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Comments on Kent Crispin's DNSO details

October 22, 1998

TO: Ira Magaziner
Senior Adviser to the President,
Policy Development
Old Executive Office Building,
Room 216
1700 Pennsylvania Avenue
Washington, D.C. 20502

CC: Honorable Mr. Pickering, Subcommittee on Basic Research; Hon. Mr. Bliley,
House Commerce Committee;  Hon. Mr. Daley, National Telecommunications and
Information Administration; Hon. E.B. Johnson; Mr. Joe Sims, Attorney,
ICANN, & Mr. Schorr, University of Southern California's Information
Sciences Institute

FROM: Stephen J. Page, Individual Respondee to DNSpolicy@NTIA.DOC.GOV;
Participant, Open Root Server Consortium (ORSC), Independent Researcher,
Network Systems, Pleasanton, California, US, representing Internet
.a(sm)-.z(sm) Name Registry, T: 925-454-8624 email: usdh@ccnet.com, and
Developer, the i(r).com(sm) network access, connectivity and content service
to the global community of i(r)ndividuals, email: ichannel@home.com

RE:Comments on Kent Crispin's (employee of Lawrence Livermore National
Laboratory) pertaining to the self-organizing process of building a Federal
Reserve-like network systems management structure for commercializing
Internet assets (Treasures), October 22, 1998, and why the DNSO is clearly
organized to be a special interest group with massive future power to
"sell-out" the rights and freedoms of individuals, violating the principles
of "symmetry", "balance", and "protections of rights and freedoms" evident
in Nature, proven in mathematics (June 4, 1998 isssue Nature magazine).

To Mr. Magaziner, and all interested parties in scalable network systems
management design,

        My comments follow Kent's comments

1) The roles of the "Names Council" and the "DNSO" described in the
ICANN draft are actually just exactly the reverse of what most people
think them to be.  The NC is a large, open membership body whose sole
function is to provide advice.  It's membership may include individuals
as well as organizations.  It has *no* direct policy making role.
It is analogous to PAB, in that regard.

The DNSO, OTOH, is the actual policy making body.  It is also a
membership organization, but the membership is limited to

        As described, the DNSO is a policy-making function, which is also a
membership organization, and because of that duality, it is nothing more
than a lobbying group for the special interests of the members, which is
guaranteed to be exclusive by its limitations to organizations.
        Acting on behalf of the executive branch of  U.S. government
through the Executive Office of the President, one would hope that there
would be greater sensitivity to the perception of impropriety which results
from operating in such a manner.
        International fundraising efforts, by both Republican and
Democratic parties, seeking financing from international parties or private
or special interest groups, have shown that people are willing to pay
hundreds of thousands of dollars for access to the White House through the
"coffees" or access to Congress through "weekend getaways" (See Bill
Moyers' documentary "The Other Scandal")
        Similarly, through the actions of the participants at the DNSO
meeting, people are willing to go to great lengths to quickly set up an
exclusive system where their interests, bought and paid for in a
multi-level funding "deal" with ISI's IANA/ICANN.  In each case, the
individual citizen's interests, which have been protected under the
Constitution, are DILUTED or polluted by the interests of greed exerted
through the quickly structured flow of money.

Special mention is made of  registries and registrars,
but other interested organizations may also join.  The DNSO is
expected to provide funding to ICANN, so the membership fees could be

        Not everything worth valuing and worthy of being involved in the
DNSO is able to pay hefty membership fees, so the membership fee is a
"barrier to entry" which is insurmountable for some important viewpoints.
This is a structural flaw in the DNSO if only those with a huge economic
stake and financial ability can be represented in this policy-making.  This
mistake is apparently being repeated again.
        Having witnessed first-hand, the mistakes which were made by
CommerceNet Consortium which was funded by DARPA in 1994, as the project
manager of an ARPA-funded network architecture project, the attempt to
create exclusivity is what made CommerceNet virtually irrelevant in time,
because they used their membership structure to bar smaller players from
participating at the outset.  Their barriers to entry were too high, their
policy-making organizations were too greedy and ambitious, and a small
company called Mosaic Communications came along and stole their thunder.
(Mosaic is now Netscape.)

