Comments Received 10-06-98

From: "Hal Lubsen" <hlubsen@altronics.com>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/6/98 7:18pm
Subject: Support for ICANN
 

COMMENTS ON

Proposal for the Internet Corporation for Assigned Names and Numbers (ICANN)

I would like to take this opportunity to express my support for the proposal from IANA to form a non profit corporation to help administer important segments of the internet.

I believe ICANN is the result of a long process with impute from hundreds of deferent parties. Although to me it is not 100% perfect on balance it does represents the  best solution for the internet.

I hope that the process moves forward in a timely manner so that responsible change will occur.
 

Regards,
 

Hal Lubsen
Altronics, Inc.
iDomains, Inc.

###

From: Mark Luker <mluker@educause.edu>
To: "'dnspolicy@ntia.doc.gov'" <dnspolicy@ntia.doc.gov...
Date: 10/6/98 2:46pm
Subject: EDUCAUSE Endorsement of ICANN

October 5, 1998

EDUCAUSE Endorsement of the formation of the Internet Corporation for Assigned Names and Numbers (ICANN)

EDUCAUSE, an association of more than 1500 American colleges and universities, strongly endorses the formation of the Internet Corporation for Assigned Names and Numbers.  We believe that the legal documents under which ICANN has been incorporated fulfill the principles and intent of the White Paper issued by the U.S. Government in May, 1998 and form an effective basis on which the U.S. Government, the Network Solutions Corporation (a U.S. Government contractor), the Information Sciences Institute of the University of Southern California (a U.S. Government contractor), and other interested parties may transfer and transition to private sector management the core technical and administrative functions of the Internet set forth in the White Paper.

Faculty, researchers, students and staff at EDUCAUSE member institutions have participated actively in the development of the Internet since its inception more than twenty-five years ago. Much of the original research and applied development of Internet technology has been accomplished on American university campuses. These schools currently own and operate more than four million directly connected Internet hosts in the .edu domain. As major Internet stakeholders, our members are committed to the principles of the White Paper and we will support ICANN's startup and continuing role in Internet management as fully as possible.
 

Brian L. Hawkins, President

Mark Luker, Vice President
 

Mark Luker, VP EDUCAUSE; Suite 600, 1112 16th St. NW; Wash DC 20036
202-872-4200 x 5351; 202-872-4318 fax; mluker@educause.edu

###

From: <silvana@cabase.satlink.net>
To: NTIA.NTIAHQ(dnspolicy),NTIADC40.SMTP40("silvana@ca...
Date: 10/6/98 6:30pm
Subject: IANA PROPOSAL

Ref.: IANA PROPOSAL

On Friday evening we received a copy of a presentation from Jon  Postel, addressed to the Secretary of Commerce, William M. Daley, and  titled "Re:Management of Internet Names and Addresses."

This document contains a list of nominees to the Interim Board, who  have agreed to serve on the initial board. It does not include any of  the candidates submitted by various entities in Latin America.

Throughout the process known as the IFWP, CABASE actively  participated in the Steering Committee, convinced, as we were, that  the objectives of the White Paper called for worldwide stakeholder  representation in the new entity.

The White Paper clearly states:

"Mechanisms should be established to ensure international  participation in decision making" (Principles for a New Sytem, point  4 - Representation)

and "These incorporators should include  substantial representation from around the world" (Incorporation)

and "It should, however, have a board of directors from around the  world" (Incorporation)

and "...the new corporation should: 1) appoint, on an  interim basis, an initial Board of Directors (an Interim Board)  consisting of individuals representing the functional and geographic  diversity of the Internet Community". (Structure)

These and other statements clearly indicated the will to involve all  regions of the world in this process and in the new entity.

Accordingly CABASE, at it's own risk and expense, undertook the  organization of IFWP-LA&C, the fourth IFWP regional meeting, attended  by 150 delegates, with simultaneous translation in three languages  (English,Spanish,Portuguese), on August 20-21 in Buenos Aires. The  meeting was webcast on the Internet, and the consensus achieved was  widely circulated at that time under the name of Consensus of Buenos  Aires .One of the consensus points called for participation of Latin  America in the Board of Directors (interim and permanent).

