From: "Ute Decker" <Ute.Decker@ifpi.org>
To: <DNSTransition@ntia.doc.gov>
Date: Fri, Jul 7, 2006 5:36 PM
Subject: IFPI submission to NTIA - re Notice of Inquiry - Continued Transition of the technical coordination and management of the Internet Domain Name and Addressing System

Dear Fiona Alexander,

IFPI, the International Federation of the Phonographic Industry, represents the record industry worldwide with more than 1,400 record company members, and national groups in 47 countries. IFPI is a member of the ICANN GNSO^s Intellectual Property Constituency and participates in ICANN^s work and meetings. IFPI continues to support the private sector leadership within ICANN.

Re question 1: Traditional principles and additional principles:

IFPI considers the principles of stability, competition, private sector lead, bottom-up coordination and broad representation as fundamental. We also believe that technical coordination of the Internet can and should guard against violation of copyright and trademarks.

We remain confident that the expanding tasks and new challanges can be met on the basis of the existing principles.

Re question 2 /3 : MOU - Has ICAN achieved sufficient progress as agreed in the MOU for the transition to take place in September 2006? Should new tasks / methods be considered?

IFPI considers that many of the requirements have been met. ICANN has matured into a stable organization capable of ensuring the security and stability of the Internet. Any amended MOU should recognize the achievements and set out clearly any remaining steps that may be required.

IFPI has noted the roll out of new gTLDs and the continued focus of time and ressources on new gTLDs. We submit that the go-ahead for any new gTLDs should be subject to demonstrated market demand and support for the affected community. The work on IDNs should be given priority, as the roll out of new gTLDs has to reflect progress on IDNs.

Re question 4-7: Stakeholder Participation:

To our experience, ICANN tries hard and generally succeeds in ensuring meaningful participation of stakeholder groups. Highlighting one area of possible improvement, communication and coordination between the Board of ICANN and the GAC are needed. For more meaningful participation of the GAC, some of the rules on timelines eg in running PDPs would have to be amended, reflecting the need for governments^ internal consultations.

Ute Decker
Global Legal Policy
IFPI - representing the record industry worldwide
54 Regent St, London, UK
www.ifpi.org