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NED candidates Q&As

5. Do you see the launch of the .uk second-level domains as a success?


- full answer -


First of all, what were the motives for launching the second-level domains at all? I think it’s obvious that the primary motive was the increased revenue that could be gained by pressurising millions of people to double up and cover their existing .co.uk presence on the web. It was launched as a money making project.

Now, there are undoubtedly some situations where a .uk works better than a .co.uk. For example, I specialise in religious domains, and among many others I have Christ.uk – it simply seems more appropriate than Christ.co.uk, unless you think religion is a business (which in some cases it is!). However, for most businesses, the introduction of .uk was frankly an inconvenience, because it put their established web property in danger unless they coughed up extra money, as a defensive mechanism, each year.

And yet, whether through poor marketing, or simply because many people simply did not want these extra domains, millions of .co.uk registrants decided not to register the .uk – even when given a generous 5 year period to do so.

That was not the success that Nominet had hoped for.

A study of the registration history makes for a rather sorry story. I’m tempted to say it was shoddy, but I’ll leave that for my answer to Question 6, and in the end you have to decide for yourself.

By the summer of 2017, three years after their launch, .uk domains were flat-lining at around 600,000 registrations. Well over 9 million .co.uk registrants had failed to register their equivalent .uk domain. For many people, it seemed, the project was of no interest. To others, it may have been an annoying inconvenience. However it could hardly be considered a success.

The largest registrars were undoubtedly hoping for a long-term windfall from .uk (indeed, one wonders whether they were champions of the project when it was proposed, because they stood to make the most money from it, along with Nominet themselves).

And then, wondrously, Nominet announced a short-term ‘free promotion’, and what followed was staggering. I cover it in detail in the next question, but suffice it to say at this point, that GoDaddy’s owned company 123Reg, and Namesco (and yes, those were the companies with directors on the Nominet Board) took this ‘gift from heaven’ as the chance to mass-register over a million domains between them, even though these were actually ‘fake’ registrations in the sense that the so-called ‘registrants’ had not asked for these domains, and the Registry-Registrar rules prohibited registrations without consent.

The benefit for Namesco and 123 Reg was that they hoped they would then persuade their ‘ghost’ registrants to later renew their domains annually – something of a desperate and forlorn hope as it turned out – and the benefit for Nominet was that it masked the failure of .uk by massaging registration figures a little.

When I say a ‘little’ I am using litotes (okay, just sarcasm): let’s look at the stats for 2017. Before the ‘free promotion’ and ‘mass registrations’ the .uk numbers had been a bit over 600,000. After this ‘magical’ promotion the figures had shot up to over 2,100,000 registrations. But the sad thing was that most of those were essentially fake: not asked for, not claimed, not wanted. Later events would prove this.

Nominet had promised the public that after 5 years, all unclaimed .uk domains would be made available to everyone. That was the agreed process and undertaking. However, the .uk domains were not doing as well as Nominet wanted to make out. Interviewed by Techradar in May 2019, the interviewer asked, “Have you seen a lot of interest from business?” The Nominet staff member – and he is actually one of the people at Nominet I generally respect – replied “Since its debut more than 2 million .uk domain names have been registered.” I’m afraid that was a rather disingenuous answer because most of those domains had not been requested by businesses, or indeed by anyone. About 1,400,000 of them had at that point been mass-registered, compared to fewer than 700,000 actually requested by customers. The mass-registrations served to mask the poor uptake of these new domains. They trebled the number of registrations claimed in their stats. But many more ‘ghost’ domains were about to follow the next month…

With weeks to go before the 5 year period came to an end, the registration of .uks had, as I say, been moribund since those previous mass-registrations. At this point Nominet, who already knew that other large registrars might follow the precedent set by their directors’ companies offered yet another ‘free promotion’, and this time Fasthosts and Ionos1&1 accepted the open door and copied their rivals, mass-registering more than a million more essentially ‘fake’ registrations. The .uk registrations were now ‘peaking’ at 3,600,000 – wow! amazing! – only problem being that the vast majority of those domains were unwanted domains, registered contrary to the registrar rule that registrants must request them, and these figures could only go in one direction… and that was a huge dump.

When one of my rival candidates said, in answer to this question, ‘.uk was very successful in the numbers registered’ I find that hard to believe when most of them were mass-registered for free, but weren’t asked for or wanted by the ‘so-called’ registrants themselves. How is that success? It was a sham. Events that followed proved this.

By January of this year, .uk registrations had crashed by 1,200,000 from the ‘fake’ peak, after Namesco (whose employee and sitting director is my fellow candidate in this election) and 123Reg dumped the unwanted mass-registrations. They’d never been asked for, they were never wanted, and they had also messed up the agreed process, that at the 5 year point Nominet had promised they would be released.

Now fast forward to this September 2020, and what we are going to see is well over a million more .uk names being dumped, because the Fasthosts group’s mass-registrations are also unwanted, were never requested, and the overall outcome will be close on 2/3rds of all the .uk registrations will have disappeared into nothingness, which was actually what they were all along.

By mid-September .uk registrations will have plummeted from a peak of 3.6 million (64% mass-registered and not requested) to little more than 1.3 million.

So has .uk project been a success? For some people, it has been useful. About 80,000 domains were eventually bought when the 5 year period was up – but over 2 million were unavailable because they’d been mass-registered. The situation 6 years after launch is that 8 out of 9 people have not chosen to buy a .uk to protect their .co.uk. That’s an awful lot of websites vulnerable to confusion, to rival companies, to maybe lost sales. In fact, as probably many of the .uk domains have been bought for speculation and warehoused, the actual use of .uk domains is even smaller.

