ICANN wants to "roll the dice" and admits "the benefits of innovation ..... are too 'speculative' to predict"
To add to our prior comment about "moral hazard": http://forum.icann.org/lists/5gtld-guide/msg00006.html which compared ICANN to irresponsible subprime mortgage brokers pushing risky NINJA loans (new TLDs), where the the profits are privatized while the losses are socialized, we read with interest the letter by ICANN to the GAC dated November 23rd at: http://www.icann.org/en/correspondence/dengate-thrush-to-dryden-23nov10-en.pdf We found it very interesting that the discussion of costs vs. benefits on page 3 of the letter were described as follows: "The economist reports to date reflect that the benefits of innovation, or the effectiveness of trademark protection developed by the intellectual property constituencies, are too speculative to predict with accuracy." This is a very telling statement, and demonstrates that ICANN has failed to meet its Affirmation of Commitments obligations to prove that benefits exceed costs when making decisions. As discussed at length in a prior comment: http://forum.icann.org/lists/5gtld-guide/msg00000.html ICANN has not demonstrated *any* rigour whatsoever in presenting empirical evidence and analysis to support its decisions. Indeed, they've done things improperly -- they've come to a decision first, and are grasping at straws trying to find *any* evidence whatsoever to support their decision. They have not even posted summaries or analyses of comments to Phase I of the "Economic Framework" made many months ago, nor published Phase II of the report (which was due 15 business days before Cartagena, a deadline which was not met). The so-called "benefits" of new TLDs are imaginary, whereas the costs are very real indeed. The proper method of an independent and trusted custodian would be to seek out the evidence first, and then come to an informed decision only after the evidence/data is presented. ICANN has put the cart before the horse. Experts like Tim Berners-Lee had warned ICANN that past TLD rollouts were a bad idea: http://www.w3.org/DesignIssues/TLD http://forum.icann.org/lists/competition-pricing-prelim/msg00016.html ICANN ignored this expert advice, and the advice of many other parties. Society suffered the real losses when these TLDs failed to live up to their hype, due to ICANN's poor decisions of the past. The root is too important to be managed by those who would "roll the dice" or actively pursue policies that are purely "speculative" in nature, especially when any gains go to a small number of ICANN insiders whereas the real losses are suffered by the greater public. ICANN's decisions were wrong in the past. Now, like a desperate gambler, they seek to "double down", increasing their bet to make up for past losses. However, they are more than simply "doubling down" -- they want to grow from 20 or so gTLDs to THOUSANDS of them. How would society react if thousands of new telephone area codes were introduced simultaneously in New York State? There would be mass confusion. Any "gains" are illusory, as they are often simply taxes on other parties (e.g. defensive registration costs, or "protection rackets" or generate confusion for consumers, i.e. are simply splitting up a pie, rather than making the pie bigger). ICANN needs to present stronger evidence than simply the "hype" of a few loud ICANN insiders focused on short-term privates gains, especially when the lessons of history (past TLD failures) and the counter-evidence is so compelling AGAINST the introduction of large numbers of new TLDs. The self-serving positions that "this time things will be different", especially coming from parties whose decisions have been proven to be wrong in the past, should not outweigh the strong evidence produced by people who have been proven RIGHT time and time again. Furthermore, even if a handful of new TLDs were introduced, ICANN's plan is *not* optimal for the public. Tender processes for operation of new TLDs for fixed terms at the lowest cost to consumers, as the DOJ/DOC recommended as offering the maximum benefits and lowest prices for consumers, were ignored by ICANN. In conclusion, we call for the GAC, DOC, DOJ and NTIA to make it clear to ICANN that they will not support ICANN's half-baked plans, until such time as the high standards of the Affirmation of Commitments have been met. If ICANN were to proceed, we call upon the DOC, DOJ and NTIA to terminate the IANA contract without delay. ICANN acts like the rogue North Korean government -- seeking private gains through provocation of the broader community. It's time for the GAC, DOC, DOJ and NTIA to compel ICANN to act responsibly, or terminate its relationship in favour of an institution that the public and consumers can trust. Sincerely, George Kirikos http://www.leap.com/