As a consequence of this forum, various entities in Latin America  agreed to form ALCI - Asociacion Latinoamerica y del Caribe para  Internet, in order to establish a regional organization that would be  representative of the majority of Internet stakeholders in the  region. This Association is currently in the organizational stage,  and initial members include entities in Brazil, Argentina, Peru,  Uruguay and Mexico. Other entities within the region have been  invited to join this Association.

The list of nominees submitted by Jon Postel, although each candidate  is a highly qualified individual, does not include any representation  of the Latin American region. Actually the proposed nine at large  members of the Interim Board add up as follows:

Europe and the U.S. have seven representatives between them  Asia Pacific have two representatives  Latin America have none

This composition closely follows Article V.6 of the proposed bylaws,  which provide that "no more than one-half of the directors may be  residents of any geographic region". Since this obviously refers to  the "at large" members, it actually means that, for example, both  Europe and the U.S.A. could have four members each, out of the nine,  leaving the rest of the world one seat out of these nine.

The importance of geographical diversity in the composition of the  Interim Board cannot be understated, since:

(a) The proposed bylaws state that the initial board "shall  establish the ongoing composition formula for those Boards following  the Initial Board, and the processes by which members of those Boards  will be selected and removed, by amendement to these Bylaws" (Section  3 b)

(b) They also state that "At large members other than those serving  on the initial Board shall be elected by a process to be determined  by a majority voice of all At Large membersof the Initial Board"  (Section 3b)

(c) The White Paper calls for the Corporation to "direct the  Interim Board to develop policies for the addition of TLDs, and  establish the qualifications for domain name registries and domain  name registrars within the system".

We cannot help but ask, if Latin America has not been taken into  consideration for representation within the Interim Board, why would  such a board consider Latin America for representation in the  permanent board ?

Also, the Interim Board is far from being a passive, merely  administrative supervisor. On the contrary it is called upon to take  important actions and make no less important decisions affecting the  interests of stakeholders all over the world (including Argentina).  Latin America is growing rapidly, there are support problems on  ARIN's side for the region, and conflicts involving trademark  legislation which in Latin America differ from other regions, and,  unless the region is represented on the Interim and subsequent  Boards, we see no guarantee that the structure of the new entity will  facilitate our activities.

Consequently we must state the following:

1) Article V.6 of the proposed bylaws is unacceptable, since,  although it may have been included as a well meaning safeguard, Jon  Postel's Interim Board proposal demonstrates the result of taking  this clause to the limit, and thus limiting geographical  representation to three regions, whereas the same proposal recognizes  the existence of five regions.

2) In view of all the above, we are unable to discover valid  reasons which could justify the exclusion of Latin America from  representation in the Interim Board. If this oversight is not duly  corrected, the conclusion will be that the Interim Board does not  constitute a valid geographical representation.

In summary, CABASE cannot endorse Jon Postel's proposal as it stands  today, since it excludes a whole geographical region from being  represented within the at large members of the Initial Board, and  establishes a clause in the bylaws that guarantees this oversight can  be permanent and legitimate, thus violating the principles stated in  the White Paper.

Regards

Tony Harris
Secretary - CABASE
www.cabase.org.ar
Tel/Fax 54-1-326-0777

###

To: dnspolicy@ntia.doc.gov
From: Simon Higgs <simon@higgs.com>
Date: Mon, 05 Oct 1998 21:10:38 -0700
Subject: Existing TLD Applications To IANA
 

Dear Mr Magaziner,

Please take into consideration the prior efforts that were made by IANA and the private sector to introduce new TLDs prior to 1997. To paraphrase Einar Stefferud - "the US Government owes protection of stakeholder rights to those who developed those rights in the process of following the lead of IANA."

The following draft was submitted to the IAHC committee in December 1996 concerning existing TLD applications, which were acknowledged by Jon Postel of IANA as part of the submissions process. It predicted US Government involvement as a consequence of ignoring this issue:

http://www.iahc.org/contrib/draft-iahc-higgs-tld-app-00.txt

INTERNET-DRAFT Simon Higgs

Catagory: Informational Higgs America

Expires 7/1/1997 December 1996

Existing TLD Applications

<draft-iahc-higgs-tld-app-00.txt>

Status of this Memo

This document is an Internet-Draft. Internet-Drafts are working documents of the Internet Engineering Task Force (IETF), its areas, and its working groups. Note that other groups may also distribute working documents as Internet-Drafts.
 

Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet- Drafts as reference material or to cite them other than as ``work in progress.''

To learn the current status of any Internet-Draft, please check the ``1id-abstracts.txt'' listing contained in the Internet-Drafts Shadow Directories on ftp.is.co.za (Africa), nic.nordu.net (Europe), munnari.oz.au (Pacific Rim), ds.internic.net (US East Coast), or ftp.isi.edu (US West Coast).

Abstract

This document is being distributed to members of the Internet community in order to solicit their reactions to the proposals contained in it.
 

There are many applications for Top Level Domains currently submitted to IANA that have not been processed yet. This document explains why the Internet Ad Hoc Committee (IAHC) must process these applications. This document does not make distinctions between iTLDs, ISO-3166 TLDs, or any other type of TLD since [RFC 1591] clearly states that "the same rules are applied to all requests".

Introduction

In January of 1993, the InterNIC was established as a collaborative project between AT&T, General Atomics and Network Solutions, Inc. and supported by three five-year cooperative agreements with the National Science Foundation. AT&T was to manage the InterNIC Directory and Database Services project; NSI was to manage the Registration Services project, and General Atomics was to manage the Information Services project.

These agreements stipulated that a peer review during the second year of performance would determine the future level of funding. The review found that General Atomics was not providing the promised level of service to the community and recommended that funding be discontinued. NSF agreed with this recommendation and in February of 1995 terminated the cooperative agreement with General Atomics. Steps were taken to minimize the disruption to the research and education community and to continue the services which the panel identified as having significant value.

A key portion of the second year review is as follows:

It is clear from the materials presented by NSI that a primary
culprit in the RS work load is the .COM domain. The current
management of .COM is not scalable since .COM is a flat domain name
space, and thus the load of administering .COM falls solely on NSI.
At present, the management of .COM is paid for by the NSF, and
hence increasing demand for .COM registrations will require
increasing support from the NSF. The panel recommends that NSI
begin charging for .COM domain name registrations, and later charge
for name registrations in all domains. Over the long run, the panel
recommends that NSI charge for all IP registration services.
 

During panel discussions a consensus emerged on a possible charging
model that requests an initial fee for registering a name, and a
recurring annual fee for subsequent administration of the name
space, to cover costs due to updating entries, ensuring uniqueness
of names in the name space, operation of root name servers, etc. It
was noted that the charge for initial registration and recurring
fees did not logically have to be the same amount. However,
charging the same amount would allow NSI to state that everyone,
including those who already have Internet domain names, will have
to pay the same amount within the initial 12 months and this might
prevent a last minute, "get them while they are free" rush on
domain names. NSI should consult with the NSF in the development of
such a policy. The NSF needs to plan mechanisms for defraying the
costs for institutions, such as U.S. R&E sites that would fall
under the .EDU domain, that may not be able to bear the new charges
directly. In the ideal scenario, any new plans should be in the
direction of a fee to the end user of a name, and thus would
facilitate the NSF's getting out of the name registration business.  [http://rs.internic.net/nsf/review/section6.html]

In the summer of 1995, InterNIC Registration Services, run by Network Solutions Inc., introduced a policy whereby it would charge $100 for an initial domain name registration which would then be valid for two years, and would charge $50 per year for each year that a domain name was renewed. This event was pivotal and created a paradym shift in the nature of the internet domain namespace as the InterNIC's registration services, which were no longer funded by the NSF, were now allowed to be run for-profit.

Since this event in 1995, portions of the community feel there is a need for new TLDs (and their supporting registries) other than the ISO-3166 TLDs. Many organizations have, as a result of the interpretation of [RFC 1591] in the light of the internet's new commercial environment, applied to the IANA to be delegated new top level domains. Many feel that they could compete with NSI in providing registration services for domain names, and others feel there is justification in granting new TLDs in order to open up the flat domain namespace and provide competition for what has become a domain name monopoly. Either way, it is clear from the size of the .COM zone file that becoming a domain name registry is a viable business opportunity, and that appears to be driving most of the new TLD applications.

