SRS Issues and Decisions Paper 01/02/02

25 January 2002

InternetNZ Council

CONFIDENTIAL TO INTERNETNZ COUNCIL MEMBERS

SRS - Issues and Decisions

1 At your meeting on 1 December 2001, you approved a number of key documents that underpin the SRS development and implementation:

• The Framework and Business Rules for the Domain Name Shared Registry for .nz;

• The proposed governance arrangements, subject to further advice from InternetNZ's legal advisor on the risks arising out of certain aspects of the ccTLD management role being managed directly within InternetNZ; and

• Principles to guide the transition to a competitive SRS environment.

2 This paper covers the following issues:

• A summary of the advice received from InternetNZ's legal advisor on limiting the risk exposure arising out of some of the activities of the Office of the ccTLD Manager;

• Options for managing these risks;

• A summary of the advice and recommendation received from Ernst & Young about the most tax efficient means of establishing a separate registry function utilising the funds currently held by Domainz;

• Costings for operating the shared registry environment (and other options) and impact on .nz domain name wholesale fees;

• Recommendations on all of the above.

Managing Risks

3 At your last meeting, you considered a paper that outlined the functions of the Office of the ccTLD Manager and the proposed governance arrangements. You requested that a legal opinion be sought from Gavin Adlam on InternetNZ's exposure to risks arising out of the functions of the ccTLD manager being governed and managed within InternetNZ rather than in a separate organisation. This opinion was provided to all Council members before Christmas.

4 The advice is that the activity that poses the greatest risk is that of authorising and contracting with registrars, enforcing those contracts and dealing with claims by registrars, registrants and others. Given this, while a single legal entity is responsible for the full range of functions, there is no satisfactory way of separating out the risks and liabilities from the wider activities of InternetNZ.

5 The opinion notes further that the establishment of a separate legal entity or contracting out the management of these substantive functions to an independent contractor does not in itself completely remove exposure to risk.

6 The advice in the opinion is consistent with the current structural arrangements in place for the governance and management of .nz.

7 Taking this advice into account, there are two options available for managing the Office of the ccTLD Manager functions in an SRS environment. These are:

• Establish a separate legal entity (a company) to run the Office of the ccTLD Manager; or

• Split the functions of the Office of the ccTLD manager between the registry and InternetNZ.

These options are further discussed below.

Functions of the Office of the ccTLD

8 To recap on the earlier paper, the functions of this office can be grouped into the following:

• .nz domain name policy

• Authorising and contracting with registrars

• Contracting with and monitoring the registry

• Monitoring .nz (including running the registry-registrar committee)

• Monitoring and influencing international developments

• Running the process for creating the second level domains and appointing moderators for moderated second level domains

9 The following table allocates the functions for both options set out in paragraph 7.

Establishing a separate entity

10 Under this scenario, InternetNZ would establish a company "ccTLD Ltd" (in preference to other legal structures) that is fully owned by InternetNZ. ccTLD Ltd would manage the operational functions as outlined in the table above. The InternetNZ Council would retain decision making on:

• Policy changes

• Long term strategy for .nz

• Changes to the .nz position on international issues/at international fora

• Major transactions (using the definition in s129, Companies Act)

• Appointment of the ccTLD Ltd board.

11 The respective expectations and obligations of ccTLD Ltd and InternetNZ could be set out in resolutions of the ccTLD Board and the InternetNZ Council, or contractually.

12 The benefits of this option include:

• Reduced risk exposure for InternetNZ with the management of the authorisation and contracting with registrars by a separate legal entity, while retaining decision making on key strategic and policy issues;

• Removes the operational management of the .nz domain namespace from InternetNZ, enabling it to concentrate on other objectives;

• Single focus organisation which should ensure better oversight of the .nz namespace;

• Consistency with the Hine Report recommendations.

13 The disadvantages of this option include:

• Additional complexity in the management of .nz through adding another structure;

• An increase in the costs of managing the .nz domain namespace;

• A risk that the InternetNZ Council may not take timely decisions on changes to policy where required;

• A greater risk of a dysfunctional relationship developing between InternetNZ and ccTLD Ltd than if the functions were all managed within one organisation.

Transferring some functions to the registry

14 Under this scenario, the registry would authorise and manage the contracts with the registrars, would make some of the policy recommendations but the remaining functions would stay with InternetNZ. In many respects, this is a replication of the current Domainz/InternetNZ accountabilities except that there is no combined registry/registrar operation.