Personally, the .uk domains work for me, in my specialist field. But I do think that the prevailing motive for Nominet and the large (mass registering) companies was the opportunity to make money, even if that meant inconvenience to their existing customers, circumvention of Registrar rules, disruption of agreed process, and some loss of reputation because of the way the large registrars and Nominet co-operated together, when actually – as we’ve seen in this Q&A process – almost all the candidates call out what happened as ‘not the right thing to do’.

It frankly bungled a project that was already in trouble. My hope for Nominet is that the interest in .uk domains will slowly increase. It probably needs to, because Nominet seems to be banking on increasing revenue to funnel into diversification projects. The logical other way to increase registry revenue is, of course, to raise the price of domain names…
 
6. Was it right for some registrars to mass-register over a million .uk domains which were due to be released for registration last July, following the right of registration period, when the registrants did not ask for them?



- summary answer –


Actually it was over two million names mass-registered.

The candidate seeking re-election – the employee of Namesco, one of the companies that did the mass-registrations – said she was ‘very comfortable’ with what her company had done.

None of the other 5 candidates are though.

‘That was done wrong.’ ‘No that wasn’t a good decision to make… it wasn’t a good thing to happen.’ ‘Was it right morally and ethically – that is a bit questionable.’ ‘I don’t think that was the right thing to do. Registrars can’t go round registering domains unless they’ve been instructed to do so.’

Exactly so: the Registry/Registrar rules specifically state that, and the rules should apply to all.

The mass-registrations ran contrary to several RRA clauses (specifically Clause 3.2 and 3.2.3, and also 3.2.6, 2.8 and 2.8.1).

What part of "You must not request a transaction if the Registrant you identify to us in the transaction has not instructed or requested you to act on its behalf" do they not understand?

Indeed, on the subject of free registrations a staff member made this point explicitly on the Nominet forum on 26th April 2017: “Registrants will have to positively register the domain through the registrar, it cannot be done by the registrar on behalf of the registrant.“

It is hard not to think that Nominet was complicit in this: when Nominet repeated the free promotion days before the 5-year deadline, they knew in advance that this could and would facilitate a second round of mass-registrations.

By the end of August 2019 .uk domains were peaking at 3,600,000 registrations, but the vast majority of these were ‘zombie domains’ attributed to ‘ghost’ registrants who never asked for the domains, never wanted them, and would never claim them. There was only one direction this usurpation of the process could inevitably take: massive name dumps.

By mid-September 2020 .uk registrations will have haemorrhaged over 2 million totally unwanted names. 2/3rds of all the .uk registrations will have disappeared into nothingness.

The whole process of the mass-registrations disrupted agreed process promised to the public, achieved very little, circumvented rules, and damaged Nominet’s reputation.

The motives: from Nominet’s point of view the mass-registrations temporarily saved face by artificially massaging registration numbers and masking the failure of .uk to take off at the level they had hoped for. It delayed judgment day. From the large registrars’ point of view, they hijacked 2 million domain names, in the hope that they’d reap renewals by people who had never asked for the names in the first place. It extended the time they could hope to get those renewals, and also stopped rival registrars getting the advantage and control of any of those names in July 2019.

I phoned Nominet several times about all this. They said it was up to the registrars what they did. Classic laissez faire. Just letting big customers do what they see fit doesn’t cut it.

If Nominet are so justified in their actions over the mass-registrations, why have they faced scathing criticism in tech media? And why do 5 of the 6 candidates in this election (the only exception being the Namesco candidate herself) call their actions into question?

The UK namespace is not the private fiefdom of a few big tech companies to do as they please. It is UK national infrastructure.

I cannot escape the personal view that what occurred here was really poor judgment. The free registrations helped these large companies as they went ahead with the circumvention of RRA rules – rules that are meant to be followed by everyone - and then the Executive sat back and watched. It wasn’t worth the bad PR, and disruption of their process, for what – the eventual dumping of 2 million ‘zombie’ domains because still, even after 6 years, they weren’t requested or wanted.
 
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6. Was it right for some registrars to mass-register over a million .uk domains which were due to be released for registration last July, following the right of registration period, when the registrants did not ask for them?


- full answer -


Actually it was over two million.

The candidate seeking re-election – the employee of Namesco, one of the companies that did the mass-registrations – said she was ‘very comfortable’ with what her company had done.

None of the other candidates were uncritical though.

That was done wrong.

No that wasn’t a good decision to make… it wasn’t a good thing to happen.

Was it right morally and ethically – that is a bit questionable.

And the fourth candidate, Lindsay Hamilton-Reid, was more forthright and I applaud her for that: she said that she didn’t think it was right, because frankly people had had 5 years to register the names if they wanted to. After that the names should have been open to others. She added that registrars can’t go round registering domains unless they’ve been instructed to do so by the registrants.


Exactly so: the Registry/Registrar rules specifically state that, and the rules should apply to all.

The mass-registrations ran contrary to several RRA clauses (specifically Clause 3.2 and 3.2.3, and also 3.2.6, 2.8 and 2.8.1).

What part of "You must not request a transaction if the Registrant you identify to us in the transaction has not instructed or requested you to act on its behalf" do they not understand?


