From: <higashida@jprs.co.jp>
To: <DNSTransition@ntia.doc.gov>
Date: Thu, Jul 6, 2006 10:00 PM
Subject: Comments: Docket No. 060519136-6136-01

7 July 2006

Ms. Fiona Alexander,
Office of International Affairs,
National Telecommunications and Information Administration,
1401 Constitution Avenue, N.W., Room 4701,
Washington, DC 20230 USA

Subject: Docket No. 060519136-6136-01

Comments on the Continued Transition of the Technical Coordination and
Management of the Internet Domain Name and Addressing System

Thank you for providing us with the opportunity to offer our comments.
As the .JP ccTLD registry, JPRS has endeavored to contribute to the
stable development of the Internet through registry operation as well
as domestic and international cooperation in various fora including
ICANN. JPRS therefore would like to express its views, based on the
extensive experience it has gained.

(a) Stability, competition, private sector bottom-up coordination and
representation of all Internet stakeholders with their diverse
interests have been the principles vital to the development of the
Internet.

(b) The Internet has evolved significantly because it is operated
based on the single authoritative root led by the private sector. In
this evolution, ICANN has played one of the central roles, and the
principles mentioned above in (a) have also developed.

(c) Having said this, we have to admit that some of ICANN's projects
are not fully completed at this moment. For example, establishment of
formal relationships with the root server operators and further
involvement of ccTLDs and governments remain limited, although they
are improving. However, from the perspective of what has been
achieved, the current level of cooperation of various organizations
exemplifies the principles mentioned in (a) above. ICANN is also
steadily evolving into an organization to help promote these
principles even further.

(d) Based on the above observations, we recognize that ICANN has the
capacity to autonomously implement its missions through properly
liaising with other relevant stakeholders in the pursuit of
excellence. Therefore, we wish to state our view that ICANN is the
organization which shall play one of the central roles in Internet
coordination, even after the completion of the Memorandum of
Understanding with the Department of Commerce.

Yours faithfully,

Koki Higashida
President, Japan Registry Services Co., Ltd. (JPRS)