Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions

February 25, 2011
Docket Number: 

IGP comments to NTIA on the IANA Functions

Comments of the Internet Governance Project on the NTIA's "Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions" (Docket # 110207099-1099-01)

This submission is from the Internet Governance Project (IGP), an alliance of academics doing research and policy analysis in the fields of global governance, Internet policy, and information and communication technology.

For better or worse, the IANA contract is perceived as one of the linchpins of global internet governance. For that reason, our comments begin by assessing the role of the IANA contract in the overall Internet governance regime.

At the highest level, there are three alternative approaches to the future of the IANA function.
1. One is to continue with the status quo, which involves the U.S. government exercising unilateral control over the nature of the functions embodied in the agreement and choosing the contractor.
2. The second approach, which is desired by many governments around the world, is to multi-lateralize the contracting process. The U.S. would share its authority over the IANA function with other governments, either on a one-country, one-vote basis or through some subset or club of privileged governments.
3. The third approach is to de-nationalize the IANA function. This means fully delegating the IANA functions to nongovernmental actors in the private sector and civil society, and eventually eliminating the U.S. government's direct authority over it.

The first two options have numerous pitfalls. Unilateral U.S. control of the IANA contract disenfranchises most of the world's Internet users, and is a thorn in the side of many other governments, including friendly ones such as the European Union. The U.S. government's role leads inevitably to a demand by other governments for equal status and draws Internet coordination processes into inter-state rivalries, adding an unduly political dimension to activities that should be driven by coordination, efficiency, technical expertise and a concern for global interoperability and the interests of all users. But making the contracting process multilateral and intergovernmental makes a bad situation worse. The involvement of multiple nation-states in basic internet coordination processes would make IANA a plaything of geopolitics and drastically increase the complexity and difficulty of its tasks.

The third approach - de-nationalization - is the best. Denationalization was in fact the original objective of the process that created ICANN. It is worthwhile to reiterate the reason why. It was understood at the time that the Internet needed a truly globalized regime for governing the coordination processes and policies associated with Internet identifiers. Territorial governments insistent upon their sovereign powers were perceived as inherently incapable of delivering that kind of globalized compatibility and coordination. This problem, it was thought in 1997-98, could be avoided through reliance on private sector organizations rooted in the Internet technical community, operating on the basis of transnationally applicable contracts and agreements.

Denationalization, however, requires that the private sector institutions that inherit the governance responsibilities be responsible, accountable and stable. Thus while we agree with ICANN's comments that the IANA contract's ultimate aim should be devolution to a private actor, we do not agree with the implication that ICANN as it currently exists should be the presumptive recipient of all the IANA functions. Part of the reason is the imperfection and lack of maturity of ICANN's accountability arrangements. A more important reason, however, is that ICANN currently combines too many functions in a single organization. Currently, ICANN performs both operational and policy making functions (e.g., running the L root), and the IANA contract unnecessarily concentrates multiple functions in the hands of a single entity. We do not think it advisable to privatize all those functions in a single corporation's hands, especially given the weakness of its accountability arrangements. We see an unbundling of the IANA functions as a way to minimize any risks and dangers that might be associated with de-nationalization. The unbundling must take place first, full de-nationalization second.

We believe therefore that NTIA should use the next cycle of the IANA contract to prepare the way for unbundling the protocol parameters, IP address resources and DNS root zone coordination functions, aiming for the eventual delegation of those separated functions to appropriately accountable non-state actors, such as the IETF for protocol parameters. We recommend that this happen expeditiously, but not too hastily - e.g., over a three-year time span.

With that preamble, we now address the first two questions in the RFC:

Q1: There is no technical or economic imperative that requires combining domain name, IP address and protocol parameter coordination in a single entity. IGP supports the comments of Internet NZ and Bill Manning regarding the feasibility and desirability of separating the distinct IANA functions. Structural separation is not only technically feasible, it has good governance and accountability implications. By decentralizing the functions we undermine the possibility of capture by governmental or private interests and make it more likely that policy implementations are based on consensus and cooperation.

