On the Effects of the Guidelines on the Current Registrants

Mr Disini claims that current PH ccTLD Registrants will suffer should The Guidelines be adopted. Mr Disini cites three services which he claims will cease to function. He lists scenarios where the Registrants would be adversely affected. This is known as raising Fear, Uncertainty, and Doubt (FUD) in the minds of everyone to prevent them from making reasonable decisions. Mr Disini states his first FUD:

Furthermore, it is the consumer who will suffer by shutting down the DotPH Registrar. Consumers will face added costs and downtime because:

1) Many domains will not work. Many clients use DotPH's free Webforwarding service to direct their domains to an existing site. These users will need to buy webhosting, since there are few registrars to turn to that offer Webforwarding for free.

Let us categorically reason away this FUD.

1. Whether the DotPH Registrar will shutdown or not is his entirely up to Mr Disini. He should not burden the NTC with his decision and the effects of his decision.

2. Should Mr Disini decide to shut his Registrar business down, then it is Mr Disini's responsibility to ensure that his clients are migrated to other Registrars without causing any of his clients unreasonable loss of service. If Mr Disini is truly responsive to his clients as he claims, then there is no reason why he can not plan the transfer of his clients to another Registrar to ensure that his clients do not suffer any unreasonable downtime. Mr Disini would only have himself to blame should his clients suffer any downtime. The orderly transfer of DotPH Registrar's clients is not controlled by the NTC nor by the Adboard. Everything is entirely within Mr Disini's control and power. Thus, the orderly transfer of his clients and the prevention of downtime and loss of service is Mr Disini's responsibility.

3. If Mr Disini's existing clients were to transfer to another Registrar, Mr Disini would have us believe that it is a certainty that they would pay for the Webforwarding service which Mr Disini claims he now provides for free. Of course, this is a possibility. However, I dispute that it is a certainty. For example, it is possible that another Registrar would provide the same Webforwarding service for free to match Mr Disini's service and get Mr Disini's clients. Another possibility is for a Registrar to charge for the Webforwarding service but to lower the Registrant fee to attract Registrants. We can all think of different scenarios that could happen in a competitive multiple Registrar environment. The beauty of such an environment is that the competitive Registrars will create their own different business models to attract the Registrants. The Registrants can then choose the Registrar which meets their own unique needs. The only certainty in a multiple-Registrar environment is that consumers would have multiple choices where they could bring their business rather than be forced to deal with DotPH.

Mr Disini continues on to the second FUD:

2) Websites will go down. DotPH is one of the few Registrars that provides free Nameserver hosting to its clients. Existing users will have to purchase nameserver hosting or get DSL lines with fixed IP addresses and host their own nameservers.

Just like the first FUD he raised, that Websites will go down is not a certainty in a competitive multiple Registrar environment. It is not unreasonable to expect that another Registrar would offer free Nameserver hosting services to its clients, just like what Mr Disini currently offers. If Mr Disini could offer it, another Registrar could surely offer it as well. Websites will go down if and only if Mr Disini decides that they would go down by not creating an orderly plan for the transfer of domain names if and when he decides to shutdown his DotPH Registrar business.

Finally, Mr Disini ends with his third FUD:

3) E-mail will bounce since the Mailforwarding service will be shut down. Users will either have to pay their ISPs extra to MX mail on their ISP mailboxes or else resort to using Hotmail and Yahoo addresses. Mailforwarding gives users the freedom to change ISPs without their mail bouncing or changing email addresses. Without this, many users will be stuck with their ISPs and be unable to shift easily.

Just like the first two FUDs, this third is not a certainty. Just like now, users would have the ability to freely change the MX records for their domains to reflect changes in their ISPs. When a user moves from one ISP to another, the user's domain name does not have to change. The domain name is not tied up with the ISP. E-mails will not bounce. Users, just like now, would still be free to change their e-mail addresses and ISPs without fear that e-mail to them would bounce.

Has Mr Disini changed his color? Is he now a consumer advocate? He decries the possibility that it would be with difficulty that consumers can select their service providers. Mind you, this is a mere possibility he is railing against. Yet he fights tooth and nail to ensure that the PH ccTLD Registrants are stuck with DotPH. DotPH is the only PH ccTLD Registry and it is the only DotPH Registrar. The DotPH Registrants have no choice and this lack of choice is not a mere possibility but the reality. The cloak of consumer advocacy does not change Mr Disini's color.

Just to assure everyone involved that these services will continue without any interruptions, PHNET officially offers to continue exactly the same services offered by Mr Disini at exactly the same prices charged by Mr Disini should Mr Disini decide to shutdown DotPH. For $35 a year per Registrant, PHNET will provide free Webforwarding service, free Nameserver hosting, and Mailforwarding services to each and every client of Mr Disini. PHNET will continue offering such services until such time that the relevant public authority has recognized the Registrars to which the services could be transferred. The only condition to this offer is that Mr Disini provide PHNET with all the necessary Registrant information to make the transfer of records orderly and timely.

Should Mr Disini decide to shutdown his DotPH Registrar business, the only certainty is that the DotPH's services will shutdown. That other Registrars will not offer the same or similar services is not a certainty. The only real uncertainty we face is the uncertainty of Mr Disini's actions. Will he cause an orderly transfer of his clients or not? The only real fear we face is the fear of Mr Disini's power. What if he decides to just erase everyone's DNS records and cause a disruption in the DNS service? The only real doubt is the doubt we have on Mr Disini's ability to administer the PH ccTLD. These are the real FUDs. Whether The Guidelines are written or not, these real FUDs would continue to exist if Mr Disini continues to control the PH ccTLD Registry without any accountability.