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Is ICANN opening up public comment periods in bad faith?

  • To: "newgtlds-defensive-applications@xxxxxxxxx" <newgtlds-defensive-applications@xxxxxxxxx>
  • Subject: Is ICANN opening up public comment periods in bad faith?
  • From: George Kirikos <gkirikos@xxxxxxxxx>
  • Date: Tue, 7 Feb 2012 06:40:20 -0800 (PST)

Submission by: George Kirikos
Company: Leap of Faith Financial Services Inc.
Website: http://www.leap.com/
Date: February 7, 2011

I read with interest that ICANN opened up yet another comment period on new 


I believe that I speak for many when I question whether ICANN is opening up 
these comment periods in good faith, or instead whether these are smokescreens, 
mere distractions to pretend that ICANN is "listening" to the public while 
staff and insiders proceed with predetermined outcomes.

I note that as of today, there are *multiple* PAST comment periods where ICANN 
staff have not yet even summarized/digested the public's input, see an archive 


This is simply unacceptable. In other organizations, people would get fired for 
not doing their jobs in a timely manner. At ICANN, such behaviour is not only 
tolerated, it is seemingly encouraged. It appears to be part of the culture of 
"willful blindness" of ICANN staff, insiders and the Board, in order that its 
"top-down" agenda can be imposed upon an unwilling public, rather than actually 
listening to the public in the "bottom-up" process that it suggests exists.

Furthermore, when ICANN does bother to get around to publishing summaries, it's 
clear that they do not even listen to what the public has to say on the topic! 
The public OPPOSED new TLDs by a great margin. It was a very clear message, yet 
ICANN kept ignoring what the public had to say, and mischaracterized their 
words when speaking to others (e.g. politicians in Washington, etc.) about the 
public "consensus."

One sees that ICANN continues to speak in that twisted and biased manner in 
this actual comment period, when it uses loaded phrases such as "carefully 
crafted, new protections" or "perception" or "perceived need" -- the underlying 
assumption being that the public is simply "stupid" and "doesn't understand" 
new TLDs, and if only the public "knew better", they would "come around" and 
"love what ICANN is doing." That is simply preposterous and arrogant. It 
demonstrates that ICANN is out of touch with reality. The informed public 
*knows* that new TLDs will be a disaster, and has said so in clear language at 
every opportunity. ICANN is not "misunderstood" as some people believe -- the 
public fully understands ICANN, and opposes its plans! Period!

ICANN acts like a greedy politician, asking for a "tax increase" to pay for a 
new bureaucracy that simply transfers wealth from the public to itself and its 
insiders. ICANN is not creating new wealth. ICANN is *destroying* wealth. 
Taxpayers see through attempts to bamboozle them that the "tax increase" is a 
good thing. Just as the public sees through attempts by ICANN and its insiders 
to bamboozle them that this new TLDs plan is "good" for the public. Attempts to 
dress up their greedy proposal using words like "innovation" fail, because the 
public is smarter than ICANN and can see through their self-serving proposals.

One need only look at the .XXX rollout, which was a disaster for the public. 
Millions of dollars were spent by universities, non-profits, individuals and 
corporations to purchase "protection" so that someone else could not tarnish 
their image/brand/identity. ICANN and its insiders do not consider this to be a 
"disaster", though --- they look at this as "innovation", and pat themselves on 
the back saying "job well done." ICANN might pretend "well, no one told us this 
was going to happen....how were we to know??" That's utter nonsense, of course. 
One can go back to the analysis of Tim Berners-Lee, who didn't mince his words. 
He said "New Top Level Domains Considered Harmful". Could one be more clear??



He was not pointing to just .mobi and .xxx ---- he was saying this about ALL 
new TLDs (see the "Title" tag in the W3C page).

ICANN and its insiders are emboldened by the dot-XXX launch. They want to 
multiply that "tax" on the public, what many have described as a "protection 
racket", a thousand-fold. ICANN suggests that "this time will be different" --- 
keep dreaming! The only thing that will be different is the *degree* to which 
the public will be damaged. ICANN wants to damage the public a thousand-fold, 
to the benefit of itself and its insiders.

ICANN instead needs to take a step back, whether willingly or by being forced 
to do so by the GAC, DOC, NTIA, DOJ or by other agents that are representative 
of the public interest. I suggest ICANN be compelled to do the following:

(1) immediately suspend the new TLDs rollout, and refund all monies collected 
to date.

(2) terminate the staff who have pushed forward this new TLDs plan over the 
objections of the public. It's clear that these staff have their own agenda 
that does not reflect the public interest, and it's time for new blood that is 
ready to *serve* the public, rather than staff who want to be "masters" over an 
enslaved public.

(3) go back and present true options to the public regarding new TLDs. In our 
prior recent submissions at:



(which ICANN has yet to summarize, although we repeat much past input) we 
identified FIVE allocation methods for new TLDs. Five! 5! Yet, ICANN has never 
presented them all as options to be seriously considered. They simply *imposed* 
in a top-down manner their single plan that maximized the benefits to ICANN's 
insiders, rather than allow for competing alternatives that maximize the 
benefits, if any, to the public. One can see some of the options that ICANN 
failed to allow the public to even *comment* on, such as:

(i) no new TLDs 
(ii) .com domains simply "ascending" to the root (no need for "defensive 
registration" concerns in that scenario, is there??)
(iii) Ascended TLDs approach, see:


which also reduces the need for defensive registrations considerable.
(iv) regular competitive bidding/tenders for lowest cost to registrants (this 
was the DOJ/NTIA/DOC proposal in December 2008)

(4) go back and do true economic studies that weigh the benefits and the costs 
*on the public* (not just the benefit to ICANN and its insiders) for ALL 
alternatives (including the four options presented in point (3) above), not 
just the self-serving single plan that ICANN wants to impose upon the public. 
The economic studies must be truly independent, with researchers selected by 
the NTIA/DOC/DOJ or GAC, and *not* by ICANN staff/insiders.

In conclusion, ICANN simply acts as if it "knows better" (which it doesn't) and 
dismisses all attacks on its extremist and disastrous plans. It is our true 
hope that ICANN not be allowed to damage the DNS further. As Tim Berners-Lee 

"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."

The existence of this comment period about "defensive registrations" is PROOF 
that "Sir Tim" was RIGHT! (maybe that's why he was knighted, due to his 
brilliance) We ask that the new TLDs plan be terminated, so that further 
"negative value to community" does not occur. By continuing to ignore the 
public's wishes, ICANN is *causing* DNS instability. A trusted custodian of the 
DNS would not be *causing* DNS instability. Yet, ICANN has been doing exactly 
that. It's time that the world recognizes that ICANN is no longer a trusted 
custodian of the DNS and its damaging plans must be opposed.


George Kirikos
Leap of Faith Financial Services Inc.

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