The WLS is an imperfect solution to an imperfect problem. The problem, “Coming up with a fair and safe way to distribute deleted domains.” First come first serve has been the status quo for some time now. Why would it change? It appears the WLS system was designed more from a marketing standpoint rather than to help consumers like Verisign claims. Verisign, a government appointed monopoly is trying to leverage their hold on the market by taking the SnapNames model and moving it to the registry side. All the arbitrary numbers in the proposal make it appear like a marketing department fine tuned the WLS on how best to exploit a consumer rather than actually solving the initial problem. I see the WLS creating more problems than it solves.

First off, they are stifling competition between the registrars that already exists. And they will be forcing some companies out of business. Second, they are building an imperfect monopoly solution to something the open market place is already serving. Everyday more and more solutions get developed by the open market place to address registering deleted domains. Third, Verisign’s technical claims for the need of the system are not accurate.

Verisign executives claim the current way is too taxing on their servers with the millions of requests they receive. And yes they were correct. Prior to a fix that was performed a few years ago it was common to see the registry crash during the middle of the night when domains were deleting. But Verisign technical personal directly responsible for the Registry have stated that there is no technical problems any more. However the executives continue to pull this technical card even though it is in direct opposition to what their own technical staff has advised to the registrars.

Why a price point at $24 wholesale plus $6 to buy the domain? Seems like a gold dig. To sell an empty space that expires in one year is crazy, why not sell the space and allow it to be renewed. Charge a normal fee like $5. A more perfect solution to the problem might be… People could register .comfailsafe, a domain that would not resolve on the Internet. If for some reason the .com version got deleted then the registered owner of .comfailsafe would receive the domain. Registrations in this shadow TLD would be just like all other TLDs. It would have a low wholesale value like $3-$6 and be renewable. People would be able to do whois lookups and see who owns the shadow domain. There would be no need for all these layers of marketing that Verisign is trying to incorporate into their WLS system. Verisign has proven they can run a registry, so why not just propose a shadow registry with all the rules of a regular registry. Everything from transfers to WIPO.

WLS Trial Period
There is no such thing as a WLS trial, if the 1yr test goes through, the effect will be 1 year and 364 days of WLS, this will effectively shutdown the alternative models and they will be too weak to compete if the trail fails after the two years.

Domain Speculators
Part of the stated reason for the high price point stated by Verisign was to “deter domain speculators” with a price that was high. If the price was set at $1, they claim, speculators would buy all the WLS subscriptions before any other people. So if Verisign is trying to really deter domain speculators then why are they not releasing information on who owns a WLS? Or limiting the number of WLS that a person can have. Seems like a shallow argument if the only deterring thing is raising more money for the Verisign monopoly rather than setting limits.

The IP Community Will Face Big Problems with WLS
Whois information is a great tool for IP lawyers, when they need to track down who is squatting on a domain they turn to whois. IP lawyers would be cut off from researching who is squatting on a WLS subscription. I don’t see WLS in the best interest of lawyers or Intellectual Property Community. They are going to need a way to determine who owns the WLS subscription.