Comments on Guidelines for Registrars

[Elisabeth PORTENEUVE <Elisabeth.PORTENEUVE@cetp.ipsl.fr>]

I have following comments on ICANN
"Guidelines for Accreditation of Internet Domain Name Registrars
and for the Selection of Registrars for the Shared Registry 
System Testbed for .com, .net and .org domains" issued on
February 8, 1999 (http://www.icann.org/draftguidelines.html).

     - Para "II N. No Economic Regulation" does not restrict
       acredited registrars from *bundling registrar services
       with other products*. I see a big potential danger on that --
       this allows compagnies like some software or telecom
       providers to associate with registrars, and enlarge 
       even more their current power.
       I keep in mind that the next Internet step may be
       telephone over IP.
       My answer to Q48 is: YES, the guidelines should require
       registrars to offer unboundled domain name registration
       services.
     - Para "IV 6. Data escrow" assumes that ICANN will designate
       a mesh of independent compagnies to keep monthly copies
       of registrar's databases. We could imagine how powerfull
       these compagnies will be, all privacy concerns,
       all necessary bureaucracy to maintain that, and eventually
       the impacted cost on registries, registrars, and registrants.
       I would suggest to empower a registrant with periodical
       copy of his records (related to names database as well as
       whois database; registrant is the right person to keep
       his own information safe), and allow him to move it
       to any other registrar if he is unsatisfied or if his
       registrar does no longer qualify for ICANN accreditation.

The reminder from DARPA military project is that a decentralised system
is less vulnerable that a hierarchical one.

I think that ICANN cannot ensure the Vigorous and Fair Competition
Among Registrars without giving the real choice to the registrant.
Any other procedure will end up in shifting power from one group
to another, creating unwanted monopolies, built enormous
and costly bureaucracy.

Elisabeth Porteneuve