.xxx (and new TLDs in general) considered harmful by W3C and Tim Berners-Lee, comments by Leap of Faith Financial Services Inc. (May 10, 2010)

[George Kirikos <gkirikos@xxxxxxxxx>]

Date: May 10, 2010
Subject: .XXX process options
From: George Kirikos
Company: Leap of Faith Financial Services Inc.
URL: http://www.leap.com/

Of the three options presented, we would only support option #3, as it would 
support ensure .xxx does not enter the root. However, we would go even further, 
and argue that other new TLDs should not be entered into the root, and indeed 
past new TLDs that ICANN did allow should not have been approved. The current 
problems are directly related to the hypocrisy of the ICANN board, having not 
accepted the initial denial of .xxx (and other new TLDs), later reconsidering 
and accepting .xxx, and then realizing they had made a political miscalculation 
causing them to have to reverse that decision. This demonstrates that ICANN is 
not acting in a technical capacity, but has been acting in a political manner. 
This leads directly to the inconsistencies that plague politicians, 
inconsistencies which would not exist if they had a narrow technical mission 
which considered the economics behind various decisions. Overwhelmingly the 
public knows that new TLDs have costs
 that far exceed the benefits, yet ICANN tries to push them forward because its 
managers/staff/insiders believe they can benefit from their introduction, at 
the expense of the public.

Had ICANN been a proper custodian and been consistent in denying new TLDs, the 
problems would not have happened. In particular, these problems will continue 
and snowball given that ICANN is attempting to introduce even more new TLDs 
over the objections of the community. It is imperative that the DOC/NTIA/GAC 
put an end to the new TLDs program, and refocus ICANN on a narrow mission.

In 2004 the W3C Technical Architecture Group and Tim Berners-Lee (yes, the 
inventor of the World Wide Web) wrote a document about new top level domains 
that still resonates to this day. ICANN, NTIA/DOC and USDOJ should pay heed to 
its insights:

http://www.w3.org/DesignIssues/TLD

and in particular:

1) "The tree structure was an improvement over the previous flat space of host 
names. It reduced the chaos, by allowing new names to be allocated in 
sub-domains without recourse to a central registration system."

A world of infinite top level domains goes backwords to a flat space, instead 
of a tree structure, and would be a step backwards and not an improvement.

2) "There have been temptations for the registry companies to consider 
themselves owners of unclaimed names."

Indeed, ICANN seems to want to institutionalize this, through bad policy, by 
auctioning entire gTLDs to the highest bidder.

3) "And because the DNS tree is so fundamental to the Internet applications 
which build on top of it, any uncertainty about the future creates immediately 
instability and harm."

ICANN through its push to create massive numbers of new gTLDs over the 
objections of the public causes instability and harm. ICANN is creating 
uncertainty about the future.

4) "Our first instincts, then should be not to change the system with anything 
but incremental and carefully thought-out changes. The addition of new 
top-levels domains is a very disturbing influence. It carries great cost. It 
should only be undertaken when there is a very clear benefit to the new domain."

Instead of the above well considered incremental approach (even advocated by 
the Department of Commerce, NTIA and DOJ) ICANN proposes a wild-west free for 
all.

5) "The chief effect of the introduction of the .biz and .info domains appears 
to have been a cash influx for the domain name registries."

That's a diplomatic way of saying "these are failed gTLDs." Only the registries 
have received the main benefits.

6) "After an unstable period when the first come first served system was in 
play and greedy squatters grabbed domains simply for speculation, it has now 
settled down."

It has now settled down implies stability.

7) "Introducing new TLDs has two effects.

The first effect is a little like printing more money. The value of one's 
original registration drops. At the same time, the cost of protecting one's 
brand goes up (from the cost of three domains to four, five, ...).

The value of each domain name such as example.com also drops because of brand 
dilution and public confusion. Even though most people largely ignore the last 
segment of the name, when it is actually used to distinguish between different 
owners, this increases the mental effort required to remember which company has 
which top level domain. This makes the whole name space less usable."

Couldn't have said it better myself.

8) "The second effect is that instability is brought on. There is a flurry of 
activity to reserve domain names, a rush one cannot afford to miss in order to 
protect one's brand. There is a rash of attempts to steal well-known or 
valuable domains. The whole process involves a lot of administration, a lot of 
cost per month, a lot of business for those involved in the domain name 
business itself, and a negative value to the community."

ICANN's mission is security and stability. Notice the massive instability they 
are proposing violates their mission. This puts into question their continued 
stewardship of the root.

9) "When the benefits of the new domain itself are small or negative (as we 
discuss below), then one looks for incentive. The large amount of money that 
has changed hands for domain names might lead a person to suspect that this was 
the motivation."

Of course it's the motivation. ICANN is driven by the desire for more 
expansion, the desire to pay above-market salaries, the desire to engage in 
world travel, etc. ICANN does not act like a non-profit.

10) "The root of the domain name system is a single public resource, by design. 
Its control must be for and, indirectly, by the people as a whole. To give away 
a large chunk of this to a private group would be simply a betrayal of the 
public trust put in ICANN."

There you have it --- "a betrayal of the public trust."

I encourage folks to read the entire document, and notice the universal truths 
it contains even though it was written 6 years ago. W3C is an objective and 
unbiased observer, and has been a great custodian in its role. Contrast that 
with ICANN, that has only acted in its own self-interest, and has been widely 
criticized. The .xxx fiasco is just one of its foibles (others include the 
VeriSign settlement, where it granted 7% annual price increases, poor 
supervision of UDRP providers, and unrealistic executive compensation).

For these reasons alone, we continue to oppose the introduction of .xxx. If one 
has read our comments to the various Draft Applicant Guidebooks, ICANN has 
routinely ignored these and many other legitimate reasons for ending the 
introduction of new TLDs (coming not only from us, but from a broad array of 
stakeholders). We hope the DOC/NTIA/GAC step in and act in the public interest, 
as ICANN appears incapable of doing so.

Sincerely,

George Kirikos
President
Leap of Faith Financial Services Inc.
http://www.leap.com/