Below is the document just released by ISOC (the international 
organisation) with their comments on the Green Paper.

Briefly, the main points are:

- support for Jon Postel's proposals for a new IANA as a central authority 
  for IP protocols, addresses, domain names and the root server system

- gTLD registries are seen as service functions for the Internet, to be 
  administered on a non-profit basis using shared database technology,
  subject to the public trust

- registrar functions are the competitive businesses that users must be
  able to move between without being tied-in

- the dispute resolution procedures already designed and facilitated by 
  POC/CORE/PAB groups provide a good basis for resolving intellectual 
  property disputes

- details of exactly how many registries, number of gTLDs etc, must be
  decided as a matter of self-governance by the Internet community and
  not by the US government.
   
Kate Lance



                   Comments of the Internet Society
                           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
                           ("Green Paper")
                            17 March 1998

I.      Introduction

The Internet Society (ISOC) wishes to thank the members of the team that
produced the referenced document ("Green Paper") for their diligent effort
against a formidable time constraint; and, for bringing forward several of
the issues that are critical to the continued evolution of the Internet.
We are confident that an international open process with no undue influence
from any one entity to discuss and resolve these issues will result in
conclusions and actions for the best interests of the Internet.


II.     Executive Summary

The development and evolution of the Internet has been in process for a
number of years.  In all those years, it has employed principles of
self-governance, out of which has emerged the concept of "rough consensus."
 Rough consensus is reached through a rigorous, openly vetted process that
produces the best of alternatives; it does not mean unanimity, but it does
mean broad based acceptance.  Cooperation amongst the Internet stakeholders
produces rough consensus and has brought the Internet to its present
successful and robust state.  The Internet Society encourages the
continuance of this proven concept.

There are several key issues presented in the Green Paper for which ISOC
has special concern or interest:

Central Authority  -  The Internet Society supports the concept of a
central authority for the management and administration of: Internet
address space, other protocol conventions essential to the use and
operation of the Internet, domain names, and the root server system.  We
note the similarity between the proposal in the Green Paper for this
central authority, and that proposed by Dr. Jon Postel of IANA
<http://www.iana.org/iana/iana-plan-980113.txt as developed through the
normal process of consensus building which has been employed for the many
years of Internet evolution.

The Internet Society expresses support for the proposal of Dr. Postel, and
believes there are common grounds upon which these two proposals can
coalesce.  We believe it would be beneficial to the continued health of the
Internet for rough consensus to result on this issue and we encourage all
interested parties to commit to supporting the concept.

Registries  - A registry is the database repository for one or more gTLDs.
A registry is a monopoly.  This is an unfortunate fact that exists, at
least for now, due to technical limitations.  As a result, a registry must
operate under different guidelines than a normal business.  The potential
for abuse through price gouging, once registrants become "locked in" to the
gTLD through the proliferation of its URLs, is significant.

Because of its unique situation, the registry function is a service
function for the Internet and should be administered on a non-profit basis
utilizing shared database technology.  This allows multiple registrars to
access and utilize the databases in the exercise of registering second
level domain names.  There should be no "ownership" of gTLDs, and they
should be treated as an international resource, subject to the public trust.

There is no particular reason why there couldn’t be multiple registries
scattered throughout the world, each with a set of gTLDs having a shared
database system with multiple registrars.

Registrars  -  True competition in the registration of domain names resides
at the point where the user, or registrant,  -  the entity who ultimately
requests the registration of a domain name  -  meets the Internet Domain
Name System (DNS).  That point is clearly the registrar function.
Registrars may be located anywhere in the world; are independent businesses
each competing for registrant business on the basis of price and value
added service; and use the registries as a clearinghouse for assuring
uniqueness in domain names.  The registrar may certainly be a for-profit
entity.

Dispute Resolution  -  As a result of the work of the International Ad Hoc
Committee (IAHC) and the continuing efforts of the many Internet
stakeholders working with the POC/CORE/PAB, a truly remarkable set of
instruments to facilitate the resolution of intellectual property disputes,
efficiently, effectively, and inexpensively has evolved.  ISOC strongly
supports this capability and urges international recognition and acceptance
of its offerings as an option for resolving intellectual property disputes.

