Attached you will find the raw transcripts from an open and public briefing that took place on February 23, 1998 by Ira Magaziner and Beckwith Burr on the subject of the Commerce Departments discussion draft on Internet governance and domain name administration. The meeting was publisised by several industry associations and open to anyone who came. These transcripts have not been fully edited for the correct spelling of names, sentence structure, or content. Thus, they only represent the effort of a commercial transcription service to transcribe a tape recording made of that briefing.
INTERNATIONAL BUSINESS MACHINES CORPORATION
Public Hearing with Ira Magaziner
White House Advisor
Associate Administrator NTIA / Department of Commerce
February 23, 1998
Professional Transcription Service
Area Code 202 347-5395
P R O C E E D I N G S
MR. : -- succinctly on what the real issues are, and I think for that, we owe you a great deal of thanks.
There are some very specific things about this meeting that we need to probably disclosed, and Roger Cochetti is going to do that for us. Thanks.
MR. COCHETTI: Thanks, Don. I will be brief, and say first, on behalf of IBM, welcome to all of you here. We are pleased that we are able to provide a facility of this sort, and facilitate a discussion and dialogue on what, to us, is an extremely important subject, namely the governance of the administrative functions of the internet. We have all watched the developments in this area take place over at least the last year and some people longer, and certainly among the most important, if not the most important, of those developments was the release on January 30 of the green paper or discussion and draft by the Commerce Depatment, which I think was notable in that it put forward a plan to address nearly all of the central administrative functions of the internet at one time and place in one system.
For those of you who have not seen that plan, or don't have copies of it, there are copies outside, and I suggest you grab one and sort of flip through it.
Some of you may or may not know, that on Friday, the plan was issued as a formal document by the NTIA, Commerce Department, in the Federal Register, and we are now in a formal comment period. As a consequence of that, there is some formality associated with today's meeting that I should remind everyone of and ask if anybody forgets that others would please remind them.
First, it is important, before you speak, that you either be identified, and if you are not identified, that you identify yourself, and identifying yourself if you are speaking as an individual, then you can identify yourself as an individual. If you're speaking on behalf of some organization or institution, then you should identify that organization or institution.
There will be a record created and preserved of today's meeting, so everything that you say is going to be on the record. The meeting is open. I can not tell you whether or not there are press attending, but I can tell you that the record will be available to anyone from the press who requests a copy of it.
And so, with that, I'd like to turn it over to, I guess, Jeff and Brien, or how do we go?
MR. O'SHAUNESSY: Well, my name is Brian O'Shaunessy from the Interactive Services Association, and a number of groups were asked to contact our members so that we could present Mr. Magaziner, the Interactive Services Association, I SOC, CIX, CDT and ITAA members were invited to come, and at Roger's request, we are now happy to have Becky and Mr. Magaziner with us today, and look forward to a lively Q and A session, and hopefully we'll take a short break about halfway through, so those of you can get coffee, and hopefully a few more people will joining us before the end of the session.
So with that, Mr. Magaziner?
MR. MAGAZINER: Thank you. First, thank you very much for hosting this. Can you hear me all right?
I won't go through the paper, because I assume you've all seen it, but let me just say a few things about the spirit in which this was offered. For historic reasons, the U.S. government has had a role in the domain name and internet address systems, and it is agents of the U.S. government, the IANA and NSI, that have been carrying out various functions under contract, in the case of IANA, and a cooperative agreement in the case of NSI.
And DARPA and NSF, which have been the contracting agencies, have been seeking to move out of this role and the U.S. government in general, as the internet has grown, has been seeking to move out of its role, because we don't believe it's appropriate for the U.S. government to have this kind of role vis-a-vis the internet as it becomes more commercial and more international.
And so last summer, the President directed us to try to make a more private international and competitive system of technical management for internet names and addresses. One of the things which we knew last July, and which we still know, but nevertheless had to disregard, is that it's much easier to stay popular if you stay at a general level than if you try to get into specifics, particularly in Washington, but we felt that, in this case, we had to get into specifics about how we were going to devolve the U.S. government role, because otherwise it would not be a smooth transition.
And so this paper is offered up as one step towards greater specificity in terms of accomplishing that goal.
Our two purposes are, first and foremost, as a kind of prime directive, if you will, is to preserve the stability of the internet. As we move through this necessary transition, we have to insure that there is stability, and that the internet does not break down in any way.
And number two, we want to move toward a more private, competitive, international system. Those are our two goals in this.
Let me finally say, by way of introduction, that a lot of the things we put in here were kind of, you know, 60/40 decisions that could have gone either way, where our own internal group, our interagency group that has produced this, were kind of disagreeing among ourselves, and where none of us were totally happy with the solution we proposed. But we couldn't think of any better one.
So I say that by way of saying that we are quite open to suggestions here for better ideas, because we don't think we've necessarily got the best ideas. They're the best we can think of, but we're not sure there aren't better ones out there.
So we are serious about the public comment period here. We're looking for ideas. We've already gotten a significant number of comments in since January 30th when the paper was put out. The period will go to March 23rd, so in effect, it will have been almost two months of comment period. And then it's our hope to fairly rapidly after that produce another draft and get going with implementing this privatization. So that's the path we're on.
Becky just got back from Europe. I just got back from Asia, where we consulted with business groups and governments and internet service providers groups and internet technical groups, and have been encouraging their comment has well.
And as Roger said, everything including e-mails we're receiving on the topic and everything else are all going to be made public. It's all going to be posted on the Web site. And even written comments we get are being scanned and posted on the Web site. So everything is a public process right now, in commenting on this. Including this meeting.
All right. Let me stop there, and why don't we just get into a discussion or questions, or whatever. Yeah.
MS. DOOLEY: I have a couple of questions Barbara Dooley from the Commercial Internet Exchange. There may be people --
MR. MAGAZINER: Barbara, I think Roger wants you --
MR. COCHETTI: I'm sorry, you need to use the microphone.
MS. DOOLEY: I have to go to the microphone. And they're not about domain names. It's about the administrative things.
Is this process now that --
MR. COCHETTI: Barbara, can you introduce yourself, please?
MS. DOOLEY: Barbara Dooley, Commercial Internet Exchange. Is this process, now that it's gone into the Federal Register -- now I get all confused with registries, registrars, and --
MS. DOOLEY: Is this an administrative rule making process, so that what comes out of it will, in fact, be implementable policy and if that is, indeed, the case, is there anything that would prevent it from being implemented? That's my first question.
