From: "Gerald L. Jenkins" <GLJ@goldbergkohn.com>

To: "'dnspolicy@ntia.doc.gov'" <dnspolicy@ntia.doc.gov...

Date: 10/13/98 4:53pm

Subject: Comments on the Private Sector Proposal for the New Domain Name C orporation

As I long time Internet user, I am deeply concerned about the

direction that the current privatization effort is taking. There seem

to be three basic choices. First, control of critical aspects of the

Internet can be transferred to a combination of a self-perpetuating body

and a small group of organizations. Second, control can be transferred

to all users of the Internet whose interests might be broader than

profit maximization and self-perpetuation.. Third, control can be

transferred away from the United States in particular and to governments

in general. Although each of the three choices has its own benefits and

risks, I have the greatest concern about the first proposal.

Ceding control to a set of private organizations who are not

accountable to governments or general user populations, no how well

meaning they may be at the outset, can give rise to disastrous results

down the road for everyone other than the favored few who remain in

control. If any such system is to be implemented, adequate checks and

balances must be implemented to minimize future risks. In this regard,

the current ICANN proposal leaves far too much to the imagination, both

in terms of how much authority the general Internet using public will

have and in terms of whether the inner workings of the proposed private

organization will be open for public inspection, review, and criticism.

Until we can be convinced that the ultimate authority over the

Internet will be broad based and fair to all, neither the United States

nor any other governmental entity should cede control over such an

important communications medium to any third party..

###

From: Izumi Aizu <izumi@anr.org>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/12/98 11:18pm

Subject: APIA Comment

Honarable William M. Daley

Secretary of Commerce

c/o Karen Rose

Office of International Affairs

National Telecommunications and

Information Administration

United States Department of Commerce

RE: Management of Internet Names and Addresses

Dear Secretary Daley,

Asia and Pacific Internet Association (APIA), a unique trade association

representing the Internet Business community of the region, would like

to express our comment regarding the Internet Names and Addresses

management issue.

APIA first would like to welcome the recent decision by the United

States Government to post the proposed drafts for the new organization

that will manage the Internet Domain Name, IP Address and other

technical resources, and to solicit comments in an open process.

As one of the supporting organizations of IFWP (International Forum

on White Paper), APIA recognizes that the one posted by IANA reflects

most of the consensus we have achieved and thus is close to the

conclusion we accept.

There are, however, still some remaining issues of our concern.

1) We hope that membership and accountability be well defined

and adopted.

2) We hope that the selection of interim Board members be as much as

open and reflects the regional, cultural and functional diversities

of Internet users around the globe.

3) We hope that in the future, the actual implementation of the

policies be carried out in an open and accountable process.

We would like to appreciate all the efforts, time and other resources,

of so many people throughout the world who have participated this

difficult task. We therefore would like to remind the United States

Government to keep the process open and inclusive upon finalizing it,

especially to the regional diversities.

With best regards,

Asia and Pacific Internet Association

Izumi Aizu <izumi@anr.org> now from KL Office

>>> WRITING THE HISTORY OF THE FUTURE <<<

CC: NTIADC40.SMTP40("Ira_C._Magaziner@oa.eop.gov")

###

From: Jim Dixon <jdd@matthew.uk1.vbc.net>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 3:45pm

Subject: ISPA UK statement on Management of Internet Names and Addresses

13 October 1998

Honorable William M Daley

Secretary of Commerce

c/o Karen Rose

Office of International Affairs

National Telecommunications and Information Administration

United States Department of Commerce

14th and Constitution Avenue, NW

Washington DC 20230

Dear Secretary Daley,

The United Kingdom Internet Services Providers Association (ISPA UK,

http://www.ispa.org.uk) is a trade association representing Internet

Service Providers providing most of the Internet connectivity in the

UK. ISPA UK is a member of EuroISPA (http://www.euroispa.org), the

pan-European federation of Internet trade associations.

On behalf of ISPA UK I would like to express our support of the

recently-submitted statement of Dr Alfred Eisner of NLIP, the Dutch

Internet trade association, regarding shortcomings in the structure

of the Internet Corporation for Names and Numbers. A copy of Dr

Eisner's statement is attached. Please note that it is also endorsed

by eco, the German Internet trade association (http://www.eco.de).

In a letter to you on 2 October Dr Jon Postel of IANA proposed that

ICANN assume responsibility for the management of Internet names and

numbers, in effect subsuming IANA's existing role in this regard.

That is, ICANN is to become the "new corporation" of the recent

White Paper on this subject.

The objective of this new corporation is the self-regulation of the

Internet industry. It is therefore surprising to us and a matter of

great concern that the Internet industry has not been consulted in

regard to the selection of the Initial Board for ICANN, nor do its

articles and bylaws give the world's ISPs any particular voice in

its management. In light of the fact that we are the industry being

"self"-regulated, in light of the fact that there are at least

proposals that the ISPs should fund the new corporation, and in

light of the fact that industry cooperation is essential to the

new corporation's success, this is inexplicable.

While the rapid pace of developments in this area have made it

impossible for the EuroISPA council to meet to formally ratify

Dr Eisner's statement, we know that other ISPs across Europe feel

the same misgivings about the lack of ISP representation in the

management of the new corporation. In fact we know of no ISP

association anywhere in the world that supports it.

We do not wish to delay the transition to the new system for

global management of Internet names and numbers. We believe that it

is vital that IANA's role in this be maintained. However, we also

believe that it is essential for the success of this exercise in

industry self-regulation that representatives of the industry being

regulated have a significant voice in it. Without the participation

and the endorsement of the ISPs, it cannot succeed.

To this end we propose that the NTIA delay acceptance of the IANA/ICANN

proposal until such time as they agree to negotiate in good faith with

representives of the global Internet industry, with the object of that

negotiation being a voice for industry in its self-regulation.

Yours sincerely,

CC: Barbara Dooley <bdooley@cix.org>

###

Jim Dixon Managing Director

VBCnet GB Ltd http://www.vbc.net tel +44 117 929 1316

---------------------------------------------------------------------------

Member of Council Telecommunications Director

Internet Services Providers Association EuroISPA EEIG

http://www.ispa.org.uk http://www.euroispa.org

tel +44 171 976 0679 tel +32 2 503 22 65

------------------------ STATEMENT OF ALFRED EISNER -----------------------

-------------- FOR NLIP, THE DUTCH INTERNET TRADE ASSOCIATION -------------

October 12th 1998

To: NTIA and Secretary Mr. Daley

From: Several ISP-organisations, by way of Alfred Eisner (pres./CEO of NLIP

Dutch ISPA)

Subject: ICANN

With regard to the published DNSPOLICY we would like to draw your attention

to what we think is a major shortcoming in the rules for and the board of

ICANN. This flaw seriously threatens the effect and working conditions of ICANN.

