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Comment from the Just Net Coalition

  • To: <comments-draft-ccwg-accountability-proposal-30nov15@xxxxxxxxx>
  • Subject: Comment from the Just Net Coalition
  • From: "Richard Hill" <rhill@xxxxxxxxx>
  • Date: Tue, 15 Dec 2015 07:45:54 +0100

Please find below a comment from the Just Net Coalition. The Coalition's web
site is at:


Richard Hill, for the Just Net Coalition


Comment from the Just Net Coalition

We refer to the CCWG-Accountability - Draft Proposal on Work Stream 1
Recommendations, published at:


Paragraph 58 of that proposal shows that the "empowered community" would
consist of 5 organizations: ALAC, ASO, GNSO, ccNSO, and GAC. Each of these
organizations is an organic component of ICANN, and the majority of them
represent the domain name and addressing industries.

Thus, the proposal does not provide for any external accountability or
supervision of ICANN: ICANN would be accountable only to entities that are
part of ICANN.

In March 2014, NTIA announced that it intended "to transition key Internet
domain name functions to the global multistakeholder community", see:


An entity (the "empowered community") that consists of organizations that
are organic components of ICANN is obviously not "the global
multistakeholder community", nor can it be construed to be representative of
that community when 3 out of 5 of the cited organizations represent the
domain name and addressing industries. 

Consequently, the proposal manifestly fails to meet the main objective
enunciated by NTIA, namely that ICANN should be accountable to a the broad
global multistakeholder community. Therefore, we oppose the recommendations
contained in the proposal.

We reiterate our proposal to turn ICANN into a proper membership
organization, see:


Alternatively, it could be envisaged to put ICANN under some public
oversight, involving a representative structure of constituencies outside
ICANN, one possibility of which is proposed in 3 of our roadmap submission
to Netmundial, see:


While the removal of the unilateral role of the US government is otherwise
welcome and long overdue, the present structure could in fact be worse than
the earlier one to the extent that it violates the principle of democratic
governance, and in particular the key political and public administration
principle of separation of powers and instituting checks and balances in
that we now have a kind of sovereign body with no outside checks or
accountability.  This is not acceptable.

Further, we note that the recommendations of CCWG-Accountability did not
achieve consensus even within that group, see:


More importantly, the process was vitiated, in that time and again there
were proposals, adopted by so-called consensus, that were subsequently
rejected and revised due to pressure from either the ICANN Board or the US
government.  This influence was exercised with respect to very fundamental
elements of the proposal (such as oversight of the ICANN Board), and ther
esult of the pressure was that the proposal was quickly reworked in the
directions asked for. Consequently, this was not a bottom-up community
driven proposal.  On the contrary, it was a proposal driven by either raised
eyebrows, or by explicit directions, by those who hold all the power

Furthermore, JNC insists that the oversight and accountability mechanisms
must be strengthened in particular in relation to any decisions that would
result in the deletion or forced redelegation of top-level domain names. We
insist that any such decisions by the ICANN board must at least be subjected
to the same community powers as decisions to propose an operating plan,
strategic plan or budget. This should apply not only to decisions to delete
a TLD or redelegate it without the consent of the previous assignee, but
also to decisions to impose rules on TLD registry operators that impose
obligations in relation to second level domain names.

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