"Country Code" TLDs

[Ron Collins <ron@frogwell.tc>]

RFC "Domain Name System (DNS) IANA Considerations" para 3.3.2 "Country
Code" TLDs

These comments relate to the recent suggestion that some alteration be
made to
established practice relating to the appointment and removal of
administrators of
Country Code TLDs.

The thrust of the suggestion seems to be that where a CCTLD relates to a
territory,
the relevant government should be able to make what disposals it wishes,
and IANA
will put these into effect without question. There are a number of
points which need
to be considered before this is accepted:-

1.    Many, possibly most, CCTLDs are at present administered by groups
and
organisations which carry on their work without reference to any
government
department. Generally a group of enthusiasts started the administration,
either
under the auspices of a university, or independently as in the case of
Nominet in
the UK. This is in line with the general trend for telecommunications
world-wide,
where government controls have been relaxed in recent years, rather than
the
reverse.

This is not to say that IANA, at the governments request, should not
intervene where
there is a clear case of failure to administer the TLD in line with good
practice,
but the idea that this should happen where no reasonable complaint can
be made
against the present administrators is quite unacceptable.

2.    Most active CCTLDs have now been operating for several years, and
attempts to
make arbitrary changes at the top may have serious commercial and legal
implications. Individuals and organisations which use names registered
with the
present registrars may suffer from any disruption following enforced
changes, and
are likely to consider legal action; such action may also be available
to those at
present administering CCTLDs who are unlikely to accept confiscation
without
protest.

The obvious targets for litigation are the organisations in the USA
which control
the Internet at the top level - where these organisations do not have
clear separate
legal personality, their officers are unlikely to escape personal
liability.

3.    A word should also be said generally on the subject of governments
and their
role in Internet regulation. At the time of writing East Timor, which is
recognised
as separate from Indonesia for CCTLD purposes, is attempting to make
independence a
reality but has no effective government. Fragmentation and lack of
control can be
seen in many parts of Africa, the former Soviet Union and the Balkans.
Is it really
a step forward to press additional powers on state institutions when
this part of
the Internet appears very healthy without them?

R.D.Collins                                Company Secretary
AdamsNames Ltd