15 The benefits of this option include:

• Reduced risk exposure for InternetNZ with the management of the authorisation and contracting with registrars by a separate legal entity, while retaining decision making on key strategic and policy issues;

• For registrars, having a single contract containing their authorisation, technical and payment obligations.

• Marginally lower costs

16 The disadvantages of this option include:

• No ccTLD manager "champion" which may lead to less effective decision making on .nz issues;

• It changes the nature of the registry from that of a small technically focused organisation;

• A risk of role confusion in monitoring .nz and registrar activity;

• Gives more authority to the registry than registrars may be comfortable with;

• Maintains a mixed focus within InternetNZ unless the other ccTLD functions are separately managed and "governed" within InternetNZ;

• Inconsistency with the governance model recommended in the Hine Report.

17 On balance, the preferred option is the establishment of a separate entity to manage the operational functions of the ccTLD Office. The transfer of the management of the registrar authorisation and contracting functions to the registry has too many disadvantages and perceived risks without providing benefits to balance these.

Separating the Registry and Registrar Functions

18 The separation of the registry and registrar functions, currently managed by Domainz, is key to establishing a shared registry environment and a competitive registrar market. The InternetNZ AGM on 23 June 2000 adopted the first recommendation of the Hine Report that the registrar function be removed from the registry, and that the registry should focus on registrars as its customers. At your last meeting on 1 December, you agreed in principle to the split of Domainz into the registry operator and a registrar, and Domainz management has confirmed that it is working on this. Advice has been sought from Ernst & Young (EY) on the most tax efficient means for establishing the separate SRS registry function, utilising the funds currently held by Domainz to fund the development of the SRS software.

19. Two options were developed and considered by EY. These were:

Option One - Incorporate a special purpose registry

InternetNZ would incorporate a new subsidiary to develop and hold the SRS software and perform the registry function. InternetNZ would receive a fully imputed dividend from Domainz, and would subscribe for shares in the new subsidiary. Staff and other assets would transfer from Domainz to the registry as appropriate. The outcomes are that funds could be transferred from Domainz to the new entity free of any tax impost, a separate registry is established without delay, and it does not close off options for disposing of the registrar part of Domainz's business.

Option Two - Develop NZIRL into the registry and have an operational split within NZIRL or establish a new registrar company

InternetNZ would use the existing company as the registry organisation, with the transfer of the DRS and existing customer base to a new company incorporated and fully owned by InternetNZ (if the split of registry and registrar operations is to be fully transparent). This option has lower compliance costs as it is not essential from a fiscal perspective to establish a separate registrar company, and therefore transfer staff and assets. The key non-staff asset that would be transferred is the existing customer list. In EY's view, care would need to be taken in establishing the value of this as any future resale that resulted in a gain in value would give rise to that gain being taxable.

20 The option recommended by EY from the perspective of tax effectiveness is Option One - the establishment of a separate registry company. In terms of other management of change issues (eg - transfer of staff), this is also likely to be more straightforward. An issue has been raised by the Domainz Chair about the size and speed of transfer of working capital from Domainz to the new entity (via InternetNZ). This needs to be managed in such a way as to enable the Domainz directors not to be in breach of the Companies Act solvency requirements. This will require, as a matter of some urgency, the forecasting of Domainz's future revenue and (registrar) costs for the next 24 months.

21 If the EY advice is accepted, then it would be prudent to establish the registry company as soon as possible, prior to the major development costs of the registry software being incurred. The development of the registry software is in three phases - technical architecture, prototyping, and then design, specification and development of the application. The technical architecture phase is about to commence and will be completed at the end of February. A contract for the development has been signed between Catalyst IT Ltd (the development partner) and Domainz (as the funder of the software development). Once the registry company is in place and adequate funding transferred, Domainz can then assign the development contract to the new entity.

22 The formal establishment of a registry company will need to run alongside Domainz's consultation with its staff on the proposed split of registry and registrar functions. This is important to ensure that Domainz (and InternetNZ) is not in breach of its employee relations obligations.

23 In terms of the functional implementation of the SRS registry, it is recommended that the SRS Implementation Team and Domainz CEO develop a joint transition plan for the establishment of the separate registry, to become fully operational at an agreed point between the implementation of the SRS software and the launch of this to the external world.