The second is that, since you both have had these consultations outside the United States, is there a general support for the green paper process to continue in this way, or have you gotten some opposition that the U.S. government should be involved in this way at all?
MS. BURR: Shall I answer the APA question? Our decision to issue this as a notice of proposed rule making was really out of concern for making this process proceed smoothly. Not that we were convinced that this was necessarily a rule making, although, in fact, some of the criteria for registries and registrars could be interpreted in that way.
Largely what we wanted to do is not get down the road so far and be stopped by a claim that this was a rule making, so we elected to proceed in accordance with the Administrative Procedures Act. So that's the first piece of this.
The question about whether we would be ready for final rule making turns on a bunch of legal standards about whether what comes out after this is adequately noticed in this paper. It's our hope that anything that comes out of this produces some consensus and is therefore adequately noticed, and we can proceed without delay. But that's the reason for the APA piece there. It's really a prophylactic, keeping us moving ahead with due speed.
MR. MAGAZINER: And the other question -- and Becky, you might want to add to this -- but my sense is that there is an acceptance, by and large, of this process as a reasoning process to proceed. I think -- you know, I attended the Apricot meeting in Manila and had about a hundred representatives -- or more, about 150 of the Asian internet community in what turned out to ultimately be about a six or seven hour series of sessions, just open discussion.
I think there was only one voice that was questioning the legitimacy of the U.S. government out of the 100 or 150. I think -- and I'm sure there are some odd voices out there that would question it, but I don't think -- I think most people are accepting it, and I think even the foreign governments who are nervous about whether we're developing too U.S.-centered a proposal nevertheless, I think, recognize that this is something that has been of the U.S. government. I think they're generally supportive of privatizing it, and I think they're not challenging the procedures so much.
So my sense is that the procedure has, by and large, legitimacy, even though I think a number of people who are involved with the GTLDMOU might have preferred a different procedure, I think they understand and recognize this procedure at this point.
MS. BURR: Yeah. I was in London and Paris, and Brussels, and my sense is that the procedure is viewed largely as legitimate. There are specific questions about whether the U.S. government should do this or that, but I didn't get questions that go to the heart of this. I think the rest of the world wants a decision that moves us into privatization, and recognizes that this is a way to get there.
MR. MAGAZINER: The other thing we get, I think, in some of the -- I think some of the government officials that I've spoken to also recognize the need to do this in a deliberate way, because they understand that, you know, we're trying to set something in motion that's going to hopefully last for decades, and if it takes an extra some number of months to make sure it gets done right, I think they're less concerned about that than they are about what gets done, ultimately.
MR. TAURENCE: Hayward Taurence, Bell Atlantic. What kind of timetable are you looking at for the introduction of new generic top level domains durring the transition phase? And also, how many do you anticipate introducing and who will decide which one is introduced?
MR. MAGAZINER: Well, this is one of the things which we're actively interested in getting comments on. What we've proposed is the introduction of five new domains during this transition period. And we have proposed a process which would be a process where there would be some independent agencies -- sorry, not agencies.
MS. BURR: Auditors?
MR. MAGAZINER: Auditors hired by the IANA that would vet the technical and managerial capability of organizations and of the solutions that they put forward to add a new name. And that once -- that the first five organizations that could technically demonstrate -- managerially demonstrate -- that they met those thresholds would each get to add one name, and that that process would begin as soon as possible.
And, you know, depending upon the comments we get, and if we take this as part of the comment period for that process, then that should be able to start within the next few months. Now, what -- and then it depends upon how many organizations, in fact, qualify. I mean, it could be that there will be five organizations show up day one and qualify within a week, and then you'll have five added pretty quickly, or it could be that it will take longer.
The reason I'm a bit hesitant is because, at least from the comments that I've received in the meetings I've been in -- and those, again, will all be posted -- there are very different opinions about this. There are a number of people who think that either no new names should be added during this transition, by rather to wait for the new organization to get up and going, or at most, one or two names should be added.
There are others who think that five is too few, and I think we need to see what we get in the way of comments here, before we know for sure what we'll do. But at least that's what we've proposed. We've proposed adding the five.
MR. TAURENCE: Let me ask just one follow up please to that, and you mentioned that this would be decided durring the transition by auditors of IANA, but IANA is an interested party in this as a member of (POCinaudible]. What is you proposal to address that apparent conflict?
MR. MAGAZINER: Well, I think what -- I think IANA is an agent of the U.S. government in this. They're under U.S. government contract. And the discussion that we have had with the IANA is that the IANA needs to function in a neutral manner, vis-a-vis all of these proposals. And we believe that John Postell and the rest of the people at USC and at ISI understand that.
And so that even though IANA has actually given encouragement, not just to the POC process, but to also other individual groups at various points, and I think we believe at this point that the IANA can carry this out in an objective fashion.
I think part of the confusion in this, and part of the difficulty, was that the community in general had to understand that if new names were going to be added while this was still under the auspices of the U.S. government, and if those new names were going to be limited in some way, which we came to the conclusion they had to be, to avoid a chaotic situation, there had to be an objective process for determining who got to do that and who didn't.
It's not something where either the U.S. government or its agent could sort of say, "Okay. I like you, so I give it to you," or "I don't give it to you," or "I think you're better than him, so I give it to" -- there had to be an objective process that allowed anybody to compete, and according to some well-understood public and objective criteria, and then some objective basis for selection, and that there were both civil legal problems, if that were not the case, and also probably individual criminal liability if that were not the case.
So I think that was well-understood, then the notion that this had to be an objective process has been understood by the IANA and by USC and ISI, as well as by the U.S. government. So we think this will be an objective process, and not one that favors one group or another.
But again, what we're waiting for is the comments on this, to see whether this holds up as a recommendation.
MR. HEATH: Don Heath from the Internet Society. I just wanted to ask a clarification of that, too, because one, IANA is not a member of the POC. They've contributed in the selection of people who produce -- who made POC, who make up the POC. They appointed some people out of the community.
But IANA's method of working has always been, in fact, to assess what the community, the community -- the broad internet stakeholders wanted and would never do anything on its own unless it was acceptable generally.
So the objectivity has got a history to it of many years, and I would agree with Ira that it's not even an issue. John knows, Postell and IANA know that they cannot function unless they are meeting the will of the internet community at large.
And that was his intent on being on this committee, of appointing people and that is to try and find out what the various communities that make up the internet wanted.
MR. RACOWSKY: Hi Ira, Tony Racowsky, NGI associates. Two questions, one substantive and one some what procedural.
