Dear EURid team,|
First of all, thank you very much for the courtesy of your detailed reply.
If I am correct in my understanding of what you have told me:
1. Pool.com are not yet accredited and if this remains the case they are not
allowed to offer any services.
2. The individual registrar has to submit a domain application, and it has
to be on a first-come first-serve basis. If the registrar (who must be
accredited) is successful in acquiring the domain name, he/she may not
re-sell the domain name (for example, to another registrar).
I feel that some further clarification may be needed, however.
Question 1: Pool.com simply attracts interest in .eu names and passes the
names of interested applicants to one of its EU-accredited registrars. In
this sense, Pool.com would not exactly be offering the service themselves.
They would be saying, "You can contact us, and we will make sure that your
application is passed on to one of our registrars to legitimately carry out.
Would this be acceptable to EURid?
Question 2: I understand the model Pool.com offers is that many people may
contact POOL for the same .eu domain name. They will attempt to legitimately
acquire this domain name through various registrars who work for them. In
the event of this being a popular domain name which various people have
asked POOL to acquire for them, there will then be an auction with the name
going to the highest bidder. Will this process be acceptable to EURid?
Question 3: I understand that Pool.com may charge $60 for each name one of
their supporting registrars acquire for the people who contacted POOL
(unless an auction pushes the price higher). Would EURid consider that
Pool.com are entitled to act as 'agent' for these registrars, and charge the
winning applicant $60?
Question 4: When you say that (without accreditation) Pool.com "are not
allowed to offer any services", does this extend to acting as the point of
contact for .eu domain applicants, where these applications will then be
dispersed to legitimate and accredited registrars working to catch domains
Question 5: Would any similar restrictions apply equally to companies like
Snapnames or Enom, if they use multiple registrars to increase their chances
of 'catching' a domain name, and then auction the name to the highest
Question 6: You say that no reselling of domain names will be allowed. Do
you mean just during the launch process? How will you stop this and enforce
this? Or do you mean no reselling ever? You will be aware that it is an
industry norm that domains may be freely traded, bought and sold, through
all the major TLDs? Surely you are not proposing to break this norm, and how
would you enforce such a rule, given that all the original registrant has to
do is change the nameservers and contact email, and another person would
have control of a domain name anyway?
These questions are in no sense meant to be critical. I am just respectfully
asking for clarification, so that the process is clear, so that rules can be
clearcut and upheld, and so that I (and other consumers) do not lose money
through EURid interventions or confiscated domains.
The last thing you want is for the launch to come crashing down (as the .info launch did 3 years ago) and therefore it is very important that EURid
anticipate as many potential 'gaps' in their processes as possible, and
intervene in advance. Experience in recent years has shown that various
registrars will attempt all kinds of methods to circumvent the established
rules in order to gain an advantage in the process.
For example, will your release of domains favour a registrar who submits
just 10 names for a favoured customer, as opposed to another registrar who
submits 2000 names for its general clientele? In this case, would the
registrar with a small number of applications gain any advantage? (This
happened in the .info LR2 names release and also the .biz names release.
And then, if one registrar just operates in its own right as a single
registrar, and another company has created 100 'shell' registrars or even
40, will that mean that the company who has exploited the technicality of
having multiple accredited registrar 'shells' will in effect *swamp* the
applications of the ordinary registrar who operates in good faith as a
single accredited entity?
My advice is that, at the very least, the distribution of names should be
built around a structure which includes "blank rounds" for any registrar
with a short list of applications. In other words, to make the distribution
fair, if an ordinary registrar submits say 1000 applications, and another
registrar submits just 10 applications, I propose that 990 'blank' rounds
should be added to the registrar applying for only 10, so that they don't
just grab 10 best names in the first 10 rounds of names being released. Or
are you going to simply let any registrar fight it out real-time, in which
case you will be inundated by people running scripts via all their 'shell'
registrars in order to grab the best domains.
Surely a controlled and orderly names release must ensure fair distribution
of domain names, and also attempt to prevent exploitation of the system by 3
or 4 companies with multiple accredited registrars, otherwise all the
registrars who simply apply as single registrars may find their provisions
for their customers have been compromised.
Just a few thoughts, but I'd be very grateful if you could consider answers
to my 6 Questions at the top of this mail. As usual, I will forward this
correspondence to various ICANN Directors, the ICANN Registry and Registrar
Liaison Managers, and representatives of the At Large internet users groups.
Thank You. I appreciate your response and willingness to engage in dialogue.
With kind regards,