NCSG Comments on Identifier Technology Health Indicator Definitions

[Tapani Tarvainen <ncsg@xxxxxxxxxxxxxxxxxxxxx>]

The ICANN Non-Commercial Stakeholder Group (NCSG) submits the
following comment on proposed roposed ICANN Identifier Technology
Health Indicator Definitions:


Unfortunately this initiative is fundamentally flawed and distracting
from actual and substantive work at ICANN. This comment period ranks
as a complete abuse of the time of volunteers in the ICANN Community
who have to stop their lives, and take time away from more substantive
issues and PDPs to respond to them. The comments below strongly
support the cries of John Berryhill, IAB Chair Andrew Sullivan and
James Gannon in setting forth that sometimes a comment topic does not
deserve consideration and should be eliminated at the start. This
said, let us share that:

* SSAC wants metrics of the DNS and that is certainly supportable;

* BUT assigning silly, strange and distorted names to issues that need
  careful and balanced review, consideration and evaluation is, as you
  have been told in other comments, DANGEROUS:

1. It's prejudicial – assigning a disease name to a certain situation
implies it is a problem. For example, DATAMALGIA (Pain from Bad Data)
delves into difficulties we have been exploring for over 15 years: of
privacy and data protection protections and laws not currently allowed
to be implemented by Registrars, of legitimate exercises of Free
Expression by individuals and organizations operating in opposition to
oppressive regimes and governments who would jail them for their views
(or worse); of students who have no phones, but do have computers,
Internet connections and ideas that to share via domain names. This
data is not a disease, but a complex policy discussion and concern.

2. It's unfair – superimposing a disease name atop an area of serious
research, study and evaluation minimizes the problems, discourages the
robustness of the debate, and makes it more difficult to fully
evaluate and resolve the issues.

3. It's unwise – labeling a serious research area with a silly name.
It diminishes the work of many years and the good faith efforts of
numerous task forces, working groups and committees. The answer here
is simple. We are technologists, lawyers, registration industry
members and other Community members who have become policy makers. We
look at facts, situations, data and evidence. It destroy and
diminishes our efforts, time and discussions to label them with silly
names. Overall, this is a poorly presented comment – you have asked us
(Commenters) to delve into a slide presentation for the materials that
are the basis of your question. The 5 disease names that have been
created impose prejudicial interpretations on debates within the scope
of ICANN, and ask us to go far beyond the boundaries of ICANN. The
answer is "no."

Respectfully submitted,

Tapani Tarvainen
for the Non-Commercial Stakeholders Group