Q2: This is not a simple question. In general, we believe that the IANA contract should avoid rigid, formalized specifications of the roles of specific actors. A U.S. government IANA contract is supposed to be a transitional device on the road to full denationalization. An IANA contract that names specific entities such as ICANN, the RIRs, IETF and ccTLD operators, and then legally requires them to fulfill certain responsibilities with respect to each other, starts to take on the characteristics of a constitution of cyberspace, one that makes the NTIA its perpetual legislator and Supreme Court. We think that is not desirable. On the other hand, we agree with Internet NZ that a well-drafted set of IANA contracts would "clearly state, for each registry, the entity that determines policy for that registry and contain clear instructions that the operator must follow the policy set out by that entity and not create any policy of its own." Ideally there would be separate contracts for each IANA function, and thus no contract would need to reference any entity other than the registry and the policy making entity for that registry.

Self | Bartholomew Allerton

Ms. Alexander,

Please find the following attached Adobe Acrobat format (.pdf) comments regarding question #2 of the RFC.


Bartholomew Allerton, retired

Comments on IANA Functions Request for Comments (NTIA) Question_2.pdf 21.49 KB

Submitted on behalf of ICANNs Internet Service Providers & Connectivity Providers Constituency | Tony Holmes

Please find attached comments submitted on behalf of ICANNs Internet Service Provider & Connectivity Providers Constituency (ISPCP), to the request for comments on the Internet Assigned Numbers Authority (IANA) functions.

Tony Holmes
Chairman ICANN ISPCPConstituency

ISPCP response to NTIA on IANA functions.doc 34.5 KB

AFNIC | Mathieu Weill

Dear Fiona Alexander,

Please find attached a submission to the IANA NoI from AFNIC, manager of the .fr ccTLD.

Best regards,

Mathieu WEILL
AFNIC - directeur général
Tél: 01 39 30 83 06

Comments on the IANA function.pdf 1.41 MB

ICANN | Rod Beckstrom

Attached please find ICANN's comments in response to NTIA's IANA functions NOI. We will also send a hard copy by mail. Please let us know if you have any questions. Thanks

ICANN Comments.pdf 445.77 KB

SIDN | Roelof A. Meijer

(Late Submission)
Dear Mrs. Alexander,

SIDN is the registry for the .nl country-code top level domain, which, with close to 4.5 million registered domains, is one of the worlds largest and most successful ccTLDs.

We welcome the opportunity to provide comments in response to the National Telecommunications and Information Administrations (NTIAs) Notice of Inquiry on the IANA functions.

Please receive our comments herewith.

Best regards,

Roelof A. Meijer


SIDN position NTIA NoI IANA March 2011.pdf 107.98 KB

Self/Tech Freedom | Michael Palage and Berin Szoka

(Late Submission)
Dear Fiona,

Please accept the following comments in connection with the IANA NOI.

Best regards,


IANA NOI Comments -Final.pdf 453.66 KB
IANA NOI Comments -Final.pdf 453.66 KB

Centr | Wim Degezelle

Dear Ms Alexander,

Please find attached CENTR's response on the NTIA's Request for Comments on the IANA Functions.

Kind regards

Wim Degezelle

CENTR Input NoI IANA - final.pdf 148.47 KB

InternetNZ | Jay Daley

Please find attached a submission in response to the IANA Functions NOI from InternetNZ. There are two attachments to this message, both identical, one in MS Word docx format and the other in PDF format.

kind regards

NTIA Submission - IANA NOI.doc 64 KB
NTIA Submission - IANA NOI.pdf 85.89 KB

Self | Eddy Kayihura


We, in Rwanda, have not yet managed the repatriate the .RW ccTLD.

Efforts started more than 6 years ago and we were warned by the current operator about the potential lengthy process.

Due to multiple factors, here we are, in 2011, without having succeeded to achieve it.

Though we understand the need to follow a strict process to assure minimal disturbance in service delivery, we believe that the process could be simplified in case the request appears to genuinely satisfy the need of the local community.

We also hope and advocate that should any change occur in the future, it would only simplify the process and not add complexity since we are almost ready in putting all the required building blocks in place based on current specification for TLD re-delegation on the IANA website.

