U. S. Department of Commerce

National Telecommunications and Information Administration

14th and Constitution Avenues, N.W.

Washington, D.C. 20230

RE: Comments on the Green Paper (Technical Management of Internet Names and Addresses) from the Internet Council of Registrars (CORE)


To Whom It May Concern,

The following is the response of the Internet Council of Registrars (CORE) to the Green Paper (GP) published Jan. 30, 1998. This document tracks through the proposals outlined in the Green Paper and provides specific comments and recommendations on solving the most critical issues necessary for launching a new era of self-governance and competition in the Domain Name System.

These issues include: speedy transition to deregulation; operating not-for-profit registries in the public trust; ending the current monopoly and not creating new ones; encouraging competition among registrars; preventing the creation of new mechanisms or regulatory processes where none are needed; supporting an existing dispute resolution process; and ensuring that users everywhere have the broadest choice for securing and administering their domain names at competitive prices.

In preparing its response to the Green Paper, CORE sought the input of its members from throughout the world, international organizations, Internet experts and other stakeholders in this phenomenon known as the Internet. The comments and recommendations reflect this process and consensus on ten steps that can be taken immediately and with utmost confidence to ensure the future success of the Domain Name System (DNS) in a global, deregulated framework.

Alan Hanson

Chairman, Executive Committee

Internet Council of Registrars

c/o First Identity Net

6050-a Avenida Encinas

Carlsbad, CA 92009



CORE agrees with the U.S. Government (USG) that the Internet is rapidly becoming an international medium for commerce, education and communication and that evolution needs to occur to solve problems with lack of competition in domain name registration. CORE also agrees with the Green Paper in its call for a bottom-up, consensus-building program, a central authority to manage the authoritative Root and an end to the participation of U.S. agencies, including the National Science Foundation (NSF), in funding these activities.

Although the stated purpose of the Green Paper, or Magaziner Plan, is to get the U.S. Government out of the Internet, in actuality it calls for the U.S. Government to become more deeply involved than ever before and delays the natural evolution that is well underway. The major concerns with the Green Paper proposals include:

In the eyes of the world Internet community, the Internet doesn’t need a plan for the U.S. Government to get out of domain name oversight an area where it was previously not involved. It just needs the U.S. Government to step aside quietly and allow the Internet Assigned Numbers Authority (IANA) to become a private, non-profit U.S. corporation managing the DNS, as it has for more than 15 years. The Internet can then manage its own affairs through global consensus and cooperation, with the support of existing volunteer organizations, industry groups, task forces and societies.

The Internet consensus and governance process has never been and should not be managed by a national government. Self-governance is just that and CORE believes the immediate transition can be achieved smoothly, quickly and transparently, with no impact on functionality and stability of the Internet.


The Green Paper noted that consultations have revealed substantial differences among Internet stakeholders on how the domain name system should evolve. It outlined four shared principles from its discussions with Internet stakeholders, although the breadth of consensus is not known since all discussions were carried out in private as part of an internal U.S. Government process.

1. Stability

To quote the Green Paper: "The U.S. Government should end its role in the Internet number and name address systems in a responsible manner. This means, above all else, ensuring the stability of the Internet. The Internet functions well today, but its current technical management is probably not viable over the long term. We should not wait for it to break down before acting. Yet, we should not move so quickly, or depart so radically from the existing structures, that we disrupt the functioning of the Internet. The introduction of a new system should not disrupt current operations, or create competing Root systems."

The role of the USG has been to fund certain technical, administrative activities through the National Science Foundation. It has been a silent partner, providing no direct impact on the stability, protocols or operations of the Internet. This has been widely documented in various Requests for Comment and other agreements, including its cooperative agreement with NSI signed in 1992 which recognized IANA as having the discretionary authority over TLDs. Internet Standards established by the Internet Engineering Task Force (IETF), Internet Architecture Board (IAB) and Internet Engineering Steering Group (IESG) provide proven precedents for operating the technical aspects of the Internet without government oversight.

The U.S. Government has been visibly absent from involvement in the Domain Name System until it began contemplating the end of the five-year contract with Network Solutions, Inc. (NSI) and raised the issue to its highest political level, with the White House.

The end to NSI's role of profit-oriented .com/.net/.org registry has no stability implications. Rerouting can be handled routinely and seamlessly, as proven during recent tests at IANA. Its ongoing experience with country codes demonstrates how hundreds of new domains can be added with no concern for stability.

The Internet has grown and served people well all over the world because it has been driven by consensus and without government interference. The most responsible thing the U.S. Government can do is end its contract with NSI on March 31, 1998, facilitate transition of complete authority for the Root zone to IANA, reassert IANA’s authority over the existing TLD registrars, including NSI, ensure that the software and information collected by NSI during its Cooperative Agreement are fully accessible to the public, encourage competition by eliminating subsidies or favored treatment for NSI and abandon any attempts, however well intentioned, at creating new and unnecessary regulatory bodies.