"We" in this case are ISP's almost worldwide. Representatives of

ISP-organisations of EU, US, Canada, and others. We met in Ottawa oct. 8th.

in the margin of the OECD-conference, and we all expressed our deeply felt

worries concerning this matter.

Notwithstanding the fact that a lot of good work has been done to reach some

kind of consen sus, the result is not completely satisfactory and does in

its present form NOT guarantee quality and continuity. The shortcoming we

are referring to is the fact that, where the issueing and control of

domainnames and ip-addresses is of crucial importance to the correct functio

ning of the Internet as being delivered to the public by ISP's, there is no

direct influence of those ISP's in running and controlling ICANN.

Since ICANN's policy and operational decisions are to be implemented by us

(ISP's) in the worldwide DNS's, and are largely to be paid for by us (and

indirectly by our customers), this complete lack of say in these matters is

unacceptable. And, just for the record: we are not and feel not in any way

represented by people from telco's, networkoperators or large computer or

software companies. One might even say: on the contrary. They are not ISP's.

To put it more abstractly: Industry-selfregulation without the crucial

sector of industry being represented, is a strange idea in itself. It is

definitely not industry selfregulation.

We are unable to discover valid reasons which could justify the exclusion of

ISP's from direct

representation in the Interim Board (now) and the final board (later). If

this oversight is not duly corrected, the conclusion will have to be that

the Interim and final Board do not constitute a valid industry self regulation.

To solve this we propose that you allow one more change in the bylaws,

leading to the effect that ISP's are directly and adequately represented.

Adequately will mean a substantive part of the board. To repair the

situation at hand as soon as possible, we ask also that the interim board

acts accordingly in their future appointments from the beginning.

With kind regards,

yours truly,

A. Eisner (Netherlands), M. Langford (Canada), M. Schneider (Germany). CIX

(USA) is also with us, but will send their reaction separately.

##

From: <JIMBRAMSON@aol.com>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 5:14pm

Subject: Comments of America Online, Inc.

To: dnspolicy@ntia.doc.gov

Re: Comments of America Online, Inc. on Private Sector Proposals for a New

Corporation to Manage Internet Domain Name System Functions

Note: Attached document is in Microsoft Word 7.0 format

October 13, 1998

Honorable William M. Daley

Secretary of Commerce

United States Department of Commerce

14th and Constitution Avenue, N.W.

Washington, DC 20230

Re: Private Sector Proposals for a New Corporation to Manage Internet Domain

Name System Functions

Dear Mr. Secretary:

The National Telecommunications and Information Administration ("NTIA") has

asked for public comments on various proposals for a new corporation to manage

Internet domain name system functions that have been submitted by various

private sector entities pursuant to the White Paper. In response to that

request for comments, America Online, Inc. ("AOL") submits this statement to

support the establishment of the new entity under the Articles of

Incorporation and Bylaws proposed by Dr. Jon Postel.

The White Paper issued an unprecedented challenge to the public. After nearly

two decades of control by the US Government and its contractors of the numbers

and names necessary for communication over the Internet, the US Government

announced that it would relinquish control to a new non-profit entity to be

formed, through a consensus process, by the private sector. The US Government

called upon the community of Internet "stakeholders" to collectively decide a

structure and mandate for the new entity and to bring the entity into being.

The US Government set out certain parameters that the new entity would have to

meet, which have guided efforts to establish the entity. For instance, the

new entity would have to be formed in a manner to ensure the continued

stability and security of the number and name address system. At the same

time, the new entity would have to promote more competition, while providing a

mechanism for bottom-up governance that includes broad-based and international

participation.

There have been major hurdles to overcome in reaching the current proposals

submitted to NTIA. Not least among these has been to identify the

international "stakeholders" of the domain name system, and to try to coalesce

a unified view about the structure of the new corporation that is to be formed

by this indeterminate group. Nevertheless, over the course of the past three

months, a diverse community of individuals and organizations has emerged and

taken up the challenge of the White Paper.

There have been at least four regional meetings around the world to air views

on the new corporation. These meetings in North America, Europe, Asia and

Latin America, which were each open to the public, were well-publicized and

well-attended. Transcripts from the meetings were posted on Web sites, and

"virtual" public discussion was carried on in a number of listservs so that

debates started at these regional meetings could continue and so that those

unable to attend the meetings could participate in the international dialogue.

These meetings and discussions provided an initial opportunity for Internet

stakeholders to identify one another and to stand up and be counted.

There have also been numerous additional meetings and discussions among those

who have expressed an interest in the shape of the new entity. Many have

occurred in public settings, often through Internet-based publications and

listservs. In particular, these discussions have included the posting of

several draft Bylaws for the new entity, including drafts proposed by Dr.

Postel. These several drafts have been commented upon and critiqued -- often

sharply -- by various US and international commercial interests, consumer

interests, educational and other non-profit interests and governmental

interests.

Several iterations of this process have ultimately concluded with the set of

Articles and Bylaws for the Internet Corporation for Assigned Names and

Numbers that have been proposed by Dr. Postel. Among the competing Bylaws

submitted for your consideration, we believe that Dr. Postel's version has

been the subject of the broadest comment by Internet stakeholders and reflects

the most visible and tested compromise of the conflicting comments of Internet

stakeholders.

As Dr. Postel enunciates in the cover letter to his proposal, there are

considerable challenges that are not resolved by the Bylaws and that will have

to be confronted by the new entity. However, we believe that the Articles of

Incorporation and Bylaws submitted by Dr. Postel represent a substantial

consensus among the voiced interests of the Internet community. We believe

that Dr. Postel's proposal provides a fair, transparent and solid framework

from which the new entity, working with the broader Internet community, can

take on the challenges ahead.

Very truly yours,

George Vradenburg III

Sr. Vice President and General Counsel

America Online

###

October 14, 1998

Honorable William M. Daley

Secretary of Commerce

United States Department of Commerce

14th and Constitution Avenue, N.W.

Washington, DC 20230

Re: Private Sector Proposals for a New Corporation to Manage Internet Domain Name System Functions

Dear Mr. Secretary:

The National Telecommunications and Information Administration ("NTIA") has asked for public comments on various proposals for a new corporation to manage Internet domain name system functions that have been submitted by various private sector entities pursuant to the White Paper. In response to that request for comments, America Online, Inc. ("AOL") submits this statement to support the establishment of the new entity under the Articles of Incorporation and Bylaws proposed by Dr. Jon Postel.