Eddy Kayihura

Kigali, Rwanda

Member of Rwanda ICT Association

IANA Function.doc 20.5 KB

Internet Governance Capacity Building Programme by Diplo Foundation | ACP Pacific Class

We are participants of the 2011 Internet Governance Capacity Building Programme by Diplo Foundation ( and are pleased to attach our comments on your RFC.


ACP Pacific Class

Summary of comments on RFCs.doc 29.5 KB

Self | Paul M Kane

May I express my gratitude to the US Government for the manner in which they have overseen the IANA functions contract over the years and thank them for the opportunity of submitting these comments.

Please see the attached document

Paul M Kane

IANA-NoI.pdf 37.95 KB

UAE Telecommunications Regulatory Authority (TRA)

Please find attached the Telecommunication Regulatory Authority of the UAE's, comments in response to NTIA's IANA functions NOI.

TRA -Submission to the NTIA on the IANA Functions NOI-31032011.pdf 165.29 KB

Internet Governance Capability Build Program 2011 (IGCBP 2011) | Dwi Elfrida Martina

Dear Sir, Madam

I am Dwi Elfrida Martina, one of participant of Internet Governance Capacity Building (IGCBP)2011. We would like to submit our comment on IANA functions, as your request. Our comments will be attached in this email (in pdf and word format). Thanks for your cooperation.

Best Regards,

Dwi Elfrida Martina
e-Service Applications officer
Ministry of ICT of Republic of Indonesia Participant of IGCBP 2011

IGCBP 2011 Answers on request for comments on IANA Functions[1].pdf 41.66 KB
IGCBP 2011 Answers on request for comments on IANA Functions.doc 76 KB

China Organizational Name Administration Center (CONAC) | Yang Yu

To whom it may concern,

Please find CONAC's response to NOI in the attachment, thank you.


Yang Yu
Director, International Relations
China Organizational Name Administration Center (CONAC)
Jia 31, Guangximen Beili, Xibahe, Chaoyang District,
Beijing 100028
Ph: +86 10 52035167
Fax: +86 10 52035002

CONAC's response to NOI.pdf 29.91 KB


(Late Submission)
Verizon's comments we filed on the IANA NOI.

Google | Vinton G. Cerf

Please see attached file.

20110331093955130.pdf 870.62 KB

At-Large Advisory Committee (ALAC) | Olivier MJ CrÃpin-Leblond, PhD (ALAC Chair)

Ms. Fiona M. Alexander
Associate Administrator,
Office of International Affairs,
National Telecommunications and Information Administration

Dear Ms. Alexander,

Please be so kind to find the Statement by the At-Large Advisory Committee (ALAC) responding to the set of questions asked in the Department of Commerce's National Telecommunications and Information Administration Notice of Inquiry, Docket number 110207099-1099-01, RIN 0660-XA23, published in the Federal Register, Vol. 76, No. 38, on Friday, February 25, 2011.

On behalf of the ALAC, I thank you for giving us the opportunity to comment on functions as important as IANA's. I remain at your disposal should you need any further explanation on any of our Statement's contents.

Yours sincerely,

Olivier MJ CrÃpin-Leblond, PhD
ALAC Chair

ALAC Statement on the NTIA NOI - Final - March 2011.pdf 822.96 KB

ITU | Alexander Ntoko

Please find attached comments by the International Telecommunication Union (ITU) as a response to Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions; National Telecommunications and Information Administration, Docket No. 110207099-01, RIN 0660-XA23; published in the Federal Register /Vol. 76, No. 38 / Friday, February 25, 2011, page 10569. You will also receive a paper copy of the comments by mail.

We kindly request your acknowledgement of the same.

With regards,
Alexander Ntoko

ITU_E910_IANA NOI response_30-03-2011_final.pdf 32.13 KB

Minds + Machines | Antony Van Couvering

Dear Ms. Alexander,

Please accept the attached PDF and Word files as our submission to the Request for Comments on the Internet Assigned Numbers Authority Functions, [Docket No. 110207099-1099-01].


