From: "Ken Ryan" <wkryan@gmail.com>
To: <DNSTransition@ntia.doc.gov>
Date: Thu, Jul 6, 2006 10:55 AM
Subject: Comment - DNS transition to the private sector

While acknowledging a significant debt to the international community
for participating in the Internet, we should remember that Internet
creation and development were U.S. taxpayer funded.

If the NTIA believes that American economic traditions such as market
orientation, private sector involvement (including risk),
entrepreneurial effort and competition (including technical
innovation) are positive forces for development, then Internet
management should exemplify and rely upon them. These principles are
not always supported at present.

One example:

The 1998 DNS White Paper introduced the idea of creating new generic
TLDs to increase competition and ostensibly increase scarce Internet
name space. In amendment 6 of the MOU in 2003, ICANN agrees to
"Continue the process of implementing new top level domains" while the
expansion TLDs approved in the past 6 years have not been successful
in the market.

The Government mandate to introduce new TLDs is uncomfortably
reminiscent of old Eastern Bloc central committee fiats in ignoring
market response. By creating the mind set that only one method of
increasing competition and scarce Internet name space is acceptable,
the NTIA and ICANN have discouraged investigation and innovation of
other approaches.

And another:

ICANN relies on the Internet Engineering Task Force to develop
infrastructure standards. The IETF has traditionally called patented
technology "encumbered". Does the U.S. Department of Commerce, which
runs the U.S. Patent and Trademark system, consider patents
encumberments, or do patents exist to spur the creation of ever
improving technology? Does the process of creating an IETF standard
(http://www.ietf.org/tao.html paragraph 8.2) sound compatible with
patenting?

May I suggest that NTIA look more closely at the generally accepted
principles of a successful market economy, and formulate policies in
agreement with them. Why othrewise consider a transition of the
technical coordination and management of the Internet domain name and
addressing system to the private sector?

W K Ryan