Subsequent to the Prince meeting, there was additional dialogue of increasing blurring between generic and so called national, top level domains particularly with the government of the British West Indian Ocean ...
MR. COCHETTI: Tony could you speak louder for people behind you?
MR. RACOWSKY: Sure. What's occurred here, for those who aren't familiar with it, is the government of the British West Indian Territories, which has a domain, two letter domain name of dot i - o (.io) basically leased, gave a 12 year lease of their rights to a British corporation called Network One, I believe, for basically operating a generic like service, so that it very much blurrs this boundry. And there is at lease one sort of commercial registrar in the UK also that has a similar relationship with respect to Turkmanistan.
So you have that sort of combined with the fact that Hank Perit last autumn conviened this group to develop a set of norms that would be potentially applicable to all domain registry functions. So I guess the issue has to do with scope and going forward, and how this blurring of any of these distictions is going to be treated.
The other is on the procedural side, has to do with the formation of this new non-profit corporation and the various parameters there that we being looked at. For example, is a congressional charter a posibility and in particular, since there are so many constituent groups that bear upon the formation of that would it be valuable to have several sort of industry groups funneling information, trying to reach consensus, and the notion that there is any internet community is a myth. In fact it's rather the converse.
MR. RACOWSKY: You've got probably a dozen or fifteen different fairly insular communities that all have to dovetail into that, whether it wouldn't be useful for each one of those communities to do something on their own to assist you?
MR. MAGAZINER: Well, first, on the first question, I think you're right that there are changes taking place in the view of various national TLD's. And to some extent, those things will happen independently of what we do.
And the governments, in general, that have those national TLD's want to have some control over it, or if they've given up that control, they want to be the ones who have done that themselves, and I don't expect we will intervene in any way in that.
And one of the things that I'm quite certain about is that we don't know -- I'm not sure if anybody else does, but we certainly don't -- what this is all going to look like five years from now. I mean, I've heard convincing arguments from people that this whole issue will become moot because of, you know, new technologies and directories, and everything else, but at this point, I think all that we can do is try to launch as best we can, and sort of take them one step at a time.
And I think the national TLD's will go ahead and go their own way, and we'll see what develops from that. I don't think we need to intervene.
On the other question, the stakeholder communities, I do agree. I think one thing that's different about the internet than even three years ago is that the number of communities, particularly various commercial communities that now are interested is much greater, and I think that's one of the changes that has been hard for the traditional internet community to adjust to, as to what that means, and how it changes the scope of things.
One of the things we're uncertain about in our report, although we know it needs to be the case, is we know that this new, nonprofit organization ought to be stakeholder-based, and it ought to be bottoms up in the way in which it works, and we know that it needs to be flexible enough, because the stakeholder community will change over time, so that there needs to be a capability within the organization to reform itself in terms of its stakeholders by some supermajority kind of process. And so we've tried to build that in as a possibility.
In terms of the initial formation, we think, at least, that the number registry piece of it, and the protocol piece of it are reasonably straightforward. The difficulty -- and probably even the name registry and registrar piece, in terms of nominations to this new board, probably can be worked out, although there's a question there about the relative weight of the national TLD registries versus the generics.
The user groups -- and I think this is what you're getting at -- there are no clear organizations to form the representation from the user groups. And we need to try to find some way, or the community does, needs to find some way, I would say, of constituting at least some groups that can get the ball rolling. You know, and maybe get the first directors appointed.
And we've heard various suggestions for that, and we're open to whatever suggestions come forward. But some way or another, there needs to be representatives of commercial users, noncommercial users, of the internet who can form themselves into groups to nominate people to this board. And whether there are existing groups that can be used, at least to get it started or not, we're not sure, and we want to see what kind of suggestions we get.
You know, various groups have been put forward as possible conveners, at least to get it started, but we're not sure. Other people have said maybe you do it the way the ETF works where, you know, you have meetings every year whose main purpose is to nominate people -- meetings among users.
And then some people say, well, maybe you do that regionally around the world. And some people have said, in the beginning, rather than try to convene a meeting like that, maybe you look to some existing organizations to make the initial nominations for the first year or so to get things rolling so you don't have to wait too long, and then you have them to set up a process, or have the board set up a process for users, or whatever, and I guess we want to see what kind of suggestions we get.
But I'd say the one thing we're convinced of is that privatizing this is the right way to go, because this needs to be stakeholder-based. You asked about the congressional charter. I guess our disposition is not to do that, because that would still leave this as -- in some way, an appendage of the U.S. government.
We think that incorporating it in the United States under our nonprofit law makes sense for a variety of reasons, because we have a well-established tradition of nonprofit corporations here. There are also within standard-setting bodies that are nonprofit. There's case law, as I understand it, that if they do things correctly can protect them from antitrust concerns, and so on and so forth.
And so we think that is a safe tradition, and we think it's also appropriate to start it here in the United States. The IANA is here. The ISI is here. The history is here. The people that are here that know the most about it.
And so, you know, convening it here as a U.S. corporation we think makes sense. But if we did it under congressional charter as a U.S. government chartered entity, we think that would be viewed by the reset of the world as inappropriate, and as not really privatizing it, which is what we want to do. So that's why we haven't gone in that direction.
MR. COCHETTI: I'm Roger Cochetti with IBM, and I have two questions. The first has to do with, if I can pronounce it, the Internet Intellectual Infrastructure Fund, which is referenced in the plan, referenced in the sense that that the fees that have gone into it are proposed to be terminated so there will be no additional funds going into it.
And I think you're aware, of course, and most people are, that the fund has been tied up in litigation.
I really have two questions about it. First, is there any extent to which you see the plan as being dependent upon any particular outcome of the litigation that's pending? And if not, how does the plan contemplate the use of the fund, or is it really sort of an irrelevant, or disconnected question.
The second area I'd ask you to comment on is the route servers. The plan makes two references to route servers, one of which is to say that it will exercise something called oversight, management oversight over route servers, or something like that; the second is that the plan calls for study to be undertaken by the government in conjunction with several private organizations on how to improve the reliability and security associated with the route servers.
And I think the question I have is, could you explain a little bit, in greater detail, the relationship you would see between the route servers and this new nonprofit organization? Thanks.
MR. MAGAZINER: Okay. To the first question, no, I don't think that the fund and whatever happens with the fund, affects the carrying out of this proposal. In the proposal -- and this was before the recent judge's decision -- we essentially had posed the question about what should be done with the funds that were in the existing fund.