Nominet | Alex Blowers

I am pleased to attach a response to the consultation on the IANA functions on behalf of Nominet, the .uk Internet domain name registry.

NTIA IANA consultation response March 2011.pdf 807.98 KB

DotConnectAfrica (DCA) | Samuel Ochanji

Dear Sirs,

We hereby submit with this attachment the above tendered request from DotConnectAfrica organization,

Samuel Ochanji
Project Coordinator/Africa
DotConnectAfrica Org
Follow us on Twitter and Facebook
Press Room

Letter to NTIA - Request for comments for IANA functions.doc 154 KB

PayPal | Michael Barrett

Fiona M. Alexander
Associate Administrator
Office of International Affairs
National Telecommunications and Information Administration
1401 Constitution Avenue, NW., Room 4701 Washington, DC 20230

Dear Ms. Alexander

PayPal is pleased to respond to the Department of Commerce's Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions [Docket No. 110207099-1099-01], in the attached document.

Michael Barrett,
Chief Information Security Officer, PayPal

PayPal-NTIA-Response.pdf 225.25 KB

Self | Christopher Wilkinson

Please find attached my response to the Request for Comments.


Christopher Wilkinson.

NTIA_IANA_NOI_2.pdf 76.62 KB

Government of India

(Late Submission)
Please find attached herewith the response by the Government of India to the Department of Commerce ,National Telecommunications and Information Administration [Docket No. 110207099–1099–01] RIN 0660–XA23: Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions.

With warm regards,
Dr Govind

Senior Director
Government Department of Information Technology

CADNA | The Coalition Against Domain Name Abuse | Yvette Miller

Attached please find CADNA’s comments on the IANA contract.


CADNA Comments on the IANA Contract.pdf 167.85 KB

United States Council for International Business (USCIB) | Christopher G. Martin

(Late Submission)
Dear NTIA Team,

Please find USCIB’s comments on the IANA NOI attached.

Best regards,

Christopher G. Martin
Manager - Marketing & Advertising, ICT, Banking, Emerging Markets
United States Council for International Business
1212 Avenue of the Americas
New York, NY 10036

FINAL USCIB comments on IANA NOI - 3-31-11.pdf 123.94 KB
FINAL USCIB comments on IANA NOI - 3-31-11.pdf 123.94 KB

Chair - Number Resource Organization | Raúl Echeberría

Dear Ms. Fiona Alexander.

The Number Resource Organization (NRO) is very pleased to submit comments to the National Telecommunications and Information Administration [Docket No. 110207099–1099–01] RIN 0660–XA23 Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions.

The NRO comments are attached.

Best Regards,

Raúl Echeberría
Number Resource Organization

NRO-comments-to-USDoC-NoI.pdf 254.28 KB

Self | Robert C. Hutchinson

Please see attached document.
Best Regards,
Robert C. Hutchinson
Dynamic Ventures

NTIA NOI on IANA.pdf 451.71 KB

Lee and Li, Attorneys-at-Law | Ken-Ying Tseng

Dear Sir,

In response to NTIA's seeking public comments on the IANA function, attached please find my comments as attached. Your attention is highly appreciated.

Best regards,

Ken-Ying Tseng
Lee and Li, Attorneys-at-Law
7F, 201 Tun Hua N. Road
Taipei, Taiwan 10508, R. O. C.
Tel: 886-2-27153300 ext. 2179
Did: 886-2-21832179
Fax: 886-2-27133966

Comments on Questions 2 - Taiwan (Ken-Ying Tseng).doc 25.5 KB

Promotion de l’Education à Distance | Antoine KANTIZA

For the Attention of Fiona M. Alexander,
Associate Administrator,
Office of International Affairs ,
National Telecommunications and Information Administration

Good morning,

I have the advantage to send you my suggestion to strengthen the performance of the IANA
The document of suggestion is in attached file and I wrote it under the word format HTML
Sincerely Yours.

