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December 26, 2009

On Domain Name Speculation, part 1

A friend of MB's, now a 2L at Bolt, sent me a copy of a work in progress. It is a framework unstated paper, that is, a trademark policy and practice paper uninformed by other policy considerations. Because of the policy development work I'm doing, in part so that municipal TLD proposals don't get blocked ab initio by trademark, and other interests, some of which may have no interest at all, under any policy framework, intellectual property, competition, self-interest, in any TLD proposals, municipal or otherwise, ever being added by ICANN to the IANA root, I wrote the sketch of an IANA function framed paper considering only the address consumption resulting from domain name speculation. This appears below.


The Internet Assigned Numbers Authority (IANA) is responsible for the global coordination of the DNS Root, IP addressing, and other Internet protocol resources. These responsibilities, and the IANA contract, are unchanged by the change from the ICANN MoU regime to the AoC regime, which took place on Sept. 30th, 2009.

The IANA function consists of three sub-functions:

1. it manages the DNS Root Zone (assignments of ccTLDs and gTLDs), as well as the .int registry, and the .arpa zone,
2. coordinates the global IP and AS number space, and allocates these to Regional Internet Registries, and
3. is the central repository for protocol name and number registries, used in many Internet protocols.

Is domain name speculation observable from the point of view of the IANA function?

This activity has generated on the order of 35 million name to address mappings, consuming between 1 and 35 million IPv4 addresses. Name based virtual hosting has replaced address based virtual hosting, however, assuming only that aggregated load limits the number of marginally profitable names assigned to a host, whether only one, or more than one IP addresses are bound to a single network interface, or the host has multiple network interfaces, and that 1 thousand names is the optimal density for commodity hosts and commodity hosting contracts, 35 million names requires no fewer than 35,000 unique addresses. The largest observed concentration known to the author is an order of magnitude smaller, so the actual use may be on the order a third of a million unique IPv4 addresses.

It is therefore not possible to avoid the conclusion that name space speculation consumes the address resource equivalent of a medium to large access network. In classful terms, the resource consumption is bounded below by half a Class B allocation (65,534), and bounded above by two Class A allocations (16,777,214). In CIDR terms, by a /17 (32,766) and a /7 (33,554,430) allocations. It is therefore "observable" from the point of view of the IANA's number space allocation function. We're down to our last 5 /8 blocks globally, a /7 is two of them.

The qustion asked, "Is domain name speculation observable from the point of view of the IANA function?" must be answered in the affirmative.

The data available suggests a best fit predictive model where the first RIR will exhaust its available pool of addresses and no further numbers are available in the IANA unallocated pool to replenish the RIR's pool will occur on 17-Oct-2012. [1]

Therefore, assuming that exhaustion of the unallocated pool of IPv4 address for any regional Internet Registry (RIR), and a cessation of address allocation results, or a recovery regime which entails efficient breech [2] is instituted, is a non-desirable policy outcome, domain name speculation, as practiced, constrained only by commodity hardware load and commodity hosting provisioning capabilities, is contrary to the basic policy implemented by the IANA's address space management function.

This harm may be reduced by reducing the address resources domain name speculators consume. This could be accomplished through a technical density requirement that domain speculators use specific /22 allocations, or through other policy means, including those which tend to reduce the return on investment to domain name speculators, and result in substantive IPv4 address recovery.


[1] http://www.potaroo.net/tools/ipv4/index.html

[2] http://en.wikipedia.org/wiki/Efficient_breach

December 24, 2009

We are competing for .nyc

Yesterday, shortly after 9:30am EST, CORE's response to the City of New York's DEPARTMENT OF INFORMATION TECHNOLOGY AND TELECOMMUNICATIONS (DOITT), RFP for "TITLE: SERVICES TO OBTAIN, OPERATE, MANAGE, ADMINISTER, MAINTAIN AND MARKET THE GEOGRAPHIC TOP LEVEL DOMAIN NAME .NYC " was delivered to the Contract Manager, 75 Park Place, 9th Floor New York, NY 10007. The bid was due by 3pm EST, and it was produced as part of a series of RFP responses we made in December, in Europe, the Americas, and Africa.

The City, (mis)informed by NeuStar, which operates .US (I wrote that bid's technical content, back in 2001), sought two proposals from each tender respondent, one for a "community-based" application, and one for a "standard" application. The terms of art are ICANN's, from the DAGv3. Naturally, NeuStar's application is the presumptive winner, and naturally, if NeuStar looses the Big Apple, its next renewal of the .US contract, incompetently competed last by GoDaddy/Afilias in 2007, will be much more competitive in 2012.