Sufficient oversight is provided through the generic Top Level Domain Memorandum of Understanding (gTLD-MoU) and a structure that includes the Policy Oversight Committee and the Policy Advisory Body, with ongoing input from the world Internet community and a separate dispute resolution process through the World Intellectual Property Organization. Such a change would have no impact on stability and, given widespread international participation, could enhance it.

2. Competition

The U.S. Government makes its own point on this issue in the section on Competition:

"The Internet succeeds in great measure because it is a decentralized system that encourages innovation and maximizes individual freedom. Where possible, market mechanisms that support competition and consumer choice should drive the technical management of the Internet because they will promote innovation, preserve diversity, and enhance user choice and satisfaction."

CORE and Internet experts from around the world agree with this statement regarding market forces and competition. However, the Green Paper doesn’t propose actions to support this philosophy. Instead, it calls for the perpetuation and consolidation of the NSI monopoly, adding new monopolies owning single TLDs and ignoring the gTLD-MoU process, which provides solutions to most of the issues outlined in the Green Paper.

The success of the Internet should be allowed to continue unabated and unhindered by unnecessary government intervention, by any government.

3. Private, Bottom-Up Coordination

The Green Paper notes: "Certain technical management functions require coordination. In these cases, responsible, private-sector action is preferable to government control. A private coordinating process is likely to be more flexible than government and to move rapidly enough to meet the changing needs of the Internet and of Internet users. The private process should, as far as possible, reflect the bottom-up governance that has characterized development of the Internet to date."

The U.S. Government discusses the need for a bottom-up approach, then flip-flops to provide top-down directions of great detail.

The IANA and ISOC recognized the need for bottom-up consensus when they launched the International Ad Hoc Committee (IAHC) process with the support of organizations throughout the world. CORE/POC evolved from this bottom-up process, which continues as CORE prepares to add more registrars, open up the CORE Memorandum of Understanding for further public comment and provide its Shared Registry System to any other qualified not-for-profit registry. Rather than create something out of whole cloth, the U.S. Government can use the CORE bottom-up model to speed the transition in the spirit of global consensus.

4. Representation.

The U.S. Government notes: "Technical management of the Internet should reflect the diversity of its users and their needs. Mechanisms should be established to ensure international input in decision making."

Many mechanisms exist, such as those established by IANA, the Internet Engineering Task Force (IETF), Internet Architectural Board (IAB) and the Internet Engineering Steering Group (IESG). As outlined in RFC 2026, "The Internet Standards Process," the procedures are designed to be fair, open and objective; to reflect existing (proven) practice; and to be flexible. Through the rigorous consensus-building process carried out by the International Ad Hoc Committee, broad representation from the global Internet community created a generic Top Level Domain Memorandum of Understanding (gTLD-MoU), providing specific standards for Registry and Registrar functions. There is no need for additional mechanisms at this time. Broad global interests will continue to cooperate and provide a collective body of expertise that far surpasses what would be available from a single entity. Should there be a future need for new mechanisms, the mechanisms should evolve from the existing consensus-building processes.


The Coordinated Functions

There is widespread agreement with the conclusion of the Green Paper that management of number addresses is best done on a coordinated basis. Further, overall policy guidance and control of the TLDs and the Internet Root server system should be vested in a single organization that is representative of Internet users.

CORE’s survey of the global Internet community found general consensus on need for the creation of a "new IANA," an independent not-for-profit organization. Since the change is really only one of corporate structure, or form rather than function, there is no need to perpetuate the NSI monopoly while waiting for a new corporate structure to become official. IANA is fully capable of continuing to carry out all duties required as designated authority for the Root zone and executing the many critical steps necessary to introduce competition and provide for stable expansion of the number of TLDs.

IANA can add new TLDs to the Root zone today, immediately launching a new era of competition. The transition can be seamless and painless. There is no need for U.S. Government "policy oversight," since IANA performed admirably without it in the past. The only thing needed from the U.S. Government is for it to stop funding IANA and allow it to move forward as recommended in the IANA plan of January 1998 and with the support of the Internet Society, IETF, IAB, IESG, CORE and other interested parties from the Internet community.

This bottom-up approach should also determine the makeup of the board of directors of IANA, its bylaws, policies, procedures, funding and other details. The evolution should not rely on a top-down artificial structure dictated by the U.S. Government or any other government. The Green Paper mentions some concerns about "premature government exit." This is a myth, except with vested interests, such as the current monopoly, NSI, which welcomes continuation of the status quo. The Internet community is more concerned with unnecessary government involvement rather than premature government exit.

The Competitive Functions -- Introduction

The Green Paper notes that the system for registering second-level domain names and the management of the TLD registries should become competitive and market-driven. It says there appears to be strong consensus that the registrar function should be competitive. The paper says there is disagreement, however, over the wisdom of promoting competition at the registry level.

