1 August 2002

Dear Ms Victory,

The US Department of Commerce has requested input from the European country-code Internet Top Level Domain managers (ccTLDs) on their vision of ICANN's current and future role.

The ccTLD registries for .ac, .de, .nl and .uk have worked closely with Verisign Global Registry in reaching a common view of a lightweight ICANN.

The draft statement was circulated to the full membership of the Council of European National Top Level Domain registries (CENTR). The enclosed document takes into account comments received. The Members of CENTR's Executive Committee, support this statement. The Chairman, Dr Willie Black, from Nominet UK and the Treasurer, Sabine Dolderer, from Denic will be pleased to discuss the issues further if required.

The document is forwarded to you and is made public with the explicit support of those involved in the discussions with Verisign and generally on behalf of all of the CENTR members.

Yours sincerely,

Marianne Wolfsgruber
CENTR General Manager


Editor: The Executive Committee of CENTR, 30 July 2002

We reaffirm our commitment to the Internet Corporation for Assigned Names and Numbers ("ICANN") as a private, international entity that is guided by narrowly defined functions for the technical coordination of the Internet numbering and naming systems.

ICANN function is to act as a central depository for information about, and provide coordination among those who operate, the technical infrastructure of the Internet, most notably in the domain name and IP numbering systems. The function of regulation remain within governmental prerogatives, whether it be of prices, services, business practices, or open competition in general.

ICANN's function is also that of a facilitator and educator, having regard to the global internet community and specifically industry self-regulations in gTLD space. It should provide a voluntary forum for exchanges of information between domain name service providers and others with interest in the DNS, as well as a forum for the development of industry "best practices". These are organized to be inclusive of all interests and follow open and transparent processes to facilitate the development of those best practices. For a ccTLD operator, most of these processes are inherent to and must be part of its service to its local Internet community. For gTLD operators, these forums are an important resource to foster interaction in the global Internet community. ICANN also identifies outreach opportunities and promotes industry based educational programs to aid Internet development around the world.

ICANN functions to oversee the development and implementation of policy relative to the mandatory UDRP, WHOIS and data escrow policies for gTLD operators, and provides oversight for the introduction of new gTLDs. ICANN should also act as a resource to assist ccTLDs in the development of voluntary dispute resolution, WHOIS, and data escrow policies that reflect the unique circumstances of ccTLD operators. Adoption by ccTLDs should be on a voluntary basis, in line with national laws and in consultation with their respective local Internet communities, including governments.

Finally, in carrying out its function as the central depository of information, ICANN will continue to be faced with issues related to the delegation and re-delegation in the administration of Registries. In the case of a ccTLD, if a relevant government has the potential for legal authority over a ccTLD operator and has the procedural means to address re-delegation issues using its own national jurisdictional tools (laws, regulations, courts), re-delegation questions should be dealt with within the local community and should not be directed to an international technical coordinating body like ICANN. A way has to be found for ensuring that ICANN receives a genuine, authoritative request for re-delegation, which it will simply have to implement.

In instances where a relevant government lacks any legal authority or procedural means to pursue the re-delegation using it own national jurisdictional tools (laws, regulations, courts), then a re-delegation request can be addressed through an international technical coordinating group like ICANN according to a set of procedures developed by the GAC-ccTLD working group and ratified by the consensus of the ccTLD community. In such instances, ICANN would not function as a tribunal or decision maker on the merits of such request but would refer the matter to a competent authority in accordance with an established dispute resolution mechanism.

To preserve continuity and stability in the DNS, in matters of re-delegation, it must be established that the incumbent registry operator has not operated the service continuously for a yet to be determined number of days, has voluntarily relinquished management of the registry, has failed to meet the quality of service expectations of the local community, including governments or has been declared bankrupt and is dissolving as a result.

We recognize that these principles require the addition of significant detail to become operational. The ccTLD Registries and the GAC have agreed in Bucharest to set up regional working parties to discuss policy issues of mutual interest, of which re-delegation is an example. We hope to be able to reach agreement on principles and procedures, taking into account regional and local circumstances, over the coming few months. For the time being we believe that the principles outlined above set forth a comprehensive picture of ICANN's proper role and functions, with corresponding implications for its organization, structure and funding.

The ccTLD community present at the ICANN meeting in Bucharest (and subsequently supported by other ccTLD Mangers not in Bucharest) considered the ICANN Evolution and Reform Blue Print as published on the 21st June 2002 but the ccTLD community could not endorse the Blue Print.