Guidelines for Accreditation of Internet Domain Name Registrars

[Jim Williams <jlw@odi.com>]

Q1.  The registry administrator function seems to be
in essence, if not in fact, a governmental function
in that it is the maintainance of a shared resource.
I think some of of explicit mention of a possible
path for this function into a non-profit structure
should be given so that objections to such a change
in the future are forstalled.

Q2.  The possibility of ICANN setting minimum standards
for resellers should be left open as a possibility, but
in a form which does not require that such standards
be set.  (This then would be an issue between ICANN
and the Registrars, not the resellers.)

Q3.  Yes.  Another issue which should be considered is
the possibility of user revolt of ICANN messes up.  As
I think the end-user is under considered by the documents
I've read in general, I would consider this a reasonably
possible event several years down the road.

Q4.  Complete separation of Registration and database
administration.

[Q5, Q6]

Q7.  Employmnet, no.  Backup/operational, yes -- very
strict.  Possibly even requiring hot backup arrangements
between Registrars.

[Q8.  ???  How much is this likely to cost the Registrar?]

Q9.  Way too high.  Being a Registrar in conjunction
with some other offering should become a reasonable
alternative with only a few hundred customers after
a few years.  There's no reason to promote a heirarchy
of middlemen.

[Q10, Q11]

Q12.  This would be better kept in-house, at least at
first -- but it is probably not all that important.

Q13.  The Administrator shouldn't also be a Registrar --
of course the Administrator who is a Registrar shouldn't
be given any other powers as the organization already
has too much power.

Q14.  No.  They allow Administration and Registration
within the same organization.

Q15.  Provide a potential mechanism for separating
Administration and Registration completely.  Then
make use of the potential provided.

Q16.  Look for reasons to force separation of the
functions.

Q17.  Yes, unfortunately.  Can further restrictions
be reasonably applied upon the inappropriate release
of this information?

Q18.  No.  Continuous would be best, or at least some
sort of nightly feed.

Q19.  No.  A distinction should be clearly made between
communications concerning DNS and other communications.
There's no reason a reasonably large ISP shouldn't also
be their customer's Registrar, and potentially making
all the ISP's communications subject to escrow will
cause problems.

Q20.  Yes, but strictly restricted to registration
data.  At the same time, Registrars should be prohibited
from using Registrarion data as a sales lead.

Q21.  The registration data should in all ways be treated,
structured, licensed, and used in such a way that the data
is _only_ usefull for resolving DNS problems.  Whatever
restrictions can be reasonably placed upon the release
of the data and still permit efficient use for it's only
valid purpose should be so placed.  No one should be allowed
to make a secondary profit (second dip) from reselling the
data.

Q22.  These provisions are about the best which can be
done -- except for not allowing this at all.

Q23.  More protections.  No reselling without express
permission of the holder in an opt-in rather than opt-out
form.

Q24.  Yes.

Q25.  Don't care about law enforcement.  The Trademark
holders need not know the actual owners unless they wish
to contest a Trademark claim.

Q26.  Yes.

Q27.  ICANN -- better yet, a representative legislative
body (but you don't have one of those yet).

Q28.  It should have the effect of law within it's
restricted domain.  Other than that, it needs to be
reasonably updatable.

Q29.  ICANN for the time being.  Review should be by
the membership organization.

Q30.  Yes, but with some sort of continuation
protection.

Q31.  Possibly for non-profits.

Q32.  Same as registration duration.

Q33.  Possibly not -- In general, too much consideration
to comercial interests and not enough to individuals is
being given in these proposals.  For instance, I see no
protection offered to individual current holders of domain
names to which they may have a legitimate claim but which
may also have an interested Trademark stakeholder.  (Say
someone named MacDonald owned macdonald.com.)

Q34.   A lower fee for a non-profit Registrar might be
in order.

[Q35. Q36 Q37]

Q38.   May want to include different rates for individual,
non-profit, commercial.

Q39.   An initial cap with some sort of inflation rate
indexing might be more prudent.

[Q40 Q41 Q42]

Q43.   Failure to pay.

Q44.   One without ties to commerce.  WTO is decidedly
a bad choice.

Q45.   No.

Q46    No.

Q46.   No -- unless the number of regisrars proves to be small.

Q48.   No -- unless the number of regisrars proves to be small.

[Q49 Q50]

Q51.   Largest constituency as best you can tell.  (Not
largest customer base -- rather largest number and
variety of stakeholders.)