Dear ICANN, My name is Andres Kello and I am the owner of the largest forum about .mobi domain names -- Mobility.mobi -- and I also sat on both the dotMobi Policy Advisory Board (PAB) and the now-defunct dotMobi Advisory Group (MAG) Steering Committee. I am also the Campaign Director of the largest grassroots campaign for .mobi -- Why.mobi. Two years ago, I sent a letter to ICANN ( http://forum.icann.org/lists/allocation-framework/msg00003.html) as a PAB member in support of mTLD's proposal for the Allocation of one (and two) character .mobi’s specifically via the Request For Proposal (RFP) framework: ~~~~~ “I would like to express my strong support for dotMobi's proposed allocation of Single Character Second Level .mobi's via an RFP (Request for Proposal) framework.” ----- I went even farther in my letter of support and specifically mentioned how the auction allocation method is detrimental to the extension and wrote: ~~~~~ "it would make sense for these highly-coveted domains to be granted to the person or company with the absolute best development plan for it - as determined by mTLD - in order to maximize their potential, rather than to the company or individual with the biggest wallet - as determined by a highest bid - who might not have the best intentions for the extension or is purely speculating on the future value of the domain, particularly since good content is critical for a young extension such as .mobi. The only way to ensure that for the SC SLD's is via the RFP framework." ----- John Levine, also a member of the mTLD PAB at the time of the original proposal, shared the same reasoning in his letter of support ( http://forum.icann.org/lists/allocation-framework/msg00005.html): ~~~~~ “It is important to allocate this important resource to entities that will provide diverse and useful services to mobile users, rather than to speculators as would likely happen were the names to be auctioned or issued first-come-first-served. Hence I endorse the plan to allocate single letter domains via an RFP process.” ----- Michael J. O’Farrell, also an mTLD PAB member at the time, shared a similar view (http://forum.icann.org/lists/allocation-framework/msg00006.html): ~~~~~ “the dotMobi registry RFP approach would be available to all stakeholder communities versus an auction that could limit the availability of the single-character second-level .mobi domain names to a few industry speculators (who could potentially outbid the merits of made-for-mobile Internet service delivery, utility and universal availability solely for future speculative capital gain).” ----- Vittorio Bertola, also an mTLD PAB member at the time, also shared a similar view (http://forum.icann.org/lists/allocation-framework/msg00007.html): ~~~~~ “1) What is the allocation method that puts the reserved names to best use? I think that it should be the method that best guarantees that all names are developed, host useful services (as opposed to being used to host pay-per-click advertising pages and nothing more) and become broadly used by final users. To this purpose, auctions seem to me an inappropriate method: they maximize the amount of money that can be squeezed out of the market, but they do not offer any guarantee that the planned use of the domain name is sound or, indeed, that the domain name will ever be used. This is even more true in gTLDs that are community-based, where making money might not be the primary purpose of the gTLD itself and of its second-level registrations, and the richest registrants might not be the ones who could actually develop services that are useful to the target community.” ----- Even Caroline Greer, Director of Policy and Industry Relations of mTLD at the time, shared a similar view ( http://forum.icann.org/lists/allocation-framework/msg00002.html): ~~~~~ “However, based on our experience and depending on the domains in question, it is our belief that auctions do not always serve the needs of a particular community and that certain domains are best allocated using a distribution model such as the one dotMobi proposes for its single character domains - a Request for Proposals [RFP] process. dotMobi uses the RFP process in conjunction with its Premium Names to ensure that its sponsored community has access to high quality content. The RFP process for single character .mobi domains would be designed in a similar way to ensure that new content, features and services are made available to mobile Internet users and that the full potential of these domains is truly recognized. dotMobi is not seeking to make any profit from this allocation process, rather it desires to see these domains allocated to those that have an interest in enabling mobile friendly content for the benefit of end-users. “ ----- To be absolutely clear, I do not intend to speak for the individuals above, and although the above quotes do not mean that their opinions have not changed since they were made, it is my strong belief that the crux and basis of the original opinions stated above at the time of the first proposal hold true now more than ever, regardless. It is not difficult to see why the Auction is counter-productive to the growth of the .mobi ecosystem. In fact, we don't have to look past the