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Copy of comments...


Enclosed is a copy of my comments, as submitted to the
U.S. government this afternoon in response to the White
Paper review process. I'd intended to include IANA on the
CC line, but obviously slipped up!

				- peterd


Honorable William M. Daley
Secretary of Commerce
c/o Karen Rose
Office of International Affairs 
Room 471
National Telecommunications and
Information Administration
United States Department of Commerce
14th and Constitution Avenue, N.W.
Washington, D.C. 20230

Subject: Management of Internet Names and Addresses - Comments

Dear Secretary Daley:

I am writing to express my comments on the several drafts which have
been submitted in response to the White Paper process.


I am President of Bunyip Information Systems Inc, a Montreal-based
developer of Internet applications and technologies. I have been
involved in the Internet since 1987, when I led the group that
established the first Internet link from the United States to
Eastern Canada. Bunyip was founded in 1991, and since that time the
company has been responsible for Archie(tm), the first automatically
maintained search engine service, as well as a number of other
research firsts. The company today focuses on Internet-based
information publishing solutions.

I have been involved with the IETF, both personally and through
Bunyip, for a number of years and as a company we are committed to
supporting open systems development and standards. Bunyip currently
has no plans to participate in the DNS industry as other than a
user, both for ourselves and our own customers, but believe that a
satisfactory resolution of this process, which successfully
addresses the current perception of instability and uncertainty, is
in the long term interests of all stakeholders of the Internet.

My Involvement with the IFWP Process:

I became personally involved in the White Paper process about four
months ago, when I started tracking the issues being debated in the
public forums established as part of the IFWP initiative. During the
past three months I have attempted to remain neutral during the
sometimes acrimonious debate, while seeking to provide whatever
input I could as an single individual who wished to see a common
consensus position emerge that would be acceptable to the maximum
number of stakeholders. I have done this primarily through the
debates on the "ifwp@lists.interactivehq.org" mailing list, although
I also participated for a short period in the discussions help by the
founders of ORSC, and have had private conversations with a number of
industry stakeholders with whom I have worked in the past.

One of the prime motivations I have had for becoming involved in
this debate has been the belief that there was far more common
ground among the various positions being expressed than was
perceived by the various players most actively engaged in the
process. In particular, I believe that there are many excellent
elements in the ICANN draft prepared by Jon Postel and his staff and
believe that if the levels of mistrust and misunderstanding in Jon's
handling of this dossier (which has been expressed by some players)
could be stripped away, there is in fact a strong basis for a
compromise solution.  Not one that will be acceptable to all
perhaps, but one that would be acceptable to most.

Sadly, I believe that the methodology used by IANA, in particular a
document drafting process in which others were encouraged to submit
suggestions to IANA, but with all drafting being done in private,
was a mistake.  Not because of the quality of the draft developed,
but because I believe it was an inappropriate mechanism for building
consensus and acceptance among those players who had already
developed a serious level of distrust in Mr. Postel's political
processes and abilities. 

As I expressed it in another context on the IFWP list, it's not just
what you do, but what you are perceived to do that matters in a
political context and in this case Mr. Postel's actions were
perceived by some as inappropriate. This has been enough to cause
considerable resistance to ideas which, if presented in an
alternative forum, would have been acceptable to a far wider

Note, this comment is not meant as a criticism of Jon Postel, whom I
hold in high regard for his distinguished contributions to building
the Internet infrastructure, nor for his draft, for which I have
expressed admiration as a good starting point in seeking a final
resolution.  It is intended to underline what I feel is still the
single biggest problem facing the stakeholders in this process, and
in particular your department, as it seeks to reach a final consensus
and resolution.

In my opinion, the heat of the debating process has interfered with
the needed analysis of the IANA draft.  If we are to ensure the
needed stability for future administration of the Internet, the final
resolution process needs to have a certain amount of effort expended
to address this yawning gap in perceptions.

