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I am pleased to provide comments on ICANN's proposed "Guidelines for
of  Internet Domain Name Registrars and for the Shared Registry System
Testbed for
.com, .net, and .org domains" dated February 8, 1999.

First, I'd like to take this opportunity to thank ICANN's management,
and staff for the time and effort  -very much of it on a volunteer basis-
that they have put
into this and other important ICANN undertakings since the Corporation came
 into being
a few months ago.  All of us committed to the stability and growth of the
recognise the essential nature of ICANN's work and owe a debt of gratitude
to those
who are building a lasting foundation for the management of the central
functions of the Internet.  Our same thanks go to the many  individuals and
who have contributed in various ways to ICANN's efforts by participating in
like the comments on this proposal.

Second, we believe that the basic structure proposed in this draft is sound
 and will
achieve the objectives described in "Section I; D Goals".  Among those
goals that are
important to us are the recognition of the importance of competition and
market forces in
the operation of the system; a fundamental respect for intellectual
property rights; a
fundamental respect for personal privacy; and a recognition of the global
nature of the

Competition in the administration of a central domain name system will
yield many
benefits, not least of which is more choices and improved prices for
consumers.  This will
in turn help the medium to grow even further.  In order to realise the
benefits of
competition in the administration of the domain name system, while also
realising these
other goals, it is clear to us that  --at least in the administration of
the global top-level
domains--  there should be a vigorous market of registrars seeking to serve
 the needs of
those who would like to register a second-level domain name.

To get from where we are today to that point will require the use of the
"registry, registrar,
registrant" segmentation that lies at the heart of  this proposal, as well
as ICANN's careful
intervention.  We think the type of intervention envisioned in this
proposal, in which
registrars are accredited by ICANN and then eligible to take registrations
from registrants
and deliver the registrations to registries, is fundamentally quite sound
and deserves the
Board's support.

Roger J. Cochetti
Program Director, Policy & Business Planning
IBM Corporation

Internet Address: RogerC@US.IBM.COM
Program Director-Policy & Business Planning, IBM Internet Division