previous auctions of Premium .mobi domains by mTLD. A recent study on Mobility.mobi showed an auction-to-development success rate of less than 10% from 100 domains auctioned with Development Requirements via Sedo in 2008. This means that less than 10 out of the 100 domains auctions had any kind of serious development. The rest were nothing more than glorified parking pages or bare-minimum developments just to stay “under the radar”. This is not surprising considering the majority of Premium Domain buyers were speculators and not end-users. I invite ICANN to check these facts for themselves and thoroughly study the list of previously-auctioned Premium .mobi domains to determine whether they sincerely consider the overall developments beneficial to the .mobi ecosystem and community at large. In light of the above, I was appalled to recently learn that mTLD have now formally requested ( http://www.icann.org/en/registries/rsep/mobi-request-30sep10-en.pdf) that ICANN allow them to allocate the one and two-character .mobi's via Auction -- a method that has been proven to fail as far as the .mobi ecosystem is concerned and as evidenced by the poor end-user uptake and development of past Premium .mobi domain names allocated via auctions. I would never have supported that as a PAB member and I do not support it now. In the interest of transparency and full disclosure, I myself own over 8 Premium .mobi domain names -- most acquired via the auction allocation method and one acquired via the RFP allocation method -- so I believe I speak with some authority when I describe the issues that have plagued the auctioning of Premium .mobi domains and have a unique ability to compare and contrast those shortcomings with the advantages of an RFP allocation method since I am one of the very few who have witnessed it from both sides. I can also confirm that mTLD enforced no more than bare-minimum development requirements when Premium Domains were allocated via auctions, whereas I had to send my RFP application to them at least three times to satisfy their criteria for thoroughness and detailedness of the development plan. With auctioned Premium .mobi domains, any site -- including a one-page site -- other than a strict parking page, was given a pass. This included 5-page mini-sites that would have taken less than 10 minutes to develop using a .mobi site builder. Furthermore, mTLD have failed to continue to enforce even those weak standards set initially which has lead to several Premium Domains that had gone “under the radar” in the past now becoming outright parking pages -- this, on some of the most valuable, most searched-for, and most sought-after .mobi domain names. It is considerably more difficult for this to happen with the .mobi’s allocated via the RFP method precisely because a potential applicant must thoroughly prove their development plans to mTLD before even being considered. Anyone will be incredibly hard-pressed to argue that an Auction allocation framework is better for the .mobi ecosystem than an RFP allocation framework executed competently. Perhaps the lack of any serious enforcement of the Developments Requirements of auctioned Premium .mobi domains is due to the fact that it is difficult to objectively categorize a development as sub-par “after the fact” without running the risk of legal retaliation by the domain holders who would argue the contrary. This is yet another reason in favor of the RFP allocation method, which allows mTLD to assess a development “before the fact” and thus more-easily avoid being disappointed with the actual developments "after the fact". Simply put, Auctions attract speculators, whereas RFP’s attract genuine end-users. The main difference being, of course, that an end-user will almost always have a business and development plan for the domain that they need to complete those very plans, whereas a speculator will not (since they are simply speculating on the value of the domain rising in the future) and will simply create a quick site for the domains they have happened to win just in order to "comply". Even worse, speculators will often times win domains they weren't even targeting simply because they seemed like a “better deal” at the time of the actual auction. All of this results in improvised development plans which -- together with weak enforcements -- have led to a rotting .mobi ecosystem amongst Premium .mobi domains. Does ICANN truly wish to allow the same thing to happen with the shortest -- and therefore most mobile-relevant -- .mobi domain names? To be further transparent, I have never applied for an RFP to acquire a one or two-character .mobi domain name nor do I have any intention of doing so in the future, whether via RFP or auction. I am speaking purely with the interest of the .mobi ecosystem in mind. As such, I would like to formally voice my strong objections to this latest request by mTLD directly to ICANN, especially considering that mTLD saw "no need to consult directly with other constituency groups" as per their request form. Sincerely yours, Andres Kello Mobility.mobi, Owner Why.mobi, Campaign Director Former dotMobi Policy Advisory Board (PAB) member Former dotMobi Advisory Group (MAG) Steering Committee Member