ICANN settlement with Verisign comments
Gentlemen: Iron Horse supports many companies, non-profit organizations, and governments connecting to the Internet. We have been in business for over 15 years and are located in Springfield, Virginia, right next to Washington, DC. Our corporation is not directly responsible for more than 5 registrations, however, our customers own thousands of domain names. As a support organization, we feel that the settlement agreement proposed will be counterproductive to both the industry and to the businesses we support. Paradoxically, the raised costs that might impact our customers because of the proposed settlement could well increase our business. The settlement agreement proposed at http://www.icann.org/tlds/agreements/verisign/ICANN-VRSN-settlement-agreement-2005.pdf does not appear to give ICANN anything it doesn't already have, but instead is designed to keep Verisign from using its legal and financial clout to marginalize ICANN. As such, the agreement recognizes the efforts by Verisign in the past that have been contrary to ICANN's interests, and thus the broader Internet interests, and specifies a process whereby the only recourse is arbitration and the projected result being a public retraction. By that time, the damage will have already been done. As I see it, this agreement actually lessens the protections of ICANN under US law. ICANN can't compel Verisign to do much under current law, but it doesn't have to agree to Verisign's position and weaken itself further. Instead, the US should formally recognize ICANN as an international standards body for the necessary functions it performs and under existing laws covering telecommunications strive to craft an authoritative and protected position for ICANN similar to those organizations that coordinate specifications, standards, security, and interconnectivity in telecommunications. The US may have to specifically cede its administrative authority to this body to accomplish better legislative control of the Internet or at least formulate policy to strongly support ICANN and intercede on its behalf for the better governance of the Internet. ICANN should be in the position to force any registrar to accede to standards, specifications, security, and other needs applicable to the larger Internet community. Verisign is only a CUSTODIAN of the root servers. It should not be dictating to governing authorities, but should be suggesting operational and logistical improvements to the processes for which it is custodian. The agreement with Verisign should be for the .com domain with no promise of exclusivity, even though there is no other contractor being currently considered for this type of agreement. Exclusive agreements with difficult out clauses are not in the best interests of ICANN or the larger Internet community. Since the US Federal government has to make use of various .com domains, like USPS.com and reservations to avoid confusion with .gov domains and provide other functions, such a contract would be contrary to normal government contracting processes in which numerous contractors using numerous methods should be solicited for the best possible public outcome. ICANN should strongly consider authorizing multiple registrars for this most important of TLD domains to avoid any disruptions in service due to any business problems or actions by Verisign. The Internet was designed with redundancy in mind. There should also be greater redundancy in the provision of DNS services for TLD domains, if possible. Verisign should not be in a position to receive perpetual control of the .com domain. It is not in the interests of anyone but Verisign. Such an agreement would not stand if Verisign were a telecommunications company, for example. A 7% increase in domain registration fees per year is far higher than what would be expected. Enhanced automation may actually make registrations LESS costly over time. The maximum allowed increase should be pegged at the Producer Price Index increase for the previous year, which is typically less than 3%. Also, ICANN should have SOME say over these price increases, and the prices charged by the various root level registrars should be enough to make them all profitable, but not produce a huge disparity between the various root level domains, though I do recognize that at the present time that a .com domain name can have greater value than another TLD domain name. As such, any decisions made about the .com domain will have broad implications for the rest of the registrars and the Internet. As the central arbiter of Internet TLDs, ICANN holds a unique monopoly position and needs to be carefully monitored. The higher fees that ICANN desires should be, in turn, justified by real business and societal needs. I do not see in the documents any rationale as to why these fees might be needed and what we will get in return for them. This agreement is NOT just between Verisign and ICANN. It could potentially directly impact all of the customers affected by these monopolies. As such, I would hope that the US federal government would work to strongly represent the interests of businesses and consumers and strive to make it the best agreement possible and stand in if the agreement would be anticompetetive. Any monopoly affecting a citizenship needs to be very carefully monitored and even controlled for the benefit of those citizens. Considering the documents I have reviewed, it is not in the best interests of the US federal government, ICANN, other registrars and companies, .com registrants, and the greater public that these agreements be entered into as they now stand. ************************************
Tony Stirk, President
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