[comments-dotorg] Comments from ACM-IGP
Comments of the Association for Computing Machinery's Internet Governance Project To the Names Council's Dot ORG Task Force Report The Association for Computing Machinery's Internet Governance Project (ACM-IGP) wishes to express its strong support for the comments of the NC Dot ORG Task Force, and its Report placed on public notice on January 18 ("Report"). In our comments below, ACM-IGP will first express some general concerns regarding the future of .ORG, and then comment directly on sections of the Report. General Concerns: Overall, ACM-IGP is very concerned that the .ORG space will be restricted as it is spun off to new technical and policy management. Unlike any other gTLD delegation to date, .ORG is not a new creation. It is an existing community; it is a valued noncommercial space. Whatever the initial intentions of the National Science Foundation in creating .ORG two decades ago, it has exceeded all expectations and bounds. Dot-ORG is the place for political and personal commentary, community organizing and family pages, as well as important organizational communication. Dot-ORG is the place for organizational communication online on the Internet, but organizational communication is not done solely by organizations. It is the communication of communities, families, schools, libraries, unincorporated associations, and formal organizations. The .ORG domain name space offers an opportunity for online participation by the most diverse group online. There is rumored to be a move to restrict .ORG to perhaps even its most narrow definition, e.g., to allow only organizations to register .ORG domain names in the future. Such a restriction on .ORG would disenfranchise entire classes of communication online. Where .COM, .NET, .BIZ and .INFO are top level domains open for general commercial domain name registration; .ORG is the only top level domain open for general noncommercial domain name registration. To assign new management for the purpose of breaking up Verisign's monopoly is a fine idea; to establish new rules that excommunicate entire classes of noncommercial communication is not. Specific Comments on Task Force Report: ACM-IGP agrees generally with the full report. We thank the Task Force for all its hard work, and the Names Council for its support of this work. We note the particular importance of the following sections: A. "[A]pplicant organizations should be able to demonstrate international support and participation from a significant number of noncommercial .org registrants." [Report, Section 1a] As discussed above, the .ORG delegation involves an existing, diverse and robust domain name space. It would not make sense for one organization (however international) or one region to dominate or win exclusive management of .ORG. An international coalition of noncommercial organizations from many countries and regions will reflect existing .ORG registrations and move forward to lay the foundation and set the policies for positive further growth of .ORG for the benefit of their countries and regions. B. "The definition of the relevant community should be much broader than simply formal nonprofit organizations. It must also include individuals and groups seeking an outlet for noncommercial expression and information exchange, unincorporated cultural, educational and political organizations, and business partnership with non-profits and community groups for social initiatives." [Report, Section 2a.] The words above were carefully chosen, and provide the core of what ICANN must protect, preserve and expand. They should be adopted in their entirety in the final ICANN proposals. C. "Dot org will continue to be operated without eligibility requirements... the registrars should rely entirely on end-user choice to determine who registers in .org." [Report, Section 2b] The Noncommercial Community has proven itself. In overwhelming numbers, it flocks to .ORG to register its domain names. It is a successful example of self-selection in the domain name space. But the Task Force Report goes a step further. It asks ICANN to require that the new registry adopt a "definition of the served community" and put into place "appropriate marketing practices" [Report, Section 2b]. We have seen that even with the inappropriate marketing practices of today (encouraging companies to register commercial domain names in .ORG), companies disdain .ORG, and the Noncommercial Community overwhelmingly register in it. Self-selection will only become better as the new registry (under the Report's proposals) actively markets to the Noncommercial Community. Conclusion: Again, our support for the Report runs to all its points and proposals. Our thanks again to the Task Force, to its chairman, and to the Names Council. We urge the ICANN Board to adopt the principles and recommendations of the DNSO in this Report. Respectfully submitted, Kathryn A. Kleiman Director, ACM-IGP |