The White Paper issued an unprecedented challenge to the public. After nearly two decades of control by the US Government and its contractors of the numbers and names necessary for communication over the Internet, the US Government announced that it would relinquish control to a new non-profit entity to be formed, through a consensus process, by the private sector. The US Government called upon the community of Internet "stakeholders" to collectively decide a structure and mandate for the new entity and to bring the entity into being.

The US Government set out certain parameters that the new entity would have to meet, which have guided efforts to establish the entity. For instance, the new entity would have to be formed in a manner to ensure the continued stability and security of the number and name address system. At the same time, the new entity would have to promote more competition, while providing a mechanism for bottom-up governance that includes broad-based and international participation.

There have been major hurdles to overcome in reaching the current proposals submitted to NTIA. Not least among these has been to identify the international "stakeholders" of the domain name system, and to try to coalesce a unified view about the structure of the new corporation that is to be formed by this indeterminate group. Nevertheless, over the course of the past three months, a diverse community of individuals and organizations has emerged and taken up the challenge of the White Paper.

There have been at least four regional meetings around the world to air views on the new corporation. These meetings in North America, Europe, Asia and Latin America, which were each open to the public, were well-publicized and well-attended. Transcripts from the meetings were posted on Web sites, and "virtual" public discussion was carried on in a number of listservs so that debates started at these regional meetings could continue and so that those unable to attend the meetings could participate in the international dialogue. These meetings and discussions provided an initial opportunity for Internet stakeholders to identify one another and to stand up and be counted.

There have also been numerous additional meetings and discussions among those who have expressed an interest in the shape of the new entity. Many have occurred in public settings, often through Internet-based publications and listservs. In particular, these discussions have included the posting of several draft Bylaws for the new entity, including drafts proposed by Dr. Postel. These several drafts have been commented upon and critiqued -- often sharply -- by various US and international commercial interests, consumer interests, educational and other non-profit interests and governmental interests.

Several iterations of this process have ultimately concluded with the set of Articles and Bylaws for the Internet Corporation for Assigned Names and Numbers that have been proposed by Dr. Postel. Among the competing Bylaws submitted for your consideration, we believe that Dr. Postel's version has been the subject of the broadest comment by Internet stakeholders and reflects the most visible and tested compromise of the conflicting comments of Internet stakeholders.

As Dr. Postel enunciates in the cover letter to his proposal, there are considerable challenges that are not resolved by the Bylaws and that will have to be confronted by the new entity. However, we believe that the Articles of Incorporation and Bylaws submitted by Dr. Postel represent a substantial consensus among the voiced interests of the Internet community. We believe that Dr. Postel's proposal provides a fair, transparent and solid framework from which the new entity, working with the broader Internet community, can take on the challenges ahead.

Very truly yours,

George Vradenburg III

Sr. Vice President and General Counsel

America Online, Inc.

###

From: "Tasker, Joe" <Joe.Tasker@COMPAQ.com>

To: "'dnspolicy@ntia.doc.gov'" <dnspolicy@ntia.doc.gov...

Date: 10/13/98 5:00pm

Subject: Comments due Today on DNS Policy

Please find attached comments responsive to the NTIA's notice.

As you requested, the comments are in the form of an attachment, in

Microsoft Word 97.

Thank you for your consideration. Please contact me if you have any

problems with this transmission.

Joe Tasker

Compaq Computer Corporation

1300 Eye Street, N.W.

Washington, DC 20005

(202)962-3830

<<Irvingcomment.doc>>

October, 13, 1998

Honorable Clarence (Larry) Irving, Jr.

Assistant Secretary for Communications and Information

United States Department of Commerce

14th Street and Constitution Avenue NW

Washington DC 20230

Dear Larry,

I appreciate the opportunity to provide comments in this matter on behalf of Compaq Computer Corporation, including its wholly owned subsidiary Digital Equipment Corporation.

Compaq supports the proposal for the Internet Corporation for Assigned Names and Numbers. We believe it is consistent with the November 13, 1997 recommendation made by Digital Equipment Corporation to establish "a broader and more inclusive oversight structure for Internet self-governance."

In that earlier correspondence to you and Ira Magaziner, we envisioned a framework that "would provide an umbrella covering a variety of loosely affiliated Internet infrastructure areas each involving policy and legal issues, of which DNS shared registration operation is one. Some other areas include IP address management, root server registration operation, BIND software provisioning and directory service creation, with each having its own distinct constituency, management substructure and policy issues." We continue to hold these views.

We believe the ICANN proposal meets this basic vision and we at Compaq are prepared to work with other Internet stakeholders to ensure stable and technically sound long-term solutions to issues of Internet administration.

Thank you again for the opportunity to comment.

Best regards.

Sincerely,

Joseph Tasker, Jr.

Vice President and Associate General Counsel

Government Affairs

Compaq Computer Corporation

1300 Eye Street, N.W.

Washington, DC 20005

(202)962-3830

cc: Ira Magaziner

###

From: "John S. Quarterman" <jsq@mids.org>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 11:14am

Subject: RE: Respuesta a Propuesta de Jon Postel

Here is a response from Latin America and the Caribbean to

Jon Postel's proposal.

------- Forwarded Message

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Return-Path: <futreras@reuna.cl>

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Message-ID: <01BDF35D.D6B5F900@futreras.consorcio.reuna.cl>

From: "Florencio I. Utreras" <futreras@reuna.cl>

To: "'Jon Postel'" <postel@isi.edu>

Cc: "'Alejandro Ortiz'" <alortiz@campus.mty.itesm.mx>,

"'Gabriela Vazquez'"

<gvazque@reacciun.ve>,

"'Leonardo Lazarte'"

<llazarte@Ipe.mat.unb.br>,

"'Sidia de Sanchez'" <ssanchez@ns.pa>,

"'Ermanno Pietrosemoli'" <ermanno@ing.ula.ve>,

"'Ida Holz'"

<holz@seciu.uy>

Cc: "'Jose Luiz Ribeiro'" <j.ribeirofilho@nc-rj.rnp.br>,

"'Julian Dunayevich'"

<julian@riu.edu.ar>,

"'Luis Eliecer Cadenas'"

<ecadenas@reacciun.ve>,

"'Raul Echeberria'" <raul@inia.org.uy>,

"enredo@reacciun.ve" <enredo@reacciun.ve>,

"Alci@intermedia.com.ar" <Alci@intermedia.com.ar>

Cc: "ebarone@mcye.gov.ar" <ebarone@mcye.gov.ar>,

"ecadenas@reacciun.ve"

<ecadenas@reacciun.ve>,

"evitale@ing.ula.ve" <evitale@ing.ula.ve>,

"holz@seciu.uy" <holz@seciu.uy>, "John S. Quarterman"

<jsq@mids.org>,

"llazarte@mat.unb.br" <llazarte@mat.unb.br>

Cc: "oportunidades@redynet.com.ar" <oportunidades@redynet.com.ar>,

"orobles@nic.mx" <orobles@nic.mx>, "ssanchez@ns.pa"

<ssanchez@ns.pa>,

tadao Takahashi <tadao@na-cp.rnp.br>,

Amadeu Abril i Abril <Amadeu@nominalia.com>,

"'Jose Soriano'"

<js@rcp.net.pe>

Subject: RE: Respuesta a Propuesta de Jon Postel

Date: Fri, 9 Oct 1998 08:21:37 -0500

Encoding: 51 TEXT

Mr Jon Postel.

