Register.com has not taken a position for or against WLS.  If and when the registry launches this service, Register.com will consider whether to offer it based on the price and conditions attached to the service.  We are committed to delivering to our customers the best in class services available.  Therefore, the registry’s price will be an important factor.  Moreover, we are concerned about some of the conditions currently being considered by ICANN - primarily, the “black out period.”  This is a period of time prior to the final deletion of a name, during which a registrar would be prohibited from selling a WLS subscription on a domain name that it sponsors.  We consider this a condition that could confuse consumers and dampen domain name competition.

Just imagine, as a registrant, you are receiving announcements from your registrar regarding the need to renew your domain name.  At the same time, you may hear from another registrar or reseller, which you do not know, that they have placed a WLS subscription on your name.  Or, you may see these unfamiliar companies’ ads or spam inviting WLS subscriptions on your name.  You cannot get the same protection from your own registrar.  In fact, your own registrar does not communicate to you about the situation.  This would bewilder and alarm your average registrant.

The registrars of record are unfairly disadvantaged as they will not be able to sell a WLS for a part of the domain name market.  This requirement would inadvertently create a disincentive to competition as the more domain names a registrar registers, the fewer WLS’s it can sell.  Considering the potential difference in the prices of the two products, it may create a disincentive on domain name sales. 

It would be much better to address any concerns that a registrar may try to take advantage of its ‘knowledge’ of whether their domain names may be deleted with a marketing prohibition.  Simply do not allow registrars to claim any special knowledge, guarantee or access to the WLS subscriptions for the names they manage.  Solve the issue without creating unintended problems.

This provision should be addressed before Register.com would consider offering the WLS service to our customers.