New Top Level Domain Applications

The application process is documented in [RFC 1591], which describes the delegation and use of the existing top level domains COM. EDU, NET, ORG, INT, GOV, MIL, and the ISO-3166 two letter country code domains. It also describes the role of the Internet Assigned Numbers Authority (IANA), which is responsible for the overall coordination and management of the Domain Name System (DNS), and especially the delegation of portions of the name space called top-level domains.

[RFC 1591] states "all requests for new top-level domains must be sent to the Internic (at hostmaster@internic.net)". If approved, these top level domains are added to the root.zone file which is carried by the root DNS servers. The latest root.zone can be found at:

[ftp://rs.internic.net/domain/root.zone.gz]
 

What has caused confusion is the scope in which [RFC 1591] accepts new top level domain name applications. Some have argued that historically only new ISO-3166 TLDs have been granted and that is the entire scope of this RFC. The actual paragraph that is in question is quoted here:

2. The Top Level Structure of the Domain Names

In the Domain Name System (DNS) naming of computers there is a
hierarchy of names. The root of system is unnamed. There are a set
of what are called "top-level domain names" (TLDs). These are the
generic TLDs (EDU, COM, NET, ORG, GOV, MIL, and INT), and the two
letter country codes from ISO-3166. It is extremely unlikely that
any other TLDs will be created.
 

Expectation and reality aren't always the same thing, just like financial projections and earnings aren't the same. Does this paragraph mean that:

a) No new TLDs of any sort will be delegated in the future?
b) Only new ISO-3166 domains will be delegated in the future?
c) There is no perceived need for additonal TLDs at this time?

It is quite apparent that any two letter country codes identified by ISO-3166 could be added at the request of that country's government at any time. It does not say other TLDs will not be created, just that it is unlikely that they will. It was, presumably, left open like this in case there was a future need for other types of TLDs. It certainly does not say that new TLD applications outside of ISO-3166 (such as the majority of new TLD applications currently submitted to IANA), are not valid applications. [RFC 1591] is quite clear on the issue of processing applications for new TLDs:

3) The designated manager must be equitable to all groups in the domain that request domain names.

This means that the same rules are applied to all requests, all
requests must be processed in a non-discriminatory fashion, and
academic and commercial (and other) users are treated on an equal
basis. No bias shall be shown regarding requests that may come
from customers of some other business related to the manager --
e.g., no preferential service for customers of a particular data
network provider. There can be no requirement that a particular
mail system (or other application), protocol, or product be used.

There are no requirements on subdomains of top-level domains
beyond the requirements on higher-level domains themselves. That
is, the requirements in this memo are applied recursively. In
particular, all subdomains shall be allowed to operate their own
domain name servers, providing in them whatever information the
subdomain manager sees fit (as long as it is true and correct).

It quite clearly states that the same rules are applied to all TLD requests. This means that the assumption by some that only ISO-3166 TLDs should be processed is incorrect.

It also says that all requests must be processed in a non-discriminatory fashion, and academic and commercial (and other) users are treated on an equal basis. It is quite clear that every application received by IANA must be processed, and that this (because the requirements are applied recursively), includes all the existing TLD applications received by IANA.

No word has come from IANA as to why these new TLD applications have not been processed. It has however, in conjunction with the Internet Society (ISOC), International Telecommunication Union (ITU), World Intellectual Property Organization (WIPO), International Trademark Association (INTA), and the Internet Architecture Board (IAB), created the International Ad Hoc Committee (IAHC) which will address the legal, administrative, technical and operational concerns, with particular attention to the questions of fairness and functional stability of the domain name space. It is now before this working group that these exisitng TLD applications must wait.

Why The Concern?

There is a trust issue at stake here. The voluntary acceptance of the IETF/RFC authority structure by the internet community has ensured that the domain name space, and the internet as a whole, have not become divided or fragmented. Losing that trust invites organizations to build incompatible standards, alternative DNS root servers, and ultimately issue name space which is incompatible or duplicates the IANA delegated namespace.

