registrars who are already using Afilias' EPP system
on a day-to-day basis.
Figure 60
Registrars Market Share in .ORG vs.
Afilias Authorization
REGISTRAR
|
Country
|
Market Share
|
.ORG Registrations
|
Afilias Auth
|
000Domains.com
|
US
|
0.000425
|
10
|
Yes
|
007Names, Inc.
|
US
|
0.006291
|
148
|
Yes
|
123 Registration,
Inc.
|
US
|
0.013985
|
329
|
Yes
|
1 eNameCo
|
US
|
0.094327
|
2219
|
Yes
|
1dni.com
|
US
|
0.002295
|
54
|
Yes
|
1st Domain.net, division
of G+D International
|
US
|
0.058195
|
1369
|
Yes
|
4Domains.com
|
US
|
0.014538
|
342
|
Yes
|
A Technology Company, Inc.
|
Canada
|
0.002806
|
66
|
No
|
Active ISP ASA
|
Norway
|
0.175859
|
4137
|
Yes
|
Address Creation
|
US
|
0.020957
|
493
|
Yes
|
aitdomains.com
|
US
|
0.329741
|
7757
|
Yes
|
Alice's Registry, Inc.
|
US
|
0.000468
|
11
|
Yes
|
Alldomains.com, Inc.
|
US
|
0.261727
|
6157
|
Yes
|
America Online,
Inc.
|
US
|
0.040298
|
948
|
No
|
Ascio Technologies, Inc.
|
Denmark
|
0.372972
|
8774
|
Yes
|
ATLNTD.com
|
Russia
|
0
|
0
|
No
|
AWRegistry
|
US
|
0.121575
|
2860
|
Yes
|
BB Online UK Ltd.
|
UK
|
0.037918
|
892
|
Yes
|
BookMyName SAS
|
France
|
0.02338
|
550
|
Yes
|
BulkRegister.com,
Inc.
|
US
|
4.691652
|
110369
|
Yes
|
CORE - Council of Internet
Registrars
|
Switzerland
|
2.350183
|
55287
|
Yes
|
Capital Networks Pty.
Ltd.
|
Australia
|
0.111671
|
2627
|
Yes
|
Catalog.com, Inc.
|
US
|
0.112988
|
2658
|
Yes
|
Computer Data Networks
|
Kuwait
|
0.005824
|
137
|
No
|
Corporate Domains, Inc.
|
US
|
0.005994
|
141
|
Yes
|
Cronon AG
|
Germany
|
0.230483
|
5422
|
Yes
|
Deutsche Telekom,
AG
|
Germany
|
0.015771
|
371
|
No
|
DirectI.com
|
India
|
0.034092
|
802
|
Yes
|
directNIC
|
US
|
1.451122
|
34137
|
Yes
|
Domain Bank, Inc.
|
US
|
0.663307
|
15604
|
Yes
|
Domain Registration
Services, Inc
|
US
|
0.168547
|
3965
|
Yes
|
DomainCity.com
|
Korea
|
0
|
0
|
No
|
domaindiscount24.com
|
Germany
|
0.065974
|
1552
|
Yes
|
DomainDiscover
|
US
|
1.371588
|
32266
|
Yes
|
Domaininfo.com
|
Sweden
|
0.134285
|
3159
|
Yes
|
DomainPeople, Inc.
|
Canada
|
0.430061
|
10117
|
Yes
|
DomainRegistry.com,
Inc.
|
US
|
0.056197
|
1322
|
Yes
|
DomainSite.com, Inc.
|
US
|
0.081447
|
1916
|
No
|
DomainZoo.com, Inc.
|
US
|
0.052498
|
1235
|
Yes
|
doregi.com
|
Korea
|
0.132925
|
3127
|
Yes
|
DotRegistrar.com
|
US
|
1.08933
|
25626
|
Yes
|
Dotster, Inc.
|
US
|
2.065587
|
48592
|
Yes
|
Eastern Communications
Co., Ltd.
|
China
|
0.003613
|
85
|
No
|
EasySpace, Ltd.
|
UK
|
0.761545
|
17915
|
Yes
|
EnetRegistry.com
Corp.
|
US
|
0.002125
|
50
|
No
|
eNom, Inc.
|
US
|
2.337983
|
55000
|
Yes
|
EPAG, Enter-Price Multimedia
AG
|
Germany
|
0.40073
|
9427
|
Yes
|
GK Group LLC
|
US
|
0.3365
|
7916
|
No
|
Gabia, Inc.
|
Korea
|
0.173861
|
4090
|
Yes
|
Gandi
|
France
|
1.835317
|
43175
|
Yes
|
Global Media
Online, Inc.
