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Comments on Guidelines for Registrars
I have following comments on ICANN
"Guidelines for Accreditation of Internet Domain Name Registrars
and for the Selection of Registrars for the Shared Registry
System Testbed for .com, .net and .org domains" issued on
February 8, 1999 (http://www.icann.org/draftguidelines.html).
- Para "II N. No Economic Regulation" does not restrict
acredited registrars from *bundling registrar services
with other products*. I see a big potential danger on that --
this allows compagnies like some software or telecom
providers to associate with registrars, and enlarge
even more their current power.
I keep in mind that the next Internet step may be
telephone over IP.
My answer to Q48 is: YES, the guidelines should require
registrars to offer unboundled domain name registration
- Para "IV 6. Data escrow" assumes that ICANN will designate
a mesh of independent compagnies to keep monthly copies
of registrar's databases. We could imagine how powerfull
these compagnies will be, all privacy concerns,
all necessary bureaucracy to maintain that, and eventually
the impacted cost on registries, registrars, and registrants.
I would suggest to empower a registrant with periodical
copy of his records (related to names database as well as
whois database; registrant is the right person to keep
his own information safe), and allow him to move it
to any other registrar if he is unsatisfied or if his
registrar does no longer qualify for ICANN accreditation.
The reminder from DARPA military project is that a decentralised system
is less vulnerable that a hierarchical one.
I think that ICANN cannot ensure the Vigorous and Fair Competition
Among Registrars without giving the real choice to the registrant.
Any other procedure will end up in shifting power from one group
to another, creating unwanted monopolies, built enormous
and costly bureaucracy.