Costs of the Shared Registry Environment

24 At the time of the Hine Report, detailed costings for running a shared registry system were not completed. There were some preliminary estimates, but there are costs that are now incurred that did not exist at that stage.¹ These estimates have led to an expectation that the wholesale fee under the SRS would be in the order of $1/month/domain name on the register.

25 Draft full year costings have been prepared for the Office of the ccTLD Manager and the registry. These costings have been prepared using the current budgets of InternetNZ and Domainz, along with other information as appropriate. The CEO of Domainz has reviewed them and some line items were increased following this. Ernst & Young then reviewed the budgets and their review is attached as Appendix B. A summary of the proposed annual budgets for the registry, the Office of the ccTLD manager and the residual functions of InternetNZ are attached in Appendix A. All budgets are exclusive of GST.

The Office of the ccTLD Manager

26 The budget is based on the Office of the ccTLD manager actively managing and monitoring .nz. The area of greatest uncertainty is responding to queries from registrants and the general public. These calls are currently handled by Domainz. The registry will not have a "public face". Registrars will deal with registrant queries, but the public and registrants will also want to seek information and raise issues with an independent entity. Not everyone will be able to access the website, nor will people necessarily want to communicate by email.

27 The budget figures assume that InternetNZ and the Office of the ccTLD Manager will share the space leased by InternetNZ. There will be some savings through this arrangement.

28 If a separate company (ccTLD Ltd) is established to run the functions of the Office of the ccTLD Manager, this will add around $20,000/annum in governance costs for this Office (taking the budget to $838,000). This assumes that the ccTLD Ltd and InternetNZ will continue to co-locate.

The Registry

29 The costings assume the registry is a separate company, fully owned by InternetNZ, with a small technical team and an admin/billing position. It is not "two geeks and a pager" with no office, using rented rack space in someone else's computer room. The registry has no public face as such. Most of its interaction will be with authorised registrars, intending registrars, the Office of the ccTLD manager and its own suppliers. Its sole focus is to manage and maintain the SRS software and the DNS. If the registry company manages other registries as well or has other activities, then some of the overheads which are fully costed against the SRS in this budget would reduce.

30 The technical support and operational costs proposed for the registry will need to be reviewed once the technical architecture has been signed off.

InternetNZ

31 I have included in Appendix A the residual budget for InternetNZ, based on no change for the rest of the organisation. This needs to be included in the costs as some of the office costs are shared with the Office of the ccTLD manager. Effectively I have stripped out from the published 2001/02 budget, the costs associated with international activities, the SRS, rebranding and the DRS review.

Comparisons of Costs

32 A comparison of costings for various scenarios is outlined in Appendix C. These take the raw costings for the entities, total them and work out an average domain name fee based on 107,500 registered domain names. This is provided for the purposes of comparison only, not to enable you to determine a wholesale fee for domain names.

33 EY have reviewed the first three scenarios only. The costs for Scenarios 5 and 6 are based on current budgets/expenditure. It is likely that Scenario 4 is under-costed as stated in the description for this scenario in Appendix C.

Summary

34 The total estimated costs of the shared registry, ccTLD manager and InternetNZ (residual activities) are in the order of $2.4 million per annum. These costs include some contingency funding for both the registry and Office of the ccTLD manager. The costs will increase by around $20,000 per annum if the Office of the ccTLD manager is established as a separate company, rather than managed as part of InternetNZ.

35 The total estimated costs of the shared registry system would appear to be lower than the costs of the status quo arrangements.

Domain Name Registration Fees

36 In the shared registry environment, there is a single wholesale price charged by the registry for each domain name that is in the register during the month. There are no additional fees charged to registrars, unlike the current fee structure which has a tiered registration fee, and fees for new nameholder setup, reactivation and annual accreditation. It is not therefore possible to directly compare the pre and post-SRS registration fees. In addition, the intention is to operate the SRS as a "not for profit" venture, but inevitably volume fluctuations and cost variations could pitch it either way (operating at a loss or in profit). The intention is for the Office of the ccTLD Manager to closely monitor the SRS costs to ensure that it does operate as close to the "not for profit" model as possible. A memorandum account could be used to smooth the registry pricing, ensuring that sudden cost increases/volume decreases do not have the entities operating at a loss. The fees will need to be reviewed annually on a formal basis.

