The outcome of the .Net rebid process will involve the security, stability and diversity of management of the Internet’s critical infrastructure. As well, the rebid process introduces competitive forces that will flow through to users in the form of cost savings and improved service levels. DENIC has submitted a bid that is consistent with the goals and interests of the Internet community and is the only proponent that has done so.

Let us consider the following factors and assess the alignment of the bids with the goals and interests for the Internet community:

Technical Expertise and Experience

There is an important distinction between claims of technical and operational scale and a practical demonstration of it. DENIC is the only bidder, excepting the incumbent, that possesses a demonstrable track record of operating similar scale registry operations. The .de namespace is the second largest namespace in operation today. DENIC is in a unique position as the only operator besides the incumbent that has a demonstrated track record running registry infrastructure at the scale that .net requires. In our view, significant weight should be given to demonstrable experience operating registry systems on the scale of .net.

Competition

The .net rebid process provides the opportunity to bring much needed competition to all levels of the domain name system. The bidding process itself drives prospective operators to promise pricing and service improvements. The greater the number of credible operators, the greater this impact in future similar processes.

In addition, DENIC has proposed a cost-based pricing model, unlike the profit driven pricing models put forward by the other hopefuls. DENIC’s proposed cost-based pricing model would initially reduce the registry by at least 10 percent with further reductions in the next two to three years.

The increase in competition amongst registrars has created significant price decreases and service improvements for registrants. It is reasonable to expect further increase in competition amongst registries will also produce price and service improvements.

Stewardship

Appropriate management of the namespace requires more than technical excellence. It also requires a demonstrated commitment to good stewardship and an alignment of interests with the Internet community. There is strong historical data indicating that shareholder interests often conflicts with the interests of the Internet community. DENIC appears to be the only applicant that has explicitly proposed a management structure that obviates this conflict. They have expressly stated in their application that they will focus on being “a truly neutral partner for all registrars” and they will supply “only services really needed by the registrars”. We believe that DENIC has demonstrated integrity, capability and stewardship, pre-requisite skills that the successor registry must possess in order to be awarded this important management contract.

We find this combination of track record and structure compelling.

Benefits for International Co-operation

Migrating management responsibility of .net to DENIC provides ICANN with a unique opportunity to strengthen ties with the International Internet community, increase the opportunities available to international businesses and increase ICANN’s connection with key stakeholder communities. We urge ICANN to consider the full potential of this opportunity and take advantage of the available benefits.

I urge the bid evaluation team to continue the careful work that ICANN has commissioned and undertake a truly merit-based selection that factors in the wide range of quality and experience that the various bidders offer.

Disclaimer: I am the President of Tucows which has an economic interest in DENIC?s application and a substantial interest in the outcome of the re-allocation of .net.