The Role of BWG in Building Bridges:

Although not a participant, I was very encouraged to see the outcome
of the so-called Boston Working Group meeting. This group took as a
starting point IANA's draft, and proposed what I feel are a number
of significant improvements. In particular I welcomed the addition
of a Statement of Principles and changes to the role of SOs. I was
particularly concerned about this aspect of the IANA draft as it
left the new organization open to the perception that it might be
hijacked by industry interests. I strongly endorse the BWG's efforts
to extend the IANA draft in constructive ways and believe their
strong focus on the role of individuals in the process is a key
element in reestablishing the trust needed to make this process

I would encourage your department to consider mechanisms to
successfully merge the BWG changes and the original IANA draft while
addressing the perception that the decision to do so would be
something left in the hands of Jon Postel. I believe if this
misperception is successfully addressed, a successful final outcome
would be assured. I also believe that doing so would address several
real shortcomings in the IANA draft. This is a case where perception
should be brought into line with reality.

I also wish to commend the BWG team for not responding to Jon
Postel's creation of a registered corporation by rushing to create
their own organization as part of a "complete offering". To have
presented the government with multiple fully functional organizations
is, in my mind, a distraction from the high level of commonality
without adding particular value, since the government has not
indicated any clear legal reasons or guidelines as to the most
appropriate form such an organization should take (as but one
example, there has been considerable debate over the merits of
California versus Delaware law on this issue. It behooves the
government to clarify its own requirements, if any, in this area
rather than simply using the existence of one of more corporate
shells to resolve this debate).

The ORSC Proposal:

I have taken note of the proposal submitted by ORSC, as yet another
set of changes which seek to build upon both the IANA and BWG
drafts. I regard some of their changes as significant improvements
and, in so far as their proposal exists as additional extensions to
the BWG document, I welcome it. Their draft document deserves to be
considered by any final merging and resolution process.

I was somewhat dismayed when I realized that ORSC, in addition to
preparing changes to the IANA/BWG collection of text, also took
steps to register its Bylaws as part of an existing corporation
which that the organization had originally prepared as part of its
own efforts to develop ORSC as an industry support organization. I
believed this to be unwise both for the perception it might leave
other players as to ORSC's intent, and because of the effect on the
process this might have if the U.S. government were to interpret the
situation today as forcing it to choose between one of several
competing proposals.

In reading the three proposals, it is clear that there is far more
common ground than there are areas of difference, although such
differences do exist. I strongly urge you to consider steering this
process towards a final, merging phase in which these three
proposals are considered as input, but with the overall selection
and dispute resolution mechanism not left in the hands of the
authors of the potentially competing proposals. To do so would be to
invite a continuation of the acrimonious debate, with little
prospect of a successful resolution.

The Ronda Hauben Proposal:

I have given some study to the proposal submitted by Ronda Hauben,
although I admit that not to the level of attention I have devoted
to the others. This is because it became clear, upon first reading,
that this document is a significant departure from the approach
taken by the others, calling for additional study and work before a
final draft could even be contemplated.

I believe that the White Paper process has already consumed far too
many resources to be reset in the way proposed and would encourage
its author to join into the final consensus-building process needed
to merge the IANA, BWG and ORSC drafts. Any other course of action
is, in my opinion, unacceptable given the history and potential for
future conflict that such an approach would likely engender.


I would like to commend the U.S. government for its efforts to bring
successful self-regulation to the Internet, in a process which by
necessity required the forging of new ground in both
consensus-building and process development (for example, in your
successful used of Internet technologies for both soliciting input
and distributing information).

I would also caution the government not to listen to nay-saying
which, at this late date, might decry the current state of play.  A
study of the three major drafts indicates that a successful merging
is possible, even though there is still considerable ill-will and
distrust still in evidence among some players.

In my opinion, what will be important for this final round is the
creation of a perception of a level playing field, and a clear
indication of the government's continued commitment to open
processes. With that, and drawing on my own experience with the
various players, in some cases dating back a number of years, I am
confident that the foundation for a successful outcome have been


Peter Deutsch,

Contact Information:

		email: peterd@bunyip.com

		Bunyip Information Systems Inc.,
		310 St-Catherine St. West,
		suite 300,
		Montreal, Quebec,
		CANADA   H2X 2A1.

		phone: (514) 875-8611
		Fax:   (514) 875-8134

     Peter Deutsch,                                 (514) 875-8611  (phone)
  Bunyip Information Systems Inc.                   (514) 875-8134  (fax)
    <peterd@bunyip.com>                             http://www.bunyip.com

   "The right of belligerents to adopt means of injuring the enemy is
    not unlimited"
                      Hague Convention (IV) respecting the Laws and Customs
                      of War on Land, Annex to the Convention, 1907.

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