From: Keith Weng <Keith@atreve.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 3/12/98 6:23am
Subject: DNS authority

It is really too bad that the various governments have taken such a
knee-jerk attitude towards DNS administration.

The internet will only continue to succeed at a pace far beyond that of
the rest of the economy if it isn't hamstrung by the bureaucracy facing
the rest of the economy.

Please adopt a more open position to global administration of DNS.

Keith Weng
San Francisco.

###

From: <FRANK.ERZ@lhsystems.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 5:27am
Subject: New top-level-domains

Hi,

my name is Frank Erz, and i´m an german it-specialist.

I think, these sites have only the one reason to get a "people opinion"
which is good for the U.S Gov. oder IANA or other american institutes.
The Internet is a _world_ wide net and if the net will be free of
american ruling now, or in some months or years makes no difference.

It is not, that all these other peoples (non americans) are stupid or
have an iq of 60. No.
It is the "national feeling" of americans to be the one nation in the
world who has the right to make rules or to rule.

At last i want to say, that a lot of good stuff comes from the U.S.A.
and that i have a lot of american friends,
but in a few ways the american way is wrong.

Frank Erz
Frankfurt/Main
Germany

###

From: Robert Ridgeway <ridgewrg@columb34.dhec.state.sc.us>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 10:49am
Subject: Proposal to Improve T. M. I. N. A.

After consideration, I believe the alternate plan proposed by
CORE is more conducive of the internet's increasing pluralistic
expansion & popular availability.

Sincerely,
Robert Ridgeway

###

From: Boudewijn Nederkoorn <Boudewijn.Nederkoorn@surfnet.nl>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 11:04am
Subject: RIPE CENTRE Respons to the NTIA Green Paper

To the
National Telecommunications and Information Administration
US Department of Commerce

In response to your Proposed Rule and Request for Public Comment, we
should like to bring your attention to the attached documents which
represent the common consensus of thirty-three ccTLD registries from
the "RIPE Area", most of them in Europe.

Three documents are attached, to wit:

"RIPE CENTR: Formation and Purpose", setting out the reasons for
and purposes of current concerted action by ccTLD registries in
the RIPE area, known by the working title, "RIPE CENTR project";

"RIPE CENTR Position Paper on Future Governance of the
Internet", setting out the common views and requirements of the
participants in RIPE CENTR in regard to this matter; and

"RIPE CENTR Response to the NTIA Green Paper of 30 January
1998", responding in detail to those sections of the Green Paper
on which the participants in RIPE CENTR share a common view.

We are pleased to have the opportunity to comment on the Green Paper,
and are confident that our concerns will be given due consideration.

On behalf of the participants in RIPE CENTR,

Boudewijn Nederkoorn

CC: NTIADC40.SMTP40("centr@ripe.net")

RIPE CENTR -- Formation and Purpose

Status: Final

Date: 13 March 1998

RIPE CENTR

RIPE CENTR is a project through which ISO 3166 Country-Code Top-Level
Internet Domain (ccTLD) Registries in the RIPE geographical area
intend to co-operate and to engage in concerted action on issues of
common concern. It is anticipated that a suitably-constituted legal
entity may be formed as a result of the project to continue this work.

At this stage, the name CENTR has only historical significance, and is
likely to be reviewed.

RIPE CENTR has developed from preparations made by RIPE, in particular
in the RIPE Top-Level Domain Working Group. These preparations are
documented in the working group task force report and in the RIPE-NCC
proposal to run the CENTR project (respectively
http://www.ripe.net/wg/tld/task-force/ripe-centr-1.1.html and
http://www.ripe.net/docs/ripe-177.html).

Prior to the forming of RIPE CENTR, ccTLD registries presented their
individual standpoints as best they could, but due to the sheer number
of them and their individually small size in comparison to some gTLDs,
this message was often drowned out. Partly for this reason a number of
ccTLD registries in the RIPE area have decided, through the focal
point of RIPE CENTR, to discuss matters of policy that affect all
ccTLDs and then, where possible, to present the group's position as
one voice. It is felt that one coherent voice from a large group will
have more influence and will make it easier for external parties to
gauge what the opinion of the RIPE area ccTLD registries is.

Although a proposal for RIPE CENTR had been on the table for a few
months a decision to go ahead with the project was only made on 2
March 1998. On this date a meeting was held to which all RIPE area
ccTLD registries were invited. Twenty registries were represented at
this meeting, all of whom agreed to support and take part in the RIPE
CENTR activities. In addition to those attending support has also been
given by thirteen other ccTLD registries, resulting in an initial
participating group of 33 ccTLD registries as listed below. These
registries are willing and able to fund the project for the initial
period of operations which is completed on 31 December 1998. During
that period the project will be managed by staff members of RIPE NCC
on behalf of the participants in RIPE CENTR.

