strong opposition to the cyber-safety application
I would like to register my strong opposition to the CyberSafety Constituency Petition and Charter. First, the subject matter is inappropriate for ICANN. ICANN is responsible for the administration of names and numbers. While there is always ongoing debate as to whether ICANN is a "regulator" or not, there is little disagreement that ICANN is well served to keep the subject matter it deals with inside some boundaries. Trying to be a regulator of content for the Internet is significantly outside even the broadest construction of ICANN's purpose. Second, the history of this application is questionable and highlights real challenges with the whole GNSO reform process. As her application outlines clearly, the drafter of this application properly participated inside the NCUC for a period of time and when she was unable to achieve her aims she took advantage of the changing GNSO to seek more power. To elevate a single-issue group or individual to the same status as the whole NCUC is simply a misuse of the GNSO process. Third, there is a long history of challenges with single-issue constituencies inside of the GNSO. The IPC, which was originally given a seat at the GNSO table for the purpose of creating the UDRP, has since evolved to simply represent a narrow interest on any matter before the GNSO. Every other constituency, at least as defined if not in practice, has a broad range of interests inside of it. Registrars have wholesale and retail, corporate and domainer and many others. The same is true of Registries, the NCUC and ALAC. Representing a single interest with a constituency has the effect of slowing the whole policy effort by minimizing productive compromise. Whois and new gTLDs are existence proofs of this. Adding another single-interest constituency will only worsen this problem. Finally, and most importantly, the issue of cyber-safety is broad and undefinable. It is impossible to reduce to a single view in ANY situation. As a parent of two Internet-active teenagers I feel it is my responsibility to ensure that what they are consuming is appropriate and to teach them right from wrong IN MY VIEW. I reject as flawed and dangerous ANYBODY else's attempt to define what is right or wrong for my children as I should not be able to define what is right for theirs. ICANN has important work to do. Debates about "appropriate" content will quickly become a loud and rancorous sideshow that will greatly distract from that work. Please do the sensible thing and turn down this application. Regards Elliot Noss CEO Tucows Inc. [writing in my personal capacity] |