All, I am attaching our official reaponse to the GIAW's draft discussion document and questions. Please feel free to review and offer comments as you will. Regards, -- Jeffrey A. Williams DIR. Internet Network Eng/SR. Java/CORBA Development Eng. Information Network Eng. Group. INEG. INC. E-Mail jwkckid1§ix.netcom.com Our response The following is a congruence of opinion givin by myself and in cull compliance and approval or our corporation and all of it's affiliates INEG. INC. & Associates JEffrey A. WIlliams ============================================================ A. A PROFILE OF THE FUTURE ENTITY 1. WHAT ARE THE FUNCTIONS AND POWERS OF THE ENTITY? a. MANAGE AND COORDINATE THE SYSTEMS; CREATE AND ALLOCATE DOMAIN NAMES AND IDENTIFIERS. ====== Our comments and/or recommendations To question #1 part (a) answer we would offer the following; We would agree that this should be the function of the "New Entity". It should however be done in conjunction and with the full voting approval of the "Stakeholders" and/or Internet community (Users) when policies are put forth or considered before the Board or any committee that may be determined or decided upon to provide for guidance and/or recommend such said procedures. This should be done to comply with the USG's "White Paper" recommendation of a "Bottom up" approach in reaching these decisions. We believe that these committees should also be selected by "Individual Stakeholder Vote" as should the Interim Board and the Permanent board of directors. We believe that in taking this path or choosing this method the best and broadest support for the New "Entity" and insure that all stakeholder groups have a fair and impartial input into the ongoing process of managing this proposed new "Entity". b. ESTABLISH A POLICY FOR THE DIRECT ALLOCATION OF IP BLOCKS OF NAMES TO REGIONAL INTERNET NUMBER REGISTRIES. ====== Our comments, questions and/or recommendations To question #1 part (b) answer we would offer the following; What needs to be determined is how and in what manner these IP Block allocations should be distributed and under what conditions? Should or can the current relative RFC's (RfC 1918 and RFC 2050) be modified? How do the current excess IP allocations to those that already have IP allocations that are not in use be reclaimed? Who and under what legal means should the reclaiming of excess IP allocations that are already distributed be effected? Currently there seems to be a precieved shortage in IPv4 IP allocations above a /21 allocation. The ARIN has discussed a reclaiming process that is strictly voluntary and has not been effective in even the smallest way. To the extent that voluntary reclaiming is unsuccessful a committee needs to be set up to seek methods of accomplishing either by voluntary or other legal means to reclaim these unused IPv4 allocations from those that seemingly are hording them and returned to a Pool for those that have need or use for those allocations. This committee should again be staffed by members duly empowered under existing law or other legal remedies that may become necessary and selected by majority vote by the stakeholder community at large in a referendum vote. Any and all policies should stand up to peer review by the stakeholders at large by referendum vote and review and approval by the Board of Directors before implementation. We also believe that other IP address systems (IPv6 (underway) and IPv8 for example) should be given serious consideration pending a technical and peer review as to add and or augment the existing IPv4 address space. This should also be given just and due serious consideration by the said committee as stated above. i. WHAT GUIDES, IF ANY, SHOULD BE ESTABLISHED (FOR THE INTERIM AND LATER ENTITY BOARDS IN THE ENTITY'S CONSTITUTIONAL? ====== Our comments, questions and/or recommendations To question #1 part (i) answer we would offer the following; One thing that should be considered as a guide is the "Bill Of Rights" to that was a balancing insterment in formulation of our country (United States of America). This was and remains at least as an important document as our Constitution is a it protect the individual. Such as it should be with the Constitution of the Internet. The Constitution of the Internet should contain language that is agreed upon by all upon a ratification process or individual stakeholder vote and yet remain flexible enough to add amendments form time to time to it much in the same way as is done the the US Constitution by a 2/3'rds Super Majority vote as is recomended by the White Paper for such possibilities. SOme language can even be borrowed from the US Constitution. Such as, "We hold these truths to be self evident, that all internet stakeholders are disposed as equals." "That they have certain inaliable rights." That among these are......... Some suggestions to these "Rights" would or might be but not necessarily in these terms: 1.) That each Internet stakeholder, be he/she/or it (Company or organization), have the right to use the internet to seek any and all information that is of a public nature in an uninhibited manner regardless of it's language of content. 