All RIPE area ccTLD registries who so wish may be participants of the
RIPE CENTR project, and until the end of the initial project period
they may individually determine the level of funding they contribute.

The work plan of RIPE CENTR is determined by its participants, however
it has been agreed that the initial work plan will be that laid out by
the TLD working group (http://www.ripe.net/wg/tld/workplan.html).
Within the work plan there are two types of items; those items that
are given to the staff running the RIPE CENTR project within RIPE NCC;
and those items, mainly policy questions, that become points of
discussion within the participants group. For the start up period
there will only be one level of hierarchy within RIPE CENTR, the
participants. All discussions and decisions will take place with input
from all participants. It is not thought appropriate at this stage to
have an executive council, or such like, in order to make decisions.
Discussions and decisions will take place by means of a mailing list
and physical meetings. Especially in the first months it is deemed
beneficial to hold a frequent number of physical meetings.

An important point to stress is that RIPE CENTR has a coordinating
function and not a controlling function for the RIPE area ccTLD
registries.

All decisions, information, studies etc of RIPE CENTR will be made
publicly available at the following URL http://www.ripe.net/centr/.

The following list shows the country, ISO 3166 code, and responsible
person for each of the 33 ccTLDs currently supporting the RIPE CENTR
project:

ANDORRA .ad Jaume Salvat
ARMENIA .am Edgar Danielyan
AUSTRIA .at Gerhard Winkler
AZERBAIJAN .az Eugene Degtyarev
BELGIUM .be Pierre Verbaeten
BULGARIA .bg Daniel Kalchev
CZECH REPUBLIC .cz Jiri Orsag
DENMARK .dk Per Koelle
FRANCE .fr Annie Renard
GERMANY .de Sabine Dolderer
HUNGARY .hu Balazs Martos
IRELAND .ie Niall O'Reilly
ITALY .it Vittore Casarosa
LATVIA .lv Guntis Barzdins
LITHUANIA .lt Daiva Tamulioniene
LICHTENSTEIN .li Marcel Schneider
LUXEMBURG .lu Marc Hensel
MALTA .mt Victor Nezval
NETHERLANDS .nl Boudewijn Nederkoorn
NORWAY .no Havard Eidnes
POLAND .pl Maciej Kozlowski
PORTUGAL .pt Pedro Veiga
ROMANIA .ro George Macri
RUSSIA .ru Alexei Platonov
SLOVENIA .si Barbara Povse
SPAIN .es Miguel A. Sanz
SUDAN .sd Ihab I Osman
SWEDEN .se Eva Froelich
SWITZERLAND .ch Marcel Schneider
TURKMENISTAN .tm Mark Henderson-Thynne
UKRAINE .ua Yuri Demchenko
UNITED KINGDOM .uk William Black
YUGOSLAVIA .yu Berislav Todorovic

-------------------------------------------------

RIPE CENTR Position Paper on Future Governance of the Internet.

Status: Final

Date: 13 march 1998

CONCERTED ACTION

By means of a consensus-building process that began in May 1997, ISO
3166 Country-Code Top-Level Internet Domain (ccTLD) registries in the
RIPE geographical area have agreed on concerted action to address a
number of common needs.

These needs are currently:

* to brief government and other parties on the concerns and
requirements of the TLD registries involved regarding the future of
the Internet Assigned Numbers Authority (IANA) and the stability of
the Internet Domain Name System (DNS) root; and

* to gather and publish information of common interest.

The RIPE area ccTLD registries, which are responsible for the
overwhelming majority of domain registrations in their area, share a
vital interest in IANA and in the stability of the root of the DNS.
They require that this interest be protected by appropriate
representation in the structures which will emerge for the governance
of the Internet.

The ccTLD registries are also eager to improve co-operation and
sharing of information and have agreed to set up and fund a joint
project which will advance these goals. This project, which will
eventually become a legal entity in its own right, is called RIPE
CENTR. Information regarding the participants, establishment and
function of RIPE CENTR may be found in a companion document.

This concerted effort by the RIPE area ccTLD registries is of
particular importance in view of the recent Green Paper on technical
management of the Internet published by the NTIA, an organ of the US
Department of Commerce. The publishing of this Green Paper, coupled
with comments from other parties, has precipitated the need for the
requirements of the ccTLD registries to be made public, before any
decisions on Internet governance are made.