|
Japan
|
0.303513
|
7140
|
Yes
|
Globedom
|
Austria
|
0.013603
|
320
|
Yes
|
Go Daddy Software, Inc.
|
US
|
2.984754
|
70215
|
Yes
|
IA Registry
|
US
|
0.164296
|
3865
|
No
|
I.D.R. Internet Domain
Registry, Ltd.
|
Israel
|
0.005016
|
118
|
Yes
|
InterAccess Company
|
US
|
0.016153
|
380
|
No
|
Interactive Telecom
Network, Inc.
|
US
|
0.001105
|
26
|
No
|
Interdomain SA
|
Spain
|
0.084252
|
1982
|
Yes
|
Internet Names
WorldWide
|
Australia
|
4.947385
|
116385
|
Yes
|
ItsYourDomain.com
|
US
|
0.791599
|
18622
|
Yes
|
joker.com
|
Germany
|
1.509189
|
35503
|
Yes
|
Markmonitor
|
US
|
0.023422
|
551
|
Yes
|
Mr. DomReg.com, Inc.
|
Canada
|
0.01254
|
295
|
Yes
|
Namebay
|
Monaco
|
0.108567
|
2554
|
Yes
|
NameEngine, Inc.
|
US
|
0.040043
|
942
|
Yes
|
Names4Ever
|
US
|
0.421985
|
9927
|
Yes
|
NameScout, Corp.
|
Canada
|
0.102191
|
2404
|
Yes
|
NamesDirect.com,
Inc.
|
Bermuda
|
0.438436
|
10314
|
Yes
|
NameSecure.com, Inc.
|
US
|
0.774638
|
18223
|
Yes
|
Neteka, Inc.
|
Canada
|
0.008077
|
190
|
Yes
|
Netpia.com, Inc.
|
Korea
|
0.106314
|
2501
|
Yes
|
NetNames
|
UK
|
0.130672
|
3074
|
Yes
|
Network Solutions,
Inc.
|
US
|
39.54932
|
930380
|
Yes
|
NewDentity.com
|
US
|
0
|
0
|
No
|
Nominalia Internet
S.L.
|
Spain
|
0.008374
|
197
|
Yes
|
NORDNET
|
France
|
0.114476
|
2693
|
Yes
|
Omnis Network, LLC
|
US
|
0.028863
|
679
|
Yes
|
OnlineNIC, Inc.
|
China
|
0.285064
|
6706
|
Yes
|
OVH Sarl
|
France
|
0
|
0
|
No
|
pairNIC
|
US
|
0
|
0
|
No
|
PSI-Japan, Inc.
|
Japan
|
0.060447
|
1422
|
Yes
|
Parava Networks, Inc.
|
US
|
0.112648
|
2650
|
Yes
|
pAsia, Inc.
|
China
|
0.00204
|
48
|
No
|
Primus Telecommunications
Pty. Ltd
|
Australia
|
0.033242
|
782
|
No
|
register.com
|
US
|
9.909392
|
233114
|
Yes
|
Register.it SPA
|
Italy
|
0.043784
|
1030
|
Yes
|
Registrars.com
|
US
|
0
|
0
|
Yes
|
Registration
Technologies, Inc.
|
US
|
0.020192
|
475
|
Yes
|
RGNames.com
|
Korea
|
0.003358
|
79
|
Yes
|
Schlund+Partner AG
|
Germany
|
2.5782
|
60651
|
Yes
|
Secura GmbH
|
Germany
|
0.031924
|
751
|
Yes
|
Signature Domains
|
US
|
0.153372
|
3608
|
Yes
|
Stargate Communications,
Inc.
|
US
|
0.576292
|
13557
|
Yes
|
TLDs, dba SRSPlus
|
US
|
0.081489
|
1917
|
Yes
|
topnet AG
|
Germany
|
0.000085
|
2
|
No
|
Total Registrations
|
UK
|
0.088971
|
2093
|
Yes
|
Transpac
|
France
|
0.077238
|
1817
|
Yes
|
TUCOWS, Inc.
|
Canada
|
10.13660
|
238459
|
Yes
|
Virtual Internet (UK) Ltd.
|
UK
|
0.007099
|
167
|
Yes
|
Wild West Domains,
Inc.
|
US
|
0
|
0
|
Yes
|
Xin Net Corp
|
China
|
0.096282
|
2265
|
No
|
YesNIC Co Ltd.
|
Korea
|
0.262492
|
6175
|
Yes
|
Source: SnapNames "State of the Domain"
database, April 2002
An additional factor to increase competitive registrar services
is the removal of the $100,000 surety instrument currently required
by VeriSign registry to register .ORG domain names. To further enhance
the competitive structure of the registry market for the benefit
of registrars, the ISOC proposal also seeks to make .ORG more competitive
versus other TLDs. The .ORG domain has been declining recently,
as promotional registrations have not been not renewed and ccTLDs
and the new TLDs have taken market share. ISOC's proposal demonstrates
how it will reinvigorate the .ORG domain behind clear positioning
and effective marketing, restoring .ORG to a competitive position
within this challenging market.
