Application Comment Details

DotConnectAfrica Trust
ZA Central Registry NPC trading as Registry.Africa
Financial Capability Evaluation Panel
Understated Registry COI Amount
9 September 2012 at 00:18:40 UTC

This comment pertains to the Financial question No. 50 – Registry Continued Operations Instrument. (To cope with the imposed character size restriction, it is presented in two parts. The first part follows hereunder, and the second part follows in a subsequent comment as a continuation.)

Comment 1 of 2

This public comment draws attention to the amount provided by UniForum for the Registry Continued Operations Instrument, which DCA Trust believes is quite inadequate for a prospective registry like .Africa (DotAfrica). The ICANN Financial Evaluation Panel should particularly note this comment to ensure that that UniForum does not pass this Financial Evaluation Criteria for the COI, if the actual COI amount provided by UniForum has been deliberately understated.

DCA notes from the published parts of UniForum’s application (Application ID: 1-1243-89583) that they have provided a Continued Operations Performance Guarantee Instrument in the amount of US$140,000.00 (United States of America Dollars, One Hundred Forty Thousand Only). In the financial aspects, they have written thus: “The Applicant has provided a Continual Performance Guarantee to ICANN of US$140,000 with ABSA Bank, a subsidiary of Barclays Plc to secure the provision of critical registry services for the dotAfrica TLD for up to 6 years. Initial registration fees are estimated to be in the region of US$18 per year.”

When this US$140,000.00 amount is compared with ICANN’s published recommended cost guidance estimates/guidelines, it would appear on quick examination that the COI amount that has been provided by UniForum along with its .AFRICA application is indeed paltry, and profoundly falls short of ICANN’s recommendations. We strongly believe that the ICANN guidance estimates serve as a uniform standard, and should therefore be utilized by all Applicants as the benchmark for preparing and submitting COI amounts.

From the published ICANN COI cost guidance estimates (available at: the sum of US$140,000 is for a registry with a projected domain name size of 50,000 to 100,000 (fifty thousand to one hundred thousand domain names). We think that a projected registration volume of only 100,000 domain names for .AFRICA is quite low by UniForum’s own standards, seeing that they claim to have registered more than 750,000 domain names under their domain.

It is clear that UniForum’s US$140,000.00 COI amount is for a smaller size domain name registry, and we believe that this amount is grossly insufficient to cater for the necessary user and registrant protection from possible risks of .AFRICA registry failure (or business failure of UniForum ZA Central Registry). In a nutshell, it appears that UniForum is unwilling to amply protect prospective users of .AFRICA from the possible risk of registry failure. US$140,000 would hardly be sufficient to safely transition and run the .AFRICA gTLD registry with an ICANN-appointed Emergency Back-End Registry Operator (EBERO); who would undoubtedly charge more (than what UniForum has provided) in keeping with the ICANN Recommended Guidelines.