IP: a USACM letter on the dot us TLD

[David Farber <dave () farber net>]

> July 19, 2001
>
> The Honorable Donald L. Evans
> Secretary of Commerce
> U.S. Department of Commerce
> 1401 Constitution Avenue, NW
> Washington, DC  20230
>
> Dear Secretary Evans:
>
> As the Co-Chairs of the U.S. Public Policy Committee of the
> Association for Computing Machinery (USACM), we are
> writing to share our concerns regarding the Department of
> Commerce's Request for Quotation (RFQ)
> [SB1335-01-Q-0740]
> for services to establish centralized management and coordination
> of .US top-level domain (usTLD).  In our opinion, the RFQ
> incorporates the Internet community and American public's
> interest in the usTLD so inadequately that it should be rescinded
> and reissued with revised requirements.
>
> While we recognize the Department's current agreement for
> operation of the usTLD expires in November of this year,
> we are concerned that closing the RFQ period later this month
> as currently planned does not provide sufficient time to support
> an open and full public discussion on the future management of
> the usTLD.  Used almost exclusively for state and local
> governments, schools, and libraries, the usTLD is a public-owned
> commodity that is rightfully regarded by the Internet community as
> a national treasure.  Accordingly, the Department should be as
> diligent in transferring the usTLD as it is in the transfer of similar
> telecommunications resources, such as the allocation of spectrum for
> new advanced wireless services.  Unfortunately, the Department's
> RFQ does not reflect the U.S. Internet community's high regard for
> usTLD.
>
> The RFQ seems to be based on a desire for administrative
> continuity rather than to build a secure policy foundation for the
> future use of the usTLD.  By issuing the RFQ in this manner,
> the Department has unintentionally limited opportunities for
> informed consideration of this proposal.  Policy requirements
> of the RFQ that merit more discussion with the Internet
> community include its:
>
> * required adoption of directives promulgated by the Internet
> Corporation for Assigned Names and Numbers (ICANN)
> including a mandate to employ a "dispute resolution procedure"
> similar to an existing ICANN process criticized by certain
> members of the U.S. Internet community as "arbitrary"
> and "capricious";
>
> * creation of a "sunrise period" to allow registered trademark
> owners to reserve their trademarks as domain names in manner
> of concern to certain noncommercial and small business domain
> holders; and,
>
> * ambivalence that allows the contractor to profit from
> performance of the services contained in the RFQ without
> enforceable mechanisms to ensure accountability to all stakeholders
> of the U.S. Internet community, including the noncommercial and
> small business constituency.
>
> In summary, the Department has not completed a careful and
> complete evaluation of the public policy requirements for the
> current and future management of the usTLD sufficient to meet
> the diverse needs of the U.S. Internet community.  Considering
> the Department plans to close the RFQ period on July 27, 2001,
> we respectfully request the Department rescind or revise the
> RFQ at this time.   At a minimum, the process should be
> delayed until confirmation of and review by Ms. Nancy Victory,
> the Administration's designee to head the Department's National
> Telecommunication and Information Administration.
>
> The Association for Computing Machinery, an educational and
> scientific computing society with over 75,000 members, represents
> a large and influential block of Internet-users in the United States.
> The USACM is pleased to offer our technical expertise to the
> development of technology policy.  We have designated as
> contacts Jeff Grove at (202) 659-9711 and Kathryn Kleiman
> at (202) 842-2345 to assist your staff in achieving needed
> improvements in the solicitation.
>
> Sincerely,
>
> Barbara Simons, Ph.D.
> Eugene H. Spafford, Ph.D.
>
> Co-Chairs
> U.S. ACM Public Policy Committee (USACM)
> Association for Computing Machinery



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