RIPE CENTR ccTLD Registry Requirements

In December 1997 a point was reached when more domains were registered
to non-US based organisations than US based organisations. For the
European area, 70% of the European-based organisations registered
their domain names with one of the ccTLD registries. As a group ccTLDs
now register a similar amount of domain names to that of the gTLDs,
and as such have comparable and equally valid concerns about future
governance of the Internet. Internet governance is a global issue as
opposed to an internal US issue and the process leading to its change
should take this into account.

The RIPE area ccTLD registries have specific requirements for any
future governance of the Internet and in particular any future
structure of IANA. These requirements are not necessarily
contradictory to those of any of the other stakeholders but it is
thought pertinent to mention them explicitly.

Before any detailed requirements are set all parties should be aware
of the following principles by which ccTLDs registries exist.

* ccTLD registries have autonomy in their relations with IANA.

* Authority of ccTLD registries comes from local consensus.
The role of IANA is to recognise the decision made by the
process of local consensus.

The ccTLD registries co-operating in RIPE CENTR are in favour of a
bottom-up self-governance of the Internet. Governmental influence in
Internet governance should be kept to a minimum.

In any future relationship that ccTLD registries in the RIPE area have
with IANA it is desirable that the following requirements are met:

* that IANA becomes a separate legal entity which has the ability
to make contracts and which can be referred to by third parties;

* that the neutrality and high quality of service now given by
IANA in the management of the "dot" root zone be continued;

* that the stability of the "dot" root zone be ensured;

* that all stakeholders of the IANA activities and in particular
the ccTLD registries in the RIPE area have a mechanism whereby they
can give collective input to IANA; and

* that IANA manages the needs of all of its stakeholders for the
common good of the worldwide Internet community.

Elsewhere, in discussion of Internet governance, considerable
attention is given to gTLD matters and how the gTLD community should
be organised. RIPE CENTR would like to stress that gTLD registries and
registrars are only one of IANA's several stakeholder constituencies,
and that the other stakeholder positions, including that of the ccTLD
registries should be taken into account more explicitly, particularly
in designing the system of membership for IANA. RIPE CENTR ccTLD
registries are willing to help fund a future IANA through such a
system of membership.

RIPE CENTR is eager to be an active participant in the future
structure of IANA and in the process of achieving this structure.

All comments regarding this position paper are welcome and will be
given due consideration.

RIPE CENTR Response to Green Paper from US Government

Status: Final

Date: 13 march 1998

Summary

This response to the US NTIA Green Paper is the common consensus of
the Country Code (ISO 3166) Top Level Domain (ccTLD) registries
supporting the RIPE CENTR project.

The RIPE CENTR ccTLD registries are unable to welcome the Green Paper
as a whole primarily because recognition of the position of the ccTLD
registries is omitted. In this response, we propose a remedy for this
omission, suggest ways in which we feel some of the proposals made in
the Green Paper can be improved, and identify specific proposals which
we welcome.

We avoid comment on the organisation of generic TLD's, on regional IP
address registries and on other technical parameters as mentioned by
the Green Paper, since these matters are outside our prime area of
interest. We concentrate on addressing ccTLD matters and the operation
of the root name server system.

The RIPE CENTR group would like to stress that gTLD registries and
registrars are only one of IANA's several stakeholder constituencies,
and that the other stakeholder positions, including that of the ccTLD
registries should be taken into account more explicitly, particularly
in designing the system of governance for IANA.

Introduction

This document is a response to the "Green Paper" issued by the
National Telecommunications and Information Administration (NTIA), US
Department of Commerce, entitled "Improvement of Technical Management
of Internet Names and Addresses", under Federal Register Docket No.
980212036-8036-01, RIN 0660-AA11, dated February 20, 1998, for which
public comment is requested until March 23, 1998.

This response to the US NTIA Green Paper is provided by the members of
a group of Country Code registries belonging to the RIPE area. RIPE
(Reseaux IP Europeens) is an open collaborative organisation whose
objective is to ensure the necessary administrative and technical
coordination to allow the operation and expansion of a pan-European IP
network. These registries -- listed in a companion document -- are
currently forming a separate body, in order to become recognized as a
major stakeholder in all matters concerning the Domain Name System
(DNS). More information on this group which is currently named RIPE
CENTR (RIPE Council of European National Top Level Domain Name
Registries) can be found in a companion document, "RIPE CENTR:
Formation and Purpose" (http://www.ripe.net/centr/docs/formation.html).

