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Comments of the Internet Commerce Association

  • To: "net-agreement-renewal@xxxxxxxxx" <net-agreement-renewal@xxxxxxxxx>
  • Subject: Comments of the Internet Commerce Association
  • From: Phil Corwin <psc@xxxxxxxxxxx>
  • Date: Tue, 10 May 2011 18:50:59 +0000

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
Description: ICA-ICANN-Net_Contract_Renewal-Comment-FINAL-051011.docx



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