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Comment on Draft Accreditation Guidelines

The ICIIU considers that all references to and inclusion of the WIPO
recommendations, as set forth in WIPO RFC3, in the ICANN Draft
Guidelines for Accreditation of Internet Domain Name Registrars
should be deleted, for the following reasons:

1) They are beyond the scope of such guidelines, which by their
definition should be limited to the establishment of alternative
registrars and not the restriction of their relationship with their

2) They are premature and ill-advised because the WIPO
recommendations have not been approved, are partisan, do not reflect
a consensus of agreement by the community that will be affected by
them, and are not an expression of a consensus of the people
assembled by WIPO to oversee the process by which they are supposed
to have been formulated (see critique by Michael Froomkin of the
WIPO Panel of Experts);

3) Infringe upon the prerogatives of the DNSO-in-formation,
rendering that organization ineffectual in completing its mission as
defined in the ICANN bylaws;

4) Are highly dangerous and counter-productive to the stated goals
of ICANN - to further free enterprise, competition, and free trade
on the Internet - because they would, if enacted, severely inhibit
any but already-large and wealthy corporations from using the Domain
Name System.

Michael Sondow
International Congress of Independent Internet Users (ICIIU) 
        http://www.iciiu.org       iciiu@iciiu.org