Position of ccTLD's in the new IANA structure

Although briefly mentioned in chapter II/B, the Green Paper appears
not to recognise adequately the significance of ccTLD's in today's
Internet. Some clarification may be appropriate:

* The first ccTLD has been assigned in the same year as COM was introduced=
(1985)

* A January 1998 Network Wizards' statistics shows the
number of hosts registered in gTLD ccTLD domains as:

gTLDs (com,net,org,mil,edu,gov,int) ---> 19547412 hosts (66%)

ccTLDs (ISO 3166 country codes) ---> 10044861 hosts (34%)

* As of January 1998 there were approximately 1.2 million second
level names registered under COM and approximately 800,000
second- and third-level names in ccTLD's.

Thus nTLD's represent a very significant constituency within the
Internet community. This constituency has the same crucial interest in
the stability both of IANA and of the DNS root as has the gTLD
constituency. We need to see this interest given the protection of
explicit representation in the management structure of the new IANA
organisation.

The two constituencies mentioned are however rather different in
nature. Country Code TLD registries derive their authority from local
consensus in each territory defined in ISO 3166, and are then
recognized by IANA. ccTLD registries have autonomy in their relation
with IANA. IANA has no means to create a new ccTLD except when new
territories are recognized by ISO. On the other hand, it is proposed
that some initial number of new gTLD's will be created, and that
others may follow later, a delicate and continuing process. It appears
that IANA may decide this through some decision process yet to be
defined.

Because of this distinction in nature between the ccTLD and gTLD
constituencies, we believe that it is appropriate to provide for
separate and adequate representation of each in the management structure
of the new IANA organisation.

We stress that the issue of representation is most important for us.
We believe that accomodating our interests does not interfere unduly
with the other interests which we recognize must also be represented.

Corporate Structure of New IANA

Although a model for the management structure of the new IANA is
suggested in the Green Paper, it is not clear to us what is intended
to be the corporate structure, or membership, of the organisation. We
suggest that the new organisation have a general assembly -- or
equivalent structure for members to exercise influence -- whose broad
membership will also include all of the ccTLD registries.

We would like to make clear our preparedness to participate in funding
the future IANA.

Operational Detail in the Green Paper

We are surprised at the level of operational detail contained in the
Green Paper. We would expect that an appropriately constituted and
responsible management board for the new IANA would be competent to
deal with all operational policy issues.

Trademark Issues

The RIPE CENTR group is well aware of the dilemma with intellectual
property rights and domain names. But since ccTLD names are usually
registered under local jurisdiction, conflicts may be solved locally.
The proposal by WIPO, however, appears very interesting and may prove
useful also on a local basis.

Welcome Elements

We can readily give our support to the following elements contained in
the Green Paper:

* The proposed bottom-up structure of the IANA and a self-regulation and
self-contained form;
* While appreciating and saluting the key role played by the US Government
and several of its agencies in the development of the Internet until
now, we agree that disengagement of government is now appropriate;
* We welcome the proposal to establish IANA as a legal entity in its own
right, and to give it a globally representative and robust management
structure;
* We rely on a stable root name server system and therefore support any
activities to even improve or at least ensure the current status;
* We welcome the opportunity to comment on the Green Paper, and look
forward to participating in constructive dialogue.

###

From: "Rway Communications (Joe Angiolillo)" <joea@rway.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 4:54pm
Subject: Green Paper comments

To Whom It May Concern:

I suggest that the duties now performed by NSI be transitioned to
the CORE under their gTDL-MoU. My understanding is that this MoU is
already supported by the IANA. The gTLD-MoU has many points in common with
the Green Paper.

Why create another proceedure when the CORE has spent the last
two years developing an agreement that is ready to take affect? By
using what the CORE has the transition from the government to the
private sector should go smoothly and rapidly.

Thanks,
Joe Angiolillo

CC: NTIADC40.SMTP40("dbshields@rway.com","webmaster@ra...

###

From: fneilson <fneilson@mauimail.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 5:02pm
Subject: Re:DOWN THE TOILET

ATTENTION: IRA MAGAZINER

Well, I might as well flush the toilet on my software development company.
What about .flush or .magazineriswreckingtheinternet? Why don't you put
those on the Internet.

I wonder if those are under the new TLD's you're going to offer us starving
companies (small business, not like NS. You know, the companies that you're
ignoring and that account for much of the growth of the WWW.)

I have put our business cards and advertising on hold until the new core
TLD's are active. Thank you for wasting my time and money while you twiddle
your thumbs.

Frank Neilson

We are approaching bankruptcy fast. And wouldn't you like to know who I
represent.

###

From: lawrencen <lawrencen@mauimail.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 5:11pm
Subject: comment

Domains confusing now. This makes job much harder because
I must find more domains to register for company.

I read comments of Internet domains. Most comment not support draft.