The Foro de Redes de America Latina y el Caribe (ENRED) created in 1991 and formed by most of the

ccTLD administrators of the LA&C region together with representatives from all the countries representing

their core networks and over a million users, has been an active participant in all discussions involving

the future of the DNS administration issue, including the gTLD-MoU and the IFWP.

Despite a more ellaborated counterproposal than we are preparing for the near future, we have decided

to send you our inmediate reaction to Version 5 of the new IANA proposal.

Our first reaction to this new document, a feeling shared by most ccTLD administrators of the region, is that

it represents a step back in a number of issues, produces confussion with regards to the openness

and transparency that the initiative is intended to have and certainly tends to forget that the

Internet needs everybody, north and south, developped and underdevelopped, techonlogy rich and technology poor,

i.e. the whole community.

More precisely:

1) It lacks accountability, since the organisation has no membership support. The 'stakeholders' are not

direct owners of the organisation.

2) We do not feel that wide International representation is clear assured. In particular, a more

precise definition of the regions like the one proposed by RIPE is needed. Also, if we want to

ensure that all points of view are represented and that the new organisation has a strong basis,

we need to put stronger bounds to the representation of any single region, 33% at most.

But, most of all, we must also make sure that different levels of development are represented.

3) We feel extremely dissapointed by your initial board proposal. All the proposed members

come from OECD countries. We have proposed 4 candidates of our region and support

the nomination of one asian candidate. No one of them has been taken into account, neither

one from Africa or other non-OECD country.

Clearly the whole Internet community is not represented in your proposal. ENRED and the

whole of LA&C do not feel that anyone from other country could represent our views. We do not

feel specially 'close' to any member of the board and simply feel that we are not represented

by any of the members and regret that an enormous oportunity to create a really new organisation

where everybody is carefully taken into account was lost.

The board, as propposed, represents only the most developped parts of the world and neglects

the possibility of a north-south interaction.

We hope that during this discussion period some action is taken to put remedy to this mistake.

Yours very sincerely,

Executive Secretariat

ENRED

------- End of Forwarded Message

###

From: Kent Crispin <kent@songbird.com>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 5:25pm

Subject: comments on "the Private Sector Proposal for New Domain Name Corporation"

Honorable William M. Daley

Secretary of Commerce

c/o Karen Rose

Office of International Affairs

Room 471

National Telecommunications and

Information Administration

United States Department of Commerce

14th and Constitution Avenue, N.W.

Washington, D.C. 20230

Dear Secretary Daley:

The gTLD-MoU Policy Advisory Body, an organization drawn from the 230

signatories of the MoU, endorses and supports the ICANN proposal

submitted to you by Professor Jon Postel. It is the proposal that has

had by far the widest review, and, though there have been complaints

of imperfections, as well as constructive comments, it embodies a

structure that can and will be refined over time, and should be

adopted now.

The Internet community has been waiting for four years for this to be

resolved. There is no reason for further delay. We urge the NTIA to

begin immediate negotiations with ICANN for the transfer of authority

described in the White Paper.

Thank you

Policy Advisory Body

--

Kent Crispin, PAB Chair "Do good, and you will be

kent@songbird.com lonesome" -- Mark Twain

PGP fingerprint: B1 8B 72 ED 55 21 5E 44 61 F4 58 0F 72 10 65 55

http://songbird.com/kent/pgp_key.html

####

From: Kent Crispin <kent@songbird.com>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 10:50pm

Subject: Comments by Kent Crispin

Honorable William M. Daley

Secretary of Commerce

c/o Karen Rose

Office of International Affairs

Room 471

National Telecommunications and

Information Administration

United States Department of Commerce

14th and Constitution Avenue, N.W.

Washington, D.C. 20230

Dear Secretary Daley:

The ICANN proposal is a result of literally years of work, and

represents compromises that are many, complex, and delicate. Hundreds

of entities -- governments, large businesses, politically powerful

organizations, and many, many smaller stake-holders have participated.

The debate has at times been very strident, even rancorous. There are

genuine differences of opinion, and many of the participants have

particular issues about which they will not compromise.

Under such circumstances it is impossible to satisfy everyone, and

necessarily, therefore, at the end there will be some unhappy

stake-holders. This is the state we are in now. The vast majority of

participants in this long process support ICANN. None of them thinks

that ICANN is perfect; every one of them has some things they would

like to see changed. Many of them have sent endorsements to IANA.

In reading the comments so far submitted it is clear that we are

reaching a point of diminishing returns as far as changes are

concerned. That is, there are entities that supported earlier

versions of the ICANN bylaws that now find fault with the latest

version. Therefore, we can reasonably expect that every further

change will please some, and anger others. There is the risk that any

major change will damage the fragile compromise beyond repair.

In addition to a few isolated complaints from serious stake-holders

there have been alternate proposals from other groups, for example the

"Boston Working Group", and the "Open Root Server Confederation":

The "Boston Working Group" proposal is an example of work by a

well-intentioned splinter group of the IFWP. They have presented a

set of modifications to the ICANN bylaws. Some of these modifications

may be good, some may be bad. But despite the fervent evangelizing

by some of the authors and a few proponents, and despite use of the

IFWP name, the proposal in fact been reviewed by only a tiny fraction

of the stake-holders that have reviewed the ICANN bylaws. I think that

the ICANN directors should seriously examine the BWG's proposal, but

there is no reason to hold up acceptance of ICANN because of it.

The "Open Root Server Confederation" submission is another example.

The ORSC, as its name implies, has a clear and well-known agenda

concerning management of the root servers, an agenda quite at odds

with many other stake-holders. Its bylaws were completed the same day

their proposal was sent to NTIA, and have had no external review

whatsoever. (The ORSC also sometimes called the "Open Root Source

Consortium", and the "Open Root Server Corporation" -- it appears to

have several names. However, "Open Root Server Confederation" was the

first one.)

