IAB comments on Green Paper

[CCs clipped a bit]

> I am under the impression that late comments to the Green Paper might not
> have much impact but there is now also a proposed "rule" which the Dept. of
> Commerce have published. Being ignorant of US governmental procedures, I
> dont know what the exact process nor its implications are, and there seems
> to have been some doubt expressed (on the IETF list - so it could be
> nonsense) as to the legality of this move. I dont know.

I think that it is more sensible to see the references to US law
as defensive measures.  Ira Magaziner cannot move unilaterally;
he has to have some justification for his actions.  Given the context
in Washington, in which special prosecutors are appointed at a 
moment's notice, this is understandable.
 
> and I understand that there is about a month left on which to comment on this.

The comment period ends on 23 March.  Then there is talk of another
proposal being issued in June.
 
> I dont propose to start a parallel discussion here but my question to you
> guys is whether or not you think it might be useful to formulate a combined
> response from the European TLD administrators community / ISP community? I
> know some of you have met with Magaziner privately - do you believe he took
> your comments on board? (Again, I admit ignorance.) Do you think they will
> listen to comments from outside the US? Is the proposed rule a Bad Thing or
> a Good Thing, in your opinion? Does it affect us at all (since most of use
> country-level TLDs)?

It certainly has bad elements in it.  While I can understand why
Magaziner is citing a legal basis for his actions, they would seem
to act as a precedent for claiming that large and important parts of
the global Internet are subject to US law.  Specifically there is a
suggestion that this includes the nTLDs: if the root is subject to
US law, then US law can determine who controls the nTLDs.  For 
openers, the registry requirements in Appendix A really ought to
be applied to the nTLD registries, shouldn't they?  

Also, Network Solutions is being allowed to keep its monopoly control
over the existing gTLDs (.com, .net, .org) and monopolies aren't good
for anyone.
 
> Do we care?

We certainly should.

--
Jim Dixon                  VBCnet GB Ltd           http://www.vbc.net
tel +44 117 929 1316                             fax +44 117 927 2015




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