37 InternetNZ has indicated previously that it will be consulting nameholders on what costs should be covered by the domain name registration fee. All estimated fees contained in this paper assume that the fees will cover all the costs of the registry, the Office of the ccTLD Manager, and the residual functions of InternetNZ. Decisions on this issue will impact on the fee levels.

Registration Volume Projections

38 The total costs of running the SRS environment have to be set against the projected domain name volumes for .nz. Domain name registrations have enjoyed a healthy growth, which has slowed considerably over the last nine months. For example, the annual growth in 2000/01 was 57% over the previous year (an average increase of 2,700 new registrations each month). This has slowed to 15% growth over the first 8 months of 2001/02 (an average of 1,700 new registrations each month). One could speculate about the drivers for future growth in registrations (for example - a buoyant local economy, registrants realising the benefits of having an e-mail address for life that is independent of their current ISP), but it will be just that - speculation. An over-optimistic projection could see the registry and ccTLD office operating at a loss, as many of the costs are fixed and are not volume driven.

39 I would recommend that any forecasts for .nz domain name registration growth are conservative. For the first year of the SRS, I would look at growth of around 3% only.

40 If the costs to be covered by the wholesale registration fee are to cover all three entities as budgeted (approximately $2.4 million), then the average annual fee would be around $25.55 (incl GST), based on raw costs and 107,500 registrations. As volumes increase, the wholesale fee will reduce as a number of the costs are fixed. This figure is indicative only and does not incorporate any management fee or provision for taxation for money moving between the entities.

41 The lowest wholesale price currently is $20 registration/renewal fee/annum that is paid by the larger providers for the 29,000 domain names they manage. To this has to be added the annual accreditation fee ($5,000) that the provider has to recover through their retail pricing, plus the lowest level of new nameholder fee of $20. No analysis has been done to identify whether the lowest wholesale price meets the full costs of providing that service (as ,nz providers customers also have to use the Domainz call centre for some aspects of their domain name maintenance) or whether it is being subsidised by the higher retail price. There could be a perceived increase in registration cost as a result of the SRS for those registrants who currently use the larger accredited providers. There are 70,000 other registrations for whom the costs should be lower or remain around the same, depending on registrar margins.

Drivers for the SRS

42 Is a lower domain name registration fee the main driver for the SRS? A review of the Hine Report earlier drafts shows that this was one consideration but not the only one. There was a consensus for the registry and registrar businesses to be split, and for there to be a competitive registrar market. The SRS concept and the business rules that underpin the SRS provide an environment for a competitive registrar market to develop. If a lower registration fee is the key driver, then I would suggest that you do not "pare back" the estimated costings to meet your key objective/desired wholesale price. The budgets are conservative but realistic.

Other Options

Do Nothing

43 If no decision is taken on whether to proceed with the SRS implementation as such, replacement software for the DRS is still wanted by Domainz. The SRS software as designed could be used by Domainz acting as both the registry and registrar (or by Domainz acting as the registry only), with an adjustment to policies and practice to fit the business rules that underpin the software functionality. Domainz's overall costs will decrease using this software as some features of the DRS do generate some of the call centre activity. But Domainz will also be carrying the cost of developing both the SRS registry software, and their own registrar end requirements. The total cost of running Domainz (as a combined registrar/registry) and InternetNZ (which would have the same functions as currently) appears to be higher than the SRS costs. If InternetNZ's "status quo" costs are $645,000 per annum, Domainz's costs would have to reduce to under $1.7 million (current year costs are around $2.2 million) to provide a lower average registration cost for registrants. The Domainz Board would also want to build in a margin in the fees to ensure ongoing solvency of the company.

44 This has not been considered by the SRS Implementation Team to date. But one option is to contract out the registry operation or the technical support to a provider who is already running a number of other systems, where the cost structure may be lower.

45 Contracting out the registry function will not be risk-free and any provider will want to make a profit. A provider may be reluctant to be the fee collection agency while there are low financial barriers to entry for registrars.

46 This option (or variations of it) and the impact of it on cost, business rules and accountabilities could be explored.

Summary

Risks arising from the Office of the ccTLD manager functions

47 You have received advice from InternetNZ's legal advisor that the riskier activities of the management of .nz cannot be separated out if the Office of the ccTLD manager is part of InternetNZ. This advice and the consequences of this are outlined in paragraphs 3 - 17 of this paper.