Prof. Antoine KANTIZA, Master UTICEF,-
Webmaster à la Radio-Télévision Nationale du Burundi &
Tél. Fixe : 00257 2222 4760 ou 00257 2221 9797
Tél.Mobile : 00257 (0) 79 994 560

Comment_performance_IANA_Antoine_KANTIZA.htm 7.06 KB

ISOC | Bill Graham

ISOC Comments

ISOC Response_Docket 110207099-1099-01.pdf 96.71 KB

IP Justice | Robin Gross

Please see attached Word file (and text below) comments from IP Justice
RE: Docket No. 110207099-1099-01
RIN 0660-XA23
Request for comments on the Internet Assigned Numbers Authority (IANA) Functions

United States Department of Commerce
National Telecommunications and Information Administration (NTIA)

RE: Docket No. 110207099-1099-01
RIN 0660-XA23
Request for comments on the Internet Assigned Numbers Authority (IANA) Functions

31 March 2011
Fiona M. Alexander
Associate Administrator
Office of International Affairs
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, N.W. Room 4701
Washington, DC 20230
Via email to:

ICANN’s Responsibility to Respect International Human Rights Principles
IP Justice [1] appreciates this opportunity to provide comment to US Department of Commerce National Telecommunications and Information Administration (NTIA) regarding improvements to the functions of the Internet Assigned Numbers Authority (IANA) and its relationship with the Internet Corporation for Assigned Names and Numbers (ICANN).

IP Justice would like to focus NTIA’s attention on one issue fundamental to all of ICANN’s responsibility -- one that impacts all of ICANN’s functions: ICANN’s obligation to respect internationally recognized human rights principles in carrying out its duties.

With power, comes responsibility. As the organization responsible for the global governance of certain functions of the Domain Name Space (DNS), ICANN must also be willing to live up to the same high standards as other legitimate governance organizations in respecting the fundamental rights of Internet users. Until a suitable legal framework is in the place that can hold ICANN accountable for circumventing internationally recognized human rights guarantees, ICANN is in no position to receive additional autonomy.

As a private corporation, there is very little to hold ICANN in compliance with international legal standards and human rights protections that nation states must respect. As a private corporation ICANN does not believe it owes any legal duty or ethical obligation to respect internationally recognized legal principles. Some contend that the legal structure of ICANN as a private corporation serves as a legal “loop hole” through which the organization can escape any responsibility to uphold human rights in the space where it governs.

ICANN’s connection to the United Stated Government through its contractual arrangement with NTIA is one of the few ways that ICANN can be held accountable to upholding fundamental rights and freedoms. The US Government is legally obligated to respect human rights, while private corporations are not. ICANN has provided mixed messages about the extent to which it owes an obligation to uphold international legal principles including human rights.

Legitimate governance organizations are rooted in legal traditions that respect human rights and have means of enforcing them. For example, the US Government is prohibited from restricting the speech of its citizens except in narrowly defined circumstances under the First Amendment to the US Constitution. Furthermore the US (and most governments that participate at ICANN) have signed the Universal Declaration of Human Rights, including Article 19, which “guarantees everyone the right to freedom of expression in any medium and regardless of frontiers”. Unfortunately ICANN remains unwilling to commit to human rights principles, preferring to remain without any legal duty or ethical obligation to ensure the public’s most fundamental rights are protected in the critical realm over which it claims authority.

ICANN must affirmatively answer that it will uphold internationally recognized human rights, but to date ICANN has flouted any obligation to protect the public in this manner. At the Rome ICANN Meeting in 2004, a European Union Privacy Commissioner said that ICANN’s “whois” policies violate international privacy protections. ICANN has done nothing to rectify this deficiency of privacy protections in its policies.

ICANN sees no duty to protect freedom of expression in the DNS either. Proposed policies for new top-level domains that would prohibit “sensitive” words as domain names are in stark contrast to internationally recognized freedom of expression guarantees. Internationally recognized legal principles of “due process” which ensure fairness can also be easily skirted in a private corporation that believes it owes no duty to the public.

Unfortunately ICANN’s lack of commitment to internationally recognized fundamental rights and freedoms threatens the healthy growth of the DNS and the global public interest. ICANN’s structure must be rooted in a firm foundation and a legally enforceable obligation to uphold basic rights. Today more than ever, we see the promise and the power of a free and open Internet to empower citizens and strengthen democracies. And we recognize the critical need to ensure the Internet remains an engine of human progress and freedom. Respect for human rights in the policies governing the DNS is critical to furthering the global public interest.