It could be that the judge may take that question and make it moot, but we think if that does not occur -- that is, if there is a fund -- there are a number of different things that could be done with it, and one of the suggestions was, you take some piece of it, anyway, to help get this organization started. If that does not come to pass, then, you know, there can be other funding for this organization. I'm not worried about that. So I don't think the plan is dependent upon this.
We have suggested that, as of April 1st, that the $15.00 should no longer be collected, as a step towards getting the U.S. government out of this. And that's -- so that will go into effect regardless. And that will also, you know, lower prices for people, which we think is appropriate.
To your other question on the route server system, we do believe that the route server system needs to be made more secure, more redundant, and managed in a more careful manner. And what we are proposing to do is to have a group associated with our critical infrastructure commission to initiate a study, along with representatives from the private sector, to make some recommendations on how to beef up the security, redundancy, reliability of that system going forward, and make sure that when we end our stewardship of the internet domain name and address system that we're ending it with a robust and secure route server system.
The intention then would be to turn that route server system over to this new nonprofit organization in terms of policy management of it. Presumably, the new organization would continue to subcontract out the routes, much as we do today, but it would hopefully be a more secure system, that they would be managing. So we do intend to privatize that.
In terms of our timing, I can assure you that the U.S. government, and this includes NSF, DARPA, the Commerce Department, the White House, and just about any other group that's involved, would like to end our involvement with this as soon as possible. But on the other hand, we have to do it responsibly, and we are caught right now between two concerns that are both legitimate.
There are a series of people in the internet community saying to us, "Look, you can't just set a date certain that you're going to get out of this, you know, next fall and hand it over to an organization that doesn't yet exist. That's not exactly meeting the goal of preserving the stability of the internet. You know, you as the U.S. government have to stay in this until you are sure that this new organization is really up and going, that it's got good operational procedures, that it has the trust of people, and so on and so forth."
On the other hand, we have a group of people out there who are not exactly inclined towards government in the internet community who are saying, "Ah, this is all a plot for the U.S. government to stay in it forever and take over the world." And so they're concerned that we've left this too open-ended.
The way we tried to solve that was to create a balance which said that, starting October 1st, this new organization will hopefully be up and going, and that as quickly as possible after that, we will begin devolving our authorities to it. But no later than two years from October 1st, we'll get out of it.
So it essentially gives a two-year buffer period for a careful transition. And that's, we thought, was the sort of prudent way to meet both of those concerns.
MS. CADE: I'm Marilyn Cade, I'm with AT&T. My question has to do with the green paper, and a concern that we have, and I know many others have as well, is we moved from an environment where there are roughly sixty million users of the internet to what we hope the future of the internet will be, as a truly critical infrastructure that is used by maybe hundreds of millions of people. The users become increasingly like consumers that use telecom services and consumer products, and they look to reliability and stability for an infrustructure that they will count on.
And one of the areas that we see in the physical world is that consumer have a brand recognition to find suppliers that they trust. So as we look at building services and products delivered to consumers over the internet, we want to see protection and recognition trademarks to avoid confusion of consumers, and to insure that we're able to protect our brands.
And the green paper does give some significant -- seems to put some significant effort into trying to identify what an effective resolution would be. Could you comment on what you've heard as you've met in other parts of the world from commercial holders of trademarks?
MR. MAGAZINER: I think there's substantial agreement about the protection of trademarks as being something important to do. One of the things that has been a little difficult for us is that even within the community that cares a lot about trademarks, there is disagreement about what would be the best way to protect trademarks.
And so while we would have liked to come with a kind of proposal for sort of one unifying way to do this, what we were finding was that different people, even within the trademark community had different views of what that should be. And we didn't feel capable, or competent, to sort of arbitrate that, if you will.
So that's why what we have proposed is that there be some minimum requirement for the protection of trademarks in terms of dispute resolution, information made available about applicants for domain names, and a variety of other things in the paper. And then we've suggested that there be a study which takes place that learns from the reality of what different registries would be doing -- name registries would be doing -- and over a relatively short period of time, tries to develop a more unified approach that will work.
And that that study get carried out in a relatively short period of time so that it's not put off for too long, but that it -- I think part of the problem is, because we haven't had a broader registry system, and because the internet is really just taking off commercially a year or two ago, there's not enough experience for people to know exactly how to do this. And so we thought having that experience, and the study, and building that in would be the best way to do it. That's what we've proposed.
One thing I would like to say, I think our latest figures indicate there are about 100 million people on the internet now, so we're -- one of the difficulties always with the internet, is if you're sort of using three-month-old figures, you're considerably out of date, but we'll be publishing a report in a couple of weeks that would indicate 100 million people, and it still seems to be doubling every year, so it's a very exciting development.
MS. CADE: Yeah. I also heard clearly that -- a recognition that trademarks are an issue, that trademarks need to be protected. Another recognition that, although it would be nice to harmonize international trademark law, we shouldn't hold up the domain name system to that huge task, and we should try to proceed forward.
So generally, there is recognition that this is an important issue, recognition that a dispute resolution proccess or two needs to be out there, and lots of questions of the variety that we heard from our trademark community when we consulted.
MR. WEITZNER: I'm Daniel Weitzner with the Center for Democracy and Technology. Good morning to both of you. First of all, I do want to say that I think that both of you and the administration deserves just tremendous credit for the direction you're the direction you are trying herd all of us and the net in. I think we're all aware it's not a simple task, and at least from CDT's perspective, we think that the direction that you have set is going to be tremendously important for keeping the net open and functioning according to democratic and decentralized values. So we, at least, thank you for that.
I wanted to just ask a question about the anticipated role of the Critical Infrastructure Commission, and the question of assuring security and reliability in this transition period, which is clearly very important. Frankly, there have been questions raised about whether the Critical Infrastructure Commission has the sort of internet security expertise that it ought to have, particularly in view of the recomendations that it's made regarding key recovery and key management infrustructures on the internet and in the telecommunications infrastructure.
And I wonder whether you would consider perhaps adopting the sort of model that the green paper suggests for adding new GTL status to out source this entirely. There are certainly internet security consulting operations which have all the expertise there is to have on this sort of issue, and I wonder whether that might not assure a more secure transition.
MR. MAGAZINER: I may have misspoken before, so let me try to clarify. We have not asked the Critical Infrastructure Commission per se to do this work. What we've done is to convene a group of representatives from around the government who are knowledgeable in questions of security, and we're going to start a process with them which will also open up to private sector involvement fairly quickly to do this over the coming, you know, X number of months. Exactly what the mix should be of private and public participation, that we're not sure, but as that group gets going, I'm sure that they'll open up.
