20 November, 2010

GoDaddy.com's Comments on .TEL RSEP

GoDaddy.com's Comments on .TEL RSEP - 
Allocation of Numeric-Only Domains

We object to Telnic's request to allocate numeric only second level domain names for the following reasons:

We believe that requesting this change through the Registry Service Evaluation Policy (RSEP) process is inappropriate. Telnic's request does not simply involve a new Registry Service as defined under the RSEP. It involves a fundamental change to its charter.

The charter for a sponsored Top Level Domain (sTLD) defines "the purposes for which the .tel sTLD is delegated." This request from Telnic is to change its purpose and not to employ a new service under its existing, agreed to purpose.  We believe that this request cannot be granted without requiring the rebidding of the .tel sTLD itself. It is unfair to other applicants and potential applicants to allow an sTLD to change its purpose after the fact. 

Telnic's promise not to allow numeric only second level registrations was a fundamental aspect of its application and, if we understand the decision correctly, a primary reason why .tel was awarded to Telnic and not Pulver (numeric only second level names were fundamental to Pulver's application for .tel at the same time).   

Since community, purpose, and use were such important aspects of the sTLD allocation decisions it seems inappropriate, fundamentally unfair,and even smells a lot like gaming, to allow an sTLD to change those aspects without an opportunity for others to bid competitively. 

One possible solution might be to allow Telnic and other interested sTLD registries to put their TLD up for reapplication in the new gTLD round.  If they retain it afterward, they will have done so through an open competitive process and fundamental changes such this one being requested by Telnic would not be an issue. 

We believe that certain other recent requests under the guise of the RSEP by sTLDs were also likely inappropriate for similar reasons and we are concerned about what appears to be a growing trend to misuse the RSEP. We hope our comments will encourage Staff and Board to review these requests more critically in the future.

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