Should the existing TLD applications not be processed, and the public trust and confidence in the IETF/RFC authority structure be lost, the repercussions will irrevocably damage IANA, and IAHC and it's participating members ability to manage the namespace. As a result, government intervention and uneccessary regulation and taxation will be forced upon the internet community in order to resolve issues that could quite easily be avoided now with a little diplomacy.

Recommendations Of This Memo

It is the recommendation of this memo, to the IAHC, to process the existing TLD applications that have been filed per RFC1591 with IANA. This memo does not explain how to go about the processing of applications, only that it must be done.

Author's Address

Simon Higgs
Higgs America
P.O. Box 3083
Van Nuys, CA 91407-3083
Phone: 818-899-1875
Fax: 818-890-0677
email: simon@higgs.com
 

This document expires 7/1/1997

Best Regards,

Simon

The bandwidth is out there...

###

From: "Rick H. Wesson" <wessorh@ar.com>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/6/98 7:50pm
Subject: NSI Agreement

NTIA:

I find your agreement with NSI unacceptable.

Your agreement states that NSI must develop the software to run the registration services. This implys that NSI will still host the Shaired Repository. This is unacceptable. NSI has IMHO has no intrest in acually meeting the deadline March 31, 1999 with full implementation by June 1, 1999. It is in their best intrest to not meet this deadline. There is no reprocussion  or non-USG oversignht on their opperation of the Registry.

I am frankly appaled at the amendment to the coperative agreement.

1) it is clear that the IANA/ICANN/NewCo should be managing
a.root-servers.net ASAP. Allowing NSI to continue the management
of the most important root server only allows NSI to strong arm
the masses as they have done for the last 5 years.

2) the timeline for the development of a shared repository
implementation would only be possable if had prior access
to such a code base. It is completely impossable for almost
any organization to develop *the* mission critical application
for the internet in the time frame outlined in the ammended
coperative agreement.

I expect NSI to delay and fail to meet their deadline and
continue profit for their delay. it is in their self intrest
not to make the deadlines, even if it was feasable.
 

3) the protocol for the SRS (shaired registry system) *MUST* be
made in the public domain and should be made available with
out any licenseing fees. NSI should not be allowed to be the
sole licensee of such an important international protocol.
 

4) the USG has not demonstrated tha ability to understand
much less access NSI's ability to preform. The last section
of the agreement gives total controll of the root to the
USG, thus invalidating any simblance of International
oversite.

I find your agreement with NSI completely unacceptable and it is my wish and hope that others will feel the same.

-rick
 

CC: gTLD-MoU Policy Advisory Body <pab@gtld-mou.org>

###

From: Jeff Williams jwkckid1@ix.netcom.com
To: NTIADC40.SMTP40("Valdis.Kletnieks@vt.edu")
Date: 10/5/98 7:50pm
Subject: response

Valdis and all,

Valdis.Kletnieks@vt.edu wrote:

> On Mon, 05 Oct 1998 19:01:17 BST, Jeff Williams said:

> > Attached is a Text Version of our (INEG. INC.) proposals for bylaws

> > for the ICANN. This is an effort determined by some 24,000 different

> > Stakeholders, users, and other interested parties and was arrived at

> > by unanimous vote of all of these groups, individuals, Users, and Stakeholders.

>

> (Apologies for swallowing troll bait.. but.. ;)

>

> The only recorded cases of 24,000 people all voting the same way

> are in totalitarian regimes where you are given a choice between

> putting the check mark where you are told or meeting the wrong end of

> a semi-automatic weapon behind the local polling place.
 

Well now you have another example. Get used to it!
 

Also, there are may other examples in corporate history and well as

World history should you care to do some research.

>

>

> C'mon Jeff. Take any good creative writing class, and they'll

> teach you to at least be *plausible* when writing fiction. Hell,

> even good fantasy writing requires self-consistency.
 
 

No fantasy, just FACT!
 
 

CC: DNS Policy <dnspolicy@ntia.doc.gov>
 

Jeffrey A. Williams

DIR. Internet Network Eng/SR. Java/CORBA Development Eng.

Information Network Eng. Group. INEG. INC.