ORSC states that their bylaws are a minor revision of the BWG

modifications, but a cursory reading reveals substantial differences

-- in particular, they include a complex membership structure that

favors their agenda (domain name issues) over other roles. Discussion

of such a structure has been a highly controversial and contentious

issue in the past, and adoption of the ORSC proposal would effectively

preempt those other points of view without review or consensus.

Given that there has been absolutely no public review of the ORSC

proposal, and that they have included a controversial and perhaps

self-serving membership structure, the ORSC proposal can not be

considered as a serious consensus effort.

There have been thoughtful comments by other contributors as well.

However, given that the USG will maintain oversight over ICANN for

some time into the future, and that the ICANN bylaws allow for

sensible modification, there is no reason to delay and go through yet

another round of meetings. Much work remains to be done in the

formation of the Supporting Organizations and elsewhere, and delay

could set things back for months.

Thank you

Kent Crispin

Owner, Songbird

--

Kent Crispin, PAB Chair "No reason to get excited",

kent@songbird.com the thief he kindly spoke...

PGP fingerprint: B1 8B 72 ED 55 21 5E 44 61 F4 58 0F 72 10 65 55

http://songbird.com/kent/pgp_key.html

####

From: "Ken Stubbs" <kstubbs@dninet.net>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 6:35pm

Subject: Comments - ICANN proposal

U.S. Department of Commerce

National Telecommunications and

Information Administration

The Internet Council of Registrars (CORE), representing Internet

organizations in 23 countries, supports the proposal by the Internet

Assigned Numbers Authority (IANA) to create a non-profit organization

called the Internet Corporation for Assigned Names and Numbers (ICANN) to

assume the administrative responsibilities for the Domain Name System as

outlined in the U.S. Government White Paper.

We believe the consensus-building approach taking by IANA over the past

year and its rapid response to suggestions from the global Internet

community resulted in a document that serves as a solid foundation for

Internet self-governance and competition.

CORE believes the processes envisioned under ICANN will ensure the continued evolution of the organization to the benefit of users everywhere. Its provisions include representation of the many stakeholders worldwide, an open and transparent process, accountability and the stability of the Internet. In sharp

contrast to other plans, ICANN provides for stability of the Internet

because it continues the administrative functions carried out by IANA for

some 15 years.

To that end, CORE further recommends that the U.S. Department of Commerce

order the transfer of the A root server to ICANN as quickly as practical.

The U.S Government should also build in significant penalties for any

unwarranted delays in creating an open shared registry system, where Internet users throughout the world can choose their Internet names, providers,

registrars, registries and other services in a more open and competitive environment.

Every day the current situation exists, users are being denied this freedom

of choice, significantly constricting the potential growth of the Internet.

We will continue to study the implications of the agreement and are somewhat apprehensive that the lack of more specific details prevent us from making a final assessment about it.

Sincerely yours,

Ken Stubbs, Chairman, CORE Executive Committee

c/o Domain Names International, USA

Phone: +1 352 750 9776 Fax: +1 352 750 9569

e-mail: kstubbs@corenic.org

(CORE * www.corenic.org)

####

U.S. Department of Commerce
National Telecommunications and
Information Administration

The Internet Council of Registrars (CORE), representing Internet
organizations in 23 countries, supports the proposal by the Internet
Assigned Numbers Authority (IANA) to create a non-profit organization
called the Internet Corporation for Assigned Names and Numbers (ICANN) to
assume the administrative responsibilities for the Domain Name System as
outlined in the U.S. Government White Paper.

We believe the consensus-building approach taking by IANA over the past
year and its rapid response to suggestions from the global Internet
community resulted in a document that serves as a solid foundation for
Internet self-governance and competition.

CORE believes the processes envisioned under ICANN will ensure the continued evolution of the organization to the benefit of users everywhere. Its provisions include representation of the many stakeholders worldwide, an open and transparent process, accountability and the stability of the Internet. In sharp
contrast to other plans, ICANN provides for stability of the Internet
because it continues the administrative functions carried out by IANA for
some 15 years.

To that end, CORE further recommends that the U.S. Department of Commerce
order the transfer of the A root server to ICANN as quickly as practical.

The U.S Government should also build in significant penalties for any
unwarranted delays in creating an open shared registry system, where Internet users throughout the world can choose their Internet names, providers,
registrars, registries and other services in a more open and competitive environment.

Every day the current situation exists, users are being denied this freedom
of choice, significantly constricting the potential growth of the Internet.

We will continue to study the implications of the agreement and are somewhat apprehensive that the lack of more specific details prevent us from making a final assessment about it.

Sincerely yours,

Ken Stubbs, Chairman, CORE Executive Committee
c/o Domain Names International, USA 
Phone: +1 352 750 9776 Fax: +1 352 750 9569 
e-mail: kstubbs@corenic.org 
(CORE – www.corenic.org)
####

From: Michael Sondow <msondow@ic.sunysb.edu>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 7:55pm

Subject: Revised comments on proposals for the NewCo

To: Karen Rose

For: Ira Magaziner, Beckwith Burr, and Wlliam Daley

From: Michael Sondow (ICIIU)

Subject: Revised comments on the proposals submitted to the NTIA for a

reorganization of the central Internet authority, termed the "NewCo".

As regards the proposal from Jon Postel (IANA), if the new entity is to

be a "public benefit" corporation organized for "charitable and public

purposes", and "will be operated exclusively for charitable,

educational, and scientific purposes", then why is its initial Board of

Directors composed of a financial strategist, a partner in a capital

investment firm, the chairman of an industrial association, the

president of a holding company, a marketing specialist, the chairman of

a telecommunications operators' association, and a management

consultant, with two academics, one of whom is probably a representative

of his national government, for window dressing? There is such a great

contradiction here between the direction of the Postel-proposed

corporation and its avowed purpose that the Postel proposal must be seen

as having been conceived in bad faith, and is therefore null and void,

beyond any consideration of the worth or lack of it of any of its

individual articles or bylaws. Indeed, as the Postel bylaws contain no

provision for a balancing of powers or public accountability, and give

up the future of the corporation exclusively into the hands of its

directors, the Postel-proposed corporation must bring about the death of

the Internet for public interest purposes, and is therefore to be

rejected prima facie and in toto.

Regarding the proposal of Ronda Hauban, there is surely much truth in

what she says, although her proposal as written is more a criticism of

the process instigated by the present administration than an outline for

a solution to the problem. Nevertheless, as Ms. Hauben says, the

abandonment of the Internet by government funding and the consequent

withdrawal of the security that such funding has provided to its

developers is a betrayal of their work to political and commercial

pressures, and will no doubt be seen as such by history. Further, her

arguments comparing the success of the user-based Internet with the

relative failure of contemporaneous commercially-controlled networks

like Compuserve are irresistible.