Since ICANN claims its objective is to promote the global public interest, it ought to be willing to adhere to internationally recognized legal principles that guarantee the public basic rights and fundamental freedoms. Removing any duty or legal obligation to respect human rights, which ICANN may have by virtue of its relationship with the US Government, would leave the public defenseless in cyberspace.

Without a legal mechanism to ensure ICANN will respect internationally recognized human rights, the same way a legitimate governance organization must respect human rights, it would be dangerous to grant ICANN further autonomy.

Respectfully submitted,

Robin Gross
IP Justice

IPJustice_comment_ICANN_IANA_31March2011.doc 37 KB

Hong Kong Internet Registration Corporation Limited (HKIRC) | Jonathan Shea

Dear Sir/Madam,

On behalf of Mr Jonathan Shea, CEO of the Hong Kong Internet Registration Corporation Limited (HKIRC), I submit the attached response to the captioned Notice of Inquiry. The original hardcopy of the attached submission will reach your address soon.


Henry CHAN

Hong Kong Internet Registration Corporation Ltd (HKIRC)
Ph: +852 2319 3830
Fax: +852 2319 2626

HKIRC Response to NTIA NoI on IANA functions.pdf 1.69 MB

ARIN | John Curran

Attached please find ARIN's comments (in pdf and in ascii text format) in response to NTIA's IANA functions NOI. We will also send a hard copy by mail.

Please let us know if you have any questions.

Thank you,

ARIN NTIA IANA NOI Response Approved FINAL.txt 10.57 KB
ARIN NTIA IANA NOI Response.pdf 4.06 MB

Association for Competitive Technology | Jonathan Zuck


My name is Jonathan Zuck and I am the President of the Association for Competitive Technology, a information technology trade association, representing nearly 4,000 small and medium sized enterprises. Attached please find our comments to the Department of Commerce Notice of Intent regarding the IANA Functions contract. Thank you for your consideration.


IANA Functions Letter 03-31-2011.pdf 205.72 KB

Kenya (Government) | Alice Munyua

Kenya comments on the Internet Assigned Numbers Authority (IANA) Functions

Kenya comments on Notice of Inquiry by NTIA on IANA Contract v4.pdf 74.56 KB

Self | Lorna Simiyu


Please find attached brief comments on the IANA as requested by the Department of Commerce raised in your (Docket No. 110207099-010) RIN 0660-XA23

Lorna T.M. Simiyu
Participant on the online Internet Governance training

Comments on the IANA _2_ Lorna Simiyu.pdf 17.7 KB
Comments on the IANA _2_ Lorna Simiyu.pdf 17.7 KB

Self | Jacob B.Odame

Please find attached my comments for the renewal of the ICANN contract.

Jacob B.Odame

Jacob_Odame_Student_Ohio UNiversity.doc 12.5 KB

ictQATAR | Mohammed El-Bashir

Please find attached ictQATAR Response to NTIA request for comments on Internet Assigned Numbers Authority “IANA” Functions .

ictQATAR Response to NTIA IANA Notice of Inquiry - 30 March 2011.pdf 906.75 KB

International Trademark Association (INTA) | Claudio Digangi

Dear Fiona Alexander:

I am writing to provide the comments of the International Trademark Association (INTA) in connection with the NTIA's Notice of Inquiry (NOI) on the "the Internet Assigned Numbers Authority Functions".

Should you have any questions regarding our submission, please do not hesitate to let me know.

Thank you for the opportunity to comment.