Indeed, on the subject of free registrations a staff member made this point explicitly on the Nominet forum on 26th April 2017: “Registrants will have to positively register the domain through the registrar, it cannot be done by the registrar on behalf of the registrant.“


So before I set out my answer, I think it’s fair to say that all the candidates except the one seeking re-election, whose company committed mass-registrations, were unsettled by what had happened. Nominet’s acquiescence in the process worries me as much as the cavalier conduct of those 4 large registrars, disrupting the whole ROR process, circumventing Registry rules, and being left to basically do what they wanted, with Nominet saying that was a matter for the registrars. Classic ‘laissez faire’ arrangement between a Registry and its largest customers. More than laissez faire – because when Nominet repeated the free promotion days before the 5-year deadline, they knew in advance that this could and would facilitate a second round of mass-registrations. Anyone who has followed the convoluted annals of ICANN, and Afilias, and Neustar (now owned by GoDaddy) as I have over 20 years will recognise the familiar pattern of large insider interests operating together for mutual exploitation of a commodity which frankly should be stewarded in the interests of all, not just powerful insiders who happen to be the biggest customers . It’s happened again recently with ICANN giving the nod for unjustified price hikes for .com domains for the next five years. They should have challenged that – they waved it through. It almost seems part of the institutionalised culture of the Domain Name Industry. The biggest companies seek to colonise the decision-making bodies and influence their decisions in their favour. That at least is my view. My personal take is that these huge (and expanding) companies shouldn’t be ‘inside’ governance bodies at all.

(continued...)
 
(continuing...)


However – to the facts and events.

Summer of 2017: .uk registrations flat-lining at around 600,000, three years after launch.

Autumn 2017: Nominet offer free registrations. 123Reg (owned by GoDaddy) and Namesco register well over a million domains. In a matter of weeks registrations have risen from 600,000 to 2,100,000.

However, most of these are registered without the registrant asking for them or wanting them

This breached the Registry/Registrar rule that forbade unrequested registrations.

Through 2018 .uk registrations, most of them unwanted anyway, continue to flat line.

June 2019: little more than days before the end of the 5-year reclaim period, after which Nominet had undertaken to release all the names to the public, it runs another ‘free registration’ promotion, knowing that this could and would facilitate over a million more .uk names to be mass-registered by the Fasthosts group, following the previous precedent, and disrupting the agreed 5-year process. It was blatant facilitation of mass-registrations that they knew were almost certainly going to happen.

Fasthosts and Ionos1&1 accepted the ‘open door’ and mass-registered over a million more domains for free, in the names of people who did not ask for them.

July 2019: the supposed end of the 5 year limit when the public were promised the release of all unclaimed .uk domains. In the event about 80,000 where taken up by the public in July and August, a tiny number compared to about 2,300,000 mass-registered domains not available because of the mass-registrations.

By the end of August 2019: .uk domains were peaking at 3,600,000 registrations, but the vast majority of these were ‘zombie domains’ attributed to ‘ghost’ registrants who never asked for the domains, never wanted them, and would never claim them. There was only one direction this usurpation of the process could inevitably take: massive name dumps.

January 2020: The Namesco name dump. By the end of January registrations have crashed 1,200,000 from their artificial peak. But the dump of unwanted names goes on.

September 2020: The Fasthosts and Ionos1&1 name dump. People have now been waiting over 6 years for access to this part of the UK namespace.

By mid-September 2020 .uk registrations will have haemorrhaged over 2 million totally unwanted names. 2/3rds of all the .uk registrations will have disappeared into nothingness.

The whole process of the mass-registrations disrupted agreed and promised process, achieved very little, circumvented rules, damaged Nominet’s reputation.


The motives: from Nominet’s point of view the mass-registrations temporarily saved face by artificially massaging registration numbers and masking the failure of .uk to take off at the level they had hoped for. It delayed judgment day. From the large registrars’ point of view, they hijacked 2 million domain names, in the hope that they’d reap renewals by people who had never asked for the names in the first place. It extended the time they could hope to get those renewals, and also stopped rival registrars getting the advantage and control of any of those names in July 2019.

I phoned Nominet several times when these mass-registrations were taking place, asking Nominet if they were going to allow these to stand. Nominet said it was up to the registrars what they did, and Nominet were content because it would (and I quote) “stop cyber-squatters getting them”. However, 5 years – as my fellow candidate Lindsay pointed out well – is sufficient time for people to make up their minds if they wanted the names. The mass dumps demonstrate that they never did want them. Instead, ironically, it was Namesco, 123Reg, Fasthosts and Ionos who turned out to be the cyber-squatters, sitting on 2 million unrequested domains, and thereby wrecking the agreed process for their release, and the public’s access to them.

What I want most of all is proper process, respected and upheld. What I hate about the domain industry is when it lapses into 'laissez-faire'. I've seen that with ICANN. I don't want it here in the UK.

I see the internet as a huge potential good, and the DNS is a key part of that fabric. The DNS needs to be administered with rules and integrity. Protocols matter. Nominet’s primary function should be to protect the system so many rely on, with a rules-based order that is enforced and maintained in a fair, uncompromised and secure way. Just letting big customers do what they see fit doesn’t cut it. The UK’s namespace is more important than GoDaddy or Namesco. Nominet are stewards on behalf of the nation. That is a privilege I expect them to live up to. This episode in my view fell short. That’s not just my view.

If Nominet are so justified in their actions over the mass-registrations, why have they faced scathing criticism in tech media? And why do 5 of the 6 candidates in this election (the only exception being the Namesco candidate) call their actions into question?

