WLS Statement of George Kirikos

May 21, 2002

My perspective on WLS is that of a consumer and also someone coming from a finance and economics background.

Briefly, I'm against the proposal as it stands now, as it will have negative consequences on registrars and consumers alike. Verisign is simply leveraging its existing monopoly at the registry level to capture a highly competitive and innovative market that currently exists at the registrar level. By doing so, they restrict consumer choice and raise prices. Part of ICANN's mission is to encourage competition, and this proposal by Verisign would be a step in the wrong direction.

I as a consumer will be hurt due to the reduction in choices. Currently I can choose amongst numerous business models, such as NameWinner, NicGenie, SnapNames (and for the record, I am a customer of Snapnames too), and other systems run by registrars, none of which Verisign identified as illegitimate or abusive when asked directly in their Questions and Answers document.

Furthermore, the wholesale cost of names would rise by several hundred percent, which eventually gets passed on to me as a consumer. For those who've read some of my postings, I've shown how one could implement the exact equivalent of WLS for the same cost as a new top-level-domain (or TLD), a "shadow TLD" was the lingo I used, which would cost roughly the same as existing domains, that is, $6/name or less. SnapNames alone expects to make $100 to $150 million over 5 years if WLS goes through, and you can bet that Verisign stands to make the same if not more. All of this is at the expense of existing market participants, and eventually consumers.

Verisign has tried to position this proposal as merely a "test", something that they should be allowed to do to simply see what happens. However, this is difficult to believe. First of all, they've put their heads in the sand and refused to analyze the current expired domains market, to create a baseline on which to do a comparison, and to measure the consquences of a change. They've simply accepted the analysis of their partner SnapNames, an existing market participant, and arrogantly ignored input from all other market participants (consumers and registrars alike). If Verisign wants to do a test, as a proof of concept, it could easily do so on the dot-TV top-level-domain, which it owns. I'm from Canada, and the dot-CA registry handled expired domains very efficiently and at no extra cost recently, showing that the Status Quo option for dot-com is is in fact the normal case in other registries. Given that the only way the "WLS test" fails is if Verisign loses money, one can see that the test is simply a charade, a way to stealthily go under the radar of ICANN and wedge itself in so that it can't be removed in the future.

I'd also like to point out that Verisign registrar is an existing partner of SnapNames. The report about the Chinese wall between Verisign registrar and Verisign registry has never been delivered, as far as I know, and this is an example of a possible conflict on the part of Verisign registry, who is supposed to provide equal competitive access to all registrars, and not favour its own companies.

In conclusion, given the policy mandates of ICANN, the proposal should either be rejected flatly, or should go through the formal consensus process, as it is clear that there will be detrimental effects to numerous market participants. ICANN should be extremely wary of creating new monopolies, especially ones that will hurt the industry and have had no consensus approval.