NonCommercial Domain Name Holders Constituency
ON VERISIGN AGREEMENT
1. The Noncommercial Domain Name Holders Constituency (NCDNHC)
has numerous concerns about the revised ICANN - Verisign registry contract posted
1 March 2001. The NCDNHC concerns arise for both substantive and procedural
reasons. However, we note that the proposed contract has some merit, and we propose
changes that would allow the NCDNHC to support the contract.
Even though the contract contains significant new policies in registrar competition
and .org registration, the DNSO was not consulted. To approve an agreement arrived
at in this manner would undermine if not destroy the DNSO's policy authority, which
is based on bottom-up consultation.
The integration of registry and registrar functions in the dominant COM domain may
be anti-competitive without other changes (see #4 and #6 below).
4. The pace of
divestiture is too slow. The divestiture of registry operations of ORG (31
December 2002) and NET (1 January 2006) should occur more quickly.
5. The possibility
of restricting ORG to only non-profit registrants is inconsistent with long-standing
policies and practices.
6. Some of the presumed benefits of the revised agreement
could be achieved by rapid authorization of new top-level domains and new registries.
7. The separation of the .com, .net, and .org registries
is a positive development. The NCDNHC supports divestiture of NET and ORG from the
COM registry to promote registry competition.
Accelerate the divestiture of ORG and NET to 1 November 2002.
9. As a supplement
to the contract revisions, we support the creation of new gTLDs devoted to unrestrcted
use and non-profit organizations by June 2002.
10. Ensure that the ORG domain remains
open to miscellaneous use and that the renewal rights of existing holders of ORG
domains are not affected in any way by the transfer of administration.