48 Your choice is either to establish a separate company to manage the majority of ccTLD functions (with policy approval remaining with the InternetNZ Council), or to move some of the ccTLD functions to the registry. You cannot implement a shared registry environment by dropping these functions (registrar authorisation and management). The establishment of a separate company will add around $20,000 in governance costs to the ccTLD managers costs.

Separating the Registry and Registrar Functions

49 This is required to implement the SRS. At your last meeting on 1 December, you agreed in principle to the split of Domainz into a registry operator and registrar.

50 Advice has been sought on the most tax-efficient way of achieving this split. The recommendation is to establish a separate registry company prior to the costs of the SRS software development being incurred. The costs of the development would be funded by a fully imputed dividend from Domainz to InternetNZ. InternetNZ would then take an equity investment in the registry company. The advice on this is outlined in paragraphs 18 - 23 of this paper.

51 The Chair of Domainz has raised a concern about the fiscal impact on Domainz of an immediate withdrawal of the full development costs (as a fully imputed dividend) for the SRS. Domainz has also raised other issues with the EY advice that they are seeking clarification on prior to the 1 February Council meeting. These issues need to be identified and addressed.

52 Your choice is either to:

• decide now to establish a separate registry, with the registrar functions remaining with Domainz; or

• leave the two functions running in parallel within Domainz until some future date after the SRS is implemented. A decision will then be required within the next year about disposing of the registrar functions; or

• establish a separate registrar company prior to the SRS implementation, and transfer the registrar activities.

Costs of the Shared Registry Environment

53 Costings have been prepared for the Office of the ccTLD Manager, the registry and the residual functions of InternetNZ. The costings for the registry will need to be revisited once the technical architecture is signed off. Contingencies have been built into both budgets.

54 The costs of running the shared registry are higher than the Hine Working Group estimated (their estimates were only a first cut). This estimate however has left an impression amongst the community that domain name fees would be in the order of $1/month under an SRS. This is not achievable.

55 The estimated costs of a shared registry appear to be around 10% lower than maintaining the status quo in respect of structures, accountabilities and relationships.

Conclusion

56 There is current comment and speculation about whether the SRS will proceed as envisaged by the Hine Working Group and/or whether a separate registry will be established. The higher estimated costs are one factor driving these discussions. It is unclear what the other drivers might be but decisions are needed so that a clear implementation plan can be put in place.

57 The Hine Report recommendations were accepted, presumably for a variety of reasons, by members. The Domainz Board has stated that they wish to replace the DRS software. The SRS registry software and registrar interfaces will achieve this, supplemented by new registrar end systems at Domainz. If you take no decisions, then change will still occur.

58 To progress the structural and non-technical implementation, decisions are needed. The recommendations below are drafted on the basis that a shared registry environment is to be implemented.

Recommendations

59. It is recommended that theInternetNZ Council:

Office of the ccTLD Manager

1. note the legal advice received (and circulated prior to Christmas) about the risks arising from some of the activities of the Office of the ccTLD manager;

2. agree to the separate identification and management of the operational ccTLD activities and functions from other InternetNZ activities;

3. agree to the establishment of a company, fully owned by InternetNZ, that will manage the operational functions of the .nz ccTLD (as identified in para 8);
4. note that if recommendation (3) above is implemented, the InternetNZ Council will retain decision making on:
• Policy changes
• Long term strategy for .nz
• Changes to the .nz position on international issues/at international fora
• Major transactions (as defined in s129, Companies Act)
• Appointment of the ccTLD Ltd board
5. request the SRS IOC, in consultation with the Administration Committee, to proceed with the incorporation of a company to manage the operational functions of the .nz ccTLD, and to report back on progress to the next Council meeting;
6. authorise the SRS IOC, in consultation with the Administration Committee, to commence advertising for the senior position within this new entity, and to report back on progress to the next Council meeting;
7. request the SRS IOC to complete the transition costings for the separation of the .nz ccTLD functions, and report back on these to the next Council meeting;

Registry

8. confirm the decision to split the registry and registrar functions currently managed by Domainz;
9. request the SRS IOC to work with Domainz :
• to mutually agree a termination of the registry management contract,
• to jointly prepare a transition strategy and plan for the transfer of the registry functions for the SRS to a new entity, including funding transfers;
10. agree to the establishment of a separate registry company;
11. request the SRS IOC, in consultation with the Administration Committee, to commence the incorporation of a company to manage the shared registry functions of the .nz ccTLD, and to report back on progress to the next Council meeting;