Back to top
|
C32. Operation of a Registry
with More than 500,000 Names
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.
ISOC has chosen to contract with Afilias, based upon the detailed analysis
in C31, to provide back-end registry infrastructure services in connection
with this bid. Afilias is the current registry operator of the .INFO TLD
and has more than 800,000 domain names under management.
ISOC will rely upon Afilias' technical experience and infrastructure
to provide a stable and seamless transition from the current registry
operation. However, ISOC will exercise complete policy and administrative
oversight of the registry in its role as registry operator.
ISOC has modeled this relationship, in part, upon the contractual agreement
between EDUCAUSE and VeriSign governing their operation of the .EDU registry.
Similar to the administrative and policy role that EDUCAUSE provides based
upon its established role as a nonprofit association in the higher education
community, ISOC believes that it is ideally suited to play a similar role
for the non-commercial registrants in the .ORG registry, with Afilias
providing the registry technical infrastructure.
Back to top
C33. Affiliations
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.
|
(a) The Applicant
or Any Entity Identified in Item C13
The Internet Society (ISOC) is comprised of more than 137 organizational
members, including nonprofit, trade and professional organizations,
foundations, educational institutions, corporations, government
agencies, and other international organizations that share a commitment
to the health of the Internet. A list of all Internet Society organizational
members can be found online at http://www.isoc.org/orgs/orgsbyname.shtml.
Afilias became an executive level organizational member of the Internet
Society earlier this year, joining other registry operators such
as CORE, DENIC eG, EDUCAUSE, Melbourne IT, Nominet UK, and VeriSign.
Donald Heath currently serves as a director of Afilias and sits
on the Internet Society's Board of Trustees. After formal introductions
between the Internet Society and Afilias, Mr. Heath recused himself
from all further discussions in connection with this matter.
On May 15, 2002 the Internet Society's Board of Trustees overwhelmingly
approved the decision to contract with Afilias to help secure the
reallocation of the .ORG registry. Specifically, the Board authorized
the President of the Internet Society, Lynn St. Amour, to enter
into a Letter of Intent (LOI) with Afilias. On May 31, 2002, the
Internet Society and Afilias entered into a LOI in connection with
this RFP, which incorporated the following terms:
- ISOC will submit an application to ICANN to become the registry
operator for the .ORG registry;
- In the application, ISOC will propose the establishment of a
separate entity, owned or controlled solely by the Internet Society:
Public Interest Registry, or PIR. PIR will serve as the registry
operator, if the application is selected by ICANN;
- ISOC (or its designee, PIR) will contract with Afilias to provide
registry technical and support services in connection with the
operation of the registry;
- ISOC (or its designee, PIR) will be the sole beneficiary of
the US$5 million endowment anticipated to be paid by VeriSign
as set forth in Section 5.1.4 of the current .ORG registry agreement;
- The application proposes a $6 a year registration fee, with
$4 going to Afilias for registry infrastructure services and $2
going to ISOC (or its designee, PIR) to provide administrative
and policy oversight functions and other outreach activities;
and
Afilias has committed to provide a $250,000 line of credit to PIR
to cover any start-up expenses, contingent upon the selection of
ISOC's bid by ICANN.
(b) Any Operator
of a DNS Registry Having More than 500,000 Registered Names.
Afilias is a privately held Irish limited corporation. It was founded
in September of 2000 by a consortium of 18 ICANN-accredited domain
name registrars, located across 10 countries: 1stDomain.net, a division
of G+D International LLC; Corporate Domains, Inc.; Domain Bank,
Inc.; DomainInfo AB; DomainPeople, Inc.; Domain Registration Services;
Enter-Price Multimedia AG (EPAG); Internet Council of Registrars
(CORE); interQ, Inc.; Netnames International Ltd; Network Solutions,
Inc. Registrar Operations; Polar Software Ltd. d/b/a Signdomains.com;
Procurement Services International (Japan), Inc.; Register.com;
Schlund + Partner AG; Sitename; Ascio (formerly Speednames, Inc.);
Tucows, Inc.
Network Solutions is a wholly owned corporation of VeriSign, Inc.,
which currently operates four registries in excess of 500,000 domain
names: .COM, .NET, .ORG, and .CC. Currently no Network Solutions
or VeriSign employee or representative serves on the Afilias Board
of Trustees/Directors.
Back to top
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