I hope that -- I mean, we've taken on a big enough chunk that's controversial enough here, without getting into encryption. Let's try to take our controversies one at a time anyway, and at least in this area, let's try to -- I mean, I think the route system has specific issues that I think are broadly recognized by everybody I've talked to as needing, you know, greater -- greater care. And we have a successful history of, you know, private management of telecommunications infrastructures and so on, and so I'm sure that can be duplicated here. It's just a question of doing it.
I mean, it -- and I'm sure, if we get private sector and the public sector people who know about this together, they can do it in a very practical way. So we'll do that.
MS. BURR: The green paper deliberately refers to bringing in the expertise of the internet community into that process, and we did that very intentionally and very specifically, because obviously it would be a mistake not to take advantage of that expertise.
MR. RACOWSKY: Just to add a postscript there.
MR. MAGAZINER: I think you need to identify yourself.
MR RACOWSKY: Tony Racowsky for the Critical Infrustructures Commission. As it turns out, I was the guy who first went over there to brief them about the problem and discuss the issue. They have a set of , kind of, their mandate actually is very broad, and they deal very effectively with a whole array of critical infrastructures. And look at it in a very kind of methodical way, that I think is extraordinarily useful.
And it was kind of a turning point for them to conceptualize this as a critical infrustructure, they sort of confessed that they had -- that this was sort of a transition occuring they should have forseen even within the scope of their work. So that they really are the right place, and it really isn't so much an encryption issues as looking at it like a highway system, or electrical power grid kind of configuration.
But there are some players that do need to be brought in that typically haven't. Frankly, it's the realization that the DNS is a very distributive system, a there are 70,000 or more individual entities who actually operate the servers that end-customers use, and there's a kind of a feed chain in there with software suppliers.
So there's a kind of a very distributed, unique community of players that have to be recognized, and brought into that proccess.
MR. MAGAZINER: Yeah. We agree. And we're trying to -- I mean, part of the reason why ultimately this all needs to be privatized is because government processes are slow and very bureaucratic and very difficult. And whenever we try to constitute, I mean, one area of the law that I have become all too familiar with is the whole question of what happens when the government tries to use private sector people to assist it, and it is a very complex set of procedures that one has to go through, and there is a great deal of uncertainty in those procedures and disagreements among government lawyers about how they should be followed. And so that's why it's so hard to constitute a public/private effort that really is meaningful from the government.
But nevertheless, we will try to get something like that constituted as soon as possible, so that over the next six months or so we can get this done. I mean, it's -- I don't think the problem itself is insoluble. I think it's just a question of getting the momentum started to solve it, and I think it will turn out to be relatively straightforward, because there are a lot of things which one can learn from existing communications systems that we already have, and the kind of security they have, and the kind of redundancy they have to carry over to this system. It's just a question of somebody doing it.
So we will try to get that started as soon as possible, and I'm sure there will be public requests for participation when that gets going. And we'll let you all know about it.
MS. DOOLEY: Barb Dooley from the CIX. I have two questions, and they're somewhat related. One has to do with trying to get proper industry, or private sector, feedback on the structure of the board. And part of it has to do with the confusion about the configuration and cost relation of the very first one, and when the green paper was proposed, there would be representatives from GTLD registries, and national registries on this board, when in fact, except for NSI, there isn't such a thing as a GTLD registry.
And so I would like some, I guess, more input on how the people who came up with that proposed board structure actually, in the real world, when we have no such things except people who propose to become some [inaudible] registry should have a very influential position on the board, which is reflecting their own business interests. And that would include NSI.
So we know we need representation of this function, but on this very first board, what kind of real world situation are we dealing with, and why is this conclusion comming that this is the way to deal with it?
The second is a related one, which is as concern of, I think CIX members and trademark owners, is what's to prevent confusion from splitting of the route from --
[END SIDE A]
[BEGIN SIDE B]
MS. DOOLEY: In other words, is there a way to keep the process on track, in the green paper process leading to some sort of administrative rule making, when in the real world, the threat is that the route will be split, that how are we going to keep this process when the danger is that the route will be split.
MR. MAGAZINER: What --
MS. DOOLEY: That there will be alternative route systems developed by people who want these top level domains no matter what this process saying. And trademark owners and other entities will be registering, as they are already, in these alternative top level domains, even though they haven't been admitted to this route server system.
MR. MAGAZINER: We don't have evidence that there is any substantial moves to split the route. I mean, there have been, for years now, some alternate domains that have been set up by people, but not to any significant degree. And so we don't believe that the route will be split. We don't think that's in anybody's ultimate benefit.
And in fact, I think virtually everybody realizes that, and so we don't believe the route will be split. I don't think that's going to happen.
And my sense is that those who would have preferred a different proposal than the one we've put forward are, by and large, nevertheless working with our process. And we don't see any substantial efforts of any sort -- I would say, not even any insubstantial ones, at this point -- to talk about splitting the routes. So I wouldn't worry about that.
The other question I don't have a good answer for you on. In the constituting of this board, we, those of us who, you know, put this proposal together, went back and forth on how to do this, and I don't think ever came to the point where we were fully satisfied with what we came up with. But, you know, the deadline was drawing near, and we had to settle on something, and we settled on the sort of least worst that we could think of.
And there are a number of problems in what we've put forward -- and I'm being very frank, because we've got -- we're sort of trying to form a joint effort here to create the best possible solution. It's not something where we're trying to defend that we've got the best solution. We don't know if we have.
We felt that there needed to be some representation from those who are in the registering business, but certainly not a dominant representation, because, as you point out, they have a business interest. And, you know, we basically said one registry, one registrar, representative. Assuming that, you know, that you have 200-some-odd registries, and that they should come up with a representative.
And, as Tony said, there's some blurring already between the national and generic ones anyway, so we sort of lumped them together. Now, I don't know whether that's right or not, but that's what we did.
And then on the registrar side, we said, "Well, okay. That's going to be a separate marketplace, so let them have a representative." And then we sad, "Okay. They need to form organizations, much like trade organizations, of registries and registrars, and they'll designate somebody. And that will rotate.
And then for the users, we basically, you know, were looking for some process for user representation, and we suggest that there ought to be at least some explicit way to make sure that, you know, nonprofits are represented as well as for profits, users. But beyond that, we were very vague, because we weren't sure what the best way to do it was.