Governance  -  The Internet Society asserts its strong belief that if the
Internet is ever to reach its fullest potential, it will require
self-governance.  If any one entity attempts to control or govern the
Internet, it is likely others would protest.  It then follows: if consensus
is not reached, the Internet could very well become fragmented and,
accordingly, cease to exist as we now know it.  While we find much in the
Green Paper with which we agree, its attempt to define details that would
be better left to the process of bottom-up consensus building, appears to
go against the principle of self-governance.  The US government would be
well-advised to leave the details such as: how many registries, for-profit
or non-profit; the number of gTLDs; the number of gTLDs per registry; to be
defined in a self-determination process such as that described in the
History section.

In the formation of the new IANA, the Green Paper calls for the creation of
a new organization to represent the Internet user community.  ISOC believes
itself to be more representative than any other organization existing
today.  Equally important, it is composed of, and represents, a veritable
who’s who of the Internet.  Regarding the broader issue of governance,
while IANA has been funded by the US government, it is chartered by the
Internet Society through the Internet Architecture Board (IAB) in RFC 1601
<http://info.internet.isi.edu:80/in-notes/rfc/files/rfc1601.txt.  While it
has accepted  US government funding, it has nevertheless operated without
other US government involvement or intervention for many years.  ISOC’s
stewardship in this matter is a matter of public record representing a
shining example of responsibility in fostering Internet self-governance.
As with the Internet Engineering Task Force (IETF), IAB, and the Internet
Engineering Steering Group (IESG), autonomy of operation is preserved.

Finally, ISOC believes it would be prudent for all stakeholders to agree to
proceed under the authority of the current IANA, with the plan presented by
the POC/CORE system.  This does not preclude other systems which would
conform to requirements established by IANA form being implemented, but
consistency should be maintained.  This action would be consistent with the
aims of the Green Paper and provides a robust means to gain controlled
experience along the lines proposed in the Green Paper.


III.    History

There may be arguments about how old the Internet is, but certainly during
the 1990s, the Internet has incurred tremendous growth and transformation.
It has emerged from the academic and government environment, primarily
within the United States, to a truly international network of tens of
thousands of interconnected independent networks.  It works because these
networks cooperate; they agree to use standards, such as the TCP/IP
protocol.  The standards were developed through a grass-roots, or bottom-up
process in an open forum where only the best ideas emerge.

The Internet reached its present robust state for many reasons:  a
brilliant protocol; an early founding period wherein the participants were
virtually unnoticed; an environment extremely conducive to cooperation
among and between the participants; the freedom to experiment in an
uncontrolled environment; an open forum using a grass roots approach to
standards development; indeed, a self-regulating and self-policing culture.
It was from this background that the concept of "rough consensus" emerged.
Rough consensus is actually derived through a very rigorous process that
weeds out the weak proposals and encourages the best.  It does not mean
unanimity, but it does mean broad-based acceptance.  This is the mode of
operation for the IETF, the dominant standards body for the Internet.

Take away cooperation, and the dynamic, innovative Internet that we have
come to know and admire will go away.

In the tradition of what made the Internet the phenomenal success that
most agree it is today, the Internet Society, in response to a proposal by
the IANA, initiated a process to enhance the Internet Domain Name System
through the introduction of competition and an efficient, effective, and
inexpensive system for dispute resolution between domain names and
intellectual property owners.  A committee was formed, the IAHC, with its
members coming from a broad geographical spectrum as well as international,
technical, business, and legal perspectives.  Employing all the techniques
learned from the history of the development of the Internet, the IAHC
produced a plan which defined a structure and processes to achieve
precisely what the Green Paper proposes to accomplish regarding domain names.

The IAHC plan, now known as the CORE/POC/PAB, or gTLD-MoU plan, is and has
been open for modification and adaptation.  It presents an excellent
foundation from which cooperative effort, with the US government as one of
the participants,  could result in an international solution to the issues
addressed in the Green Paper.  It has the added benefit of having been
produced in the traditions of the Internet and would be enhanced by wider
participation as herein suggested.