Most people (including me, originally) assume that the Names Council
is sort of an executive council of the DNSO, but that is most
emphatically not the case -- we asked.  This is all spelled out in
detail in the ICANN bylaws, but the language is somewhat opaque.

        To use the ICANN Bylaws as the final word is misleading.  These
Bylaws were created with little input, no oversight, and a narrow viewpoint
which can be shown to be in violation of the mathematical proof of how
network systems work over time.  The ICANN "vision" and its Bylaws
structure, will not scale over time, precisely because they are not
harmonized to the Universal Network Systems Law(c).  The Bylaws need to be
more harmonious with the mathematics of network systems, which is why
ORSC's Bylaws (or BWG's) are preferred in the long run.


3) There will be only one DNSO.  Whether it is a committee within
ICANN, or a separate organization, or even a separate corporation,
there is just one DNSO.  One can imagine hypothetical organizational
structures with multiple DNSOs, but it isn't going to happen.
Therefore, all interested parties have to get together to form one.

        The fact that ICANN specifies just one DNSO, and DNSO is a special
interest group with a hefty membership fee, means that ICANN is shaping up
to be something familiar, without the protections, a "Fifth Branch of
Government" similar to the Federal Reserve System, which is commonly
referred to as the "Fourth Branch of Government".
        ICANN, (the Federal Reserve System) is going to only have one group
of exclusive banks which will distribute policy to the Internet (the DNSO
represents the equivalent of the Federal Reserve Banks).  Since Dr. Postel
was to play the role of Mr. Greenspan, and now he's gone, where is the body
of oversight which insures that the new system will be accountable to
People?  Who appointed the Board?  Where was the oversight?  Did the U.S.
government put in place any protections for U.S. citizens?  (If not, our
rights were diluted.)  The Fed does influence world economic policy, and it
does so in a way which ripples worldwide.
        Since domain names are language elements, what's missing is the
trans-national organization for names which is structured like the Group of
Seven (nations) with which Mr. Greenspan and other U.S. federal financial
representatives confer, which I would suggest would be the Group of Seven
of the world's most widely used Western language experts (due to the
character limitations of the DNS system).  This group would be comprised of
American English, British English, German, French, Spanish, Italian,
        A Federal Open Markets Committee, (FOMC) equivalent could be
structured to insure that open market principles which are harmonious with
the Universal Network Systems Law(c) are applied to all activities which
are related to the full use of the language-assets (domain names) and
mathematical-assets (IP numbers) which are the "treasures" which are best
protected under an asset-trust structure similar to the Presidio Trust (San
Francisco), which is subject to Congressional oversight, not operational

4) One way or another, ICANN will be in operation soon.  There are
only a very few entities with any reason at all to delay formation of
the DNSO, and sentiment at the Barcelona meeting was almost
unanimously in favor of moving as quickly as possible.  No one wanted
to start the new year without the DNSO being formed.

        It is no surprise that the sentiment is in favor of moving as
quickly as possible.  It is not every day that one is able to move with no
oversight, with a green light from the U.S. government, which is proceeding
to dilute the rights and protections of citizens, without insuring that the
jewel-like treasures (language assets, domain names, and mathematical
assets, IP numbers) are not protected for scalable use by future
        As you have so clearly shown, the DNSO which met is a special
interest group, which is about to make the same mistakes which CommerceNet
made.   Fortunately for consumers, CommerceNet was not the only game in
town.  Unfortunately for everyone now, the ICANN system IS the only game in
town, there are no alternatives, so it is much more important that the
organizational system is allowed to be inclusive of all (not limited to
special interests).

5) As to whether POC/PAB/CORE want to take over the DNSO -- it doesn't
matter what they might want to do, because it isn't possible.  The
other constituencies involved all have strong points of view, and in
fact, if you look at the meeting notes you will see that the ccTLDs,
in the person of Bernard T., appear to be trying to take over the
DNSO.  But they can't take it over, either, for reasons that are
obvious to anyone with half an ounce of political realism in their

        Again, it is being made very clear what is happening.  At the
asset-core, there is no place for politics, but here it is right before our
eyes, takeover attempts by the ccTLD faction, of the DNSO.  The ICANN (the
Fed) has been incorporated for two weeks and already one of the factions of
the DNSO (Federal Reserve Banks) are already mounting a coup.


Stephen J. Page

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