Demand Media comment on the SSAC Report - Dotless Domains

[Jeff Eckhaus <eckhaus@xxxxxxxxxxxxxxx>]

We would like to thank ICANN for the opportunity to comment on this SSAC report 
and the recommendations therein. While many may see this as a “techie” issue 
that does not affect them, we believe that the current process of researching 
and writing this paper and the subsequent comment period areoutside the current 
process of what is in the Applicant Guidebook (AGB) andessentially a re-writing 
of the AGB after ICANN has collected over $300 million in funds from applicants.

The current AGB in Section 2.2.3.3 already prohibits the use of dotless 
domains.  The section clearly states which types of records are permissible in 
a TLD zone, and then goes on to state: "An applicant wishing to place any other 
record types into its TLD zone should describe in detail its proposal in the 
registry services section of the application. This will be evaluated and could 
result in an extended evaluation to determine whether the service would create 
a risk of a meaningful adverse impact on security or stability of the DNS." So, 
if a registry wanted to add additional records they would be funneled into the 
Registry ServicesEvaluation Process (RSEP) which would then follow the existing 
process for introducing new Registry Services.

Why is ICANN subverting the policy and rushing to permanently ban a potential 
service across all TLDs, that is currently not permitted, before the first new 
gTLD is even delegated?  ICANN has a well thought out RSEP policy that requires 
a request from a registry seeking the service and then an evaluation process to 
evaluate the specificrequest and its impact on the security and stability of 
the DNS. This RSEP process has been used extensively in the past and is trusted 
and should be utilized if and when a registry decides they would like to offer 
dotless domains or any other service outside of what is allowed in the current 
AGB.

With critical issues in front of us that have yet to be resolved, such as 
batching, metering, certainty of the new TLD timeline and analyzing the 1,000 
per year TLD limit into the root, we believe resources would be better spent 
elsewhere.  We should respect the process we have in place in the AGB and focus 
on the evaluation and delegation of new TLDs, rather than spending unnecessary 
time on banning something that is already prohibited.


Jeffrey Eckhaus
SVP Corporate Development
Demand Media

Demand Media
www.demandmedia.com<http://www.demandmedia.com/>
5808 Lake Washington Blvd.
Ste. 300
Kirkland,WA 98033

email eckhaus@xxxxxxxxxxxxxxx<mailto:eckhaus@xxxxxxxxxxxxxxx>




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