The following material is copyright 1998 by Dave Crocker.

Date: Mon, 02 Feb 1998 08:24:18 -0800
To: Keith Dawson <dawson@world.std.com>
From: Dave Crocker <dcrocker@brandenburg.com>
Subject: Re: Comments on NTIA plan?


It remains to be seen whether the GP succeeds and whether CORE can
survive if it does.

I'm afraid I don't have anything good to say about the GP, except
for the parts it has taken from the gTLD MoU work (but, of course,
does not acknowledge) such as about dispute resolution.

Here are some quick comments, not particularly ordered:

1. Contrary to both US and industry desires, it INCREASES government
   involvement, rather than reduces it. Domain Name administration
   and IANA have been going fine without USG intervention, with the
   exception of the PROBLEMS caused by NSF's handling of NSI,
   particularly making it and the gTLD business an instantaneous US$
   50M per year market.

3. The desire for shared registration and for more gTLDs has been
   under consideration by the Internet community for 4 years. The
   IAHC was the classic "blue ribbon panel" selected to resolve the
   matter and its work has been underway for 14 months. The green
   paper ensures at least another year of delay.

4. The paper has very conflicting requirements, since it specifies
   some very near-term deadlines but also has requirements which
   will take a long time. Form the corporation, select the board --
   oops, we first have to form international associations which the
   Internet will acknowledge as representing users, industry, etc.
   In other words it specifies mutually exclusive requirements.

5. It purports to propose an experiment but that suggests that its
   effects can be reversed. They can't be.

6. It purports to want to test competition among registries but pays
   no real attention to the matter of name portability.

7. It ensure minimal economies of scale for registries, since each
   operator of a registry gets only one registry. (ooops. except NSI,
   and THEIR infratructure was conveniently funded by the revenue
   stream the NSF authorized.)

8. It legitimizes and makes permanent NSI's control over com/net/org.

9. It allows NSI to have control both over the com/net/org data base
   (registry operator) AND to allow it to be a registrar. This is
   called a conflict of interest. For-profit motives ensure the
   worst possible end-user effects with this arrangement.

10. It specifies no meaningful oversight of the registries. As such,
    the fact that this is an integral part of the Internet
    infrastructure and that it is particularly important to end-
    users gets no meaningful representation in the operation.

11. It purports to want freemarket testing but imposes many stringent
    (and some silly) requirements on registries. The technical
    requirements list in the Appendix is actually rather amateurish,
    though that isn't obvious.

12. It does the same for registrars, and this is particularly
    inappropriate. It requires full-time guards at the computer
    sites, for heaven's sake.

The list will no doubt expand as I spend some more time evaluating,
but this should suffice for now.

Thanks for asking.

d/

--------------------
Dave Crocker                                          +1 408 246 8253
Brandenburg Consulting                           fax: +1 408 249 6205  
675 Spruce Dr.                               dcrocker@brandenburg.com
Sunnyvale, CA 94086 USA                    http://www.brandenburg.com