I am far from suggesting that Nominet’s intentions were pure evil or anything like that. No. In my view Nominet were just too casual, and I cannot escape the personal view that what occurred here was really poor judgment. The free registrations helped these large companies as they went ahead with the circumvention of RRA rules – rules that are meant to be followed by everyone - and then the Executive sat back and watched. It wasn’t worth the bad PR, and disruption of their process, for what – the eventual dumping of 2 million ‘zombie’ domains because still, even after 6 years, they weren’t requested or wanted.

I am not being negative in this. I want Nominet to flourish. But the UK namespace is not the private fiefdom of a few big tech companies. It is UK national infrastructure. It is vital it is run with best standards that can be trusted. If these large registrars can hijack agreed process, and do their own thing (and the Executive basically said it wasn't Nominet's business - even when the RRA clauses were circumvented - it was up to the big companies to police themselves)... if the largest registrars can dominate policy outcomes to this extent, then that is very concerning... not only in the past but for the future as well.
 
Okay, I'm going to blast through the last 5 statements to get them done, because I'm moving to the next stage of my election candidacy.

If you like things more succinct, a simple overview of what I stand for can be seen on the homepage of my website.
 
7. In September, about 1 million .uk domains are set to drop, with only 2.3 million .uk’s currently. Why are people not renewing .uk?


- summary answer –


This question slightly embarrassingly exposed some of my fellow candidates’ poor grasp of what these September drops are all about, or their attempts to gloss over the reason so many are dropping. It references the September dump of over 1 million mass-registered .uk domains by Fasthosts and Ionos1&1.

One candidate hazarded a guess that the registrants had bought the domains cheap when Nominet offered its promotion. That would actually be… over 1 million people NOT buying them at all. Never asked for. Never wanted. Most people did not want to be pressured into paying for 2 domains instead of 1 when this money-making project was launched. They did not welcome the potential brand confusion it could cause and the inconvenience, but even so they voted with their feet and turned away. That should have been the end of it

The director and candidate whose company perpetrated mass-registrations suggested: ‘The registrants will have loads of renewal reminders, not only from the registrar they bought them from, but also from Nominet.’ No. The whole point about the September mass dump and Namesco’s own dump in January – and indeed over 2 million names dumped in total – was that the “registrant” never “bought” them in the first place.

No, these domains were not “bought”. They were not requested. They were never wanted. In some cases the named registrants were dead. The reason people are not renewing them is that they were effectively ‘fake’ registrations, ‘zombie’ domains, naming ‘ghost’ registrants who had no part in the process. Is it hard to understand, then, why so many people are not ‘renewing’ them?

These mass dumps, and the collapse in the .uk figures (from a 3,600,000 peak to around 1,300,000 in a few weeks’ time) are demonstrable evidence of how unwanted the domains were. They had 5 years to get them and use them if they wanted to. Over 6 years later (thanks to the disruption of the process) they still do not want the domains.
 
7. In September, about 1 million .uk domains are set to drop, with only 2.3 million .uk’s currently. Why are people not renewing .uk?


- full answer -


This question slightly embarrassingly exposed some of my fellow candidates’ poor grasp of what these September drops are all about. I do think – given that I am a registered nurse and supposedly an industry outsider – that I should expect other candidates to at least have some handle on events going on. Maybe I am just a nerd when it comes to the domain industry (always have been – ICANN used to struggle with my stubborn exhumation of facts)… but look at the wording of the question…

It starts with reference to the September dump of over 1 million mass-registered .uk domains by Fasthosts and Ionos1&1 which, of course, and as outlined in my answers to Questions 5 and 6, were never asked for, and were never wanted.

It then asks: ‘Well why are people not renewing them?’ I would expect my fellow candidates to be well-versed about what this dump of a million names was all about, and why and how it had come about.

One candidate hazarded a guess that the registrants had bought the domains cheap when Nominet offered its promotion. That would be… over 1 million people NOT buying them at all, and the registrars enabled to mass-register them all, without the registrants asking them to or wanting them to.

The director and candidate whose company perpetrated mass-registrations suggested: ‘The registrants will have loads of renewal reminders, not only from the registrar they bought them from, but also from Nominet.’ No. The whole point about the September mass dump and Namesco’s own dump in January – and indeed over 2 million names dumped in total – was that the “registrant” never “bought” them in the first place. They never wanted them then, and they still didn’t want them when they expired. As Lindsay Hamilton-Reid said, along with all the other candidates on the ethical front, it was not right to mass-register these domains – as she added, you can’t go about registering domains if you haven’t been asked to. The Registry/Registrar rules clearly state that you mustn’t.

That was actually a very strong reprimand of the sitting Namesco candidate’s company. There is clear water between those two candidates on this issue.

However, Nominet’s executive have questions to answer as well, about what I would say was poor judgment on this issue: they let this all happen, and that’s why we now have the September mass-dump of domains, which completes the deletion of two million domains that had been ‘mass-registered’.

No, these domains were not “bought”. They were not requested. They were never wanted. In some cases the named registrants were dead. The reason people are not renewing them is that they were effectively ‘fake’ registrations, naming ‘ghost’ registrants who had no part in the process. Is it hard to understand, then, why so many people are not ‘renewing’ them?

These mass dumps, and the collapse in the .uk figures (from a 3,600,000 peak to around 1,300,000 in a few weeks’ time) are demonstrable evidence of how unwanted the domains were. They had 5 years to get them and use them if they wanted to. Over 6 years later (thanks to the disruption of the process) they still did not want the domains.

There are people who want to use .uk domains. But you’re not going to get 2 million people to renew domains they never registered in the first place.
 
8. In hindsight, would it have been better for the brand, consumer, and longevity of the exercise, if there had been a permanent link between .co.uk and .uk?



