From: <>
To: <>
Date: Fri, Jul 7, 2006 4:30 PM
Subject: Our comment on DNS Transition

Ms. Fiona Alexander,
Office of International Affairs,
National Telecommunications and Information Administration,

Subject: Docket No. 060519136-6136-01

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

7 July 2006

Thank you for providing us with the opportunity to submit our
comment on a very important issue for the Internet. As a member of
the so-called Internet Community, we have long been supporting concept
of private sector approach for the technical coordination and
management of the Internet DNS. In a word, we understand the ICANN as
the only competent entity, at the moment, to assume this role, hence
we sincerely hope that the US government will eventually transit the
role to ICANN upon its full corporate maturity. In the following, we
explain some of our thinking backing this idea, instead of responding
to individual questions posed in the docket.

(a) Stability, competition, private sector bottom-up coordination and
representation of all Internet stakeholders with their diverse
interests are vital principles for the development of the Internet.
ICANN has achieved significant work in these themes.

(b) Evolution of the Internet heavily depends on the single
authoritative root DNS zone maintained so far by private sector
initiative. ICANN has been playing key role in assuring uniqueness of
the root zone since its foundation.

(c) Although dialogue with governments is somewhat different scope
from private sector initiative, it is important for the real world
solution. ICANN seems to be very flexible in this regard, and
gradually succeeding in this direction.

(d) Establishment of formal relationship between ICANN and the root
server operators is yet to be done, but ICANN is making considerable
effort for this, and hopefully completed in the future.

(e) Relationships between ICANN and ccTLDs are significantly improved

These are some of our thinking, and we hope that the US government
will take these points into account in making decision about the MoU.

Respectfully submitted,

Naomasa Maruyama
On behalf of the Board of Trustees, Japan Network Information Center