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Comments on strategic plan

  • To: strategic-plan-comments@xxxxxxxxx
  • Subject: Comments on strategic plan
  • From: "Ken Ryan " <ken.ryan@xxxxxxxxxxxxx>
  • Date: Sat, 26 Feb 2005 04:59:20 +0100

If ICANN's mission is to coordinate the allocation and assignment of  (i.e. 
make available) a globally unique 'public name space' and numbering system for 
the Internet, then your primary customer base is the large group of individuals 
and organizations that acquire and use these unique identifiers - not just the 
?organizations and individuals who transact directly with ICANN.? 

ICANN has always prioritized its stakeholders ? these may include customers but 
in many cases they are identifiable as part of a supply chain for delivering 
products and services, the unique Internet identifiers, to your primary 
customer base.  

With a Government mandate in a growing market, ICANN risks subordinating market 
needs to the requirements and desires of your other stakeholders, and 
consequently downplaying market mechanisms. 

ICANN's  second strategic priority is to increase competition and choice in the 
domain name market.  The number of accredited registrars and resellers has 
grown since ICANN was created, resulting in lower consumer costs, but further 
increasing competition between registries is more problematical.  

In 2000 there were 44 proposals for new generic TLDs; seven new gTLDs were 
selected but have not been successful in the market.  According to ICANN's 
minutes of the Autumn '03 meeting in Tunisia they ?have faced significant 
acceptance problems."  Your Evaluation of New TLDs of August, '04 reiterates 
this sentiment.

Based on market reactions to the new gTLDs only 10 proposals were submitted for 
expansion TLDs in the most recent round.  At that rate of decrease, when will 
the concept of increasing registry competition by adding TLDs implode?  

If a registry were to fail economically, which is a legitimate risk in a 
competitive market, what impact would it have on the stability of the Internet 
and the risks that subsequent prospective registries would be willing to 

Does a further increase in registries support, or collide with, market demands? 
Registration statistics indicate that your primary customer base has already 
exercised its choice. Today the .COM top level domain owns 96.9% of all 
registrations in the combined .COM/.BIZ name pool and 70.8% of registrations in 
the larger name pool including .NET, .ORG, .INFO and .US.  In both cases, this 
hegemony has increased during the month of February, 2005. 

New TLDs may be confusing, suspicious or meaningless for information seekers, 
prompting businesses to reject them.  While the cost of registering a domain 
name has fallen, the addition of new TLDs increases costs for those businesses 
that want defensive registrations in multiple TLDs, and sunrise registration 
periods limit the number of new domain names actually made available for new 

Bottom-up consensus cannot determine what will succeed in the marketplace 
unless bottom-up means market based.  Is it strange that an expensive secondary 
market and wait list system have developed in parallel with the expansion TLDs? 
 The market is best served when choice is available, of course, and these offer 
an alternative, however limited, to the hand-me-down notion of more TLDs. 
Does your primary customer base know or care whether ICANN completes the MoU 
process with the US DoC, your first 'identified objective from ICANN 
stakeholders'?  Has your primary customer base shown it prefers namespace 
within the traditional TLDs rather than 'efficient introduction of new TLDs to 
increase competition in the domain name space', another identified objective?

In a letter dated Jan. 4, 2004,  Assistant Secretary Michael Gallagher of the 
Department of Commerce wrote to US Senator George Allen of Virginia, with a 
copy to Dr. Paul Twomey at ICANN: ?...the Department's position [is] supportive 
of the introduction of new Top Level Domains, which we have adopted as a means 
of increasing competition and choice in the domain name market. However, 
consistent with the underlying policy of private sector management of the 
Internet, the Department does not proscribe or otherwise direct ICANN as to the 
means of introducing such competition.? 

The Internet community has often found powerful technical solutions to vexing 
problems - IDN and IPv6 are two recent examples which enjoy a high profile 
because they address customer needs.  The Strategy states: ?As with other 
global standards, the DNS must be updated as technical innovations are 

Additional innovation is possible.  One example - name multiplexing within TLDs 
would solve traditional problems such as lack of namespace,  it would remove 
the rationale for cybersquatting, name hoarding and speculation, make 
contentious UDRP unnecessary and could generate a new class of Internet related 
services.  Entirely different approaches may also exist.

ICANN does not author Internet protocols, but  prodding your supply chain to 
propose alternative means of solving identified problems, then testing these 
proposals in a market environment, should fit within your mission of 
coordinating, at the overall level, the global Internet's system of unique 
identifiers.  It maps well to your core values.            

Suggesting that ICANN's ultimate success rests on meeting customer needs  may 
be platitudinal, but I miss the market orientation in ICANN's proposed 

Thank you for the opportunity to comment.

Ken Ryan

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