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Letter from Charles Gomes to Dan Halloran

Global Registry

May 28, 2003

Mr. Dan Halloran
Chief Registrar Liaison
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292

Re: Letter from GoDaddy, dated May 8, 2003, re. WLS Offering from VeriSign

Dear Dan:

The purpose of this letter is to respond to the claims made by Mr. Robert Parson of GoDaddy Software in his letter to you, dated May 8, 2003, regarding the WLS Offering from VeriSign, Inc. I submit this letter with due respect to Mr. Parsons, recognizing that you are already fully aware of the information I provide below.

Mr. Parsons' first claim is that "the WLS will have a chilling effect on competition in the registrar market." Under the present situation, there are a few registrars who compete for deleted domain name registrations. If the WLS is implemented, all registrars will be provided the opportunity to compete on equivalent terms in this market niche, including those who currently offer registrar-based services. So it seems to me that competition will be expanded. Moreover, the end-user benefit will be improved because only a registry-based service can guarantee 100% fulfillment when registrations are deleted.

Mr. Parsons goes on to say that "the WLS will eliminate and thus replace the various backorder processes developed and implemented by the various registrars who have them." These various registrars do so by sending extraordinarily high numbers of robotic domain name registration requests to the VeriSign Com Net Registry that currently costs VeriSign significant unreimbursed expense to process. VeriSign has implemented a temporary system to support such activity since August 2001 and has continued to support it without charge since that time. Mr. Parsons later goes on to say that "the WLS will essentially eliminate all alternate forms of back ordering currently in the market." First, that would only happen in cases of second-level domain names for which WLS subscriptions are made; all other domain names would be available for other backorder services by registrars. Second, assuming that most end-users would be more attracted to the WLS because of its 100% efficacy, when domain names are deleted, those registrars who currently have such processes would be fully eligible to participate in the WLS program and thereby replace and possibly even increase their business in this market, at the same time being able to offer consumers a more effective service.

Finally, Mr. Parsons says that if the WLS is offered by VeriSign, ICANN would be "allowing VeriSign to be both the registry and the registrar." VeriSign's proposal for the WLS made it very clear that all WLS subscriptions would be sold to end-user customers through registrars and that registrars would determine the price for those subscriptions in the same way they do for second-level domain name registrations. I fail to understand how VeriSign would be acting as a registrar.

Thank you very much for your consideration of this matter. If you would like to discuss any of these matters further, please feel free to contact me.


Charles A. Gomes
Vice President
VeriSign Com Net Registry

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."