via email

Mr. Stephen Crocker
Chair, Security and Stability Committee
Internet Corporate for Assigned Names & Numbers




Dear Mr. Crocker,

I write to you on behalf of Tucows Inc. concerning Verisign's recent arbitrary change to the behavior of the .com and .net zones. We appreciate the efforts of ICANN's Security and Stability Advisory Committee in organizing the community consultation that occurred today. We would appreciate it if these comments were also entered into the formal record of the proceedings.

Tucows is the largest wholesale domain name registrar and operates registration services in a number of top-level zones. We also work directly with thousands of Internet Service Providers and Web Hosting firms in over 100 countries. We have had unique operational experience in the field of TLD registry operations as the developer of the first operational EPP registry platform, OpenXRS, which was used by Liberty Registry Management Services, a former Tucows subsidiary, to operate the .info domain name under contract to Afilias Inc.

In each of these roles, we depend on the stable and predictable operation of the domain name system and the related infrastructure. We trust that the respective operators will conduct themselves accordingly. Verisign's recent actions were unannounced and unilateral. This seriously damaged the trust relationship between the operators of the domain name system and its users. Unless the community can place its trust in the operators of the critical components of the domain name system, there can be no stability and predictability in the domain name system.

Tucows is involved with the operations of over 5000 domain name resellers. They have spoken clearly to us. Verisign must not be allowed to make arbitrary changes to critical infrastructure like the .com and .net zones. In a recent survey of our resellers, 69.4% of respondents were able to identify specific and measurable negative impact. They reported malfunctioning applications, increased bandwidth usage, customer confusion and increased support loads. Industry data indicates that the average customer support call costs a provider between $25 and $38. Service providers receive no consideration from Verisign for answering customer questions resulting from Verisign's changes and none of them will be able to recover these additional unexpected costs. This is not the "prejudice and bias of a few folks who have a set way of doing things," as Verisign has stated, but rather, a clear plea from a large and directly affected constituency.

The internet does not exist to solely serve the interests of Verisign's shareholders. ICANN has granted Verisign a lucrative long-term contract only to operate the top-level zones for .com and .net. If they wish to extract additional value from this exclusive grant, then ICANN must first provide them additional rights for which the internet community, via ICANN, should be duly compensated. This is not only a matter of economics, it is a matter of trust - trust that must be restored as quickly as possible. Restoring this trust may include the development of a process by which registry operators can propose new amendments to their operational agreement and have those amendments quickly approved or declined. Without such a process, true operational stability and security of this important resource will be hard to achieve.

Tucows continues to support ICANN's efforts to return the domain name system to a more appropriate operational status and we are committed to the discovery process undertaken by the SECSAC . We urge the participants towards a resolution that meets the expectations of the internet community and stakeholders in the domain name system by providing clear and conscise terms of operation to Verisign Inc. and the other registry operators.

Regards,


Ross Wm. Rader
Director, Research & Innovation
Tucows Inc.

Document Permalink: http://blog.r.tucows.com/blog/_archives/2003/10/7/4096.html