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[ga] CDT Letter on .org
Members of the General Assembly,
CDT has just sent an open letter to the ICANN Board regarding the
.org redelegation process. I'm attaching it here for your review;
comments and responses are very welcome!
Best,
Rob Courtney
* * *
Vint Cerf
Chairman
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601
August 30, 2002
Dear Dr. Cerf,
As one of the Internet's most successful domains, .org's redelegation
will implicate millions of registrants and affect the core of the
Internet's non-commercial community. We commend the hard work done by
many to date, and we view the recently-published staff report as a
useful document for the Board's consideration. We therefore offer
this open letter to you and the Board, urging that the broad
interests of the non-commercial community be kept in mind as the
staff report is finalized and the redelegation decision is taken.
*Finding the Right Priorities in .org Bidder Evalution*
The .org domain has always benefited from its unique position as a
home for non-commercial activity amid the Internet's many commercial
enterprises. CDT appreciates the Board's request to the
Non-Commercial Constituency for a report evaluating the eleven
registry applicants on certain criteria - largely touching on the
.org registry's relationship with the non-commercial community - and
note that report's excellent evaluation of the applicants on those
criteria.
However, the final impact of the .org redelegation on the
non-commercial Internet community will extend from all aspects of the
registry's operation, not just its administrative structure or
advisory practices. As many in the ICANN community know, technical
capability, financial stability, and competency in customer service
are critical considerations. For many, perhaps most, non-commercial
domain name holders, these concerns come first and foremost. As such,
we wish to underscore the following metrics and priorities for the
evaluation of .org applicants:
* The .org registry must exist on a strong technical
foundation. Redelegation cannot be considered a success if names do
not resolve quickly, accurately, and reliably. Any other benefits
that non-commercial organizations would receive from the new registry
would have little value if this basic technical mission is not
fulfilled. Registry applications should offer ample evidence of their
technical plans' robustness, scalability, adaptability, and, above
all, workability.
* The .org registry operator should have a workable financial
model. The eleven applications before ICANN encompass a wide variety
of approaches to funding the registry's operation. Even a cursory
review of the domain names market will reveal that operating a major
registry is a non-trivial undertaking; it is unlikely that every one
of the eleven proposed approaches will succeed. A bankrupt registry
operator will not be able to fulfill the registry's basic technical
requirements, and the non-commercial community should make
identification of workable financial models a high priority. The new
registry will have a very short start-up time, and must be able to
demonstrate its ability to be financially and technically stable on
January 1, 2003. Several bidders have also expressed their intention
to apply for the $5 million endowment offered by VeriSign to a
non-profit registry operator. It is not yet clear whether all those
bidders will qualify for the endowment, nor when or how the money
will be paid out. Registry applicants' positions would be enhanced by
publishing their plans in the event that the money is not immediately
forthcoming.
* The .org registry requires rapid, effective customer
support. Although the .org registry operator will not be involved in
the retail sale of domain names, high-quality support for .org
registrars will bring benefits to the .org registrant community as
well. The ability of .org registrants to have their problems resolved
and maintenance performed quickly and effectively would be a major
benefit for the non-commercial Internet community.
* The .org registry operator's activities at ICANN should
reflect its registrants' unique interests. As on of the world's five
largest registries, .org constitutes a major slice of the
international domain name community. Its operator will have
significant influence in the gTLD Constituency (and any successor
body) and in ICANN as a whole. The direction in which that authority
is exercised are of great interest to registrants in .org. Registry
applicants' plans for supporting registrants' interests at ICANN are
a key aspect of their applications.
* When the registry operator addresses questions of registry
policy, consultation with the registrant community should be a
priority. Historically, the ICANN Board has assumed authority over
questions of gTLD policy. Where the registry operator has sole
discretion over a policy decision affecting registrants, however, it
should be prepared to make such a decision only after substantial
consultation with the registrant community. Structures of outreach,
input, and advice should be outlined ahead of time.
* Applicants' creativity in posing new ways to support and
expand the non-commercial community's use of .org should be
recognized. The eleven applications have shown an impressive
diversity of proposals for using .org to bring new benefits to the
Internet's non-commercial community, providing a valuable indicator
of the registry's potential. Such creativity should be acknowledged
both by the Board and the community, and any ideas that cannot be
implemented in the new .org should certainly be remembered for the
future.
Finally, as the Board approaches its decision on the .org
redelegation, it is of paramount importance that it continues to
employ open, transparent, and objective decision-making processes.
Such a key decision should not be tarnished by appearances of
arbitrariness, and a strong commitment to openness can prevent such
misconceptions.
CDT hopes the Board and the entire ICANN community will keep these
priorities in mind as they continue their review of the staff report
and the eleven applications. It is our continued belief that only
applications achieving excellence in all of these areas would
adequately serve the non-commercial Internet community.
We look forward to the Board's progress on this important issue.
Sincerely,
Alan Davidson
Associate Director
Center for Democracy & Technology
Rob Courtney
Policy Analyst
Center for Democracy & Technology
cc: ICANN Board of Directors
--
Rob Courtney
Policy Analyst
Center for Democracy & Technology
1634 Eye Street NW, Suite 1100
Washington, DC 20006
202 637 9800
fax 202 637 0968
rob@cdt.org
http://www.cdt.org/
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