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  • To: cctld-sunset-comments@xxxxxxxxx
  • Subject:
  • From: Alexey Soldatov <saa@xxxxxx>
  • Date: Wed, 31 Jan 2007 14:19:24 +0300

Dear All!


This is the formal comment by the Foundation of Internet Development (FID, http://www.fid.su) that currently supervises the .SU domain operation as a public community oriented domain.


As a result of initial consultations at the beginning of 2006, the FID initiated and formalized in summer 2006 the special project on developing .SU policy (SU-PDP Project) that should correctly represent the .SU community interests and bring the domain operation into accordance with the ICANN and other related international regulations. The SU-PDP project provided significant input to our understanding about current ICANN and ISO recommendations and ccTLD and GNSO practices.

We also think that current discussion initiated by ICANN was very helpful for us to read interesting comments and (worldwide) community opinions. We are thankful to many contributors whose comments actually confirmed our thoughts about importance to serve and to listen to the user community. We also realized what important role the Internet plays in modern life for all Internet users.

We will use this opportunity to briefly introduce the Foundation on Internet Development and explain its major goals and current thinking/ priorities.

The Foundation was created in 2000 by initiative of the companies and individuals who pioneered and took active part in the Internet introduction, development and dissemination in the former Soviet Union starting from 1990-92. Starting from 2003, FID took over the coordination of the .SU user community, which identifies itself as sharing common cultural, language, historical and business values.

The major goals and activity of FID is to support community-oriented projects on Internet technologies and Internet information resources and services development. The FID is a non-profit public organisation, all income received from the .SU registration is spent to support grants, project competitions, conferences, education and training that have effect on all our community.

As an example, in 2005 FID organised the International conference devoted to the 15th anniversary of the Internet development in FSU and Russia. It created the virtual Internet museum, and started many other interesting initiatives.

Recent competitions on the best educational information resources and school website marked participants from many FSU countries and grants were awarded to winners from Russia, Kyrgyzstan and Ukraine.

In general, in its activity the Foundation is committed to represent .SU user community, on one hand, and to support it further development, on other hand.

Please find below our answers to the Guiding questions.


> 1. Should IANA adhere to the ISO-3166 standard and remove > top-level domains from the DNS root that become transitionally > reserved (i.e. retired)?

Generally NO. This should be subject to protecting domain users rights.

In particular, the .SU domain name space hosts numerous businesses, communities, scientific, educational and non-governmental initiatives which are international by their nature and actually cover not only geographical and cultural space of the former Soviet Union (not as state but as historical unity of people) but also spread over international users that associate themselves with this community.


> 2. If so, by what process should this be conducted?

ICANN should not consider the removal process as far as it can affect real users rights. But we have strong opinion that the whole current simple rule of trying to remove actively used domains even if they are transitionally reserved is obviously outdated.

It was invented but actually never used in practice. We think that this rule should be revised to develop more constructive relations between ICANN and ISO-3166/MA processes and also not used backward.

In relation to the "SU" country code, we think that ICANN should ask ISO3166 MA to make it exceptionally reserved.

We also understand that current general Internet realities and also existing large .SU user community don’t make the removal or transition process handled very simple.


> 3. What implementation timeframes for removal should be > specified?

ICANN should better develop new rules that can avoid such problems (rather artificial) in the future but in general not trying to use it backward.


> 4. If removal is test-based, what specific milestones should > signify removal from the root zone?

In any planned actions ICANN should first talk to real user community, understand their values, vision and operation, and next develop its actions together with this community.


> 5. What pre-emptive right, if any, should existing operators > have toward a new code that covers an area previously > serviced (in whole, or in part) by another code?

In case if the user community decides to move to another domain, their rights for moving their existing SLD domains must be guaranteed. For the general discussion, ICANN may need to develop common recommendation how to organize the migration. Although process should be considered as internal to the specific community but in some cases it may need to be done under the ICANN supervision.


> 6. In the event there is more than one code for a particular > country available for its use (e.g. GB and UK), what policy > should govern their status?

To our knowledge and understanding, few individual cases with multiple domain codes, like UK and GB, don’t create problems with current DNS operation. They rather should be treated as legacy situation of the past Internet development.

And we support the idea that the ICANN representative in ISO3166 MA should play more active role in linking between the Internet user community and ISO as a standard body. This will help to avoid possible misunderstanding and problems in the future.


Summarising we want to repeat that we see this discussion as very useful that will help ICANN to develop more consistent rules. But at the same time we believe that the relation between ISO3166 country codes and ICANN governed ccTLD, gTLD and sTLD should be revised in the most constructive and Internet user focused way.


We will be ready to contribute our efforts and cooperate with ICANN and community to resolve existing problems and uncertainties with the major mission to serve our community.

------------

Alexey Soldatov,
FID Coordination Council Chairman


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