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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

Dear Mr Daley,

BitoS choose not to support the fifth IANA draft of the ICANN proposal in
its current make. BitoS seek some more changes before BitoS can leave its
full support to ICANN, however BitoS want to acknowledge the great efforts
from IANA in writing the draft.

Background of BitoS

BitoS ( http://www.bitos.org/ ) has in 6 months time become a broad
organization of interest for Swedish players such as portals, on-line
newspapers, service providers and others that see the need for new
services (Content Providing and Media Distributing) for a trusted Internet
infastructure and the need for consensus between traditional players,
copyright owners and holders and Media Distributors and Service Providers.

BitoS has working groups in such as Copyright, Ethics, E-commerce,
Marketing and Internet infrastructure.

BitoS has with great interest followed the formation of the new
organization that would manage and assign domain names, addresses, and
identifiers. BitoS has, through its members, observed the IFWP process,
but has not until now actively, as an organization, participated in the
formation of the new organization.


BitoS has studied the proposed fifth IANA draft of Articles and Bylaws of
ICANN (working name) and has the following concerns:

1. First BitoS would like to thank the IFWP Steering Committee for their
great efforts with the IFWP process.

2. BitoS is very positive that the U.S. government try to obtain
self-regulation of the Internet. BitoS fully supports the thought of
self-regulation of this matter.

3. BitoS support that the technical work of the new corporation will be
built out from the existing IANA technical team built by the efforts of
recently deceased Dr Jon Postel.

4. It is not clear how the board of directors will be composed. BitoS
promote a solution where the board of directors is composed on the
following grounds:
+ geographical diversity (no single nation should be able to gain more
than 33 percent of the votes on the board)
+ organizational diversity (no stakeholder should be able to, in any way,
gain a majority of the votes on the board)
+ accontability (some sanctions should be triggered against any board
which do not work in the coherence of their assignment, the sanctions
could be political as well as judicial)
+ transparancy (minutes and decisions of the board of directors should be
available to the public)
+ organizational freedom (when appointed to the board of directors, no one
board member should be an officer of the organization which appointed him
or her - an optional solution is that any organizational connections are
brought out in the open).

5. BitoS would like the U.S. government to consider the possibilities of
incorporation of ICANN anywhere in the world including Europe.

On the behalf of BitoS workinggroup for Internet infrastructure,

Mikael Pawlo

Stockholm, Sweden, the 18th of October 1998

Att: Mikael Pawlo
Box 5275
S-102 46 Stockholm



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