- summary answer –



The reason why the two domains were not coupled at the outset was obviously financial. If Nominet had just given the .uk name to the .co.uk holder for free indefinitely, then the dominant purpose behind their decision to launch .uk would have been cancelled out. On the other hand, if the .co.uk had been coupled to the .uk and then registrants were required to pay for both, they would have voted with their feet.

If you ran a business, using the .co.uk, then the introduction of the .uk could pose a threat to you if somebody else registered it. So you might feel kind of forced to pay the extra, reluctantly. In practice over 9 million registrants chose NOT to pay double for something they didn’t want.

On the other hand, if you were newer to domaining, given that most .co.uk domains with good names have been taken for years, you might see the introduction of .uk as an opportunity. But domainers are only going to register a niche selection of names they believe can be monetized. You need a far wider constituency to come on board to make something like .uk work on a larger scale – but people already had .co.uk for their purposes, and felt no need to cough up extra money to duplicate what they already had online.

As for the ‘longevity’ of the exercise, mentioned in the question: I don’t see .uk going away. I think it will have longevity, but any growth may be unspectacular.

But surely that’s alright? Domains exist for people and communities. If they want them, they will register them. This is where a sense of proportion is needed in Nominet’s understanding of itself. Domains don’t exist for the sake of vast corporates making money, or even Nominet’s expansion projects. They exist for people to use, if they want to. So, seen in that light, .uk will grow in proportion to its usefulness.
 
8. In hindsight, would it have been better for the brand, consumer, and longevity of the exercise, if there had been a permanent link between .co.uk and .uk?


- full answer -


I think life is full of ‘what if’s. In any case, here we are now, and in real and practical terms there is little point closing the stable doors after the horse has bolted.

The reason why the two domains were not coupled at the outset was obviously financial. If Nominet had just given the .uk name to the .co.uk holder for free indefinitely, then the dominant purpose behind their decision to launch .uk would have been cancelled out. They launched .uk to make money for themselves and the very large registrars who would make most from the new cash cow (or so they hoped).

On the other hand, if the .co.uk had been coupled to the .uk and then registrants were required to pay for both, they would have voted with their feet. They would have declined to renew the .uk ones. We know this because that’s exactly what happened when they declined to renew 2 million mass-registered names that they just did not want.

Would the permanent link have been better for the brand? If it had been permanently free, then yes it possibly may have been. But that was never going to happen.

From the consumer’s point of view, there are multiple takes on this, depending on the various types of consumer.

If you ran a business, using the .co.uk, then the introduction of the .uk could pose a threat to you if somebody else registered it. So you might feel kind of forced to pay the extra, reluctantly, if it mattered much to you. You had five years to make that decision which was a huge amount of time to make up your mind. In practice over 9 million registrants chose NOT to pay double by getting the second level domain.

On the other hand, if you were newer to domaining, given that most .co.uk domains with good names have been taken for years, you might see the introduction of .uk as an opportunity to get a really useful name for your enterprise. About 80,000 domains were taken like that at the end of the 5 year period when all unclaimed domains were supposed to be released. The problem was that over 2 million names were not released then for the reasons discussed in Questions 5, 6 and 7. Added to which, the really good names that came on stream were hoovered up in questionable circumstances, because Nominet had lost control of some parties who seemed to ‘game’ their processes with huge success to the detriment of others.

In any case domainers are only going to register a niche selection of names they believe can be monetized. You need a far wider constituency to come on board to make something like .uk work on a larger scale – but people already had .co.uk for their purposes, and felt no need to cough up extra money to duplicate what they already had online.

As for the ‘longevity’ of the exercise, mentioned in the question: I don’t see .uk going away. I think it will have longevity, but any growth may be unspectacular. But surely that’s alright? Domains exist for people and communities. If they want them, they will register them. This is where a sense of proportion is needed in Nominet’s understanding of itself. Domains don’t exist for the sake of vast corporates making money or even Nominet’s expansion projects. They exist for people to use, if they want to. That is all part of Nominet’s unusual platform. It’s a privileged platform, but it also involves protection of people’s access to namespace, and stewardship on behalf of the UK and communities and charities and all kinds of public and private services.

So, seen in that light, .uk will grow in proportion to its usefulness.

Of course, Nominet may be able to communicate all kinds of ways that people could use .uk, and if that connects with people – great!

I suspect in reality it will be quite a gradual journey.
 
9. During the time of great economic uncertainty and a global pandemic, how do you think Nominet should be supporting registrars and registrants?


- summary answer –


In my answers to this series of questions I haven’t avoided raising tough questions for Nominet, and I think that’s exactly what a director who wants the best for a company should do.

However, I genuinely like it when Nominet does things well: The Samaritans Self-Help App, the work with Stem 4. And along with its Digital Citizenship Badge, Nominet has supported the Scouts’ Great Indoors Project, to engage young people during lockdown and promote digital skills. Along with BT, Nominet has supported ‘Future Dot Now’ and in lockdown ‘Devices Dot Now’.

I believe that Nominet works best when it harnesses its funding and its tech connections in collaboration with existing charities.

Now moving to registrars and their registrants, this is for many people indeed a time of great stress and for some families the economic crisis is pitiful. Registrars have had chances to pass on some Nominet concessions where they encounter registrants in difficulty, which they hopefully have, looking out for all those in vulnerable situations such as many in the hospitality sector.

More concerning in the context of the present consultation on dropping domains is the impact that radical changes could have on some Nominet members themselves. To be plain, this is a terrible time to impose sweeping changes.