The Electronic Frontiers Foundation has submitted a proposal (not yet

added to the NTIA site by 10/5/98) whose main advance over others is its

addition of mechanisms to ensure the transparency of the operations of

the various boards, organizations, and committees of the newcorp. These

mechanisms should be seen by all interested parties, or at least all who

are interested in fair play, public responsibility, and democratic

process, as advantageous and worthy of inclusion in any proposal

ultimately accepted.

There remains to consider the proposal of the Boston Working Group. By

its insistence upon a membership structure and other modifications,

notably those regarding the relationship between the Supporting

Organizations and the Board, and of the role of the Financial Officer,

this proposal goes some way in relieving the lack of accountability

inherent in all the proposals by the IANA and the ICANN. Nevertheless,

it does not go far enough in stipulating mechanisms to ensure financial

accountability and the control and review of fee structures affecting

the entities of the Internet infrastructure and the resultant costs to

users of Internet services, including the cost of allocation of domain

names. Without public review and a balance of powers in setting cost and

pricing structures, no private corporation managing Internet services

can be accountable to the public and respondent to its needs. However,

these matters are bridged at least in the proposal of the Boston Working

Group, which, for this reason and because of its definition of a

membership structure and the accountability of its board of directors to

this membership, is the only proposal thus far presented from which a

final document could be derived. It remains, among other things, to

incorporate in it a precise method for selecting directors, and other

procedural matters absent in all proposals to date. Such matters cannot

be left for decision to an interim board because that gives too great a

power to it and this is in clear contradiction with the transitional

nature of that body. It should be added here that the suggestions of

William Semich for ensuring financial accountability, and the dangers of

not doing so, should be heeded, and the necessary articles added to

bylaws.

In sum, of the three proposals published by the NTIA, that of the

Boston Working Group is the only one which holds out a promise of

successful modification so as to form the basis of a responsive entity

fulfilling the role designed for it by the Department of Commerce. With

the addition of:

-- the EFF's transparency provisions;

-- William Semich's methodology for financial accountability;

-- an observance of Ronda Hauben's historical perspective obliging a

continued role for governmental oversight;

-- the replacement, with a better wording, of certain sections such as

IV-1(e) in, for example, terms suggested by the ORSC;

-- the addition of a Hearing Board, with appropriate rotating selection

of members, as suggested in the by-laws proposal submitted for the

INEG by Jeff Williams, and in the ORSC proposal;

-- and a re-evaluation of the membership structure as proposed by the

BWG, to perhaps include a majority or totality of Individual Members,

the proposal of the Boston Working Group can be molded into a document

that will not only satisfy the great majority of interested parties

including the public, but become a lasting basis for the continued

growth and useful expansion of the Internet.

####

From: MURON Olivier BD/DINU <olivier.muron@francetelecom.fr>

To: Non Receipt Notification Requested IPM Return R...

Date: 10/13/98 9:58am

Subject: EC-PoP Statement of Support for ICANN Proposal

Tuesday, October 13th 1998

European Commission Panel of Participants (EC-PoP):

Statement of Support for ICANN Proposal

---------------------------------------

The members of the EC Panel of Participants recognize the

value of IANA's efforts to build consensus on this matter.

The EC-PoP is pleased to acknowledge that significant

progress has been made since the fourth iteration of the

draft and that most of the issues identified by the EC-PoP

have been addressed.

The members the EC-PoP believe that the proposal submitted

by ICANN is a realistic basis for the launch of the new

Corporation, provided that the Initial Board take action

to correct the following shortcomings:

- Improve safeguards against extra-territorial application

of US law and US public policies. The proposed Articles of

Association and Bylaws provide insufficient protection against

the possible overruling of international law or other

countries' laws, social concepts and cultural values.

- Ensure more balanced international representation.

All stakeholder groups, sectoral and regional, need to be

reassured that their interests will be equitably represented

on the Board - we are aware that some have expressed concern

on this respect -. In the current draft, more than 50 percent

of the members of the full final Board could come from a single

region such as North America or Europe. By the time the Bylaws

are reviewed as per Article V, Section 4,Paragraph a, this

threshold should be reduced to one third of the total number

of board members and provision should be made for an equitable

representation of all stakeholders interests.

The EC-PoP would like to point out that delays in incorporating

the new IANA can create lasting imbalances with respect to

the needed international and competititive equilibrium.

Smooth implementation of ICANN and its supporting organisations

is key to preserving the stability of the Internet.

About the EC Panel of Participants (EC-PoP)

-------------------------------------------

On July 7th 1998 the European Commission called for a European

consultative meeting as preparation for the IFWP meetings, the

results of this meeting can be found at:

http://www.ispo.cec.be/eif/dns/conclusions.html

One of the results from that meeting was the establishment

of an EC Panel of Participants (EC-PoP), a European group of

stakeholder representatives, to discussed a common position

in the IFWP process and to advise the EC.

The EC-PoP has responded on September 9 to the IANA's third draft

issued on August 24, 1988,

see: http://www.ispo.cec.be/eif/dns/statement.html.

The EC-PoP has expressed serious concerns about the NSI-IANA

cooperative draft (fourth draft issued on September 17, 1998),

see http://www.ispo.cec.be/eif/dns/ec-pop.html.

***************************************************************

On behalf of the European Commission Panel of Participants,

Olivier MURON

FRANCE TELECOM

olivier.muron@francetelecom.fr

+33 1 44 44 54 89

CC: Non Receipt Notification Requested IPM Return Requ...

####

From: "Oscar A. Robles Garay" <orobles@nic.mx>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 8:11pm

Subject: Proposal for the new organization

The LACTLD (Latin American & Caribbean country code Top Level

Domain Organization) represents Argentina, Brazil, Bolivia,

Chile, El Salvador, Mexico, Peru, Uruguay and Venezuela. We are

members of both ENRED (Foro de Redes de America Latina y el Caribe)

and wwTLD alliance.

We want to express our support to the IANA's fifth set of proposed

bylaws which Mr. Jon Postel recently sent to the USG NTIA.

However, we continue to be deeply concerned about the lack of

representation on the proposed new IANA board for the

regions of Latin America, and Africa.

The Green Paper of the USG had previously touched upon this

issue, and we unanimously agreed upon it during a recent meeting held in

Buenos Aires, Argentina (as part of the IFWP process).