2.) That each Internet stakeholder, be he/she/or it (Company or organization), have the right to approve any and all additions of gTLD's or TLD's be they of a private or public nature and any an all policies that may be determined in order to add these gTLD's or TLD's too the DNS system. 3.) That each Internet stakeholder, be he/she/or it (Company or organization), has the right to, as either an individual or as a grouped organization regardless of type, nature or stature, vote for any and all Board members, committee formations and any and all of that committees members. 4.) That each Internet stakeholder, be he/she/or it (Company or organization), have the indivertable opportunity to provide input or proposals to either the "Board of Directors", at any time, and that those proposals be given equal consideration regardless of origin. DOCUMENTS) IN CONNECTION WITH THE POLICY FOR, AND DIRECTING ALLOCATION OF, IP BLOCKS OF NAMES TO REGIONAL INTERNET NUMBER REGISTRIES? ------------------------------------------------ A.1.b.i. Comments: ====== Our comments, questions and/or recommendations To question #1 part (b.i) answer we would offer the following; See comments question #1 Part (b). ------------------------------------------------ c. ESTABLISH A POLICY FOR ADDING TLDS AND ESTABLISH THE QUALIFICATION FOR REGISTRARS AND REGISTRIES WITHIN THE SYSTEM. THE GOVERNMENT PAPER STATES THAT THE ENTITY SHOULD "DIRECT THE INTERIM BOARD TO DEVELOP POLICIES FOR THE ADDITION OF TLDS," AND, IN ADDITION, "ESTABLISH THE QUALIFICATIONS FOR DOMAIN NAME REGISTRARS WITHIN THE SYSTEM." i. SHOULD THESE POLICIES BE ESTABLISHED BY THE INTERIM BOARD OR BY THE FINAL REPRESENTATIVE BOARD OF THE ENTITY? ------------------------------------------------ A.1.c.i. Comments: ====== Our comments, questions and/or recommendations To question #1 part (c.i) answer we would offer the following; We have come to the conclusion that and addition of any new gTLD's and TLD's should be determined by the Final Board of Directors. And that any addition of gTLD's or TLD's must have the approval of the stakeholders at large by individual or organization Vote, where Organization= 1 Vote, should that be preferred by some organizations, or by Individual stakeholder=1 vote should that stakeholder choose to be represented in that manner. It is also our belief that any policies that may be developed or determined from time to time for the process of adding any new gTLD's and TLD's by any commette or by the Board of Directors themselves should be subject to peer review and or amended, by the stakeholders as is suggested in the White Paper. ------------------------------------------------ ii. SHOULD THE TWO POLICIES BE DIFFERENTLY TREATED? QUALIFICATIONS FOR DOMAIN REGISTRARS ARE DESIGNED TO PROVIDE QUALITY SERVICES TO THE INTERNET COMMUNITY INCLUDING THE ENCOURAGEMENT OF COMPETITION AMONG POTENTIAL AND EXISTING REGISTERIES AND REGISTRARS. TLD IS DESIGNED IN PART TO MEET DEMAND FOR NAMES AND REDUCE THE PRICE OF THE EXISTING NAME INVENTORY WHILE AT THE SAME TIME MAINTAIN THE STABILITY AND COHERENCE OF THE SYSTEM. HENCE, THE CONFERENCE MAY PROVIDE SEPARATE GUIDELINES TO EACH OF THESE POLICIES. SHOULD THESE GUIDELINES BE REVISITED AFTER THE INTERIM BOARD HAS ARTICULATED THE POLICIES? ------------------------------------------------ A.1.c.ii. Comments: ====== Our comments, questions and/or recommendations To question #1 part (c.ii) answer we would offer the following; First it our opinion that existing guidelines for registrars and registries are or soon will be inconsequential as the new "Entity" should have the opportunity to provide for it's own guidelines for Registrars and Registries. So any suggestion of a policy here is really invalid at such time that the Permanent Board of Directors are in place. We realize that during transition that the Iterimm Board will need to continue the present practice, such as it is. But it is that practice of determining what or whom may become a registrar or a registry in the private sector that of consideration in the forming of this new "Entity". The Interim Board should not have any powers to effect this situation presently without the vote of the stakeholders at large. We think it would be in everyones best interest to allow for the Permanent Board of Directors and any committees that may be formed to make these policies with the full approval of the stakeholders at large by either referendum vote or by ratification process, pending peer review. ------------------------------------------------ iii. SHOULD THIS WORKSHOP DEAL WITH THESE ISSUES? ------------------------------------------------ A.1.c.iii. Comments: ====== Our comments, questions and/or recommendations To question #1 part (ciii) answer we would offer the following; We believe that due to the shortness of time scheduled for this conference that it would be unwise to do so at this conference But that this workshop could be formulated and done at another scheduled conference or via electronic media exchange process or both. ------------------------------------------------ d. EVALUATE AND SUPERVISE THE IMPLEMENTATION OF THE POLICY IN ORDER TO DETERMINE THE CIRCUMSTANCES UNDER WHICH THE TLDS ARE ADDED TO THE ROOT SYSTEM. i. WHO SHOULD SET FORTH THE POLICY FOR DETERMINING THE CIRCUMSTANCES UNDER WHICH NEW TLDS ARE ADDED TO THE ROOT SYSTEM? ------------------------------------------------ A.1.d.i. Comments: ====== Our comments, questions and/or recommendations To question #1 part (d.i) answer we would offer the following; It is our considered recommendation and/or suggestion that the new "Entity's" Permanent Board of Directors, as one of its first orders of business mandate that a committee be set up consisting of both volunteers and Paid staff members, that both are subject to Stakeholder referendum vote, immediately determine what policies(s) that should be used for Registrars, Registries ISP's, and or IAP's for determining what and how many new gTLD's and TLD's should or could be added to the Root system. This committee should be open to excepting input from the Internet community as to what gTLD's or TLD's they would like to see or would suggest. ------------------------------------------------ ii. WHAT GUIDELINES, IF ANY SHOULD BE PROVIDED TO THOSE WHO WOULD SET FORTH THIS POLICY? SHOULD THIS CONFERENCE DEAL WITH THIS QUESTION? ------------------------------------------------ A.1.d.ii. Comments: ====== Our comments, questions and/or recommendations To question #1 part (d.ii) answer we would offer the following; See answer to these questions in Part (d.i). ------------------------------------------------ iii. WHAT OTHER CONTROVERSIAL ISSUES INVOLVE MANAGEMENT? SHOULD THESE ISSUES BE DEFINED AND SET ASIDE FOR ANOTHER SESSION? SHOULD THE WORKSHOP PROVIDE PROCESS FOR RESOLVING CONTROVERSIAL ISSUES? ------------------------------------------------ A.1.d.iii. Comments: ====== Our comments, questions and/or recommendations To question #1 part (d.iii) answer we would offer the following; As to what other controversial issues involve management, it is our opinion any and all controversial issues should be of great interest to management They should be involved actively as well. As to "should the workshop provide a process for resolving controversial issues?" It is our belief that the workshop should prepared to set up a forum and process to settle these issues, but that there is not enough time in this short forum to go much beyond that. ------------------------------------------------ e. SUPERVISE THE OPERATION OF THE AUTHORITATIVE ROOT SERVER SYSTEM, AND COORDINATE THE ASSIGNMENT OF OTHER INTERNET TECHNICAL PARAMETERS AS NEEDED TO MAINTAIN CONNECTIVITY ON THE INTERNET. i. IS THERE A NEED TO PROVIDE GUIDES FOR SUPERVISORY AND COORDINATING FUNCTIONS? DO THESE FUNCTIONS REST ON PROFESSIONAL EXPERTISE, REGARDLESS OF INTERESTS? ------------------------------------------------ A.1.e.i. Comments: ====== Our comments, questions and/or recommendations To question #1 part (e.i) answer we would offer the following; We believe that the current Root server system needs to be reengineered. That there needs to be a migration from the current hiarchial system to a more advanced technical system or that the current Root server system needs expansion and more diversity or at least that some input to some other Root server system needs to be considered. There are many other alternatives that have been tested an some that are currently in use that should be given consideration to being included into the current Root server system. We also believe that professionals and/or those that have either experience or equivalent experience should be coordination these functions. ------------------------------------------------ ii. ARE THERE SUPERVISORY AND COORDINATING FUNCTIONS THAT INVOLVE POLICY DETERMINATIONS? IF SO, WHICH ARE THEY? ------------------------------------------------ A.1.e.ii. Comments: ====== Our comments, questions and/or recommendations To question #1 part (e.ii) answer we would offer the following; They should have viable and considered input to policy determinations. But that a committee should be set up to make these policy determinations. And that that committee should have the full approval and be mandated by the Permanent Board of Directors with the stakeholders vote as to whom will be serving on that committee and for how