And so we're looking for suggestions for that, and trying to get a sense of what the community would think would be a fair way to do it. And one thought we put in then was just to say that, since probably none of us would be certain of the best way to do this, try to build in some flexibility.
In other words, you could have something where at least you get the first board nominated, almost like incorporators, for a period of time, so that even if you're not sure about the process that nominated that first board as users, that at least you can get going. And then you can sort of see, and have a little longer once you see how things develop, to get a more -- a broader, a process that has a broader base of support.
And then secondly, as I said earlier, build into the bylaws some ability to change the stakeholder structure with the supermajority of the corporation, so that if there's some major changes in stakeholder over time, that you can sort of accommodate that.
Now, that was the best we could think of, Barbara and I, can't say to you that we were wholly comfortable with it, but it was the best we could think of. So we're looking forward to whatever suggestions we get.
MS. BURR: I think, with respect to the sequencing issue, we did anticipate probably that some new GTLDs may well be added before the new not for profit corporation is fully up and running. So you would get some additional registries and registrars out there.
The other thing is that I -- the fact that people have commercial interests is not a disqualifier, clearly. Commercial users will have commercial interests, and we're certainly expecting that they will participate. U.S. competition laws will be a huge help here with respect to making sure that people operate in a fair and transparent process, and we are counting on the application of those laws to keep this body going forward on an open and competitive basis.
MR. WEITZNER: Danny Weitzner, CTD, just to follow up on that question. Do you have any thoughts about what your role, what the U.S. government's role is going to be, in vettying, approving, sheperding, guiding, this critical process of selecting members of the board, and if you don't that's a very fair answer too.
MR. MAGAZINER: No. I think our hope would be that we won't have a role. That is, that the stakeholder organizations will nominate people, and that our role will be more one of putting some broad boundaries. That is to say that we're going to turn over these authorities we have to an organization, and we want to just be sure that organization has a sufficient consensus and a sufficiently broad stakeholder representation.
But beyond that, I would not think we would have any role in the development of board members, or anything of that sort. And it's a very, very hard line to walk right now, and we're constantly consulting our lawyers about exactly how to walk this line. But I think the idea model is one where this organization is formed from the stakeholders, not from us, but where it is formed within a broad enough set of precepts that we've laid down in the papers so that we, then, could transfer our authorities to it.
I guess that's the line we're trying to walk. Does that make sense, or is it --
MR. WEITZNER: Yes, it does. I think that's a fair answer. Just to refresh my memory, what does that say about the time line? By when does this --
MR. MAGAZINER: Well, our hope is to get this organization up and going by the end of the summer, by the end of September, and get a board constituted, you know, around that time, and then have it begin to set up operations. And then the idea would be for us to turn over authorities to it as soon as possible, once it's up and going.
And we've recommended at least in this report that it hire a professional CEO from, you know, with a management background in industry or whatever, and an executive vice president who's familiar with legal questions, since there are likely to be legal challenges in the beginning. And they need to set up the right kind of by-laws and structure and so on to withstand those legal challenges. And then the IANA would move over there, in terms of technical functioning and so on.
And we don't know for sure how long that will take, and that's why we've left ourselves a two-year period, but our hope will be it will be as soon as possible after that.
And I'm sorry, the U.S. government contracts, as you know, with IANA and NSI will end at the end of September, and one of the things we will need to be doing during this period, assuming we move ahead with this plan starting in April, is to conduct a negotiation with NSI and with IANA, and in the case of NSI, it will be a negotiation which accomplishes the creation of a level playing field for the competition ahead, in the case of IANA, something which moves their operation over to this new corporation.
So our idea would be that that would be going on in parallel with the setting up of the new organization between now and next October, and it's our intent to try to create a level playing field between NSI and other registrars, and between NSI and other registries, as soon as possible, as well.
MS. CADE: Marilyn Cade, AT&T. I have another question about the transition. And sort of following to the time line, as I've heard you explain it, you expect there would be an introduction of some new GTLDs at some point this late spring or summer, under the provisional authority of IANA, based on the selection of the first five entities who meet certain criteria.
We've heard that some of the registrars have accepted preregistration of significant blocks of domain names, and that is, of course, a concern to trademark holders. What role will the USG play in their oversight to IANA in helping to identify what problems might exist in the introduction of new GTLDs that address that particular problem?
MR. MAGAZINER: Well, I don't know -- we haven't looked at that specific problem. We know that's the case, that a number of the registrars have taken names. I think there are a couple of existing models of that, if you will -- I don't know if model is the right word, but examples. You have some registries that have been in existence for a year or two years registering people under dot per, or dot web, or whatever. And then you have the core registrars who've preregistered in anticipation of various GTLDs being added under the core proposal.
I'm not sure exactly how that will work its way through during this transition, but one thing I can say is that we are working very closely with the IANA, and we're talking, you know, a number of times a week, and will continue to do that during this whole process. I think there is a clear understanding on the IANA's part, and also on the government's part, that we're going through a very delicate period during these next couple of months, and that we have to be fully in sync and working together very closely, so that we can all get through this in a proper way and not all hang together, but rather, all succeed together.
So I don't know if that's oversight, but I would guess it's cooperation. It will be a joint responsibility.
MS. BURR: We have asked specifically for recommendations, suggestions, input, with respect to this clearance issue, which certainly involves the preregistration question. That, as all of the trademark holders in the group know, is very complicated, and that is something that we specifically would like to get additional input on in during the comment period.
MR. MAGAZINER: Let me just say one other thing. I mean, the easiest thing for us would be if we could punt on this. That is, if we could say, "Okay. We're lame ducks. We're getting out of this. Let's wait for this new organization, and we're not going to change anything until that comes into being."
And that would certainly make our job easier. And I guess what we were convinced of is that even though that would be easier for us, that it might not set up the best conditions for the competition ahead if we didn't allow the registrars and some other registries to get going in the meantime. That it would delay the onset of competition.
And so that's why we went against our better visceral judgment about what was in our own best interests, and said, we'll go ahead and try to create this transition, and try to create -- allow some of these new registries to be created, just because we thought it probably was the right argument that it would help prepare the groundwork for a quicker competition.
But if there was an overwhelming set of opinions from the broad community that said, "No, just wait," then I'm sure we would be amenable to listening to that.
MR. : Linc [Inaudible] from Bell Atlantic. One stakeholder that I hesitate to mention, but we I guess we all need to understand your perspective on is Congress. What do you need out of them if anything, and what role do you expect them to play? I'm sure you've talked to the folks up there on the issues.
