VeriSign Comments re. Single Character Name Allocation Framework

["Gomes, Chuck" <cgomes@xxxxxxxxxxxx>]

VeriSign respectfully submits the following comments in response to
ICANN's solicitation for 'Public Comment on Single Character Name
Allocation Framework'.

 

1.      VeriSign supports the goal of using excess funds of any single
character name allocation process for top-level domains for benefit of
the greater Internet community.
2.      As noted in 'Single-Character Second-Level Domain Name (SC SLD)
Allocation Framework' ('Framework Document') as posted by ICANN on 13
June 2008, "The gTLD registries currently employ diverse models for
allocation of second-level domain names."  The diverse models represent
one of the key values of a competitive market and that value should be
continued with regard to any special allocation mechanisms for single
character names for existing gTLDs.
3.      Because of the diversity of existing gTLDs, VeriSign believes
that an auction model may be appropriate for some gTLDs and not others.
Moreover, in cases where an auction might be used, the particular type
of auction model used might vary according to the gTLD.
4.      The Framework Document states, "The use of funds resulting from
the allocation of single-character names should be subject to careful
oversight, either by the ICANN Board or by a Board appointed,
community-based trustee."  We certainly support the fact that there
should be transparency and accountability of funds intended to benefit
the greater Internet community but want to point out that such goals
could be achieved without direct ICANN Board involvement.  Of course, to
the extent that any such funds become a revenue source for ICANN, that
portion of funds should be subject to Board oversight via ICANN's budget
process.
5.      In the Annex of the Framework Document ICANN states, "ICANN
recognizes that a one-size-fits-all approach may not work for all
registries, and that there may be variations proposed by certain gTLDs."
In fact multiple proposals for release and allocation of single and
two-character gTLD second-level names have already been submitted and
several have already been approved and implemented.  This approach
appears to be working well via the Registry Services approval process,
at least where that process is being followed according to contract
terms, and we believe that approach is an appropriate way to deal with
the diversity of existing gTLDs.
6.      On Tuesday, 17 June, 2008, VeriSign submitted to ICANN its
proposal for the allocation of single and two-character domain names
through an auction method as recommended by ICANN.  VeriSign's proposal
would provide a way to significantly benefit the greater Internet
community and would allow for the transparency and accountability of
funds generated as a result of the auction method.    The proposal has
not been posted by ICANN yet.
7.      Any process for allocating single and two-character names should
be trustworthy and provide for accountability and transparency.

Chuck Gomes