Costs

12. note the work on estimated/indicative costs for the registry, Office of the ccTLD Manager, and residual InternetNZ functions;
13. note that the costs of the SRS environment are higher than originally estimated in an early draft by the Hine Working Group;
14. note that the total estimated costs of the SRS would appear to be lower than the costs of the status quo arrangements;
15. note the recent decline in growth in domain name registrations;
16. note that a fees model will be prepared that incorporates taxation provision and reflects changes in domain name registrations over a full year;
17. note that no announcements can be made on SRS fees for two reasons - costs have yet to be confirmed, and InternetNZ has also indicated earlier that it wishes to consult on what costs are to be funded by domain name fees;

Other

18. note that the SRS software development is about to commence;
19. note that transition/implementation planning requires decisions to be taken about structures, accountabilities and relationships; and
20. agree that, in the event that you decide not to proceed with the SRS implementation as set out in the Hine Report, any communications on this will be co-ordinated and managed by InternetNZ.

Rose Percival
SRS Implementation Team

Appendix A

Estimated Costings (Annual)

1. Office of the ccTLD Manager

2. Registry

3. InternetNZ (residual budget)

Appendix B

Ernst & Young Opinion on Costings

24^th January 2002

Rose Percival
SRS Implementation Manager
InternetNZ
Level 4
89 Willis Street
Wellington

Dear Rose

Operating Budget Review for Registry and ccTLD

Background and Introduction

Background

Ernst and Young ES Consulting have been requested by InternetNZ to review the proposed budget for the Registry and ccTLD . The review was requested to provide an independent view in considering the draft budgets. E&Y Chartered Accountant Professional Services was not required by InternetNZ for this particular assignment.

InternetNZ requested that the review address the following:

• Review the draft costings for the Registry Office and the ccTLD from an independent perspective

• Consider the Impact of the options considered on the monthly wholesale fee for domain name registrations

Approach

Due to time constraints, the approach that was adopted was to ;

1. Review the draft costings that have had been prepared for the Registry and ccTLD

2. Meet with the SRS implementation manager to understand the justification in the budgets provided

3. Meet the CEO of DomaiNZ and review the draft budgets to understand and indentify any further budgetary impacts particularly in regards to the IT component.

4. Collate any remaining information that was provided

Costs not considered

The following costs were not considered part of the draft budgets and were not considered part of this review ;

• Costs to establish a standalone entity

• Transition costs

• Management fee from the registry to InternetNZ or the ccTLD office and /or tax implications

• SRS project implementation planning

• DRS legacy costs

• Setup and support costs for the Registrar application interfacing to the SRS application

Additional Assumptions

The following additional assumptions were made as part of the scope;

• Budgets and volumes are a snapshot from October 2002
• The budgets are draft and will be reviewed after a final decision is made
• Contingency will be managed by exception
• InternetNZ budgets were not considered as part of this review
• Architecture plan and support of the SRS Application are not complete. Therefore it is assumed that the budgetary costs will be based on the DRS application's operational and maintenance costs
• Legal implications have been considered as part of contingency

Findings

From the information provided the following recommendations were made ;

Within the Regsitry budgets the IT Costs were changed to reflect the interviews with the CEO of DomaiNZ. These changes were related to the Hosting and Network costs, extenal/support and advice and the firewall maintenance.

Additional recommended changes were also suggested to the ACC premium, travel, phone and general expenses components of the budget to represent the allocated staff.

In relation to the ccTLD budgets recommended changes were suggested to the ACC premiums and general expenses to represent the allocated staff.

Conclusion

In considering the above information provided to us and the interviews conducted, the ccTLD and Registry draft operating budgets appear to provide all relevant line by line information. In addition it would appear that the workings for each item within the budget will meet the business need in assessing the wholesale fee for Domain name registrations.

Please do not hesitate to contact myself on 09 375 2654 or Mark Beder on 025 899 109 if there are any queries.

Yours faithfully
Ernst & Young

Michael Murphy
Principal

Mark Beder
Senior Manager

Appendix C - Raw Cost Comparisons for Scenarios

1 For example, at that stage not all the hosting of secondary servers for the DNS were being charged for.