I expect the DOITT also took delivery of applications from Verisign, NeuStar, and Afilias, the other three gTLD registries, as well.

Hmm. Back in 1998 I came up with the idea of a TLD policied by, and for, Indians. I couldn't come up with the $40k to risk in a 7-of-40 gamble, and knowing Mike Roberts and Ester Dyson as I did, I didn't risk Indian money on something in which the weakest players would prove to be a group with millions in circa-2000 risk capital, the Getty Foundation, and the Airline Industry. That idea became sponsored TLDs, that is, things that had more "policy" than $6. And that in turn became, through the hands of Dirk Krischenowski, the idea of Cities as sponsors, starting with Berlin.

From an Indian with policy but no cash, through Berlin, then Barcelona, then Paris, to Manhattan. All that is missing is $24 worth of mirrors and beads.

Our advantage is technical competency, which is the least interesting part of the problem, speaking as CORE's CTO, and we've more time on target thinking through policy intending to make a City's name space something other than a domainer zoo, populated by pay-per-clicks and blogspam exploits.

Of course, the NeuStar informed City is likely to be "informed" that policy other than $6 will result in a couple of hippies forming the entire registrant base for .NYC, loosing the City $illions in lost revenues.

So from that starting point, what is the delta between "community-based" NYC and "standard" NYC?

Assuming that only those trademarks who's products aren't sold in NYC {are really going to go out of their way to avoid / are not qualified to participate in} the community-based NYC Sunrise phase, the delta is composed of ... Mongolian registered trademarks. Polar umbrella vendors. Australian trademarked time-share packages. So the delta for the rights-of-others policied mechanisms, the Sunrise and Landrush phase(es) for "community-based" NYC vs "standard" NYC is zero. So it really comes down to ... domainers. The "value" of a "standard" with just $6 as policy is all the domainers registering typos and squats and ...

Our proposal is no domainers, and yes meaning, as we did in Catalan, so that what one clicks is ... real. We think that in the long run, that (a) is more useful to the City's users, and (b) domainers, like swine in a shellfish bed, ruin the fishery. We believe that zoning increases the total use value of land, and name space mandates increase the value of name spaces.

So now, now that the applications are in the DOITT's hands, the real contest, the contest to inform the bloggers of the City of New York, and through them, the users who's first clicks are "in" the City of New York, that a moment of choice is upon them. The easy money of the domainers, followed by ... life west of the Pecos, or the money of, and the interests of, residents.

Anyone have suggestions for NYC bloggers to buy ad placements with?

October 18, 2009

How to write "New York"

Motivated by my friend Barry, the following:


LtR Scripts

纽约市 Chinese (Simplified)
紐約市 Chinese (Traditional)
뉴욕시 Korean
ニューヨークシティJapanese

Νέα Υόρκη Greek
Нью-Йорк Russian

न्यूयॉर्क शहर Hindi

Nua-Eabhrac Galic


RtL Scripts
ניו יארק סיטי Yiddish
ניו יורק Hebrew
مدينة نيويورك Arabic
شهر نیویورک Persian

October 17, 2009

100,000 blank checks

Checque-and-Pen.jpgSitting at my immediate left in a conference room at the Wilmer Cutler Pickering Hale & Dorr last December and scribbling on the back of what may as well have been an envelope, Jon Nevett, Senior Vice President, Network Solutions1, came up with the 100,000 cap to toss back at the absent authors of the Charles River Associates, Inc. report, the pro forma stab at an economic analysis of ICANN's new gTLD program2.

The bare bones: ICANN allows registrars to own registries, but limits the ownership in registrars by registries to 15%. ICANN thinks its about to see on the order of 500 registry applications (I'm working on dozens for CORE and CORE's clients, NYC included). The morons at CRAI came up with two really bad ideas. First, end the registry-registrar separation rule. Second, allow "single registrant" applications. The first means everything is tossed in the air, the second means every fool is a "TLD consultant" to the idle rich and corporate drones. Not the best way to start an expansion from 20+ TLDs, most of which are not doing that well, or maintain a focus on ending a monopoly which still holds 86% of the market, after 7.1% was divested, and 6.5% is ... competitive.

So, if you'd 100,000 blank checks, the right to sell at whatever the payer is willing to pay to be the first, last, and only buyer, for things like abc.nyc or cnn.nyc or nbc.nyc or pbs.nyc or 3m.nyc or ...

How would you loot the bank? I stayed across a narrow street from the Federal Reserve night before last, and had the tunnel not already been booked by Michael Moore and a bevy of moles, I'd have tried to make a withdrawal of bullion or soup stock or something liquid.

