Some comments of Acreditation Guidelines

[jeff Williams <jwkckid1@ix.netcom.com>]

All,

  In reference to: A. Contemplated Structure of the Domain Name
Registration Business  from the ICANN's web site the following questions
were posed
that we (INEGroup) have some comments and proposed answers to.

Q1. Is the segmented model for the provision of domain name registration

services described above appropriate? How could or should it evolve over

time?

Answer/Comment - As segmented model is inappropriate for the furtherance

of strong growth in the Registrar/Registry business and industry and
would
hamper or otherwise impair stability in the internet accordingly.
Rather a more
free form model would be more appropriate to meet the continuing and
potentially ongoing demands of the stakeholder community as many have
already pointed out over the past two or three years.

Q2. Are there any reasons why resellers should be accredited?

Answer/Comments - Accrediting resellers has advantages and disadvantages

that are difficult to judge in advance.  There should be some general
and
very basic guidelines, but full accreditation would be both difficult to

oversee as well as potentially more expensive than the benefit would
be worth in the long run.

B. The Goals: Preserving the Stability of the Internet and Introducing
Competition

Q3. In the context of accrediting registrars for the DNS system, is
preservation of
          universal and durable resolution of domain names an important
requirement for
          preservation of the Internet's stability? Are there other
stability issues that are
          particularly relevant in that context?

Answer/Comment - The term durable resolution is an ephemeral one
depending
                                 on how you view that subject area.
What is important
                                 with respect to stability is multiple
and redundant DNS
                                 architectures (More than one).  Any
single architecture
                                 has the advantage of being well
understood, but also has
                                 the disadvantage of becoming our of
date from a technological
                                 standpoint, and therefore provides for
long term instability and
                                 lacks forethought and efficiency.  It
also hampers the incentive
                                 for further development of DNS itself
as it evolves leading
                                 to non-competitiveness.  We believe
that we are at this
                                 juncture with already existing DNS
architectures such as
                                 GRS and SROOTS already in existence
today.

Regards,

--
Jeffrey A. Williams
CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
Information Network Eng. Group. INEG. INC.
E-Mail jwkckid1@ix.netcom.com
Contact Number:  972-447-1894
Address: 5 East Kirkwood Blvd. Grapevine Texas 75208