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Comment on "Draft guidelines for Accreditation..."

My comments following, relating to specific questions/points.

B.Q5 "Are there significant principles in addition to those stated above
that domain name registrar accreditation should seek to promote?"
Internationalization. Although V.3 already introduces the concept, it is by
far underestimated and should not be mixed with "categories of prospective
domain holders". Registration services to any category of user should be
generally available from multiple sources to all Internet users before
"targeted" registrars should be allowed to operate.
It should be clearly stated that no more than 2 out of the 5 or more initial
registrars be U.S. businesses. Of course, this should not introduce any
requirement for customers to use a specific registrar basing on geographical
location. Also applies to O.Q51.

I.Q24 "Does the proposed mechanism for anonymous holding of SLDs adequately
ensure that accurate contact  information is available as required for
proper operation of the Internet?"
Contact information could be just an e-mail address with the registrant
granting for the address being current, reachable, and responsive. For
instance, at least one NIC requires the address pointed by the postmaster:
field (this could be simplified by requiring the address postmaster@domain)
to exist and be operative (this is an example).
Contacts should be published (e-mail only) for mail exchange (postmaster),
DNS zone administration and legal issues (maybe). I think technical
questions should not be mediated by the registrars to allow prompt and
cooperative maintenaince of DNS functionality.
One could also think of addresses such as
legal-contact@registered.name.domain.net automatically created and invisibly
aliased to the real contact's address, but this would allow for e-mail to
flow through the registrars' hosts, which could be innapropriate by some
country's privacy requirements and for overall fault tolerance.

I.Q30. "Should the guidelines limit the duration (e.g., two years) for which
SLDs can be registered?"
Registrant should be allowed to keep a registered SLD as long as they wish
without re-registering, provided they are not in contempt of the rules.

I.Q48. "Should the guidelines require accredited registrars to offer
unbundled domain name registration services?"
Yes, and, moreover, they should not be able to bundle a product/service with
domain registration and "hide" the registration fee in the bundle, or
waiving the maintainance fee. Or any other measure deemed sufficient to
prevent the formation of trusts between registrars and large ISPs.

O.51 "In the event that more that five registrars meet the criteria equally,
what mechanism should be used to select among them?"
Geographical representation of the international community: i.e., at least
one registrar per existing regional NIC, with no specific country or
continent having majority of representation.

B.3.c. Remove "unless ICANN found that disqualification due to such
involvement would be contrary to the best interests of the public and the
Internet" since it would be very difficult to ensure an impartial judgement
on the matter without explicit and clear rules.

Best regards,
	Davide Migliavacca

Davide Migliavacca - Inferentia, Milano IT
Phone +39 02599281 Fax +39 0259928221
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