Hello Debbi.
My name is William Walsh, a consultant and developer from Fresno, CA,
and operator of what is, admittedly, a very small webhosting service.
I have been involved in Domain Name Policy issues for 4 years now, and
helped plan and develop the operations of one of the country code Top
Level Domains.
I am writing because I don't see any media coverage of the impact this
change by NSI is going to have on both individual and personal domain
name holders, and the small sized ISPs. Your article at
http://www.wired.com/news/news/technology/story/20878.html brings no
mention of these issues.
Throughout the world, credit cards are NOT the norm. In many
countries the ability to use credit cards is severely restricted, both
from legal as well as economic reasons. Not to mention that a rather
large percentage of Americans do not have credit cards either.
Their ability to register domains has been seriously impacted by this
change in policy. When I mentioned this on the NSI hosted
Domain-Policy list, I received the following reply from an NSI
spokesperson (who clarified that, while he was the person responsible
for ISP portion of the prepayment implementation, that these were his
personal comments only):
> Some individual users do not have credit cards, and this is more common
> internationally, so they will not be able to register directly with
> Network Solutions, we will recommend to them that they register through
> one of our premier members who may choose to offer them credit.
The problem with this is that we are now shifting the burden for
domain registrations to the ISP. Lets face it, NSI was never
seriously affected if a domain name registrant did not pay the
invoice. They didn't have someone else they had to pay for that
transaction if it defaulted. But for ISPs there is no hope of them
offering credit customers as the spokesman implied, since the ISPs
will be held responsible now if they extend credit to a customer.
The NSI spokesman appears to be addressing this issue in this
paragraph :
> The 200 or so ISPs around the world who are members of our premier programs
> and the 2000 ISPs who use our ISP support center will be able to continue
> receiving invoices for their domain registrations as long as they maintain a
> reasonable payment percentage (nearly all the ISPs already do this).
Just to note, 2000 ISPs is but a VERY small percentage of ISPs and
IPPs worldwide, and even just a fraction of US based ones. Also, to
qualify, ISPs must maintain this elusive "reasonable payment
percentage." For larger ISPs, the sheer volume of registrations will
make sure they are well within the "average" NSI sets. But for small
to medium sized ISPs all it takes is a small number of their customers
to default to throw their percentages askew and make them (and their
customers) ineligible for this program.
ISPs who do not qualify will have to apply for a business account if
they want to avoid their customers having to go to NSI's site (and be
subjected to NSI's advertisements for its other services) and use
their credit cards to pay for names. Over a week ago, in an interview
with a reporter from internetnews.com, I talked about prepayment
policies and their impact on ISPs worldwide. Prepayment requirements
being enforced at the ISP level, as NSI is attempting to do, could
tie up thousands of dollars in liquid capital for even the most
moderate small to medium sized ISPs and webhosting services.
Many will see Prepayment Requirements as A Good Thing. While I would
disagree with them overall (and would say that indeed lack of a prepay
policy has been good for the Internet, for domain name holders, for
ISPs, and even for NSI) if a prepayment policy is absolutely necessary
(something I do not concede) there are proper ways of implementing one.
I was involved with a country code top level domain for over a year,
and helped form their policies on such issues as prepayment. Our
solution was that domains were registered and entered into the database,
but not activated, until payment was received. Unpaid and inactivated
domains would remain in the database for 30 days, until payment was
made either with the on-line billing/payment service (for credit cards)
or by check/mo via the mail. This was an acceptable compromise that
enabled users from literally all over the world (including
underdeveloped countries) to easily and simply register and obtain
names without undue hardship, unlike the current NSI policy.
Many of my customers over the years have resided in areas where credit
cards are not so easy to obtain. In some countries even getting your
bank to issue a certified check in US dollars for payment of a service
to a US based company is very difficult. India is one of the hardest,
with some banking laws that would make you cringe. NSI's policy
accommodated even those tough situations. Now those people are being
left out in the cold, or will find themselves having to send all their
registrations through one of the larger India based ISPs who can
afford to open an NSI account. This would be akin to small local ISPs
having to send domain registrations through, and make payment to, a
company like Mindspring or PSINet, which is clearly a situation where
those ISPs can gain a competitive advantage.
I've not touched much on the impact on individuals here, but I think
the issues are clear. Their ability to register domains is now
seriously impeded by this requirement. NSI has taken a very
US-Centric position in an industry that is clearly international in
scope.
It is my belief that this policy was undertaken under pressure from
the Dept. of Commerce's NTIA and ICANN. It is also my position that
both of these groups are completely and totally out of touch with the
implications on individuals and ISPs. Currently there is NO
individual representation in the ICANN, or in the Domain Name
Supporting Organization of the ICANN. The ISP constituency is
dominated by organizations, and not by actual ISPs, and they have made
it difficult, and indeed discourage, individual ISPs from joining.
ICANN likes to characterize those that oppose its policies as NSI
shills or consultants. That is a complete mischaracterization as
well. I hope that this email will give you a slightly more broad view
of this issue, and the implications of these policies.
Best Regards,
--
William X. Walsh
General Manager, DSo Internet Services
Email: [EMAIL PROTECTED] Fax:(209) 671-7934