We do believe that at least one individual with as

substantial qualifications as the current nominees could be

found in the Latin America and Caribbean region, and

therefore would like that if a comment from wwwTLD is to be

submitted, this point was mentioned.

-LACTLD

CC: NTIADC40.SMTP40("lactld@nic.mx","iana@iana.org")

####

From: Patrick Greenwell <patrick@namesecure.com>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 7:50pm

Subject: Comments on proposals for new private sector corporation

13th October, 1998

HONORABLE WILLIAM M. DALEY

Secretary Of Commerce

C/0 Karen Rose

Office of International Affairs

Room 471

National Telecommunications and Information Administration

United States Department of Commerce

14th and Constitution Avenue, N. W.

Washington, D.C. 20230

RE: Management of Internet Names and Addresses

THE AUTHOR

Patrick Greenwell is the CTO of NameSecure, a company providing domain

name registration services since 1995. I also serve as a board member of

the Internet Service Providers' Consortium(ISP/C), the largest trade

association of small to mid-size ISPs' in the world. In addition, I have

filed comments to the NTIA's "Green Paper," and have participated in the

International Forum on the White Paper(IFWP), having attended meetings in

Reston, Geneva, and Singapore as both a participant and as a member of the

the IFWP Steering Committee, the group charged with organization of meetings.

INTRODUCTION

On behalf of NameSecure, I would like to offer our support for the Boston

Working Groups proposed amendments to the ICANN documents, and also to

acknowledge the work of the ORSC in creating their proposal, which is based

on the Boston Working Group's proposal.

THE ICANN PROPOSAL

The current ICANN proposal as offered does not meet the criteria outlined

in the White Paper, and are unacceptable for a number of reasons:

1) It does not meet the mandate of openness or transparency.

The White Paper states:

"The organizing documents (Charter, Bylaws, etc.) should provide that the new

corporation is governed on the basis of a sound and transparent

decision-making process, which protects against capture by a self-interested

faction, and which provides for robust, professional management of the new

corporation."

With regards to access to information the ICANN bylaws offers:

" The Board shall publish, at least annually, a report describing its

activities, including an audited financial statement and describing any

payments made by the Corporation to Directors (other than reimbursements of

expenses). All minutes of meetings of the Board, Supporting Organizations

(and any councils thereof) and Committees shall be approved promptly and

immediately following approval shall be made publicly available on the Web

Site and otherwise; provided, however, that any minutes relating to personnel

or employment matters, legal matters (to the extent the Board determines is

necessary or appropriate to protect the interests of the Corporation), matters

that the Corporation is prohibited by law or contract from disclosing publicly

and other matters that the Board determines are not appropriate for public

distribution shall not be included in the minutes made publicly available. For

any matters that the Board determines not to disclose, the Board shall

describe in generic terms in the relevant minutes the reason for such

nondisclosure."

This allows for a board that can:

a) Refuse to divulge expense reimbursement information, no matter how

large, or of what nature.

b) Enter into contrived contracts with privacy provisions and thus refuse

to divulge any information surrounding the contracts.

c) At it's sole discretion, deem any matter not appropriate for public

distribution and not divulge that information.

2) There is a lack of financial accountability in the ICANN proposal.

While the current ICANN proposal allows the Board to set fees for services

offered to the supporting organizations, it does not offer any means of

independent review of the fee structures or budget. Indeed, it does not

even offer supporting organizations input into the fee structures that

they will be subject to.

3) There is an inherent conflict of interest when naming supporting

organization representatives to board positions.

Under the current ICANN proposal, there are provisions to give nine of the

board seats to three each of the names, numbers, and protocol councils.

Yet later, "Section 7. Conflict of Interest," states:

" No Director shall vote on any matter in which he or she has a material and

direct interest that will be affected by the outcome of the vote."

This creates a situation of permanent conflict of interest. Even should

Board Members of the new corporation that are representatives of the

Supporting Organizations reasonably be expected to "serve as individuals who

have the duty to act in what they reasonably believe are the best interests of

the Corporation and not as representatives of their Supporting Organizations,

employers or any other organizations or constituencies" as called for in

"Section 8. Duties of Directors" there is the very real possibility that

many of the votes of the new organization would have a direct effect on the

individual Supporting Organizations, thus rendering representatives of those

Supporting Organization ineligible to vote.

4) The ICANN proposal is weak on membership

Under the current ICANN proposal, the Initial Board of the new organization

could decide against a membership-based organization, leaving the organization

in a potential closed loop, and subject to capture by a small group of

interests.

5) The ICANN proposal is a product of back-room negotiations led by a

single US Government contractor.

Repeatedly throughout the White Paper there were references to the need for

the private sector to form the new corporation such as:

" For example, a new not-for-profit organization must be established by the

private sector and its Interim Board chosen."

The private sector was not responsible for drafting the ICANN draft 5

documents, The Internet Assigned Numbers Authority(IANA), a US Government

contractor, was. The private sector was not responsible for the incorporation

of ICANN. The incorporation of ICANN was performed at the direction of

representatives of IANA. The private sector did not choose the Interim Board,

IANA did. The documents, the corporation, and the proposed Interim Board

members are a not a product of the private sector, as was called for

repeatedly within the White Paper.

The private sector was indeed involved in a process to establish consensus

and principles regarding the formation of the new organization. This process

was called the International Forum on the White Paper(IFWP.) The IFWP held a

number of meetings throughout the world, which were completely open to all

that wished to attend, and did produce a series of consensus items, that were

vetted at succesive meetings as to the structure and formation of the new

corporation. A mailing list was also maintained for ongoing discussions of

these issues. The IFWP saw participation from a broad spectrum of stakeholders

including domain name registries, domain name registrars, ISPs, the regional

Internet address registries, trademark interests, business interests, end

users, and representatives of IANA itself.

The consensus items that were arrived at by the largest and most representative

group of stakeholders in this entire process, have been repeatedly ignored by

IANA, and this ignorance shows in the current IANA proposal in the

aforementioned areas. At all times, IANA, has in a process parallel to

the IFWP continued to draft documents behind closed doors in cooperation with

mostly unknown parties. At one point early within the IFWP process, IANA

asked the participants to take the IANA draft documents as the basis for

discussion. This request was rejected by the majority of participants, yet

rather than join the open, representative process that was taking with the

IFWP, IANA chose to continue to draft documents in private. While this

was certainly their right, any claims that their proposal represents

the consensus of the Internet community are categorically false.

Further, we have the account of Jonathan Zittrain of Harvard's Berkman

Institute, who volunteered to organize a compromise meeting between various

stakeholders to produce a common set of documents, and was in constant contact

with representatives from IANA during this time. In a recent email regarding

IANA's position on attending the compromise meeting that the Berkman Center

was attempting to organize he stated: "IANA went from noncommittal to a firm

"no," and said it would ask others to forego such a meeting as well."

