Suggestions for the Internet Corporation for Assigned Names and Numbers

[Joseph Friedman <josephf@touro.edu>]

Dear members of the Board of Directors of ICANN,

I'd like to offer some suggestions for an improved Internet Corporation
for Assigned Names and Numbers.  I will not be able to attend ICANNs
public meeting personally, but I do have some ideas I think would be
beneficial to the new organization.  I summarized them below as best I
could, and I hope you as well as the rest of the Board of Directors
find merit in some or all of these suggestions.  I ask that you share
these ideas with the board and with the public in your meetings.


Here are 10 issues I considered:


1) The name of the organization

The name of the organization, currently the Internet Corporation for Assigned
Names and Numbers (ICANN), should be renamed to the Internet Assigned Number
Authority (IANA).  In his 5th and final iteration of the proposed Articles of
Incorporation of the "New IANA" prior to its submittal to the NTIA, Dr. Jon
Postel noted that many people commented that the name change from IANA to ICANN
in the 4th proposal "has not met with universal acclaim" and that "there is
apparently strong sentiment for continuing to use the name Internet Assigned
Numbers Authority and the acronym IANA". And he requested additional input from
the community.  Shortly afterwards Dr. Postel passed away.  I believe the name
of the organization should be IANA, and I don't know of anyone who would have
any objections to such a move.


2) The root servers

All the authoritive root servers for the Internet's Domain Name System
(currently there are 12 maintained by volunteers, the United States Government,
the United States Military, Network Solutions, and the University of Southern
California/Information Science Institute) should be under direct custody and
maintenance of ICANN.


3) Separation of the root and the SLD

The root (the "dot") should be separated from the Second Level Domain (SLD)
servers.  Currently they are both served by the same physical and logical
servers.  i.e. the millions of SLDs, ibm.com, uu.net, are in the same servers
as the root.  Technically and logically it makes more sense to separate these
functions.  Separating them will also relieve millions of SLDs from the root
servers.


4) The SLD servers

The Second Level Domain (SLD) servers should also (in my opinion) be under
direct custody and maintenance of ICANN.  Currently the SLDs are served by the
same servers as the root.  Another option would be to contract out to the best
bidder maintenance of these servers.

Currently maintenance of the existing SLD servers are done by Network Solutions
(NSI), under contract with the United States.  I do not believe NSI should be
the contractor for .COM .NET .ORG and .EDU perpetually.  Eventually these
should also be re bid.


5) Annual fees

I do not believe whoever maintains the SLD servers should charge the registrars
(or registrants) an annual fee per domain.  There is no annual cost associated
with maintenance of a domain in a server.  There may be a cost to adding and
modifying information for a domain, so perhaps the charges can be based on
adding new domains and modifying existing domains.  (It is even questionable as
to the costs involved adding and modifying domains considering that these
functions are processed by automated systems.)  The largest and primary cost a
registrar incurs, is maintaining the database (which isn't seriously affected
by the number of domains it contains) and for customer service requiring manual
assistance (which ideally would be minimized).


6) Shared gTLDs

All registrars should be allowed to register domains in all the shared gTLDs
(.COM, .ORG, .NET, and the new ones.)  Prices for registration would be
negotiated between the registrar and their customers.  Any domain registrant
should have the right to transfer their domain from any registrar to any other
registrar, in as much as consumers have the right to transfer their local and
long distance telecommunications provider as often as they please.  This is
fair competition.

The .EDU TLD should be a shared TLD maintaining the current restriction that
its limited to registrations by public institutions of higher education.

ICANN should maintain a whois database (at whois.internic.net?) that provides
domain and contact information on all the shared gTLDs.  It would also be nice
if arrangements can be made with all the ccTLD registrars, the U.S. Government
domain registrars (.GOV & .MIL), the .INT registrar, as well as the IP
registries (ARIN, RIPE, and APNIC) to share their public whois database with
ICANNs as to provide one point-of-contact for a whois database.


7) The InterNIC

The name "InterNIC" (short for the Internet Network Information Center) and the
internic.net domain, should not remain in the sole custody of NSI after the
completion of the transition.  The term "InterNIC" is not a NSI concept or
brand name.  The term was used for the U.S. Government contract awarded to NSI,
AT&T, and General Atomics.  All 3 companies have used the term in conjunction
with their part of the contract - NSI for registration services, AT&T for
directory services, and GA for information services.  It would not be right for
NSI to assume sole control for that name and domain.  It should be transferred
to ICANN which should use it as an information resource (maintaining the RFCs
as is done currently, etc.) and a directory of all the official ICANN
registrars.


8) Adding gTLDs

Add as many new gTLDs as possible.  This of course should not be done all at
once, but over the course of time. Every short, memorable, generic (3-5
characters?) word, in all major languages, should be added as a new shared
gTLD.  i.e. .INFO, .STORE, .HELP, .INC, .CORP, etc.  Any word that is short and
memorable would be wanted by many parties and it is only fair that it be a
shared gTLD.  I believe there should be 100's even 1000's of new shared gTLDs
added to the root.

Note:  There is no technical limitation on the number of TLDs that can be
in the
root.  This is demonstrated by:

-There are currently about 200 TLDs. (including the gTLDs, ccTLDs, .EDU, .GOV,
.MIL, and .INT)
-Dr. Postel, in his original proposal in '96, proposed the creation of 150 new
gTLDs.  Who is more of an authority on the technical capabilities than Dr.
Postel?
-And most importantly, as I mentioned earlier, currently the root servers also
function as the SLD servers which have literally millions of domains.  If the
root is capable of maintaining millions of SLDs there is no reason why it
couldn't handle millions of TLDs.


9) Adding TLDs

After some time to digest these changes, ICANN should strongly consider
allowing anyone or organization to register there own TLD.  For example IBM
might register .ibm as a TLD it would use for its internal purposes.  I might
register .friedman for myself.  Of course ICANN would likely want to set
policies on this i.e. pricing, and perhaps limiting the number of TLD
registered to an organization.  This proposal should only be implemented after
there are many (1000's?) of shared generic TLDs in the root.

There is no real reason domain names must be in the second level (SLD) or
higher.  They can be in the first (root) level as well.  One benefit (certainly
not the only) of allowing open registration of TLDs in the root, would be
easier, shorter domain names. (i.e. www.ibm and mike@ibm instead of ibm.com.)


10) Trademark disputes

It is my strong belief that domains should continue to be assigned on a
first-come first-serve basis, and that ICANN and the registrars should be
prohibited by ICANN policy from refusing to assign a domain, taking away a
domain, or suspending a domain due to alleged or possible trademark
violations.  The only time a domain should be refused or revoked is with a
valid court order from a  court with jurisdiction in the place of resident or
business of the registrant.  (If someone believes there trademark has been
violated by a domain registrant, they shouldn't be able to drag the registrant
to a court in a far away jurisdiction, nor should they be able to pick 'n
choose a friendly court.)  It is not the business of ICANN or the registrars to
determine who has a valid trademark, in what jurisdiction, for what industry,
and decide if the another party is using a domain in a manner that legally
constitutes a violation of a trademark or whether its considered fair-use,
comical-use, or whether or not the domain is being used in a manner that
confuses consumers with a trademark owner.  There can also be more than one
legitimate holder of a trademark in different jurisdictions and/or industries
that both have a right to the same trademark.  In such an instance a court
would not have any basis to take a domain from one party.  In short, leave the
decisions to a court-of-law.  Let them arbitrate as they always have and always
will.


Sincerely,
Joseph Friedman