It is very well to carry out public benefit works in the wider community (which I commend) and yet not good if it fails to show the same care to people in its own household (its members).

Therefore I propose that during this Covid-19 season and its economic aftermath (and I don’t think we can expect all this to be sorted overnight) the issue of dropping domains should be put on hold for – I suggest – 24 months.

In that interim period Nominet could try to double down on system flaws and parties gaming their processes, and at the same time trial other people’s proposals for an effective and working system, rather than just freezing options to the binary of auctions or ECA.

I think this is an issue of basic respect, when a company knows its decisions will significantly impact on people who have committed to its systems, who need time to re-model their businesses (and family finances) if changes go ahead, but who also deserve efforts to see if other rational proposals can be explored and even trialled during this hiatus in so many people’s lives.
 
9. During the time of great economic uncertainty and a global pandemic, how do you think Nominet should be supporting registrars and registrants?


- full answer -


In my answers to this series of questions I haven’t avoided raising tough questions for Nominet, and I think that’s exactly what a director who wants the best for a company should do. Fear-driven, defensive management tends to suppress open-mindedness or dissent, and can reduce vibrancy, imagination, lateral thinking, creativity. Therefore I think it is absolutely right for me to be challenging and demanding, and a confident company will welcome that.

However, I genuinely like it when Nominet does things well. So I want to start by affirming and applauding the measures that Nominet has already taken to support various groups, inside and outside the domain industry, during lockdown.

The Samaritans Self-Help App, funded and supported by Nominet, was a brilliant tech-supported concept, especially relevant in a time of lockdown and sadly, for many, financial crisis.

Similarly, the work with Stem 4, was genuinely valuable in helping young people over mental health, and this past year has undoubtedly been a time of great stress for many children and young adults.

Along with its Digital Citizenship Badge, Nominet has supported the Scouts’ Great Indoors Project, to engage young people during lockdown and promote digital skills.

Along with BT, Nominet has supported ‘Future Dot Now’ and in lockdown ‘Devices Dot Now’.

I believe that Nominet works best when it harnesses its funding and its tech connections in collaboration with existing charities. In my opinion the ones I’ve mentioned above are good examples.

If Nominet is to be an exemplary Registry in an industry that has a very imperfect track record, then it needs to give value in all its activities – and by that I don’t just mean price, I mean decency, goodness, and engagement with the society and communities it serves. That kind of excellence (what Plato called apetn) is classy. So I really encourage initiatives like these, and I hope if/when elected to engage closely with Nominet staff engaged in projects like these. This isn’t (or shouldn’t be) about PR and window dressing. This is about a mindset that good management tries to see permeating through the whole company. Everything about Nominet should aspire to be classy.

Now moving to registrars and registrants, this is for many people indeed a time of crisis. For some families the economic crisis is pitiful. Can Nominet afford to suspend or reduce registrations fees across the board, or put back renewals by 6 months? That depends what reserves they have, but realistically I don’t expect that to happen, and maybe the pragmatic approach has been to empower registrars to draw on Nominet support where they encounter registrants in difficulty, for example in sectors like hospitality facing especial hardship because of the pandemic.

More concerning in the context of the present consultation on dropping domains is the impact that radical changes could have on some Nominet members whose livelihoods are likely to be threatened, and who I know – from listening to members on forums – are concerned for their businesses and their family finances.

To be plain, this is a terrible time to impose sweeping changes, and this is something within Nominet’s power to defer or to further review.

If Nominet wants to be regarded as a decent company, I suggest that in the present unprecedented health and economic crisis, they owe some respect to the members who would be affected by changes that Nominet appears to be proposing.

It is very well to carry out public benefit works in the wider community (which I commend) and yet not good if it fails to show the same care to people in its own household (its members).


Therefore I propose that during this Covid-19 season and its economic aftermath (and I don’t think we can expect all this to be sorted overnight) the issue of dropping domains should be put on hold for – I suggest – 24 months. When I say ‘put on hold’ I suggest that should not equate with doing nothing. I believe that in that interim period Nominet could try to double down on system flaws and parties gaming their processes, and at the same time trial other people’s proposals for an effective and working system, rather than just freezing options to the binary of auctions or ECA.

The really regrettable thing about the consultation on these issues has been the impression that Nominet is set on imposing one of their two basic ways, regardless of the people they say they want to consult with. This is reflected in the choice people are asked to make between Nominet’s options, whereas to be open and truly listening there should have been a third option – ‘Other ways forward’ – so the actual range of opinions could be properly measured. It is quite significant that more people have signed Andrew Bennett’s petition than have participated in the consultation.

So I suggest that the best way Nominet can help its registrars at this time of crisis is to put changes on hold, allowing time to consider all options further. I think this is an issue of basic respect, when a company knows its decisions will significantly impact on people who have committed to its systems, who need time to re-model their businesses (and family finances) if changes go ahead, but who also deserve efforts to see if other rational proposals can be explored and even trialled during this hiatus in so many people’s lives.
 
10. Nominet has changed significantly as an organisation since (the questioner) encountered it first in 2001. What do you think have been the main positives and negatives on that progression?


- summary answer –


I registered my first UK domains in the late 1990s and back then you received your certificates through the post. The internet was younger and its full commercial scope had not yet been envisaged by many people.

