Suggestions for the Internet Corporation for Assigned Names and Numbers

[Joseph Friedman <joseph@usa.net>]

Dear members of the Board of Directors of ICANN,

I'd like to offer some suggestions for an improved Internet Corporation for Assigned Names and Numbers.  I will not be able to attend ICANNs public meeting personally, but I do have some ideas I think would be beneficial to the new organization.  I summarized them below as best I could, and I hope you as well as the rest of the Board of Directors find merit in some or all of these suggestions.  I ask that you share these ideas with the board and with the public in your meetings.


Here are 10 issues I considered:


1) The name of the organization

The name of the organization, currently the Internet Corporation for Assigned Names and Numbers (ICANN), should be renamed to the Internet Assigned Number Authority (IANA).  In his 5th and final iteration of the proposed Articles of Incorporation of the "New IANA" prior to its submittal to the NTIA, Dr. Jon Postel noted that many people commented that the name change from IANA to ICANN in the 4th proposal "has not met with universal acclaim" and that "there is apparently strong sentiment for continuing to use the name Internet Assigned Numbers Authority and the acronym IANA". And he requested additional input from the community.  Shortly afterwards Dr. Postel passed away.  I believe the name of the organization should be IANA, and I don't know of anyone who would have any objections to such a move.


2) The root servers

All the authoritive root servers for the Internet's Domain Name System (currently there are 12 maintained by volunteers, the United States Government, the United States Military, Network Solutions, and the University of Southern California/Information Science Institute) should be under direct custody and maintenance of ICANN.


3) Separation of the root and the SLD

The root (the "dot") should be separated from the Second Level Domain (SLD) servers.  Currently they are both served by the same physical and logical servers.  i.e. the millions of SLDs, ibm.com, uu.net, are in the same servers as the root.  Technically and logically it makes more sense to separate these functions.  Separating them will also relieve millions of SLDs from the root servers.


4) The SLD servers

The Second Level Domain (SLD) servers should also (in my opinion) be under direct custody and maintenance of ICANN.  Currently the SLDs are served by the same servers as the root.  Another option would be to contract out to the best bidder maintenance of these servers.

Currently maintenance of the existing SLD servers are done by Network Solutions (NSI), under contract with the United States.  I do not believe NSI should be the contractor for .COM .NET .ORG and .EDU perpetually.  Eventually these should also be re bid.


5) Annual fees

I do not believe whoever maintains the SLD servers should charge the registrars (or registrants) an annual fee per domain.  There is no annual cost associated with maintenance of a domain in a server.  There may be a cost to adding and modifying information for a domain, so perhaps the charges can be based on adding new domains and modifying existing domains.  (It is even questionable as to the costs involved adding and modifying domains considering that these functions are processed by automated systems.)  The largest and primary cost a registrar incurs, is maintaining the database (which isn't seriously affected by the number of domains it contains) and for customer service requiring manual assistance (which ideally would be minimized).



6) Shared gTLDs

All registrars should be allowed to register domains in all the shared gTLDs (.COM, .ORG, .NET, and the new ones.)  Prices for registration would be negotiated between the registrar and their customers.  Any domain registrant should have the right to transfer their domain from any registrar to any other registrar, in as much as consumers have the right to transfer their local and long distance telecommunications provider as often as they please.  This is fair competition.

The .EDU TLD should be a shared TLD maintaining the current restriction that its limited to registrations by public institutions of higher education.

ICANN should maintain a whois database (at whois.internic.net?) that provides domain and contact information on all the shared gTLDs.  It would also be nice if arrangements can be made with all the ccTLD registrars, the U.S. Government domain registrars (.GOV & .MIL), the .INT registrar, as well as the IP registries (ARIN, RIPE, and APNIC) to share their public whois database with ICANNs as to provide one point-of-contact for a whois database.


7) The InterNIC

The name "InterNIC" (short for the Internet Network Information Center) and the internic.net domain, should not remain in the sole custody of NSI after the completion of the transition.  The term "InterNIC" is not a NSI concept or brand name.  The term was used for the U.S. Government contract awarded to NSI, AT&T, and General Atomics.  All 3 companies have used the term in conjunction with their part of the contract - NSI for registration services, AT&T for directory services, and GA for information services.  It would not be right for NSI to assume sole control for that name and domain.  It should be transferred to ICANN which should use it as an information resource (maintaining the RFCs as is done currently, etc.) and a directory of all the official ICANN registrars.


8) Adding gTLDs

Add as many new gTLDs as possible.  This of course should not be done all at once, but over the course of time. Every short, memorable, generic (3-5 characters?) word, in all major languages, should be added as a new shared gTLD.  i.e. .INFO, .STORE, .HELP, .INC, .CORP, etc.  Any word that is short and memorable would be wanted by many parties and it is only fair that it be a shared gTLD.  I believe there should be 100's even 1000's of new shared gTLDs added to the root.

Note:  There is no technical limitation on the number of TLDs that can be in the root.  This is demonstrated by:

-There are currently about 200 TLDs. (including the gTLDs, ccTLDs, .EDU, .GOV, .MIL, and .INT)
-Dr. Postel, in his original proposal in '96, proposed the creation of 150 new gTLDs.  Who is more of an authority on the technical capabilities than Dr. Postel?
-And most importantly, as I mentioned earlier, currently the root servers also function as the SLD servers which have literally millions of domains.  If the root is capable of maintaining millions of SLDs there is no reason why it couldn't handle millions of TLDs.


9) Adding TLDs

After some time to digest these changes, ICANN should strongly consider allowing anyone or organization to register there own TLD.  For example IBM might register .ibm as a TLD it would use for its internal purposes.  I might register .friedman for myself.  Of course ICANN would likely want to set policies on this i.e. pricing, and perhaps limiting the number of TLD registered to an organization.  This proposal should only be implemented after there are many (1000's?) of shared generic TLDs in the root.


There is no real reason domain names must be in the second level (SLD) or higher.  They can be in the first (root) level as well.  One benefit (certainly not the only) of allowing open registration of TLDs in the root, would be easier, shorter domain names. (i.e. www.ibm and mike@ibm instead of ibm.com.)


10) Trademark disputes

It is my strong belief that domains should continue to be assigned on a first-come first-serve basis, and that ICANN and the registrars should be prohibited by ICANN policy from refusing to assign a domain, taking away a domain, or suspending a domain due to alleged or possible trademark violations.  The only time a domain should be refused or revoked is with a valid court order from a  court with jurisdiction in the place of resident or business of the registrant.  (If someone believes there trademark has been violated by a domain registrant, they shouldn't be able to drag the registrant to a court in a far away jurisdiction, nor should they be able to pick 'n choose a friendly court.)  It is not the business of ICANN or the registrars to determine who has a valid trademark, in what jurisdiction, for what industry, and decide if the another party is using a domain in a manner that legally constitutes a violation of a trademark or whether its considered fair-use, comical-use, !
or whether or not the domain is being used in a manner that confuses consumers with a trademark owner.  There can also be more than one legitimate holder of a trademark in different jurisdictions and/or industries that both have a right to the same trademark.  In such an instance a court would not have any basis to take a domain from one party.  In short, leave the decisions to a court-of-law.  Let them arbitrate as they always have and always will.


Sincerely,
Joseph Friedman


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