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Username: USTAR
Date/Time: Fri, October 20, 2000 at 11:57 AM GMT (Fri, October 20, 2000 at 7:57 AM EDT)
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Subject: IATA is Not Independent and Not without Bias


Dear Arab Air Carriers Organization:

USTAR appreciates your comments. You state: "consumers remain reluctant to purchase travel over the web because of uncertainty about the reputation and reliability of ".com" website operators who may be geographically remote, and whose qualifications and capabilities have not been verified by any independent party."

However, IATA is not an independent party. IATA is first and foremost an organization whose mandate and objective is to serve its airline members. To the extent that airlines are a major industry sector, one which historically has significant influence over the travel industry as a whole, we see no basis upon which to deem that IATA has any true "independence". IATA is inextricably linked to the desires and mandate of its airline members.

You also state: "IATA has served as a neutral, trusted intermediary for decades ... it is ideally positioned to perform the screening and verification functions which lie at the heart of the proposal and which are notably absent from today's ".com" environment".

However, IATA is not neutral and never has been. It proposes to become the "gatekeeper" to its so-called "acceditation" of legitmate travel businesses, effectively seeking to "brand" the .travel TLD as the "trusted", "recognized" moniker for travel businesses on the Internet. USTAR is deeply concerned that IATA will attempt to impose its heavy-hand on restrictive, arbitrary criteria in the acceptance of .travel users, in the same way it has, for years, restricted the accreditation and growth of the travel agency sector. In the end, IATA will pit the industry against itself: those who use .com or other TLDs will be characterized as "non-accredited", somehow "untrustworthy".

It is indeed ironic that IATA seeks to support the expansion of e-commerce and the growth of Internet-based transactions, but, at the same time, wishes to put controls in place to define prospective merchants using standards it and it alone decides. One only has to look at the history of IATA's arbitrary restrictions on travel agency accreditation: 1) only certain physical locations are acceptable; 2) only certain types of business can be conducted at the location; 3) only certain types of signage are acceptable; 4) only certain hours or operation are acceptable; the list goes on and on.

USTAR fully supports the expansion of the .travel TLD initiative. However, we are very much opposed to any single sector taking control over this domain, particularly one which itself has a conflict of interest in that they are a directly effected stakeholder.

IATA's application for the .travel TLD should be rejected by ICANN on the basis that IATA cannot assure a neutral and unbiased management of this domain, and that IATA has already, by its own admission, stated it intends to "accredit" potential users. The use of .travel by end-users should not be subject to IATA's view of the world of travel. Such control over this domain will create unnecessary barriers for prospective users, and runs counter to IATA's own members' statements where the majority desire to have no imposition of rules governing Internet based travel transactions.

The mantra of the airlines in the current U.S. Department of Transportation review of Internet air travel transactions has repeatedly been "keep Internet air travel applications free from regulation". IATA speaks with "forked-tongue"; now, it itself wishes to become Internet air travel's premier regulator.

USTAR appreciates this opportunity to reply to your comments.     


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