Demand Media comment on the SSAC Report - Dotless Domains
We would like to thank ICANN for the opportunity to comment on this SSAC report and the recommendations therein. While many may see this as a “techie” issue that does not affect them, we believe that the current process of researching and writing this paper and the subsequent comment period areoutside the current process of what is in the Applicant Guidebook (AGB) andessentially a re-writing of the AGB after ICANN has collected over $300 million in funds from applicants. The current AGB in Section 184.108.40.206 already prohibits the use of dotless domains. The section clearly states which types of records are permissible in a TLD zone, and then goes on to state: "An applicant wishing to place any other record types into its TLD zone should describe in detail its proposal in the registry services section of the application. This will be evaluated and could result in an extended evaluation to determine whether the service would create a risk of a meaningful adverse impact on security or stability of the DNS." So, if a registry wanted to add additional records they would be funneled into the Registry ServicesEvaluation Process (RSEP) which would then follow the existing process for introducing new Registry Services. Why is ICANN subverting the policy and rushing to permanently ban a potential service across all TLDs, that is currently not permitted, before the first new gTLD is even delegated? ICANN has a well thought out RSEP policy that requires a request from a registry seeking the service and then an evaluation process to evaluate the specificrequest and its impact on the security and stability of the DNS. This RSEP process has been used extensively in the past and is trusted and should be utilized if and when a registry decides they would like to offer dotless domains or any other service outside of what is allowed in the current AGB. With critical issues in front of us that have yet to be resolved, such as batching, metering, certainty of the new TLD timeline and analyzing the 1,000 per year TLD limit into the root, we believe resources would be better spent elsewhere. We should respect the process we have in place in the AGB and focus on the evaluation and delegation of new TLDs, rather than spending unnecessary time on banning something that is already prohibited. Jeffrey Eckhaus SVP Corporate Development Demand Media Demand Media www.demandmedia.com<http://www.demandmedia.com/> 5808 Lake Washington Blvd. Ste. 300 Kirkland,WA 98033 email eckhaus@xxxxxxxxxxxxxxx<mailto:eckhaus@xxxxxxxxxxxxxxx> ________________________________ Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Demand Media, Inc. Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you.