IANA also chose to name Interim Board nominees. At no time was there a

public nomination process explained, nor were there any published criteria

as to the basis for nominee selection, or who would be involved in the

selection process. From all known accounts, these Interim Board nominees are

the product of IANA and IANA alone.

The effective result of this fundamental refusal to participate with

other parties openly is that any stakeholder and or interested party that did

not agree to conduct negotiations with IANA in private, or were not invited

to do so, were left without a voice in the resultant proposal.

THE BOSTON WORKING GROUP PROPOSAL

The Boston Working Group(BWG) proposal contemplates changes to the ICANN

proposal which address the glaring deficiencies present in the ICANN proposal:

1) Openness and transparency

a) Audited financial statements of *all* expenditures are required.

b) Suggests that the board adhere to principles of open meetings

of such states as California, which greatly enhance access

of the public to information.

2) Financial Accountability

a) Allows the Supporting Organizations to submit proposals

for fee structures within their scope.

b) Requires the board to set fees according to an agreed upon

business plan.

3) Conflict of Interest in Board Structure

The Boston Working Group Proposal removes the ability of Supporting

Organizations to appoint members to the board, while maintaining their

place as the basis for formulation of policy, subject to board review,

comment, and approval or rejection. Not only does this eliminate

conflict of interest in this regard, it also prevents an inequitable

distribution of representation to a small group of stakeholders.

4) Membership

The Boston Working Group's proposal requires the new corporation to move to

a membership-based organization, thus ensuring greater representation of

differing interests, and making the new corporation much less subject to

capture.

5) Private Sector foundation

The Boston Working Group's proposal is the result of an open and inclusive

process held by those that are truly within the private sector, as called

for within the White Paper. The meeting in which the amendments were produced

were open to all interested and affected stakeholders, and a multinational

group with members from differing stakeholder groups attended and

offered input.

The Boston Working Group proposal does not offer a slate of proposed Interim

Board nominees, citing the need to represent the IFWP membership and consensus.

It proposes the selection of Interim Board members by vote, which is

consistent with an open and representative organization.

CONCLUSION

For the above enumerated reasons, we feel that the Boston Working Group

proposal fully meets the criteria of the White Paper, producing an open,

transparent, and accountable organization. We therefore urge the Department

of Commerce to recognize the work of the Boston Working Group as the proposal

most worthy of consideration, or at a minimum require a futher open meeting

among stakeholders on equal terms to produce a single set of consensus

documents that were desired from the outset.

Finally, I would like to respond to a statement that Dr. Jon Postel of IANA

made recently in testimony presented to Congress last Wednesday that referred

to those that have opposed the closed process that IANA has been engaged in

as a "small fringe of extreme views." If this were indeed the case, and it was

only a small fringe that is arguing for openness, representation, and

accountability in the new corporation, as the White Paper has called

for, then it would indeed be a sad state of affairs that we face. Thankfully,

as you will see by the many other comments from a wide range of stakeholders,

it is not.

####

From: "Paul M. Kane" <Paul.Kane@nic.AC>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 5:32pm

Subject: RFC Private Sector Proposal

Sirs,

Brief and personal comments, concerning Private Sector Proposal for the

New Domain Name Corp.

The ICANN proposal is not perfect but is workable. The lack of financial

accountability and the reduced influence of the Supporting Organizations

on the Board, should in my opinion should be reviewed. Yet, these are

elements the interim Board can address. As to the the transfer of the

Root to the Private Sector, this may take a little longer as the full

Board must be able to demonstrate all components of the new organization

are stable.

Faithfully

Paul M. Kane.

Administrator

INternet ONE.

####

From: Peter Lucht <Peter.lucht@mci.com>

To: NTIA.NTIAHQ(dnspolicy)

Date: 10/13/98 2:40pm

Subject: Comments of MCI WorldCom, Inc.

To Whom it May Concern:

Below and attached as a Microsoft Word 98 document please find the

comments of MCI WorldCom, Inc., regarding proposals for administration

of the Internet domain name system.

---------------------------------------------------

October 13, 1998

Hon. William M. Daley, Secretary

United States Department of Commerce

c/o NTIA/OIA

14th & Constitution Ave., NW

Washington, DC 20230

Secretary Daley:

MCI WorldCom is pleased to comment on the private sector proposals for a

new organization to provide the functions currently provided under U.S.

Government contract by the Internet Assigned Numbers Authority (IANA) at

USC Information Sciences Institute. This statement is in response to the

Department of Commerce's September 29, 1998 press release and its notice

posted at the web site of the National Telecommunications Information

Administration (NTIA: www.ntia.doc.gov).

For approximately three years, several efforts have been made to develop

proposals to re-organize and re-constitute the administration of the

central administrative functions required for the proper operation

of the Internet. For the most part, these proposals have revolved around

the establishment of a private sector, non-profit organization which would

manage the allocation of Internet Protocol addresses, top level

domain names, the population of root domain name server databases and the

registration and documentation of identifiers needed for the operation of

the Internet Protocol Suite.

MCI WorldCom believes that any organization set up to perform these vital

functions must be international in character, in the private and

non-profit sector, and plainly mindful of the interests of the widest

range of

parties interested in the well-being and continued smooth operation of the

global Internet. MCI WorldCom has participated in many of the discussions

concerning this matter and, as a major supplier of Internet services,

believes that the transition to this new administrative organization must

be undertaken with considerable care to maintain the healthy operation of

the Internet during the period of organizational change.

MCI WorldCom believes that the proposal for the establishment of the

Internet Corporation for Assigned Names and Numbers (ICANN) submitted of

behalf of the existing IANA on October 2, 1998, in its fifth draft form,

represents the most workable plan for the new administrative organization.

Although we

believe that improvements could be made in some provisions in the proposed

By-Laws, perhaps as instruments executed by the Board of Directors for

the new organization, it is MCI WorldCom's position that this proposal

enjoys the support of the vast majority of affected parties and would

serve these

many stakeholders and the users of the Internet better than any

alternative proposed thus far.

MCI WorldCom has already made commitments to support the new organization

in all ways it deems reasonable, including short-term financial support if

this is needed, and encourages all other interested parties to join with

many others in the Internet Community who have expressed similar support.

Together, we can assure the survival and continued healthy growth of the

Internet on a global basis.

Sincerely,

Vinton G. Cerf

Senior Vice President

Internet Architecture & Technology

MCI WorldCom, Inc.

CC: Karen Rose

####