MR. MAGAZINER: Yeah. We've been in consultation with committee members and staff of the committees that have expressed an interest, and really, of anybody who's expressed an interest in Congress on the issue. And I think, as a matter of both desirability and ultimately necessity, we want to make sure that we don't get out of line with what the relevant congressional committees, and so on, would want to have done here. So we'll continue that consultation as things go ahead.
I think so far, we've not had any negative responses. I think a lot of people on the Hill are just waiting to see what reactions are, but -- and a lot of others have been generally supportive of the direction we're taking. But we certainly will make sure that we don't get out of line.
Right now, we don't see any specific congressional actions. There have been some questions raised about the issue of the fund, and what gets done with that. And that I think our legal people at Commerce and at Justice may need to be in some discussions with members of Congress about. But other than that, I don't think there's anything specific.
MS. BURR: We have had, just as part of expressions of interest, some inquiries about whether the trademark study needs to be facilitated in some particular way. Those are ongoing discussions. But generally, I think that the -- we're in a keep- everybody-informed mode here.
MR. LEVY: I'm Stuart Levy, with a question as an individual. The appendix 2 specifies certain minimum levels of dispute resolution procedures for trademarks. Who do you anticipate, given the timetable you're laying out, will decide whether these dispute resolution procedures are adequate? And also, where do you envision it falling between having sort of a full blown proccess in place, versus having something just to tide you over until that process is set up in the future?
MR. MAGAZINER: Well, the who's easier to answer than the what. The -- what we've already asked the IANA to be thinking about is a process whereby we would hire one or more auditors, if you will, for want of a better word, and there would need to be at least one auditor with technical evaluation capabilities to evaluate when a registry could meet, you know, the technical requirements, and then at least one auditor, and it may or may not be the same auditor, who would be able to make the determinations managerially about issues like trademark, and so on.
And what is of concern to us here is that, you know, those orders be hired in an objective process. And that they then, themselves, are the determiners, rather than us or the IANA, of when an organization meets those criteria. So that it's an arms length objective evaluation that's made.
And what we've said, right now, I think the IANA is preparing the specifications for what that bid might look like and so on and so forth, so that if we do decide to go ahead after the comment period, that that can move quickly, in terms of the hiring of these auditors.
In terms of what would be put in place, again, based upon the comments we get, I think our intention was to have a common requirement that had to be there, as a minimum, for trademark protection, and we put some things in the report that suggests what should be included there, although we're open to hearing others. And then we try to get the study in place as soon as possible.
And I think our desire is to have those minimum things there so that you lessen the chance that harm is done during this transition period. And so that you can learn from what goes on, and then to have the study really produce a more robust system that could then be implemented.
And again, that just gets back to the fact that we're not sure what the right system is right now, and that serious trademark lawyers and serious trademark holders are disagreeing right now on what the best way to do this is. So that's why we think the study is the right way to go.
MR. TAURENCE: Hayward Taurence, Bell Atlantic. I'd like a clarification if I could get one, of something that's in the paper that I've puzzled over since it came out. This relates to jurisdiction for trademark purposes. The paper says that at the time of registration, registrants could agree that in the event trademark dispute involving the name registered, jurisdiction would lie where registry is domiciled, where the registry data base is maintained, or where the A route server is maintained.
Is that "or" used in the colloquial sense, or is it used in the logical sense? In other words, is there a choice by the registrar as to where jurisdiction lies, or is it, which is what would be implied by a logical "or", or is it used in the colloquial sense, and that is, jurisdiction would lie in all three places?
MR. MAGAZINER: Let's not accuse the government of being logical. That would be beyond their capability, I think. I think the intent was to, to leave open the possibility of jurisdiction in all three places, so that there could be a choice of jurisdiction.
MS. BURR: And to solicit comments specifically on that piece of it.
MR. MAGAZINER: Yeah. But I think -- I mean, this question of jurisdiction is one that is quite important to a lot of people, and I think what we were trying to do is leave open the possibility for jurisdiction in a number of places, so that it would assuage people's concerns about the jurisdictional question.
Because if -- you know, to be frank, and I think this is something we need to hear more on, getting back to what Tony was saying earlier, if you have some geographical entity somewhere, which is able to have a domain name of some sort, or where something could be based, and that entity may have a different philosophy of trademark than would be common in most of the commercial world, and there could be the possibility of avoiding trademark protection by structuring things in such a way that that entity's law would be the only law that could be applicable, that would not be a good situation.
So what we're trying to do is to create a multiple jurisdiction possibility here so that the trademark holder can be protected in a jurisdiction that recognizes trademark. I mean, that's -- that's the goal, to be honest.
But I think exactly how you do that is what we're looking for advice on, and I think we tried to word this in a way that left that open. So I think I've just clarified that we're not being logical. But nevertheless, trying to achieve an important goal.
MR. O'SHAUNESSY: Roger has notified me that we have five minutes, so if there are any more questions, we could wrap up.
MR. HEATH: Don Heath from the Internet Society. Relative to the green paper in some cases you've wisely chosen, I think, to avoid being very specific on defining the details of an implementation plan. Other cases, you've been very specific. Is there a reason? And how did you choose?
MR. MAGAZINER: Probably evidence of the randomness of the universe, as much as anything. I think we --
MR. MAGAZINER: We became specific where we felt we had to, and stayed general where we could get away with it, I think. I think the -- look. I think the general goal was to privatize this effort and to do it in a responsible way. And I think where we became most specific is in this transition period, because once we've understood we're privatizing, and once you've gotten specific about the constituting of a board to privatize, then basically you can be general about everything else, because what you can say is, "Look. We're going to constitute this new organization, and it will make all these decisions going forward, and that's more appropriate than for us to do it." Which I think there's broad agreement on, to privatize.
So we were able to stay general. But when we got to the question of what do we do in the transition, there we had to get fairly specific. So, for example, with the NSI negotiations, we listed a number of specific things we felt were necessary because there were a lot of people in the community that were concerned that NSI would be able to continue in a virtual monopoly. And that's not their intent, nor our intent in this. We got to get on a level playing field. So we got specific about that.
And then we got specific about this GTLD process, because that's something that we're going to be in some way responsible for during this transition, and therefore, we felt we had to get to a greater level of specificity in saying what our intentions were there, in order to satisfy the questions people would have.
So that's really why. I mean, I can't defend it, but I can just describe it. And again, we'll welcome comments, if people think we've been too specific in some places, or too general in others.