long. ------------------------------------------------ f. COORDINATE THE ASSIGNMENT OF OTHER INTERNET TECHNICAL PARAMETERS. g. SERVE IN A QUASI-JUDICIAL CAPACITY IN REVIEWING ADMINISTRATIVE ACTIONS. i. WHOSE ADMINISTRATIVE ACTIONS ARE TO BE EVALUATED? WHO ARE THE PARTIES? WILL IT BE A JUDICIAL ADVERSARIAL PROCESS AND WHY? ------------------------------------------------ A.1.g.i. Comments: ====== Our comments, questions and/or recommendations To question #1 part (g.i) answer we would offer the following; With respect to (e.), the IANA and other apropriate should be the reviewing body for coordinating body for internet technical parameters as is recommended in the White Paper. The other bodies that may or could be considered might be the IETF, W3C, and a group that is determined by the Board of directors as an independent body or that a totally Independent body determined by the Permanent Board of Directors with the input from the IANA, IETF and the W3C for advisory purposes. With respect to (f.), the Permanent Board of Directors should have a judicial advisory staff to handle any legal situations that may be required, but that that Permanent Board of Directors should serve in that judicial capacity. This should be incorporated in the Constitution of the Internet as part of it's articles. With respect to (i.), there should be the availability of judicial review should the membership or the Stakeholders request it. ------------------------------------------------ 2. WHAT ARE THE ASPIRATIONS AND FUNDAMENTAL PRINCIPLES THAT SHOULD GOVERN THE ENTITY, ITS DECISION MAKING BODIES, ITS STRUCTURE AND OPERATIONS? ====== Our comments, questions and/or recommendations To question #2 part (d.ii) answer we would offer the following; The fundamental principals should be determined and included within the Constitution of the Internet and the "Internet Bill of Rights" The principals should be worked out by the stakeholders in a series of "Internet Constitutional Conventions". THESE ASPIRATIONS AND FUNDAMENTAL PRINCIPLES SHOULD BE CONTAINED IN THE CONSTITUTIONAL DOCUMENTS OF THE ENTITY. THEY SHOULD GUIDE DECISION MAKERS IN CONFLICT RESOLUTION PROCEEDINGS TO BE APPLIED IN PARTICULAR CASES. a. MAINTAIN STABILITY AND PREDICTABILITY OF DOMAIN NAME AND IDENTIFIERS ALLOCATION, COORDINATION AND MANAGEMENT PROCESS. HOW IS THIS OBJECTIVE TO BE ACHIEVED? i. ESTABLISH TECHNICAL CRITERIA AND POLICIES IN THE FORM OF GENERAL PRINCIPLES, RULES, AND PROCESSES (RULES). THE PRINCIPLES UNDERLYING THE POLICIES SHOULD AIM AT MAINTAINING THE INTEGRITY AND DEVELOPMENT OF THE INTERNET, ENCOURAGING COMPETITION AMONG SERVICE PROVIDERS AND TAKE INTO CONSIDERATION THE VITAL INTERESTS OF THE AFFECTED PARTIES (DIRECTLY AND INDIRECTLY). ------------------------------------------------ A.2.a.i. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.i.) answer we would offer the following; In essence we agree with these proposals. It however incumbent to realize that these proposals must be given to the internet Stakeholders to approve and consider for their individual vote. ------------------------------------------------ ii. ESTABLISH GENERAL CONDITIONS FOR PROSPECTIVE CHANGES OF RULES. RETROACTIVE RULE CHANGES WILL NOT BE ADOPTED EXCEPT IN UNIQUE SITUATIONS. ------------------------------------------------ A.2.a.ii. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.ii) answer we would offer the following; And yes, we agree. An yet again this principal must indeed be approved by the stakeholders by individual vote prior to adoption or implementation. ------------------------------------------------ iii. PUBLISH THE RULES AND THE REASONS FOR THEIR ADOPTION. REFRAIN FROM TAKING ACTION BEFORE THEY ARE PUBLISHED. ------------------------------------------------ A.2.a.iii. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.iii) answer we would offer the following; We agree in total with this resolution. ------------------------------------------------ iv. PROVIDE OPPORTUNITY FOR HEARINGS ON THE RULES AND CHANGES ------------------------------------------------ A.2.a.iv. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.ii) answer we would offer the following; We agree totally with this. We would add however that upon conclusion of those hearings that any resolutions that may be reached be given to the stakeholder community for their vote before adopted and /or implemented and that that a majority vote must be reached before implementation can proceed. ------------------------------------------------ v. ALLOW AD-HOC CHANGES WITH RESPECT TO PARTICULAR SITUATIONS AFTER NOTICE OF THE APPLICATION FOR CHANGES, AND OPPORTUNITY FOR HEARING AND PRESENTATION BY AFFECTED PARTIES. ------------------------------------------------ A.2.a.v. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.v.) answer we would offer the following; We agree in as far as to provide for resolution of Domain Name disputes or gTLD/Tld collisions. As for any other rule ad-hoc changes they must receive a peer review and approval by the vote in majority of the Stakeholder community. ------------------------------------------------ vi. PUBLISH OTHER INFORMATION THAT THE MEMBERSHIP OF THE INTERNET COMMUNITIES MAY BE INTERESTED IN RECEIVING; ------------------------------------------------ A.2.a.vi. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.ii) answer we would offer the following; The Internet community IS the membership by default. ------------------------------------------------ vii. ESTABLISH PROCEDURES TO PREVENT THE USE OF THE PROCESSES DESCRIBED ABOVE IN ORDER TO SLOW DOWN OR PREVENT DECISIONS BY THE ENTITY, ESPECIALLY WITH RESPECT TO DAY TO DAY OPERATIONS. ------------------------------------------------ A.2.a.vii. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.vii) answer we would offer the following; We tend to agree as long as that procedure does not exclude the review and vote of the Stakeholder community except where day to day operations issues are concerned. ------------------------------------------------ b. SEEK CONSUMER SATISFACTION: PROVIDING CHOICES, LOWER COSTS, INNOVATIVE AND DIVERSE SERVICES. HOW IS THIS OBJECTIVE TO BE ACHIEVED? i. ENCOURAGE COMPETITION AMONG SERVICE PROVIDERS; ------------------------------------------------ A.2.b.i. Comments: ====== Our comments, questions and/or recommendations To question #2 part (a.ii) answer we would offer the following; To achieve consumer satisfaction and diversity of service is a hand in glove in our experience The internet community must be served to the best of the "Entity's" ability and should be paramount in any decision that is to be considered. Competition should always be encouraged and even assisted in and where it can be done without diversely effecting the Internet User in general. ------------------------------------------------ ii. AVOID PRACTICES THAT CONTRIBUTE TO MONOPOLIES. ------------------------------------------------ A.2.b.ii. Comments: ====== Our comments, questions and/or recommendations To question #2 part (b.ii) answer we would offer the following; We agree with this completely. ------------------------------------------------ iii. OTHERS? ------------------------------------------------ A.2.b.iii. Comments: ------------------------------------------------ c. ATTAIN FLEXIBILITY THROUGH PRIVATE SECTOR, BOTTOM-UP COORDINATION. HOW IS THIS OBJECTIVE TO BE ACHIEVED? ====== Our comments, questions and/or recommendations To question #2 part (c) answer we would offer the following; To achieve this is really something that should be built into the Internet Constitution. We consider that providing competition, diversity of services, expanding the Root server system and IP address space protocols that coming form the Internet software development community sector of the Internet community this will be self perpetuating. i. ESTABLISH CHANNELS OF COMMUNICATIONS AND RESPONSIVE MECHANISMS TO INTERNET COMMUNITIES MEMBERS. ------------------------------------------------ A.2.c.i. Comments: ====== Our comments, questions and/or recommendations To question #2 part (c.i.) answer we would offer the following; It is paramount that good and numerous channels should be provided in order for the new "Entity" to be successful. ------------------------------------------------ ii. OTHERS? ------------------------------------------------ A.2.c.ii. Comments: ------------------------------------------------ d. USE AN OPEN, TRANSPARENT DECISION MAKING PROCESS THAT INVOLVES NOTICE AND HEARING OR AN OPPORTUNITY OF PRESENTING VIEWS. ====== Our comments, questions and/or recommendations To question #2 part (d) answer we would offer the following; The process to which this must be accomplished should be as diverse and encompassing as can be possibly done and constantly viewed for improvement. i. BOARD MEETINGS CAN BE CLOSED, EXCEPT FOR MEETINGS CONSIDERING POLICY DECISIONS IN WHICH PRESENTATIONS ARE MADE. THESE SHOULD BE CONDUCTED OPENLY, AS SUCH MEETINGS ARE UNDER THE SUNSHINE ACT. ------------------------------------------------ A.2.d.i. Comments: ====== Our comments, questions and/or recommendations To question #2 part (d.i.) answer we would offer the following; Andy and all board meetings or committee meetings should have minutes must be published for the Internet community to review and post or input comments as and where that Stakeholder community sees fit. These Minuteness must be published on multiple forums. ------------------------------------------------ e. ESTABLISH A BROAD-BASED REPRESENTATION OF THE INTERNET COMMUNITIES (IN THE U.S. AND ABROAD) AS A WHOLE, AND MEDIATE AMONG THEReceived on Sun Jun 28 1998 - 21:18:39 UTC
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