There are over 200 TLDs currently. It is not
clear to me that adding more well accomplish the objectives or address the problems
set out in the report. Currently there are other gTLDs and even some ccTLDs
that are being promoted and used as gTLDs. Yet, businesses continue to promote
and use .com. Further, a very large number of .com addresses are not active.
Working Group C's report makes a vast number of assumptions about the benefits of
new TLDs without supporting documentation. Thus, it is not clear that adding
new TLDs will solve the issue. I think we should instead look more closely
at how the current TLDs are being used. The same arguments that support the
creation of a .union can be made for hundreds of other TLDs. Is it
clear that having hundreds of new TLDs is a good thing for the Internet Community?
I am not certain that it is. Would it be better if we simply used the
current ccTLDs and made everyone register domain names based on where they are located
or where the server is located? I am not suggesting that is a better approach,
but it seems there has been no analysis and testing to determine what would be the
proper approach to resolving the issues raised in the report, such as how do we provide
companies just entering into e-commerce a chance to obtain an easy to remember domain
name. Further, it difficult for me to agree that there is some consensus
that new TLDs should be rolled out promptly when a large number of the Working Group
if not the majority at least recognize that there are still a variety of issues that
need to be resolved. For example, there is certainly no consensus on
how to protect against a stampede of people all trying to register both well known
trademarks as well as popular generic words such as "computer" regardless of whether
there is 1 or 10 new TLDs. By stating that there is consensus on rolling
out new TLDs the report implies that ICANN should move forward and allow the adoption
of new TLDs without resolving such issues. In fact, ICANN should not rollout
any new TLD until there has been a resolution on issues such as the need for accessible
and relevant contact data, registry maintenance issues, and the like. ICANN
should undertake to study the current problems being encountered in the registration
process by collecting and evaluating data through appropriate sampling and surveying
methods. The report raises but certainly does not resolve other issues such
as whether new TLDs should be restricted or open. There are different unresolved
issues for restricted TLDs such as how the restrictions will be enforced. Trying
to resolve both the issues for open as well as restricted TLDs as part of a test
rollout will only further complicate the process. ICANN should first seek to
resolve the issues with respect to one or the other type of TLD, and use recognized
research methods to evaluate the need for one or the other type of TLD, before proceeding
with any kind of test rollout.
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