E-Mail jwkckid1@ix.netcom.com

###

From: Bob Allisat <bob@fcn.net>

To: William Allen Simpson <wsimpson@greendragon.com>

Date: 10/6/98 12:41pm

Subject: SHUNNING: Life Sentance?

William Allen wrote:

> I remind you that we had called for formally shunning Allisat (in

> February) and Williams (in July) in the IETF; for abusive language,

> personal attacks, and excessive cross-posting. Please do not reply

> to Allisat or Williams postings on the IETF list. (I left Williams

> in the CC to help activate the bogon filters.)
 

William, I fully realize you may never get this message but  here goes anyways: I humbly  apologize for any discomfort or difficulties I may have caused you in the past. I have  endeavored to stick to topic and be polite and so on. Is  this shunning a life sentance?  Do I have to share my cell with Mr. Williams? If so I think I prefer solitary.  What can I do to get in your  or the IETF's good books?  What is the procedure to  get unshunned?
 

Thanks in advance for your  or anyone elses kind consider-  ation.
 

Sincerely,
 

Bob Allisat
 

Free Community Network . bob@fcn.net . http://fcn.net
 

CC: IETF ORG <ietf@ietf.org>

###
 

From: <Valdis.Kletnieks@vt.edu>

To: Jeff Williams <jwkckid1@ix.netcom.com>

Date: 10/6/98 1:01am

Subject: Re: INEG. INC. Proposal Bylaws Proposal for the ICANN

On Mon, 05 Oct 1998 19:01:17 BST, Jeff Williams said:

> Attached is a Text Version of our (INEG. INC.) proposals for bylaws

> for the ICANN. This is an effort determined by some 24,000 different

> Stakeholders, users, and other interested parties and was arrived at

> by unanimous vote of all of these groups, individuals, Users, and Stakeholders.

(Apologies for swallowing troll bait.. but.. ;)

The only recorded cases of 24,000 people all voting the same way are in totalitarian regimes where you are given a choice between putting the check mark where you are told or meeting the wrong end of  a semi-automatic weapon behind the local polling place.

C'mon Jeff. Take any good creative writing class, and they'll teach you to at least be *plausible* when writing fiction. Hell, even good fantasy writing requires self-consistency.
 
 

CC: DNS Policy <dnspolicy@ntia.doc.gov>

###
 
 

From: "William Allen Simpson" <wsimpson@greendragon.com>

To: IETF ORG <ietf@ietf.org>

Date: 10/6/98 9:58am

Subject: Re: INEG. INC. Proposal Bylaws Proposal for the ICANN
 

> From: Valdis.Kletnieks@vt.edu

> On Mon, 05 Oct 1998 19:01:17 BST, Jeff Williams said:

> > Attached is a Text Version of our (INEG. INC.) proposals for bylaws

> > for the ICANN. This is an effort determined by some 24,000 different

> > Stakeholders, users, and other interested parties and was arrived at

> > by unanimous vote of all of these groups, individuals, Users, and Stakeholders.

>

> (Apologies for swallowing troll bait.. but.. ;)

>

I remind you that we had called for formally shunning Allisat (in February) and Williams (in July) in the IETF; for abusive language, personal attacks, and excessive cross-posting. Please do not reply to Allisat or Williams postings on the IETF list. (I left Williams in the CC to help activate the bogon filters.)

> The only recorded cases of 24,000 people all voting the same way

> are in totalitarian regimes where you are given a choice between

> putting the check mark where you are told or meeting the wrong end of

> a semi-automatic weapon behind the local polling place.

>

Oh, I'm sure there are other examples. Large corporate entities with formal proxy voting, for example.
 

The surprise is "unanimous". Especially as I consider myself a "Stakeholder", and I was not consulted.

All he has to do is post the names, addresses, and email contacts of all the unanimous voters, so that it can be verified, in the interest of "transparency". Please, not to the IETF list, but I'm sure that NTIA would be happy to record the information for posterity.

WSimpson@UMich.edu

Key fingerprint = 17 40 5E 67 15 6F 31 26 DD 0D B9 9B 6A 15 2C 32
 
 

CC: Jeff Williams <jwkckid1@ix.netcom.com>

###