The responsible thing to go back in the drawing board.
This Internet part of everyone, not U.S. company only.

I learn English so make comment to you.

Thank you,

###

From: "Joseph Yeung" <yeungjoseph@hotmail.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 5:13pm
Subject: Listen to the Internet community

DEPARTMENT OF COMMERCE
TO: IRA MAGAZINER

The draft proposal for Internet Governance is very well written. I am
encouraged by the step the U.S. Government is taking in creating this
proposal. I do, however, have some concerns.

Trademark disputes in the area of domain names are inevitable. The
draft does not mention trademark dispute resolution procedures. It does
not mention anything about international trademark organizations such as
the World Intellectual Property Organization.

International participation, further, is crucial from all stake holders
in the Internet, from industry and users. Inclusion rather than
exclusion is the way to build a democratic, secure Internet.

Competition has been given to only five registrars. How will this
create real competition with Network Solutions as one? They have
already established much influence in this market, and they have a
client base who are paying them as I write this. Others, however, would
not have this large advantage. The CoRe registrars would further be
disadvantaged if Network Solutions became a CoRe member, though I have
heard it is open to companies who wish to join as long as they meet
certain requirements.

CoRe is not mentioned in the draft. This is disappointing because their
proposal makes the most sense, even over the draft. Maybe it isn't
perfect, but at least it addresses all the points above.

What's more important than talking is listening constructively. Listen
to the European Union and Australia. And to the rest of the Internet
community. Take the majority view to heart because that is the
foundation of democracy

Sincerely Yours,

Joseph Yeung

______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com

###

From: "Jose Fernandez" <jfernan@mailcity.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 4:39pm
Subject: http://www.gtld-mou.org

Please do not make a rash decision and ignore the work of the gtld mou. You may
visit this at http://www.gtld-mou.org if you missed it, Mr. Magaziner.

It's hard to overlook something that makes so much sense unless there's other reasons
(CIA friends, NSI payoffs, etc.) to ignore it.

Jose

Get your FREE, private e-mail
account at http://www.mailcity.com

###

From: frank noran <noran@discoverymail.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 4:45pm
Subject: INTERNET DOMAIN DISCUSSION DRAFT

Dear Sirs and Madams,

I wish to wholeheartedly congratulate and voice my approval to Ira
Magaziner and others involved in preparing the Discussion Draft for the governance of the Internet Domain Name System.

It's grrrrrrrrrrrrreat! It's lightàyet filling. It's vagueàyet too vague.

This proposal is key to preserving the Network Solutions monopoly and creating a false sense of competition. What we don't need on the Internet is an open and accountable
system that is legitimate in the eyes of Internet stakeholdersàboy have you ensured that in the draft!

That gtld-mou could only bring legitimacy to the domain name system. The move by government to wrest control of the system from legitimate agencies, such as IANA and from
the people of the United States was self-serving and did not meet with approval of many in the Internet community.

This gtld-mou was supported by Jon Postel, head of IANA,
a man who has made an unmeasurable contribution to the Internet's development. His support has undoubtedly lent legitimacy to the gtld-mou. And the fact that it came out of a two-year consultative process with the Internet community. And the fact that it has international approval. And the fact that it opens the domain name registration market up for real competition. And the fact that it's a solution that's ready to implement NOW, not two years from now.

You will undoubtedly receive a barrage of negative response from those involved in the gtld-mou, especially those who have a financial stake in the plan's success, and from most of the Internet community, including countries all over the world, who have also not been adequately addressed in your draft. Good job, Ira!

Again, thank you for your efforts on this plan and congratulations! Without your valuable insight, where would we be now? Perhaps with 7 more domain names and a good deal of Internet growth, employment, and innovation.

Sincerely,

Frank Noran

Sent by Discovery Mail

###

From: Dave Womack <dwomack@dragons-inn.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 9:21pm
Subject: Internet Input

The internet works, and it works because one entity
manages one machine well.

Let's not trash the information superhighway! Let's
keep things the way they are!

Regards,

Dave Womack

###

From: Joe Yamiolkowski <jyamiolk@nimbus.ocis.temple.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/13/98 11:47pm
Subject: Server Registration?

Dear Madame or Sir,

I would like to know if there is a registration process to maintain a
server (e.g. "...lycos.com"). Could you please advise me of this
process if it is indeed necessary.

Thank you.

Sincerely,
Tim Hicks

###

From: "jfernan@mailcity.com" <jfernan@mailcity.com>
To: "dns@ntia.doc.gov" <dns@ntia.doc.gov>
Date: 3/13/98 10:43pm
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