From: Justin Sullivan 
Sent: Wednesday, 22 September 2004 11:33 AM
To: info@auda.org.au
Subject: Submission to auDA Comptition Panel - JustNet Pty Ltd

I am writing on behalf of accredited registrar JustNet Pty Ltd (GoDomains) re the draft paper 
released by the Competition Panel.

Our belief is that the market size and dynamics in Australia are not conducive to the multiple 
registry model that is again being considered by the Panel. We support a single registry for all 
.au 2LDs.

The high skew towards "com.au" in the .au space also means that any multiple registry model is 
likely to leave one operator with the bulk of the .au namespace and one or more other operators 
with a much smaller volume of domains.

>From a registrar perspective, this is of concern to us in that a
multiple
registry model would involve us needing to deal with two or more organisations for our .au domains 
and consequently significantly increasing our overheads.

The Panel has noted that auDA could require the technical interface to be the same across multiple 
registries, thus minimising technical changes required at the registrar level. However, even 
relatively minor changes to technical interfacing could present additional costs to registrars and 
involve significant redesign of registrar/registry interfaces.

We also anticipate that a multiple registry model would entail numerous additional overheads beyond 
the technical aspects of the interaction. Additional contractual relationships with registry 
operators requires time and possible legal expense for contract review. The need for additional 
cash accounts at multiple registries involves more banking and bookkeeping costs for registrars. 
In combination with the low volumes involved in the 2LDs other than com.au, the overhead may be 
quite high relative to the value of the business being conducted. It is also more burdensome in 
percentage terms on registrars with lower transaction volumes. Managing the additional billing and 
technical support relationships on an ongoing basis would increase complexity and cost.

It is our understanding that almost all of the current auDA accredited registrars are small businesses, 
many of whom license domains as a core or sole product. The additional overheads in the multiple 
registry model are likely to impose a significant burden on these small businesses. We feel a 
multiple registry model could have the effect of decreasing competition in the marketplace rather 
than its intended aim of increasing competition. The additional costs involved to registrars in an 
already highly competitive market could lead to an increase in retail prices for domains and make it 
less likely that future reductions in auDA or registry fees are passed on to consumers.

We also envisage that if multiple registry interactions were needed, a number of registrars may elect 
not to interface with registry operators other than "com.au". This is due to the small volumes of 
domains involved in the smaller 2LD namespaces. If this were to happen, competition outside of com.au 
would reduce and prices for many 2LDs would be likely to increase as a result.

The new geographic names to be released by auDA will face similar issues with registrars and again we 
believe a single registry model is the best competitive outcome: if the implementation of new 2LDs can 
be done under existing registry contracts, billing arrangements and technical implementations we 
believe registrars will have much stronger support for new namespaces. If new registry relationships 
are necessary, we for one would be reluctant to offer new 2LDs unless a very compelling business case 
existed.

In seeking to meet the objective of the Competition Panel to attain greatest economic efficiency, our 
view is that this is best attained by competitively selecting a single, well-run and competitively 
priced registry operator that can meet all the required technical and service level issues across all 
.au 2LDs. We do not believe the .au industry will change sufficiently in the short or medium terms to 
warrant the recommendation of a multiple registry model for the foreseeable future.

Justin Sullivan
Managing Director
JustNet Pty Ltd