Best regards,
Claudio Digangi

Claudio Digangi
External Relations Manager - Internet & the Judiciary International Trademark Association

Comments of the International Trademark Association (INTA).pdf 159.05 KB

China Internet Network Information Center (CNNIC) | Xiaodong Lee

Dear NTIA,

China Internet Network Information Center (CNNIC) welcomes the National Telecommunications and Information Administration (NTIA) request for public comment on the Internet Assigned Numbers Authority (IANA) functions. CNNIC appreciates NTIA’s commitment to preserving the security and stability of the Internet DNS. In the meantime, we would like to emphasize that the security and stability of the DNS are shared responsibility among all stakeholders in the Internet community, which CNNIC thinks is yet properly incorporated in the management of the IANA functions. In this context, CNNIC would suggest that the future management of IANA functions reflect the smooth operation of IANA and reflect the interests of multi-stakeholders in the Internet community.

Specifically, CNNIC would like to make comment on the questions raised in the NTIA’s NOI,

1. The IANA functions have been viewed historically as a set of interdependent technical functions and accordingly performed together by a single entity. In light of technology changes and market developments, should the IANA functions continue to be treated as interdependent? For example, does the coordination of the assignment of technical protocol parameters need to be done by the same entity that administers certain responsibilities associated with root zone management? Please provide specific information to support why or why not, taking into account security and stability issues.

Generally, CNNIC doesn’t think it’s necessary to separate the IANA functions except for running a root server by IANA itself. CNNIC would suggest any separation of IANA functions take into consideration the stability and smooth operation of the functions.

2. The performance of the IANA functions often relies upon the policies and procedures developed by a variety of entities within the Internet technical community such as the IETF, the RIRs and ccTLD operators. Should the IANA functions contract include references to these entities, the policies they develop and instructions that the contractor follow the policies? Please provide specific information as to why or why not. If yes, please provide language you believe accurately captures these relationships.

CNNIC thinks IANA contract should include references to ccTLD operators for advice with regard to the ccTLD management principles and guidelines on IANA performance. Similarly, it is also advised that other performance of IANA functions consult with other proper entities to meet the demand of other stakeholders.

3. Cognizant of concerns previously raised by some governments and ccTLD operators and the need to ensure the stability of and security of the DNS, are there changes that could be made to how root zone management requests for ccTLDs are processed? Please provide specific information as to why or why not. If yes, please provide specific suggestions.

CNNIC submitted its IDN ccTLD application last year, and the request process took two distinctive processes within ICANN and IANA. While the ICANN process is relatively clear and transparent, the IANA delegation process isn’t clear and well-defined, which made CNNIC made a strenuous effort to meet the requirement. Based on this experience, CNNIC suggests the IANA process optimized to ease the burden with regard to the change of the request of ccTLDs. Moreover, it is also suggested the approval process by DOC be removed in the IANA process when change of request is submitted by ccTLDs to reflect the fact that the ccTLDs are to serve local community of the nation. The change of root zones should be maintained by IANA itself completely without involving DOC and Verisign.

4. Broad performance metrics and reporting are currently required under the contract. Are the current metrics and reporting requirements sufficient? Please provide specific information as to why or why not. If not, what specific changes should be made?

The reporting should be public, and the best multi-stakeholder model is to change the DOC-supervising-only model, and make IANA to be a real independent organization or run by an independent organization, which is supervised by the global Internet communities themselves.

5. Can process improvements or performance enhancements be made to the IANA functions contract to better reflect the needs of users of the IANA functions to improve the overall customer experience? Should mechanisms be employed to provide formalized user input and/or feedback, outreach and coordination with the users of the IANA functions? Is additional information related to the performance and administration of the IANA functions needed in the interest of more transparency? Please provide specific information as to why or why not. If yes, please provide specific suggestions.

Current IANA contract failed to include Service Level Agreement (SLA) in its service to the whole Internet community. In order to better serve the Internet community and to protect the stability and security of the Internet, it is highly recommended that SLA be introduced in the IANA management and the performance of IANA be published in a transparent and timely manner.

6. Should additional security considerations and/or enhancements be factored into requirements for the performance of the IANA functions? Please provide specific information as to why or why not. If additional security considerations should be included, please provide specific suggestions.

IANA should strengthen the multi-stakeholder model, and ensure all the root server operators to follow the policies and instructions that are developed by the community. Of course, as a neutral organization, it’s not necessary for IANA to operate a root server by itself.