When I look at Nominet’s positives since then, I’d say that its systems and the management of domains are easier. Compared to many companies in the domain industry, I find Nominet reasonably responsive. I’ve mentioned in Question 9 my very positive views about some recent Nominet public benefit initiatives, where I am impressed that, collaborating with other organisations, tech can be harnessed to help young people and others, at a time of great challenge. Finally, on the positive side, I genuinely believe Nominet has a platform where they can be an exemplary Registry, doing what they’re entrusted to do: running the UK namespace without clique or favour. I believe it has that potential, and I could name some staff members who I believe have the presence and ability to achieve that.

On the negative side of the coin, I sometimes feel that the management of things is unsubtle. For example, the way the candidates Q&A webinar has been tucked away and made unnecessarily tedious to access. On the negative side of public benefit work, I share the doubts many people have about Nominet closing down the charitable trust, and bringing their charitable work in house. Something tells me – and especially if Nominet ends up generating funds from expiring domains – that it is discreet and appropriate to put some distance between the company and the administration of charitable funds.

Also on the negative side, Nominet is vulnerable to consolidating tech empires, who will seek any opportunity to expand into Nominet’s governance and ways of working, and colonise the company with a kind of investment fund, corporate mentality. I think some members feel that things have shifted that way in Nominet. In seeking to expand out into the US and global market, Nominet will need to guard against losing sight of its raison d’etre: the stewardship of the UK namespace. That is an entrusted platform: what it’s been commissioned to protect. It’s also a major source of revenue.

So my concerns – rational ones, not overwhelming ones – are in the area of corporate expansionism: both Nominet’s own understood need to diversify and expand, and the risks of large tech companies colonising the company, and using their presence and commercial dominance to influence policy, to monetise processes, and even not impossibly to buy out the company and add it to their acquisitions. It’s this corporate mentality that I feel most cautious about: the way things are done, the way people are treated, the service people receive – and the ethos and integrity of the company, which could be a very good company, but which needs openness, creativity, diverse opinions, challenge, humour, the ability to listen more to customers.
 
10. Nominet has changed significantly as an organisation since (the questioner) encountered it first in 2001. What do you think have been the main positives and negatives on that progression?


- full answer -


I registered my first UK domains in the late 1990s and back then you received your certificates through the post. The internet was younger and its full commercial scope had not yet been envisaged by many people.

Back then I was appalled by some of the Registries and Registrars further afield in the wider world, when it came to .com, and (for example) the fiasco of the .info launch. I was also very unimpressed by ICANN and the way it seemed entwined in a world of insiders – registries and registrars – who seemed to be entangled in all sorts of conflicts of interest. There were exceptions in that world. Elliot Noss at Tucows was accessible, personally intervened several times for me, and could usually be seen taking ethical high ground. At the other extreme I found Afilias abysmal, and I was very involved in forcing them to re-run their .info launch when I proved that thousands of people (including one of their own directors) had used fake trademarks to snatch the best .info domain names in their sunrise period.

In contrast I found Nominet here in the UK a more straightforward set up, and more ‘what you see is what you get’. It was a much smaller operation back then of course, less marketed than it is today, less corporate in nature, and I suppose some would say less ambitious. Nevertheless it worked, a bit clunkily, but it served my needs.

When I look at Nominet’s positives since then, I’d say that its systems and the management of domains are easier. I know I can be challenging in some of my views, but I do generally find that I can get through to Nominet staff, and some staff have been easy to engage with. Of course, as with many companies, when you start challenging or pressing the wrong buttons, there’s a tendency for people to close down dialogue and become distant and minimally responsive. I’m used to that defensive instinct in company people. Nevertheless, compared to many companies in the domain industry, I find Nominet reasonably responsive.

On the negative side of that coin, staff do sometimes seem to be fed a party line on a contested issue. For example, in conversations with them they have NEVER acknowledged the clear and incontestable fact that the mass-registrations contravened RRA clauses (specifically Clauses 3.2 and 3.2.3, and also 3.2.6, 2.8 and 2.8.1). As I mentioned in Question 6:

What part of "You must not request a transaction if the Registrant you identify to us in the transaction has not instructed or requested you to act on its behalf" do they not understand?

That kind of wall of silence and pretence on an issue can all become a bit Alice in Wonderland at times.

I sometimes feel that the management of things is unsubtle. For example, I undertook to respond to all these questions within 24 hours. In the event, the notification of the Q&A webinar was tucked away at the very foot of a separate message, and even then, it required the hassle of applying for the password for access to view it, and so I missed that link for several days. Other people probably did too. But the signal it gives out – and I can well believe it, having finally viewed the webinar – is ‘We don’t feel this gives a very good corporate impression of Nominet, the candidates aren’t well focussed, some of the questions impugn us, and it’s probably better to tuck it away and firewall it so a minimum number of people bother to view it.’

In contrast, my answers are public, less rushed, and hopefully better-informed: they are being published on the leading UK domain name forum, on Nominet’s own forum, and (as I undertook on my election video) on my website at Susannah.uk. People should be able to have simple access to what election candidates stand for, and candidates should be happy to be open about their views. Although I will not reproduce the Q&A session in its totality, we do not live in Communist China, and I have analysed some of what was said on that webinar from a reporting and journalistic point of view, including a very small number of quotes, most of them quoted indirectly. I have said all along that I will run for election on my agenda not Nominet’s agenda. I did offer the possibility of participating in the filmed webinar if I had 24 hours’ notice of questions, but that offer was not taken up. Besides, basing my campaign on my own chosen platforms suits me better, because it makes the point that I am a candidate who wants to be seen as independent and not a corporate shill. That said, although I dislike Nominet’s tendency to corporate defensiveness, I do still see the potential good in the company, in specific staff I’ve engaged with, and I hope my openness and good humour (and hopefully kindness) will be infectious. I am socially confident.

