Comments of the Internet Commerce Association
The full comments of the Internet Commerce Association on .Net contract renewal and revision are attached. The Executive Summary states--- * Rights protections mechanisms developed for the new gTLD program, especially Uniform Rapid Suspension, should not be imposed on .Net through the contract renewal and revision process. The .Net registry is far too important to be a "guinea pig" for these incomplete, controversial, and thoroughly untested mechanisms. * We do not oppose allowing VeriSign to make commercial use of .Net traffic data so long as ICANN rigorously enforces the contract restrictions on reintroduction of SiteFinder or other wildcard services and such data is made available on a nondiscriminatory basis. We also have no objection to .Net's transition to a thick WHOIS model under the applicable contract requirements. * While we do not object to the provision that would allow ICANN to better serve the Internet community through the provision of marketing and incentive programs by VeriSign to "underserved geographies", we believe that a tight definition of that term as well as additional safeguards should be written into the registry agreement to prevent potential abuse of these programs by registrars or registrants, as well as potential cross-subsidization by registrants residing in the developed world. In addition, ICANN should disclose how it has utilized the $6.8 million annual excess transaction fee (as of 2010) that .Net registrants already pay into a restricted fund that is intended to benefit "developing country Internet communities". Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/cell "Luck is the residue of design" -- Branch Rickey Attachment:
ICA-ICANN-Net_Contract_Renewal-Comment-FINAL-051011.docx |