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Date: 3/31/98 8:05am
Subject: O:?DMSTX?SITACOM3.DOC

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Geneva 31 March 1998

SITA response to US Department of Commerce Green Paper on
the Governance of Internet Domain Names

We have read the above mentioned Green Paper with great interest and are writing to outline SITA's position on the matter. SITA considers that the Internet community has an enormous responsibility in this initiative, and believes that a "no comment" action could be considered as a "non-opinion" on a matter that will have a tremendous impact on all the sectors of society.

The world is experiencing an exponential growth in Internet traffic which is defying any kind of planning and projections. The international community of users is seeking a fair and enhanced system to structure and register Domain Names on the Internet. Traditional means of organizing Internet technical functions need to change. The pressure for change reflects the widespread dissatisfaction in the way these names are structured and registered. The absence of competition in domain name registration and mechanisms for resolving disputes between trademark and domain name holders are both expensive and cumbersome.

We welcome the US Department of Commerce's commitment to ending its direct involvement in Internet governance but we are concerned by the following issues:

Today the Internet is global because its transcends geographical borders. Users, businesses, telecommunications companies, and institutions from all over the world have developed and paid for the Internet and today the Internet is overwhelmingly a result of commercial investments. This Paper constitutes a direct implication of the United States in the governance of the Internet, which is in our view questionable;

According to the Paper Internet governance would be transferred to a U.S. based corporation subject to U.S. law, and a new system would ensure U.S. jurisdiction over trademark issues and dispute resolution processes, all of which are questionable in our view. Moreover, this does not reflect the US commitment to end its involvement in Internet governance and in fact is contradictory to a fair representation of worldwide stakeholders in Internet coordination functions;

Internet addresses which began originally as a project of the U.S. government, are still registered through a group contracted by the National Science Foundation, a U.S. government agency. In April 1997, international organizations, national firms and cyberspace bodies which established CORE to deal with the registration issues signed an agreement that sets up a new structure for registering addresses on the Internet. The CORE initiative has made an enormous contribution to the development of the Internet, and in our view, further consideration should be given to this alternative. We do however recognise that this new private-sector initiative may at present leave more questions unanswered than answered;

The US Government favours a competitive, private-sector-driven approach on Internet matters. Domain Names constitute a global network as long as we all follow the same rules to have an integrated Internet. The root server system was developed under a Defense Department contract however we believe the system should be handed over to a private-sector entity which could determine which approach will ultimately prevail. Any approach that seeks to fracture the Internet should be avoided;

Provision of a flexible system for on-line dispute resolution under international supervision should be taken into consideration when implementing a final plan.

In SITA's view, it is not proper that the registration of Internet addresses should be a function of one single government. There should be competition in assigning Internet names because there is a value to names. SITA considers that it would be preferable to adopt the best features from existing systems and initiatives to harmonize guidelines and adapt the Commerce Department's plans to provide a consistent framework which reflects best international practice.

SITA would like to make sure that these concerns are brought to the attention of the US authorities and that due consideration is given to the concerns of the international community when implementing any changes to Internet governance.

Yours sincerely,

Frederik de Cock

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