IV.     The Critical Issues

Among the most critical issues discussed in the Green Paper are:

1. The concept of a Central Authority for the administration of Internet
Protocol (IP) addresses and parameters, domain names, and the root server
system;
2. The concepts of Registries; whether they be for-profit or non-profit;
"ownership" of gTLDs by registries; and, the use of shared database systems;
3. The concept of competitive Registrars;
4. Dispute Resolution mechanisms between domain name holders and
intellectual property owners;
5. The direct and implied issues of Internet Governance.

A.      Central Authority (The New IANA)

The Internet Society expresses its support of the document
<http://www.iana.org/iana/iana-plan-980113.txt written by Dr. Jon Postel
and as evolved through an international vetting process.  We believe it is
similar enough to that proposed in the Green Paper to warrant consideration
as a basis upon which to arrive at strong international consensus.

ISOC does not believe it is necessary for the Green Paper to attempt to
define the specifics of board makeup for the new IANA and that the board
makeup should be determined through public discussion, electronic forum,
and other iterative mechanisms to arrive at an acceptable resolution.  The
IETF has a long and successful track record of resolving complex and
difficult issues through this kind of process and these deliberative
processes can be used as a role model.

As the new IANA relates to TLDs, registries, and registrars, the Internet
Society offers the following observations which have recently been
discussed within the IAB and the IESG:

i. All TLDs, generic and country-code based, should derive their
authorization and existence from the new IANA.  The general rules of RFC
1591 <ftp://ftp.isi.edu/in-notes/rfc1591.txt would apply.

ii. The special gTLDs of .mil and .gov should be treated, for historical
reasons, as additional country code TLDs for the USA.

iii. For generic TLDs, the IANA board would designate either one registry
with responsibility for all gTLDs or several registries, each with
responsibility for one or more gTLDs.  The designation process would
involve proposals and competition; the registries would be operated as
non-profits clearly separated from any other components of the same
organization; title to the data and databases would clearly remain with
IANA (the registry would obtain no equity interest in the databases by
consequence of assembling, holding, or operating them); and, the IANA
contracts with registries would contain provisions for appeals, frequent
review of registry operations, auditing and testing of ability to
transition to other registry operators, and early termination of contracts
for not operating the registry efficiently or in accord with the public
interest.  IANA should be able to require performance bonds and/or other
mechanisms for ensuring appropriate behavior both during registry
operations and in the transition from one registry to another.

iv. In general and in the long term, economies of scale are likely to tend
toward a single registry, operated as above, for all or most gTLDs.
However, this is not a requirement; the IANA board may make other decisions
and arrangements.  For a short transition period (see vii., below), it is
likely that the registry for the existing gTLDs would be different from
that for new ones.

v. In general, all authorized registrars would be permitted to make
registrations in all gTLDs, and it would be a contractual requirement on
registries to accept such registrations.  Final review of qualifications
for registrars (and appeal from any delegated system) would rest with IANA
and not with the registry.   However, the IANA board may accept proposals
for specific gTLDs with different rules about candidates for registration
and registrars; as with any other gTLD, IANA shall designate an appropriate
registry.

vi. The operation of the root domain and corresponding servers and
supporting services is, as outlined in the GP, an IANA responsibility.
Should IANA choose to delegate day-to-day operational responsibility to an
organization with registry or registrar responsibilities, sufficient
contractual and organizational boundaries would be required to avoid any
plausible possibility of abuse of the relationship.

vii. For a transition period and in order to facilitate that transition,
the US government is encouraged to contract with a qualified organization
for the registry operation of any existing gTLDs (e.g. .edu, .gov) not
handled elsewhere.  Such a transitional contract should be short, should
explicitly recognize IANA’s oversight authority, and should contain the
general provisions outlined above (specifically, non profit, public trust
assumptions, IANA ownership of data, IANA appeal and audit, clear
separation from any organization in the registry or root operations
business  -  noting that several of these provisions are slight refinements
on those proposed in the Green Paper).

viii.  In order to support the speedy transition that is generally agreed
to be preferable to a long and extended process, the qualifications for
registrars established in the gTLD-MoU should be taken as a starting point.
The existing registrars authorized by that process should be recognized