We are prepared to be pinned down here. I mean, we knew when we were putting this out that we were going to have to pin ourselves down, make some controversial and unpopular decisions. But -- so we're not going to shy away from that.
Any other questions or comments? I'd like to just raise one issue that's come up in all my other meetings. I'm surprised it didn't come up today. But just to throw it out on the table.
I think the issue that's come up most often, aside from the issue of how many domain names to add, is the question of whether the registries should be non-profit or for-profit. And this was one of those close decisions that we came down on the side of saying it should be for profit. Or sorry, it should have the ability to be for profit. They could be either, in our construct.
There are -- I think there is a strong sentiment among a number of people that they should be not for profit, the registry business, and others who think there should be -- ultimately just be one registry.
But that's something that, because we've already picked up a lot of differing points of view, and because it's a hard call, I'd welcome you to think about, and give us your comments on. You don't have to do it today, but I'm just saying, when you make your comments to us, that would be very useful.
MR. HEATH: Don Heath from the Internet Society, but since you did bring it up, adding to the comment. It should be clear in everybody's mind that a registry, of course, is the back end part.
MR. MAGAZINER: Right.
MR. HEATH: And the registrar is dealing with the customer.
MR. MAGAZINER: That's right.
MR. HEATH: The only customer, being the people with registered domain names. The only people who would deal with the registry are the registrars.
MR. MAGAZINER: That's right.
MR. HEATH: So for them to be profit or for profit a lot can be determined from that. Whereas a registrar meets the world, and there's real need for competition.
MR. MAGAZINER: Right.
MR. HEATH: For service and price and so on. So I think that's worth considering on that issue. But I think people should consider it.
MR. MAGAZINER: Yeah. I think the registrar question, I think everyone's pretty much agreed that the registrars should be profit making, competitive, marketplace, and so on. The question comes to the registries, and particularly the generic registries. And -- anyway. So that's just something to throw out.
MR. TELAGE: Don Telage, Network Solutions. The issue of the registry/registrar and the issue of registry being for-profit or not-for-profit is a really difficult issue, and as Mr. Magaziner knows we have frankly taken no position on that and prepared to support any concept. But one issue I think that needs to be brought up by this group is that the registry function is a very significant investment intensive activity, and at least for some foreseeable time until technology obsoletes it, it will require continual upgrade of services.
Frankly, from NSI's three years of experience as head of the business model, we see no way to garner the kinds of investment funding required to build, establish, maintain, and update that kind of registry without an investment model. So that's been one of the, probably the driving issues. When you're talking of investing upwards of tens of millions of dollars, if you look at the requirements here and you come visit our site you'll see the kind of thing that's required.
That needs to be put into the mix too.
MR. MAGAZINER: Yeah, and I think that's what leads you to either one of two alternatives there. Either you say, "Okay. If we've got to go under investment, then we set up a competitive profit-making marketplace, and people can make the investment and try to get a return on their investment by profit mechanism, or it can lead you the other way, to say you make that, therefore a service function that somehow is supported either through the nonprofit organization or through the registrars in some way, or whatever.
And I think it's the either/or of that model which we're hearing a lot of varying opinion on, and which, you know, is one of those hard decisions to know one way or another. But in any event, I just wanted to flag that, because we'd like more thought on that, and that's one that hadn't come up today.
Are there any other -- yeah.
MS. RODAN: Rita Rodan, I'm an intellectual property attorney. I know we've hear a lot today about protection of trademarks on the internet which is apprapo in the context of issuing new TLDs, but I was wondering if you invisied this new corporation to be set up to articulate any policy about the protection of intellectual property like copyrights generally over the internet.
MR. MAGAZINER: No. We think that's a separate topic. One of the things that I think is implicit in this proposal that we've made -- and I should say this -- is that we don't see any central body, whether intragovernmental, or even non profit private, governing the internet and handling all issues, or even many issues. We think that the decentralized nature of the internet, rather, calls for a series of special purpose bodies that carry out various functions.
So you have the IATF, you have the IAB, you'll have this new organization, and you'll have others dealing with, we hope, privacy issues, and other issues. And that's more the model we see for the internet, is the decentralized model with organization's that are focused on specific goals, but don't try to govern the world, or get too broad, or whatever.
On the copyright issue, we have proposed legislation to ratify the WIPO treaties that were negotiated a year ago December. We have negotiated an agreement with the EU where they are supporting ratification within their own countries of those treaties, and we are hopefully going to have an agreement with the Japanese fairly soon, where they will do the same, and so on.
So we are pushing on that front for copyright protection, and we understand there are very difficult and controversial issues to be resolved on that in terms of fair use doctrine, and defeating devices, and liability, and so on and so forth. But we think those can be resolved.
MS. BURR: But not in this context.
MR. MAGAZINER: Not in this context, but in a separate effort that we are also undertaking. And also, we think patent issues need to be addressed, and we've proposed in our strategy paper that those be discussed, as they now are being, in the -- in WIPO, and also in the quad that exists among patent and trademark offices.
So according to the president's electronic commerce strategy issued last July, that whole issue of copyright protection, and also the patent issue, are issues that we have to deal with, and we are dealing with, but not in this context. Those are separate.
And I would refer you to Andy Pincus at the Commerce Department, who's kind of overseeing the effort on the copyright issues, and to the Patent and Trademark Office on the patent issues right now.
Any other --
MR. TAURENCE: Hayward Taurence form Bell Atlantic. One hopefully quick questions and that is what do you see as the interplay between this greenpaper here and the Bonnaman internet charter.
MR. MAGAZINER: I don't think there is any interplay, per se. I think this has to proceed in a certain schedule, in a certain way, and it will. This Bonnaman proposal, we are still trying to understand what it is, and what it means. It hasn't been formally communicated to us. We've seen it, obviously, but it's not been formally communicated, and my understanding is they are still working out the details of what they intend with it.
And so we -- you know, we'll study what it is. We respect Commissioner Bonnaman and, you know, we'll wait to see what it is they're actually proposing.
We've made clear that we don't think it makes sense to have any kind of, you know, intergovernmental organization or anything like that set up with respect to the internet. But it's unclear from what we've seen whether that's what's being proposed or whether something else is being proposed. We don't know yet.
MR. O'SHAUNESSY: If there are no further questions --
MR. MAGAZINER: Thank you all very much for coming.
MR. COCHETTI: May I ask, if anyone did not register on the way in, to please do so on the way out.
[End of proceedings as recorded.]