ICANN|ARCHIVES

Internet Corporation for Assigned Names and Numbers

June 10, 2000

To:     tld-interest@icann.org
from:  James Love, Consumer Project on Technology
         John Richard, Essential Information
Re:    Expressions of interest from parties seeking to operate and/or sponsor any new TLD registry.

I am writing to express the interest of Essential Information (EI) and the Consumer Project on Technology (CPT) in sponsoring new TLD registries.

1. CPT/EI's March 1, 2000 request.

CPT and EI first wrote to ICANN to propose sponsorship of new TLDs on March 1, 2000. CPT and EI's March 1 letter proposed ten new TLDs, including:

.union, .customers, .complaints, .sucks, .ecology, .isnotgreen, .isnotfair, .shareholder, .taxpayer and .unite

A copy of the March 1, 2000 letter is attached, and is incorporated in this letter, with the following modifications. With respect to .union, it is our position that the .union TLD should be controlled and managed by labor unions. Therefore, we will not be proposing EI/CPT sponsorship of the .union TLD.

Our March 1, 2000 letter sought to illustrate the types of uses for TLDs that would benefit the NGO community. Among the TLD proposals in our March 1, 2000 letter, CPT/EI are most likely to apply for the .sucks or .ecology TLDs in the proposed ICANN request for proposals beginning in August.

With respect to the much discussed .sucks proposal, we should point out that many businesses are seeking to prevent the public from using similar names by preempting registration. For example, Bell Atlantic has recent registered verizonwirelesssucks.com, verizonwirelessblows.com and verizonwirelessbites.com. Verizon and other companies seek such registrations to prevent their critics from having a voice, not to use the domain names to publish information. The EI/CPT proposal of prohibiting the registration of verizon.com and verizon.sucks to the same organization would protect the public from such tactics, and expand the name space. CPT/EI's proposal to use the profits from the .sucks TLD to fund a foundation that supports free speech illustrates the types of benefits to the Internet community that are possible when allocating the rights to various TLDs to competing parties.

2. Additional TLD proposals.

CPT/EI will also apply for the rights to use .watch and .critics. We believe that these TLDs will expand the name space, and create important domains for free speech and criticisms.

Like similar TLDs, it is envisioned that a .watch or .critics TLD would be used in connection with names that may be protected by trademark.

CPT/EI also is considering an application for .ngo, a TLD that would be reserved for use by civil society organizations. With respect to the .ngo proposal, CPT/EI may withdraw its request in the event that a suitable non-profit applicant is willing to sponsor .ngo. CPT/EI feels strongly that the .ngo TLD should not be sponsored by a profit making entity, and that the .ngo registry should restrict the use of .ngo to non-profit organizations.

3. Request for all words in English, French and Spanish dictionaries.

Some have proposed that TLDs be awarded on the basis for first come first serve requests, without any clear limit on the number of TLDs one could sponsor. Therefore, we ask for the rights to use all of the words in Microsoft's English (US), French (France) and Spanish dictionaries in new TLDs. EI/CPT understands that ICANN may feel it is unreasonable to award all of the words in these dictionaries to one organization. Indeed, we think such a policy would be unreasonable, and urge ICANN to adopt rules against such a name space grab.

James Love
telephone: 202-387-8030
email: love@cptech.org
web: www.cptech.org

March 1, 2000 letter to ICANN asking to create new Internet Top Level Domains

John Richard
Essential Information
P.O. Box 19405. Washington, DC 20036
http://www.essential.org/

James Love
Consumer Project on Technology
P.O. Box 19367, Washington, DC 20036
http://www.cptech.org/

March 1, 2000
Esther Dyson
Chair
Internet Corporation for Assigned Names and Numbers (ICANN)
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292 USA

Dear Esther:

This letter is to propose that Essential Information be permitted to establish a registry for new top level domains (TLDs). It is our intention to create several TLDs that would facilitate free speech and criticism, and enable consumers, workers and others to organize. Each of these TLDs will be operated under its own management charter. The particular TLDs that we propose include:

.union
.customers
.complaints
.sucks
.ecology
.isnotgreen
.isnotfair
.shareholder
.taxpayer
.unite

Our plans for each domain are as follows:

.union

The .union TLD will be a "union label" for cyberspace. EI is working with the international labor union community to develop a management system for .union. Use of the domain would be restricted to bona fide labor unions. Examples of use of this TLD would include:

nike.union
exxon.union
microsoft.union

as well as other uses, such as dcprinters.union, for links to union printers in Washington, DC. EI will be holding meetings with members of the labor community to discuss the policies for the management of this domain. It is our goal to use the .union domain to strengthen union organizing efforts, and to make it easier for workers at a firm to communicate with unions that represent workers at the firm, or who are seeking to organize workers at the firm, and for unions in different countries to coordinate efforts with each other.

.customers

EI will create a self governance management organization for .customers. This domain will be used to create democratically managed membership organizations of the customers of particular companies. The customer organizations would be able to address any number of consumer problems. For example, ford.customers might organize to address safety, service or warranty issues on Ford automobiles. Safeway.customers might organize in favor of labeling of genetically modified foods. Bellatlantic.customers might address Bell Altantic service and pricing issues in regulatory proceedings. Bankofamerica.customers could address ATM charges and other bank fees. The .customers domain will be a cyberspace version of the "Citizens Utilities Boards" that were set up in several US states in the 1970s, funded by voluntary contributions from customers of public utilities.

.complaints

EI is studying different models for the use of .complaints, to give consumers specific information about mechanisms to address product or company specific complaints, and to permit customers to share information about company practices with each other.

.sucks

This TLD will be used to facilitate criticism of a firm or organization, such as aol.sucks, wipo.sucks, or even greenpeace.sucks. We would not permit the organization that owned an associated domain to also own .sucks, so it would expand the name space in an important way. The domain would also be available for other uses, such as work.sucks, life.sucks or television.sucks.

Our plan is to create an independent non-profit free speech foundation that will be funded by fees from the .sucks registration. The Dot Sucks Foundation (http://dot.sucks) will fund Internet related free speech fights.

We recognize the .sucks TLD will be offensive to some persons, but we do not think that this should exclude .sucks from being approved by ICANN. We believe the .sucks domain will be popular in the marketplace, and also generate important funding for the free speech rights of individuals and small organizations.

.ecology
.isnotgreen

These two TLDs will be managed by environmental groups, to create forums to discuss and criticize the environmental policies of businesses, governments and other organizations.

.isnotfair

This TLD would be used by civil rights groups to discuss issues of discrimination or workers rights. We will be holding discussions with a variety of civil rights organizations to determine the management structure for the TLD. It is our intention to create a space where the public can quickly review a company's record on employment practices. For example, Texaco.isnotfair or coke.isnotfair might have links to information about discrimination suits involving these companies, or to organizations working on various discrimination or fairness issues.

.shareholders

This TLD will be used by church groups who organize shareholder suits on issues of conscience.

.taxpayers

The .taxpayers TLD would be given to democratically elected taxpayer organizations that would monitor budgets and management practices of governments. Examples of this TLD would include Arlington.VA.Taxpayers, Anchorage.AK.Taxpayers, London.UK.Taxpayers, Sydney.AU.Taxpayers.

.unite

EI is evaluating different models for the use of .unite.

These are serious proposals to use the power of a TLD to enable citizens to improve civil society. We believe the creation of domains like .union, .customers, .isnotgreen, and .isnotfair will create powerful mechanisms to share information and organize.

We would like to meet with the ICANN staff to discuss these proposals further.

Sincerely,

John Richard Director Essential Information

James Love Director Consumer Project on Technology