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Username: RCourtney
Date/Time: Sat, August 31, 2002 at 1:25 AM GMT
Browser: Microsoft Internet Explorer V5.21 using Macintosh
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Subject: CDT Comments on .org


        CDT has just sent an open letter to the ICANN Board
the .org redelegation process. I'm attaching it here for the
forum's review.


Rob Courtney

* * *

Vint Cerf
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

* 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

* 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.


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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