Comments of ISP & Connectivity Providers' Constituency on New TLDs

The ISPCP constituency's comments on the proposals for new Top level Domains

The ISPC fully supports ICANN in its efforts to ensure that the stability and reliability of the Internet is not challenged through the addition of new generic Top level Domains. As stated previously this principle is considered to be of paramount importance to the ISPC.

Against that background ICANN is urged to adopt a stable framework against which their evaluation of the applications can take place in a coherent manner. Whilst the constituency does not see it is their role to offer comment on individual applications, in an effort to assist in advancing the very difficult task facing ICANN it would like to suggest some top level principles which would assist.

1. In keeping with the earlier debates and conclusions drawn, regardless of the number of applications received as few as possible gTLDs should be introduced this time around.

2. Every effort must be made to substantiate that all new Registries involved in the domain name space are viable. If any level of doubt exists, ICANN should not consider the matter further without concrete evidence to dispel those concerns.

3. Within all new domains Registry functions should be undertaken on a 'not for profit' basis, whilst competition within the Registrar function is viewed as a key requirement

4. Public benefit must be a prime consideration and this lends itself to the development of a framework which would classify the new gTLD space into categories, under which different entities could then sit e.g. garages, car sales, car repairs etc could all exist under .car. As well as aiding public understanding, this approach would also greatly assist browser functionality.

5. In the initial phase, with a limited number of gTLDs being introduced, no organisation should be considered for the delegation of more than one gTLD.

6. The full scope of each assignment should be clearly articulated in order to avoid subsequent confusion and infringement.

7. In advance of any new domain name registrations, clear guidelines should be developed regarding the registration of second level domains.

8. Applications should be assessed against a benchmark test of expanding the growth of the Internet for the overall good of the community.

9. No preferential treatment should be given to any applicant who has been involved in pre-registration activities. On the contrary such activities should be frowned upon as an act of bad faith as this clearly went against ICANN advice.

In addition to the above points the ISPC also endorses the joint statement made by the Business and Intellectual Property Constituencies covering registrar and registration procedures, UDRP and the WHOIS database.

Michael Schneider
- Chairman -