report-card.jpgJackson Hts., New York, August 3, 2014 - Not too long ago my wife dug up a Report Card of mine from 1954. While I’ve had quite a few since - some better some worse - on this eve of the .nyc Landrush I thought it might be fun to issue another that assesses my work on the .nyc TLD.

But what to assess? I could base it on the 2001 Internet Empowerment Resolution, which set my original course on .nyc, and claim an A grade. After all, the city has acquired .nyc and will run it as a public interest resource. “Great work Tom.”

But it’s 2014, and 13 years have elapsed. Over the last decade, as the ICANN’s new TLD award processes were evolving, my research uncovered broad areas where a city-TLD could facilitate a city’s operation: portals, markets, identity, security, privacy, economic development, civic and neighborhood betterment, and more. A fair assessment should consider how well those findings were reflected in .nyc’s structure.

Had this assessment taken place in 2009 high marks might have been in order, for when the city issued its Request For Proposals it included many of our findings in the requirements.

But the ICANN’s planning dragged on, and our research continued. And I recall speaking with a city official in 2012 about recent findings. Frustrated, he chided me for continuously raising the bar: “We’ve done everything you asked for. We can’t keep changing things. Be realistic.”

[Let me pause here for a moment to point out the transition from “I” to “we” in the previous paragraph. For this was a collaborative endeavor with my work enabled by a plethora of others. First there were my fellow community board members who listened and trusted that a city-TLD was important. There was the gentleman from Germany who goaded me in 2005 to reengage after a two year hiatus; a top TLD lawyer from Florida who guided me for several years; a board of directors who steered and encouraged me; a family that put up with this massive time eater; good friends who encouraged and criticized me; individuals and organizations that backed our effort with digital and financial resources; software engineers and other experts who advised; smart people in the DNS industry who taught me the ins and outs; city officials who strove to make the effort a success; and more. So I’m changing the nature of this assessment to one that looks at the overall city-TLD development process and its outcome. As to my personal Report Card, my work was far from perfect. Had it been better, our city-TLD would likely have provided more nuanced and beneficial features and benefits. But I’d like to think that I improved somewhat from my 1954 B in Effort.]

Before getting into the assessment, one final note on the city-TLD development environment. As the details of .nyc’s roll-out become clear, it’s increasingly apparent that we’ve been operating in what the economists call an “asymmetric knowledge” situation. This occurs where there’s inadequate expertise for one side to call upon in a negotiation. With this the first time cities have had the opportunity to develop their TLDs, the metric presented for comparison by the knowledge holder, the contractor, was name sales, not an improved quality of life. As a consequence, New York and the other cities applying for their TLDs were unprepared to evaluate the spectrum of opportunities presented. For a parallel situation see The Simpsons episode Marge Vs. The Monorail.

So, how did WE do?

I’ve rated 12 policy and operational criteria below. While the policies guiding these were selected during the Bloomberg years, the grades test against the current administration’s “progressive” standards. This results in rather poor grades: 2 Bs, 2 Cs, 3 Ds, 2 Fs, and 2 Incompletes. Summarized on a 4 point system, the effort receives a disappointing 1.3 GPA. But the two Incompletes and some flexibility the city built into the system offer some hope.

That said, here’s the good and the bad. Note: Some digging into the Links might be required to uncover the basis of our suggested remedies.                                                               

Subject Grade Explanation Remedy Links
C Inadequate pre-registration review. Post registration enforcement. Public pays for challenges. 
Expand P.O. Box description to include virtual office. Pre-registration review. More spot checks. City led challenges.
Market Creation Inc. No sign of development of local markets.
Many generic names reserved, so the potential exists for new local markets.  More
Landrush Auctions F No prior use preference. A regressive high-bid blind auction policy to resolve name contention. 60% of revenue flows to contractor in Virginia.
Give priority to existing name users. Run public auctions - put name contestants in touch with one another. More
Name Distribution Equity
F City rejected NYS Trademarks and d/b/a names of current business and organization owners.
Institute London’s Local Priority Preference process enabling existing businesses and organizations to get the names they now use. More
Sustainability  D- No expressed sustainability policy or programs. Third level name use in dotNeighborhoods effort is saving grace.
Few reserved names for future use. Establish programs enabling sharing and recycling of names.
Local Jobs D- No new registrar jobs created in city. Saving grace: you can request info on becoming registrar
Train and ease entry for local registrars. More
Consumer Friendly
C Complex and circuitous complaint process - city, ICANN, contractor, and At-Large have roles.
Centralize complaints. Assure refund for Landrush auction losers.
Governance D Closed city advisory board.
Create channels for public engagement.
Government Names
B+ The de Blasio Administration has acquired hundreds of names to foster city operations.
More transparency and public engagement in name selection would have earned an A.
Neighborhood Names B+ Traditional neighborhood names have been reserved for licensing to local residents. Dedicate funding for endeavor. More
Premium Names Inc. Regressive high-bid auctions for 2,000 names such as,,,, etc.
Premium names should have public interest clause. Hold public forums to create awareness and opportunity for local collaborations. More

Looking toward our next Report Card, we expect it to evaluate the work we’re doing outside the city. We’ve start working on an ICANN project setting the criteria for future applicants for city-TLDs: How do they prove their readiness. We’ve begun advocating that city-TLD applicants preparedness be improved by increasing the current level of awareness from “Non-objection” to “Informed Consent.”  As well, we hope to require engagement of the user community, through the formation of an At-Large Structure, in creating these applications. And finally, we hope to reorganize the mass of materials we’ve assembled over the years into an accessible resource library.   

Learn about Inc.’s thoughts for the future of city-TLDs.

Filed August 3rd, 2014 under Civics, Education

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