I’ve mentioned in Question 9 my very positive views about some recent Nominet public benefit initiatives, where I am impressed that, collaborating with other organisations, tech can be harnessed to help young people and others, at a time of great challenge. I agree with my fellow candidate, Lindsay Hamilton-Reid, that collaboration is the key to best outcomes, with Nominet trying to support and facilitate projects where charities identify needs, and working with them.

On the negative side of public benefit work, I share the doubts many people have about Nominet closing down the charitable trust, and bringing their charitable work in house. On the one hand, I’ve admired quite a bit of the recent good work done. I can see why an in-house approach might be useful when you’re using your connections to draw on people’s skills. On the other hand, something tells me – and especially if Nominet starts to generate funds from expiring domains – that it is discreet and appropriate to put some distance between the company and the administration of charitable funds. For that reason I am inclined to favour the restoration of a Nominet Trust separate and distanced from the company.

(continued...)
 
(continued...)

Finally, on the positive side, I genuinely believe Nominet has a platform where they can be an exemplary Registry, doing what they’re entrusted to do: running the UK namespace without clique or favour. I believe it has that potential, and I could name some staff members who I believe have the presence and ability to achieve that.

In contrast, on the negative side, Nominet is vulnerable to consolidating tech empires, who will seek any opportunity to expand into Nominet’s governance and ways of working, and colonise the company with a kind of investment fund, corporate mentality. I think some members feel that things have shifted that way in Nominet. It is true that the domain market is mature and because sales of uk domains have sometimes seemed moribund, the temptation (or logic) is to expand and seek out other markets. That’s not unthinkable but it is fraught with dangers and vulnerabilities. There are arguments for diversifying, as Nominet has, into management of other Registries. They have near to 2 million domains ‘under management’, handling back-end technical functions. That at least is native to Nominet’s founding commission. When it comes to cyber security, there are many ‘big players’ in that sector, and to compete Nominet are probably going to need to find their specialist niche in the market. In one way, expansion into cyber security fits with Nominet’s own responsibilities and role within the UK’s Active Cyber Defence. However, in seeking to expand out into the US and global market, Nominet will need to guard against losing sight of its raison d’etre: the stewardship of the UK namespace. That is an entrusted platform: what it’s been commissioned to protect. It’s also a major source of revenue.

So my concerns – rational ones, not overwhelming ones – are in the area of corporate expansionism: both Nominet’s own understood need to diversify and expand, and the risks of large tech companies colonising the company, and using their presence and commercial dominance to influence policy, to monetise processes, and even not impossibly to buy out the company and add it to their acquisitions. That is the methodology of the consolidating Registries and Registrars, and their parent companies. GoDaddy has spent over a billion dollars in buy-out acquisitions in the past year. Nominet is tiny. More than that, GoDaddy itself is now a Registry as well as a Registrar, and as a Registry is seated and positioned inside Nominet. That really does raise questions about conflicts of interest.

At this point in time though, and in the three years of directorship if I am entrusted, it’s the corporate mentality that I feel most cautious about: the way things are done, the way people are treated, the service people receive – and the ethos and integrity of the company, which could be a very good company, but which needs openness, creativity, diverse opinions, challenge, humour, friendliness. If elected I don’t doubt for a minute some people will be anxious about me on arrival, fearing I will be disruptive. I don’t doubt there may be efforts to marginalise me, and tuck me away in roles where I can do least damage. Tucked safely away like the Q&A webinar, where it can’t do any harm to the company image. It’s obvious there’s a risk of that. But at the same time, what an opportunity: to engage with people, to meet new people, to be a new presence, to learn from people, to share with them, to support, to challenge, to seek out the good and call out the bad, to colonise the company myself, to influence, to be someone people can turn to in times of trouble, as they get to know me, to care about people, to be positive and aspirational. Some people have said ‘Don’t bother.’ But I believe I have the social confidence to take people on, ideally with good results, and to enjoy that process along the confrontation margin lands between fear and trust. I look forward to ‘first contact’ with our CEO for example. Will be interesting!

If we’re asking candidates about the company’s positives and negatives, that’s one factor in the equation. As a director though, there’s another factor and that is what positives the new director can bring into the organisation. I’ve been a governor grade in prisons, I’ve faced down high security inmates, and wings on the edge of riot. I’ve been a Head Teacher with all the experience that involves, dealing with people. I am a nurse. No, I’m not an insider but I’ve got a better grasp of industry details (I suggest – watch the Q&A video and see if you agree) than most of the other candidates. Not being an insider is arguably better than being an insider, because I have no conflicting interests. None whatsoever. I am running my candidacy my own way, and I want to support all Nominet’s positive qualities and potential. As I said before, challenging things is what a director should do, and a confident company will welcome that. I can be a handful, but all my referees confirm my maturity and emotional intelligence. And goodwill.
 
11. Are you a member of the Company? If not, why, and will you join?


Yes. I’ve been registering hundreds of domains at any one time since the late 1990s. I am a Nominet member and a registrar, and take a close interest in the company, and have for years.

I have also been engaged with ICANN as an elected member of ICANN at Large, challenging bad practice and sometimes helping to force changes.

However, I have worked primarily outside the industry, in governing prisons, running schools, and the past ten years in healthcare. I am currently employed as a nurse and senior clinician in the NHS.
 
Okay, that's my statements completed, for the record.

From here on in I will be succinct. Read the key points I am standing for here on the homepage of my website.
 

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