Application Comment Details

Comment 2 of 2 - re: ‘Understated Registry COI Amount?’

We believe that the sum of US$140,000.00 provided by UniForum ZA CR is not sufficient to run all the critical registry functions of .Africa gTLD with an EBERO such .as: --DNS resolution for registered domain names; Operation of the Shared Registry System; Provision of Whois service; Registry data escrow ; Maintenance of a properly signed zone in accordance with DNSSEC requirements

The ICANN cost guidance estimates are more credible since these were provided after analyzing the costs obtained from several potential providers who responded to the Emergency Back-End Registry Operator – Request for Information.

If UniForum has clearly deviated from ICANN’s guidance estimates, it means that they have paid no attention to user and registrant protection, but have instead, put in a smaller amount and tried to justify same without considering the likely risks to users and registrants who have a lot to lose in the event that the .AFRICA registry fails and the amount of money (US$140,000.00) already set aside by UniForum prove too small to enable ICANN successfully transition the .AFRICA registry to an EBERO.

It is also possible that UniForum does not intend that in the event of the failure of the .AFRICA Registry, that ICANN be allowed to use an EBERO to continue running the registry functions of .AFRICA gTLD, because they intend, irrespective of any possible capacity limitations on their part, that if .AFRICA fails, then they should also be allowed to continue operating the registry based on the following statement that is indicated in their application to ICANN: “Due to its considerable investment into its technical registry capacity for .ZA, including the procurement and development of technical skills and resources, the Applicant is able to leverage this against the provision of critical registry services for dotAfrica in the event that the TLD is commercially unsustainable in its own right.”

If UniForum deliberately under-estimated the COI costs in order to submit a smaller COI amount, it is also possible on the other hand that they have actually charged more for the unit cost (at US$18.00) of standard domain names and put in a lower projected domain registration volume simply to justify the lower COI amount whilst still remaining in expectation of sizable registration revenues that they hope to garner for their registry operation. Anyhow, we believe that the ICANN Financial Evaluation should pay particular attention to this comment, and subject the UniForum COI estimations and the type of justifications that they have provided (in support of the COI amount submitted) to closer scrutiny. We think that irrespective of how UniForum managed to arrive at their own COI estimation, they should have compared it with the ICANN-recommended Cost Guidance Estimates in order to validate their own estimations and assumptions.

Even so, we believe that the ICANN Financial Evaluation should seriously consider this comment to ensure that UniForum does not earn the maximum evaluation points allowed for Question 50; and should actually be failed on this particular financial criteria because of their failure to provide ample risk protection for users and registrants on account of the understated COI amount that they have provided even as it is quite apparent to anyone reviewing their application that they have completely disregarded ICANN’s COI cost guidance estimates.