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From: <postel&#167;ISI.EDU>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/20/98 8:53pm
Subject: IANA's Comments on Docket No. 980212036-8036-01

Comments of the Internet Assigned Numbers Authority (IANA) in regards
to the Department of Commerce, National Telecommunications and
Information Administration 15 CFR Chapter XXIII
[Docket No. 980212036-8036-01]

Improvement of Technical Management of Internet Names and Addresses:
Proposed Rule ("The Green Paper")

20 March 1998

We commend the United States government on its "Green Paper" which
formalizes the need to improve the technical management of Internet
names and addresses, along with the transfer of Internet technical
management functions from the current government-sponsored agreement.
In addition, we concur with the proposal to open the domain name
system for competition while maintaining the stability of the
Internet.

Internet Governance:

There is an unambiguous need for technical coordination of the
Internet. The root name server system and the unique assignment of
Internet Protocol (IP) addresses and numbers must be maintained for
the global Internet to function.

Historically, IANA developed as the central authority for these
functions as an outgrowth of United States government-sponsored
research which fostered the development of the Internet. It is time
for that organization to evolve.

We propose the following for the new IANA:

o the new organization should be the central authority for root server
functions and Internet Protocol address and number assignment

o the new organization should be a separate, not-for-profit entity

o the new organization should be industry-supported with consensus
governance (maintaining a functioning tradition of Internet
self-governance)

o the board of directors should represent the global Internet and its
constituent users

o the new organization should develop and maintain the criteria for
registries and registrars with the consensus of the Internet community

Domain Names:

We applaud the results of the International Ad Hoc Committee (IAHC)
and the development of the generic Top Level Domain Memorandum of
Understanding (gTLD-MoU).

We maintain that the preferred evolution at this time is toward a
non-profit registry with multiple, competitive registrars.

We believe that new gTLDs can and should be introduced to the system
in a controlled manner by community consensus.

We see the trademark issue as a complex one best addressed by experts
in that field and respect the work of the IAHC and Policy Oversight
Committee (POC) in this area.

We believe that the US government has a key role in managing the
transition of the current operation of the COM, NET and ORG gTLDs by
the Internic to a new model of operation consistent with the
principles being established for competition in domain name
registrations.

Root Servers:

We agree that root server security and maintenance can be improved. In

order to evolve to a standard operational model, we suggest the
following:

o performance requirements

o contracts for operation

o criteria for root server site selection

o redistribution according to objective criteria

o maintenance by third-party service organizations

US Domain:

We believe that discussion of the US domain should be pursued
independently of the overall management structure for the Internet or
the discussion of gTLDs.

We note that under the current US domain structure and delegations the
General Services Administration already has the authority to
transition all xxx.GOV domain names to xxx.FED.US domain names and all
yyy.MIL domain names to yyy.DOD.FED.US domain names.

Conclusion:

We believe that the root server functions should be moved as soon as
the new organization is incorporated. We suggest that competitive
domain name registrations begin using the Council of Registrars (CORE)
model immediately thereafter.

This response is based on our reading of all public responses (to
date) to the "Green Paper", and is subject to revision based on
further comments and consensus from the global Internet community. We
are ready to move forward with the new IANA non-profit organization.

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