Founded in 1997, China Internet Network Information Center (CNNIC), a non-profit organization, assumes the responsibility of “.CN” and ".中国/.中國" ccTLDs registry and other services for the development of the Internet in China, which are authorized by Chinese government. CNNIC is also an active participant in the global Internet community, helping to shape the global Internet policy making process for the sake of Chinese Internet users.


Xiaodong LEE

Deputy Director General and Chief Technology Officer, CNNIC

CNNIC comments on IANA Funcionts.pdf 302.91 KB

Self | Shawn Gunnarson

Attached are comments in Word 2007 format on the above-referenced NOI. Please contact me if you have questions or concerns.

Thank you.

R. Shawn Gunnarson

IANA Functions Contract NOI_RSG Comments.pdf 119.78 KB
IANA Functions Contract NOI_RSG Comments.pdf 211.78 KB

Cisco | Robert Pepper

Cisco Comments

Cisco.pdf 1.29 MB

NetChoice | Steve DelBianco

Please accept the attached comments in response to NTIA's request for comments on IANA functions.

Steve DelBianco
Executive Director
NetChoice and

NetChoice on IANA Contract.pdf 117.64 KB

Nokia Siemens Networks | Derek Khlopin

March 31, 2011

Fiona M. Alexander
Associate Administrator, Office of International Affairs
National Telecommunications and Information Administration

Re: NOI in Docket No. 110207099-1099-1

Dear Ms. Alexander,

Please find attached comments from Nokia Siemens Networks in response to NTIA's Notice of Inquiry requesting comments on the Internet Assigned Numbers Authority (IANA) functions. I have included the comments in both our preferred format, PDF, but also in Word format as the NOI did not specifically include PDF format as an option.

Please contact me with any questions about this submission.

Best regards,
Derek Khlopin

NSN Comments to NTIA on IANA Functions.doc 70.5 KB
NSN Comments to NTIA on IANA Functions.pdf 71.57 KB

The Multilingual Internet Group | Khaled Fattal

(Late Submission)
Dear Ms. Alexander

The Multilingual Internet Group is pleased to submit the following comments in PDF format to the National Telecommunications and Information Administration process on the Internet Assigned Numbers Authority functions.
[Docket No. 110207099–1099–01] RIN 0660–XA23: Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions

Best regards,

Khaled Fattal
Group Chairman
The Multilingual Internet Group
Linking Together The Current & Next Multi-Billion Multilingual Internet Users
Member of ICANN President's Advisory Committee on IDNs (ICANN)

Khaled Fattal MLIGRP letter to NTIA on IANA.pdf 238.26 KB

Self | Jean-Jacques Subrenat, Beau Brendler, and Eric Brunner-Williams


Please find our comments on the IANA Function NoI attached as a .pdf.


letter-to-NIST-re-IANA-functions.pdf 67.92 KB

European Telecommunications Network Operators (ETNO) | Caroline Greer

Dear Ms. Alexander,

The Association of European Telecommunications Network Operators (ETNO) is pleased to present its attached

ETNO Reflection Document - Response to the National Telecommunications and Information Administration of the US Department of Commerce on the Internet Assigned Numbers Authority (IANA) Functions

ETNO represents 40 major European telecommunications operators from 35 countries ( attached paper has the format of a Reflection Document, meaning it has been unanimously approved by all Member companies and has been endorsed by the Association’s Executive Board. The paper falls in the public domain and may be published.

In ETNO’s view, the responsibilities of the IANA functions should remain as a whole within ICANN and not fall under any direct government oversight. In this respect, we urge ICANN to work towards fully implementing the Affirmation of Commitments and its resulting recommendations for improvement and we ask the US government to act as a catalyst in this direction.

Many thanks,

Kind regards,

Caroline Greer
Regulatory Affairs Manager
European Telecommunications Network Operators (ETNO)

RD348 - IGV NTIA on IANA.PDF 119.26 KB

eCOM-LAC | Anthony Harris

Fiona M. Alexander
Associate Administrator
Office of International Affairs
N.T.I.A. - U.S.Dept. of Commerce

Please find attached response to the RFC on the
IANA Functions.

Yours truly,

Anthony Harris
Executive Director