From: Bruno Wolff III <bruno@wolff.to>
To: <DNSTransition@ntia.doc.gov>
Date: Mon, Jul 3, 2006 11:40 AM
Subject: The Continued Transition of the Technical Coordination and Management of the Internet Domain Name and Addressing System

I have been following ICANN since the initial election of directors. (I voted
in that election.)

Initially I had much hope for ICANN, as Network Solutions was not doing a
very good job as a registry. While there has been some improvement in
registry operations since then, things could be better. And the indications
are currently that for .com things will be getting worse.

ICANN should not be involved in domain name disputes within a top level
domain. It has been effectively making new trademark rights and that should
not be part of its job.

ICANN has not been allowing the creation of new top level domains at a
reasonable rate. It is charging a lot of money up front for consideration
and is worrying about aspects of new top level domains that it shouldn't be.
It shouldn't be ICANN's business what purpose, if any, a top level domain
has. That should be up to the registry operator.

Because ICANN has prevented competition in top level domains, it should at
least make sure the monopolies it has created for running the domain registries
for .com, .org and .edu, are running them in the public interest. This means
keeping prices in line with costs, not allowing the companies running the
the DNS servers to sell or publish information about what IP addresses are
making queries, allowing domain holders to keep their name and contact
information secret, not supporting domain name speculators at the expense
of people purchasing domain names by giving full refunds after trial periods.

ICANN wastes a lot of money. They do not need to be staffed at the levels they
are, nor do they need to throw parties at exotic locations around the world.

ICANN should be very transparent as part of providing a public service. In
practice they are extremely secretive with most decisions made behind
closed doors.

The current management of ICANN has a terrible track record extending back to
its creation and you should strongly consider not giving them any more chances
and instead give a new group a chance to provide its functions.