CDT Comments on .org

[Rob Courtney <rob@xxxxxxx>]

I apologize for the lateness of this comment, but I hope it's useful 
nonetheless. This letter was sent to Dr. Cerf earlier today.

Best,

Rob Courtney

* * *

Vint Cerf
Chairman
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601


August 30, 2002


Dear Dr. Cerf,

As one of the Internet's most successful domains, .org's redelegation 
will implicate millions of registrants and affect the core of the 
Internet's non-commercial community. We commend the hard work done by 
many to date, and we view the recently-published staff report as a 
useful document for the Board's consideration. We therefore offer 
this open letter to you and the Board, urging that the broad 
interests of the non-commercial community be kept in mind as the 
staff report is finalized and the redelegation decision is taken.

*Finding the Right Priorities in .org Bidder Evalution*

The .org domain has always benefited from its unique position as a 
home for non-commercial activity amid the Internet's many commercial 
enterprises. CDT appreciates the Board's request to the 
Non-Commercial Constituency for a report evaluating the eleven 
registry applicants on certain criteria - largely touching on the 
.org registry's relationship with the non-commercial community  - and 
note that report's excellent evaluation of the applicants on those 
criteria.

However, the final impact of the .org redelegation on the 
non-commercial Internet community will extend from all aspects of the 
registry's operation, not just its administrative structure or 
advisory practices. As many in the ICANN community know, technical 
capability, financial stability, and competency in customer service 
are critical considerations. For many, perhaps most, non-commercial 
domain name holders, these concerns come first and foremost. As such, 
we wish to underscore the following metrics and priorities for the 
evaluation of .org applicants:

	* The .org registry must exist on a strong technical 
foundation. Redelegation cannot be considered a success if names do 
not resolve quickly, accurately, and reliably. Any other benefits 
that non-commercial organizations would receive from the new registry 
would have little value if this basic technical mission is not 
fulfilled. Registry applications should offer ample evidence of their 
technical plans' robustness, scalability, adaptability, and, above 
all, workability.

	* The .org registry operator should have a workable financial 
model. The eleven applications before ICANN encompass a wide variety 
of approaches to funding the registry's operation. Even a cursory 
review of the domain names market will reveal that operating a major 
registry is a non-trivial undertaking; it is unlikely that every one 
of the eleven proposed approaches will succeed. A bankrupt registry 
operator will not be able to fulfill the registry's basic technical 
requirements, and the non-commercial community should make 
identification of workable financial models a high priority. The new 
registry will have a very short start-up time, and must be able to 
demonstrate its ability to be financially and technically stable on 
January 1, 2003. Several bidders have also expressed their intention 
to apply for the $5 million endowment offered by VeriSign to a 
non-profit registry operator. It is not yet clear whether all those 
bidders will qualify for the endowment, nor when or how the money 
will be paid out. Registry applicants' positions would be enhanced by 
publishing their plans in the event that the money is not immediately 
forthcoming.

	* The .org registry requires rapid, effective customer 
support. Although the .org registry operator will not be involved in 
the retail sale of domain names, high-quality support for .org 
registrars will bring benefits to the .org registrant community as 
well. The ability of .org registrants to have their problems resolved 
and maintenance performed quickly and effectively would be a major 
benefit for the non-commercial Internet community.

	* The .org registry operator's activities at ICANN should 
reflect its registrants' unique interests. As on of the world's five 
largest registries, .org constitutes a major slice of the 
international domain name community. Its operator will have 
significant influence in the gTLD Constituency (and any successor 
body) and in ICANN as a whole. The direction in which that authority 
is exercised are of great interest to registrants in .org. Registry 
applicants' plans for supporting registrants' interests at ICANN are 
a key aspect of their applications.

	* When the registry operator addresses questions of registry 
policy, consultation with the registrant community should be a 
priority. Historically, the ICANN Board has assumed authority over 
questions of gTLD policy. Where the registry operator has sole 
discretion over a policy decision affecting registrants, however, it 
should be prepared to make such a decision only after substantial 
consultation with the registrant community. Structures of outreach, 
input, and advice should be outlined ahead of time.

	* Applicants' creativity in posing new ways to support and 
expand the non-commercial community's use of .org should be 
recognized. The eleven applications have shown an impressive 
diversity of proposals for using .org to bring new benefits to the 
Internet's non-commercial community, providing a valuable indicator 
of the registry's potential. Such creativity should be acknowledged 
both by the Board and the community, and any ideas that cannot be 
implemented in the new .org should certainly be remembered for the 
future.

Finally, as the Board approaches its decision on the .org 
redelegation, it is of paramount importance that it continues to 
employ open, transparent, and objective decision-making processes. 
Such a key decision should not be tarnished by appearances of 
arbitrariness, and a strong commitment to openness can prevent such 
misconceptions.

CDT hopes the Board and the entire ICANN community will keep these 
priorities in mind as they continue their review of the staff report 
and the eleven applications. It is our continued belief that only 
applications achieving excellence in all of these areas would 
adequately serve the non-commercial Internet community.

We look forward to the Board's progress on this important issue.


Sincerely,


Alan Davidson
Associate Director
Center for Democracy & Technology

Rob Courtney
Policy Analyst
Center for Democracy & Technology

cc:	ICANN Board of Directors

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