Re: [wg-c] Commission Working paper on the creation of .EU

["A.M. Rutkowski" <amr@netmagic.com>]

At 05:05 AM 2/3/00 , Keith Gymer wrote:
>The European Commission Working paper on the creation of the .EU Internet
>top level domain, dated 2nd February, 2000 is available at:
>http://europa.eu.int/comm/dg13/index.htm

Hi Keith,

The questions are those expected.  However,
it's the surrounding text and footnotes
that may raise some concerns - especially
for the DNSO which one would expect to be
an essential part of this process.

1. The central proposition of the paper is
that "...the corresponding [ccTLD] code is
a form of unambiguous identification and location
of the activity." The term "activity" is not
explained.  This proposition constitutes the
primary underpinning for the EU domain proposal,
which asserts that this is desirable "...to
ensure the appropriate degree of adherence
to European law and policies...."

Is it appropriate or even feasible for
DNS registration to constitute a form of
authentication as the fundamental basis
for the application of European law?

2. The paper contradicts itself. It states
in Sec. 5 that "this principle [that there
should be a tangible relationship between the
principle location of the entity concerned
and the territorial scope of the ccTLD
registry] is respected in practice by all
national ccTLD Registries within the EU."

This is a patently untrue. Four member countries
Austria, Denmark, Luxumbourg, and the United
Kingdom do not respect this practice. These
four ccTLDs encompass 36% of all the EU
ccTLD domains (i.e., SOAs) and 28% of all
the EU ccTLD hosts as of the RIPE NCC
18 Jan 00 data.

The paper obliquely concedes this fact
in footnote 2 by asserting that these four
member country ccTLD registries may not
be in conformance with European Law and
are "under consideration [i.e., being
investigated] by the Commission."  Is
anyone aware of this investigation?

3. The most interesting assertion in the
paper is found in footnote 19, to the effect
that "ICANN will require in future [sic]
that the operators of Internet web pages
can be located through the DNS registration
system."  Is anyone aware of such
contemplated action?

4. Another assertion is that "...the
DNS has not been expanded or developed
consistent with [Internet] growth."
Although clearly there could be more new
TLDs, is anyone aware that there is a
cap on DNS zone files? :-)

5. The CEC has also now asserts that "this
[COM] domain ...is in practice predominantly
North American."  All of the CEC's public
arguments for various sorts of actions
taken against the administration of the COM
domain were based on the CEC's assertion
that the domain was intrinsically global.

6. The Paper makes no mention that this same
proposal was expressly a part of the CEC Green
Paper on Numbering released 20 Nov 1996, but
not pursued for the past 3 1/2 years.  Then
the principal CEC issue was harmonization
with their X400 domain name system.

--tony