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GTLD-MOU POLICY OVERSIGHT COMMITTEE=20
NOTICE 97-02=20
SUBJECT: Review of new generic Top Level Domains (gTLDs)
RESPONSE:=20
=20
The Domain Name Rights Coalition (DNRC) is a public interest =
organization which has
followed and critiqued the IAHC/iPOC since its formation. DNRC =
represents the interests of
entrepreneurs, small businesses and individuals on the Internet. Its =
Board of Directors includes
Kathryn Kleiman, President, an Internet and telecommunications attorney =
in Alexandria, Virginia,
and previously a data communications analyst on Wall Street, Michael =
Doughney, co-founder of
DIGEX, a large Internet Service Provider in Beltsville, Maryland, and =
Mikki Barry, co-founder of
InterCon Systems Corporation, the earliest manufacturer of Internet =
connectivity software for the
Macintosh platform in the 1980s, and an Internet attorney. =20
DNRC submitted extensive comments about the new gTLDs proposed by =
iPOC in
response to the Notice of Inquiry of the Department of Commerce. These =
comments can be
found on the DNRC website at http://www.domain-name.org and on the =
Department of
Commerce website at http://www.ntia.doc.gov/ntiahome/domainname. =
Section C, Creation of
New gTLDs, answers 10-14, address the concerns of DNRC on these issues.
DNRC calls for iPOC to suspend this private request for comments -- =
Review of new
generic Top Level Domains ("this proceeding") -- as well as its other =
private requests for
comments now taking place. The timing for these proceedings is =
premature and the limited
audience which follows iPOC is far too small to justify creation of =
far-reaching rules by iPOC.=20
IPOC must suspend this proceeding at least until issuance of the =
report of the U.S.
Department of Commerce which is expected on November 1, 1997 -- less =
than a month away.=20
The Department of Commerce conducted a Notice of Inquiry which succeeded =
in reaching many
parts of the far-flung, diverse, and multi-faceted Internet community. =
The DOC successfully used
the U.S. Federal Register, the Department of Commerce website, listserv =
announcements and
phone calls to contact a wide range of organizations and individuals to =
notify them of the
proceeding. Although expedited, the proceeding allowed over a month and =
a half for evaluation
of the questions and formulation of responses. Those participating =
knew that the U.S.
Government has a track record in responsible management of the Internet =
as well as public
accountability in its decision making process. The Internet community =
awaits the DOC report as
the next step in the formulation of the transition of Internet =
governance.
While we thank the individuals who have served on the IAHC and =
iPOC, it is only right
and responsible for iPOC to yield to the Department of Commerce at this =
time. IPOC is a private
group and, in light of the entrance of a powerful, legitimate and =
representative governmental
body, should suspend its private comment and discussion periods at least =
until the Department of
Commerce report is issued. Perhaps after this date, iPOC may be able to =
attract the attention of
the Internet community which it seeks to represent. =20
DNRC further notes that iPOC continues to proceed through comment =
periods and
report/rule revisions without consensus and with undue haste. Thirty =
days does not provide the
Internet community with adequate notice to read, discuss, and respond to =
the questions raised. As
private groups repeatedly stressed to the U.S. House of Representatives =
during the Domain Name
Hearing of September 30, 1997, the Internet is a well-functioning and =
robust system. Rushed
question periods are likely to lead to answers which are not democratic =
and do not have the
consensus of the Internet community. Once again, DNRC urges iPOC to =
catch its breath and
suspend this and its other private requests for comment pending the =
upcoming report from the
Department of Commerce.=20
For more information regarding these comments, please contact =
Kathryn Kleiman, Esq.,
President of DNRC, at kathrynkl@aol.com or Harold Feld, Esq., Secretary =
of DNRC, at
hfeld@cov.com.
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