From: Martha/Donna Allen <wifponline@igc.apc.org>

To: NTIA.NTIAHQ(usdomain),NTIADC40.SMTP40("audrie@neta...

Date: 10/4/98 9:07pm

Subject: Public Comments on .us Internet domain

October 4, 1998

Karen Rose

Office of International Affairs, NTIA

Room 4701, U.S. Department of Commerce

14th and Constitution Avenue, N.W.

Washington, DC 20230

Dear Ms. Rose:

I write as President of the Women's Institute for Freedom of the Press whose goal since its founding 27 years ago is to increase communication by women (and by all unheard people) speaking for themselves, to enable them to participate in democracy by having their information heard so it can be taken into account in the nation's decisions.

We are concerned that our equal citizen rights under the First Amendment be protected in the new communications technology. First Amendment rights are citizen rights for the individual (part of the Bill of Rights for individuals), not a corporate property right and should have precedence -- or at the very least, equality -- over any rights granted to corporations for commercial purposes.

The First Amendment prohibits the federal government from adopting any policy or applying any legislated regulation favoring corporations over the individual citizens whose equal political rights the First Amendment was written to protect.

In response to your ".us Request for Comments," we wish to record our support for the handling of these policy issues relating to the .us domain by a U.S. Internet Council, through which the U.S. Internet community can negotiate policy for the .us domain under the jurisdiction of U.S. law and the U.S. Constitution.

Such an Internet Council could separate the policy and technical administration of domain names and protect our free speech equality with commercial speech, and avoid the conflict betwen citizen rights and rights obtained by wealth. We believe this also could provide an example of democracy for the international community.

We support the existence of the Internet Council also because it permits more democratic participation on policy by all citizens and establishes a body accountable to all of us Internet users, and leaves independent the technical overseers of the domain name system.

We support the .us domain being first organized into a small number of second-level domains based on the type of content to be organized. There can be some for commercial content, personal content, and the political speech the First Amendment originally intended. We oppose basing SLDs on geography as in conflict with the universality of the basic citizen right to communicate with equal access to the public at large.

While non-commercial and commercial may have equal protection in the .us domain, no special precedence should be given to trade mark owners in obtaining a domain name. This would violate the democratic concept of equal citizen rights.

The Internet came into being as a personal and political communication tool and should not now have the wealth of commercial companies given preference for buying and selling over citizens' rights to communicate. We need to protect the first-come, first served equality that has made the Internet a citizencommunication right, after over 100 years during which one's access to the public depended on one's wealth, due to the high cost of communications technology.

Preserving the domain name registration equality in fast turnaround is essential to preserving our First Amendment right to freedom of speech.

We strongly support the recommendations of the Domain Name Rights Coalition and urge you to give those recommendations your highest priority. There are as well many other benefits that would derive from the protection of the .us domain, and we feel it is your duty acting on behalf of the federal government to provide this very basic protection. We see you having the opportunity to make a landmark decision and one that will be a turning point for democracy, not only here in America but world wide.

Thank you for taking this historic step for all of us.

Sincerely yours,

Dr. Donna Allen, President

Women's Institute for Freedom of the Press

3306 Ross Place, N.W.

Washington, DC 20008-3332

Phone and Fax: (202) 966-7783

E-Mail: wifponline@igc.apc.org

World Wide Web: http://www.igc.org/wifp/

###