The City of New York would like to know ... cause ... it wants a cut of the vig. The City assumes that Jon's 100k cap will be in the ICANN contract, and the contractor has a duty to ... relieve the last virgin of her material encumberments.

On Monday we'll be discussing the registry-registrar separation issue. Steve Salop, Professor of Law and Economics at Georgetown will open. I found him to be a low information neo-liberal ideologue at Sydney, as did most of my peers in the trade. Apparently he's now got some domaintools.com data to support his "economist's conclusions". He'll be followed by Brian Cute, VP at Afilias who will be arguing for ... allowing Afilias to become a com/net registrar and go after the 85% of the market Afilias and NeuStar isn't competitive with as the org/info and biz/us, respectively, registry operators. He will be followed by Richard Tinsdale who will be making the regulation harms innovation case for Enom. He will be followed by Michael Palage and one of the InterTube's least useful units of biomass, a clown from Syracuse, making the regulation is harmful for children and green plants case for clients, in Michael's case, and for status at a school where orange rhymes with something, in the clown's case. They will be followed by David Sappington, who will address Jon's proposal (which he seems to think is the Registrar Constituency's proposal, showing serious lack of ICANN political clue), also for status at a school where there are (non-rhyming) oranges. I'm the last presenter, making the case for no change in the 15% cap rule, just fixing the brokenness in the .aero, .coop and .museum contracts. Joe Sims, senior anti-trust partner at Jones Day will be the moderator. My slides are here (.pptx). My PowerPoint is ugly too. I hate PowerPoint. I also hate Word.



1 Jon coincidently announced today his planned departure from NSI.
2 The backstory on the "economic analysis" is that it is one of the Herculean Tasks Zeus or the Intellectual Property Constituency or a couple of tame Republican morons in the House have imposed on ICANN before it can ... do anything except do PR pieces about how wonderful things are everywhere. Its a farce, a holding action, by parties quite happy with things not changing a whit.

October 08, 2009

For my punishment ...

I've been sentenced to write our proposal for New York City's top-level domain. Weeks of happy python coding lost to Word and Excel ...

The up side is that I get to go into town.

The down side is that I get to look at greed very, very closely.

BHdrEvil1024x768.jpg

October 06, 2009

The ICANN Gong Show

jaye-barry-gongshow.jpgThere are several contenders for the 2009 ICANN Gong Show Awards. There's the .food adventure, which went from smashingly presented to smashed plates in just under one half of an ICANN inter-meeting cycle. From cater to crater in 6 weeks or so. A life cycle wicked close to that of a drosophila. Then there's the odd lot that keeps trying to sell us a .fam in which Father.Really.Does.Know.Best. They keep hinting they've Opus Dei money, but short of seeing them swing under a bridge I'm unconvinced by their offers of proof thus far. Abstractly, the policy model they'd like (if they knew how to draw a Venn Diagram using two or more crayons) is interesting, but I'm more interested in financial applications and their security than ensuring the knees of any teenage girl are securely fastened together. Then there's the guy who's going to leverage his full-contact modified martial arts studio (before he clocks out of the business on injuries to self or other) into .mma, with millions of mini-he's registering their bare knuckles behind his.

I'm fairly partial to the .green baby that NeuStar is going to deliver in which, well, coal could be clean, so Koch Industries really should be able to register its tending.towards.greenish.or.yellowish.decomposing.meats, and nuclear power could be safe, so Avrea really should be able to register its tending.towards.not.immediately.fatal.radiation.level.wastes, and ...

But the biggest, dumbest slow moving thing in ICANN space, the Gongliest Gong Show contestant evah, is the City of New York. They dumped an Idiot's RFP for .NYC into the digital Hudson yesterday. 60 plus pages of below average disjointed and uneven "borrowed copy", 15 of which are blank addenda, almost all of which any idiot in this business knows by heart, and not a thought provoking sentence from beginning to end.

Imagine, coming up with the idea of "blogs" and deciding that the blogosphere (skippy coined "blogtopia") should exist so that ... government and corporations could promote their goods and services (odd how well those two dance together), promote tourism and kwelism in teh nu media rez, and ... pick up a pantload of Google Ad Sense dollars. That is the City with the Same Name Twice.

The basis for contract award is the highest offer of revenue to the City. Not the greatest service, the biggest payout. It could just as well be a casino franchise, or a collateral marketing agreement for a toy, say .nyc, the mouse pad that ... doesn't do a damn thing except leak shredded plastic and icky goo. It makes the value claims of a Chia Pet look pretty damn forward minded in comparison.

There is an election in four weeks and I've thrown an "Attention Policy Director" memo over the transom.


The image is from Jaye P. Morgan's skit on the Gong Show in 1978.

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