<HTML><FONT FACE=arial,helvetica><FONT SIZE=2 FAMILY="SANSSERIF" FACE="Arial" LANG="0">To All: I wanted to share the comments that ACM-IGP submitted today to the Names Council in support of the Dot ORG Task Force Report. This is an important Report, with far reaching implications. Our comments are below.<BR>
<BR>
If you support the Task Force Report, and/or ACM-IGP's Comments (as individuals or organizations), please feel free to submit an email to the Names Council. The email address is: comments-dotorg@dnso.org. They can be as short as a line or two. You might want to include the line: "with apologies for the late-submitted comments..." Regards, Kathy<BR>
------------------ Comments of ACM-IGP ------------------------------<BR>
Comments of the Association for Computing Machinery's Internet<BR>
Governance Project<BR>
To the Names Council's Dot ORG Task Force Report<BR>
<BR>
The Association for Computing Machinery's Internet Governance<BR>
Project (ACM-IGP) wishes to express its strong support for the<BR>
comments of the NC Dot ORG Task Force, and its Report placed on<BR>
public notice on January 18 ("Report"). In our comments below,<BR>
ACM-IGP will first express some general concerns regarding the<BR>
future of .ORG, and then comment directly on sections of the<BR>
Report.<BR>
<BR>
General Concerns:<BR>
Overall, ACM-IGP is very concerned that the .ORG space will be<BR>
restricted as it is spun off to new technical and policy management. <BR>
Unlike any other gTLD delegation to date, .ORG is not a new<BR>
creation. It is an existing community; it is a valued noncommercial<BR>
space. Whatever the initial intentions of the National Science<BR>
Foundation in creating .ORG two decades ago, it has exceeded all<BR>
expectations and bounds. Dot-ORG is the place for political and<BR>
personal commentary, community organizing and family pages, as<BR>
well as important organizational communication. <BR>
<BR>
Dot-ORG is the place for organizational communication online on<BR>
the Internet, but organizational communication is not done solely by<BR>
organizations. It is the communication of communities, families,<BR>
schools, libraries, unincorporated associations, and formal<BR>
organizations. The .ORG domain name space offers an opportunity<BR>
for online participation by the most diverse group online. <BR>
<BR>
There is rumored to be a move to restrict .ORG to perhaps even its<BR>
most narrow definition, e.g., to allow only organizations to register<BR>
.ORG domain names in the future. Such a restriction on .ORG<BR>
would disenfranchise entire classes of communication online. Where<BR>
.COM, .NET, .BIZ and .INFO are top level domains open for<BR>
general commercial domain name registration; .ORG is the only top<BR>
level domain open for general noncommercial domain name<BR>
registration. To assign new management for the purpose of<BR>
breaking up Verisign's monopoly is a fine idea; to establish new<BR>
rules that excommunicate entire classes of noncommercial<BR>
communication is not. <BR>
<BR>
<BR>
Specific Comments on Task Force Report:<BR>
ACM-IGP agrees generally with the full report. We thank the Task<BR>
Force for all its hard work, and the Names Council for its support of<BR>
this work. We note the particular importance of the following<BR>
sections:<BR>
<BR>
A. "[A]pplicant organizations should be able to demonstrate<BR>
international support and participation from a significant<BR>
number of noncommercial .org registrants." [Report, Section<BR>
1a]<BR>
<BR>
As discussed above, the .ORG delegation involves an<BR>
existing, diverse and robust domain name space. It would not make<BR>
sense for one organization (however international) or one region to<BR>
dominate or win exclusive management of .ORG. An international<BR>
coalition of noncommercial organizations from many countries and<BR>
regions will reflect existing .ORG registrations and move forward to<BR>
lay the foundation and set the policies for positive further growth of<BR>
.ORG for the benefit of their countries and regions. <BR>
<BR>
B. "The definition of the relevant community should be much<BR>
broader than simply formal nonprofit organizations. It must<BR>
also include individuals and groups seeking an outlet for<BR>
noncommercial expression and information exchange,<BR>
unincorporated cultural, educational and political<BR>
organizations, and business partnership with non-profits and<BR>
community groups for social initiatives." [Report, Section<BR>
2a.]<BR>
<BR>
The words above were carefully chosen, and provide the<BR>
core of what ICANN must protect, preserve and expand. They<BR>
should be adopted in their entirety in the final ICANN proposals.<BR>
<BR>
C. "Dot org will continue to be operated without eligibility<BR>
requirements... the registrars should rely entirely on end-user<BR>
choice to determine who registers in .org." [Report, Section<BR>
2b]<BR>
<BR>
The Noncommercial Community has proven itself. In<BR>
overwhelming numbers, it flocks to .ORG to register its domain<BR>
names. It is a successful example of self-selection in the domain<BR>
name space. <BR>
<BR>
But the Task Force Report goes a step further. It asks<BR>
ICANN to require that the new registry adopt a "definition of the<BR>
served community" and put into place "appropriate marketing<BR>
practices" [Report, Section 2b]. We have seen that even with the<BR>
inappropriate marketing practices of today (encouraging companies<BR>
to register commercial domain names in .ORG), companies disdain<BR>
.ORG, and the Noncommercial Community overwhelmingly register<BR>
in it. Self-selection will only become better as the new registry<BR>
(under the Report's proposals) actively markets to the<BR>
Noncommercial Community. <BR>
<BR>
Conclusion:<BR>
Again, our support for the Report runs to all its points and<BR>
proposals. Our thanks again to the Task Force, to its chairman, and<BR>
to the Names Council. We urge the ICANN Board to adopt the<BR>
principles and recommendations of the DNSO in this Report.<BR>
<BR>
Respectfully submitted, <BR>
Kathryn A. Kleiman<BR>
Director, ACM-IGP</FONT></HTML>