1 April 2001
M. Stuart Lynn
Thank you for your letter regarding issues that have been raised on the proposed agreements between ICANN and VeriSign. Like you, we have been listening carefully to comments made about the proposed agreements from both inside and outside the ICANN system and we are committed to do our best to be responsive to them. VeriSign has been, and will continue to be, both a good corporate citizen in the larger sense and a responsible participant in the Internet community and we've looked at the various concerns that have been expressed from that perspective.
Accordingly, I am both pleased and comfortable to tell you that in connection with our implementation of the proposed new contracts, we are in substantive agreement with the five points in your letter. I have also discussed these matters with the VeriSign Board of Directors and have their concurrence that, subject to ICANN and U.S. Department of Commerce approval, we would be willing and able to live up to these new commitments. Having said that, however, I want to offer a few observations that I believe are warranted.
First, the enormous, and enormously complex, questions of WHOIS are not ones that VeriSign can answer alone; nor are they questions that involve only technical matters. Making progress on our commitments in this area will require that important non-technical questions be addressed by the community and it will require the faithful cooperation and support of quite a few other companies and organizations. We would hope and expect that ICANN management will take a leadership role in helping to pull together this level of community participation and support.
Second, regarding the changes in the practices of the VeriSign registries or registrar that are contemplated in your letter, without exception we believe that these are practices that should be observed by both VeriSign's businesses and by its competitors. Little will be accomplished by the VeriSign registries engaging in some form of best practices if other registry operators do not do so as well. This point is particularly relevant to the first bullet under point 4 in your letter, which relates to the VeriSign registries giving more advance notice to registrars of its introduction of new services. In the increasingly competitive environment between different Top Level Domain registries, providing advance notice of the introduction of new services by any registry will have the effect of alerting that registry's competition to an innovation in the marketplace. We all want to avoid a situation in which registry innovations and competition are discouraged. Therefore, we would agree to provide 90 days notice of new or significantly changed registry services, but only if an identical requirement was applicable to all other un-sponsored TLDs.
Third, because trust is so important a part of the culture of VeriSign, we have taken very seriously our commitments regarding the separation of registry from registrar activities, and we are very confident that our track record in that regard has been exemplary. Nonetheless, with regard to point 5 in your letter, which relates to the use of some reasonable and specific sanctions against registries if they are found to have violated the registry/registrar separation requirements, we agree. This, however, is also a practice that should apply to all registries, should be subject to appropriate advance notice requirements, and should allow the utilization of the arbitration process contained in the contract to deal with any disputes.
We appreciate the time and effort that you and your staff, as well as Members of the Board, the Names Council and many others in the Internet community, have put into the effort to bring us to this point. We look forward to working with you, and other members of the community, to a constructive conclusion to these discussions and to the improved environment that we believe the new agreements will foster.
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