The Benefits of Not-for-Profit Registries

CORE, the Internet Society, Educom, European Union and many other organizations believe Registries should be operated as non-profit and in the public trust. Since registries are largely administrative, back-office operations, there is no need to compete. They have little, if anything, to offer in added value for customers, since customers would deal with Registrars.

The concept of establishing single gTLD registries as new parallel monopolies would cripple competition. Registries operating in an unregulated environment as proposed by the Green Paper would own gTLDs rather than simply administer them, opening the way for predatory pricing practices and gouging. Users would have zero portability of their names and would have to either pay or abandon them. It is unlikely someone wanting a .com or .biz TLD would opt for .tree even if the monopoly registries were price gouging. Single gTLD registries would have no need to market or innovate and would be almost totally insulated from market pressures. The Green Paper talks about supply-side competition but ignores the demand side. It also misses the difference between two separate markets: initial Secondary Level Domain (SLD) registrations, and renewals.

As long as one wanted to keep his or her domain name, there would be no option but to pay whatever the Registry charged. This potential "monopoly lock-in" must be avoided at all costs. Today’s $35 renewal fee could become next year’s $350 renewal in a monopoly situation.

Addresses should be owned by the individual and be fully portable among Registrars, just as one moves a surname and phone number from one long-distance telephone company to another. If a registry is operated as a non-profit organization and with a Shared Registry System (SRS) for multiple domains, users could shop among registrars for the best prices and service. The gTLDs should be like the oceans, the moon or the sky – open to everyone and owned by no one.

The Creation of New gTLDs

The Green Paper says some concern for the stability of the system requires that expansion of gTLDs proceed at a "deliberate and controlled pace" to allow for evaluation of the impact of the new gTLDs and well-reasoned evolution of the domain space. Further, it notes that the number of new top-level domains should be large enough to create competition among registries and to enable the new corporation to evaluate the functioning, in the new environment, of the Root server system and the software systems that enable shared registration. At the same time, it should not be so large as to "destabilize the Internet."

As noted earlier, proven systems and procedures are in place to ensure the stability of the Internet. Comments by the IAB and other technical experts indicate there should be no concern with adding multiple new gTLDs. Dr. Jon Postel, of IANA, originally proposed adding up to 150 to provide more choices for users worldwide. The number of new gTLDs should be determined based on evaluation by IANA and customer need, not artificial mechanisms. The IAB noted there is no technical reason for the proposed limit of one gTLD per registry. The seven gTLDs proposed by CORE were selected by POC based on an international consensus developed independently of CORE.

The scarcity of gTLDs proposed in the Green Paper would enhance the monopolistic power of each profit-oriented registry. With few gTLDs, the best strategy for profit-oriented registries would be to charge monopolistic prices from the start because price increases might be difficult and the price competition will only start as soon as a wide choice of gTLDs appears.

Giving each registry a maximum of one start-up gTLD would be anti-competitive when the current NSI monopoly is allowed to keep three. From an investment standpoint, running a single gTLD radically increases capital and operational costs per gTLD for all except NSI. Many single gTLDs would not be popular enough to support a monopoly registry, resulting in significantly higher costs for users or the potential failure of small registries. Today’s software and hardware provide the capability of handling hundreds of TLDs on the same machine for maximum efficiency.

The Green Paper notes that different Registries could have different policies, data format, protocols and design interfaces. This could lead to instability and confusion. On the other hand, there will be significant cost savings and improved efficiencies and effectiveness from having a Registry administer multiple gTLDs.

CORE has developed the software for a Shared Registry System that provides a technically advanced interface for Registrars and instant online confirmation of domain registrations. The benefits of a SRS with multiple gTLDs include: lower costs, standardized and reliable service, stability and international portability. The CORE SRS is undergoing acceptance testing and load-testing for production use. Registrars have interfaced their systems with the SRS and are ready to begin live user registrations from servers on five continents.


Competition among Registrars is useful and desirable. It allows users to choose different suppliers for the same goods he or she wants. The CORE model puts power in the hands of the consumer. The non-profit Registry runs on a cost-recovery basis and Registrars compete on the price and efficiency of their administrative work and any other services that provide added value.

The gTLD-MoU and CORE MoU can provide the ethical foundations for new Registrars. It has been signed by more than 200 organizations from throughout the world. It eliminates many of the problems that could be experienced with a for-profit Registry of a single gTLD and a captive group of Registrars. Among the potential abuses, the MoU addresses "cybersquatting," where an entity grabs multiple SLDs and then attempts to charge whatever the traffic will bear to the individual who wants the name. It deals with other issues raised by the Green Paper, such as providing a legislative framework for registrars, independent oversight (POC) and acting with the advice of an independent and open body, the Policy Advisory Body (PAB).

The Trademark Dilemma

The Green Paper proposes that each name registry establish minimum dispute resolution and other procedures related to trademark considerations.

Multiple rules for identical problems will cause confusion, create worldwide chaos and a full-employment act for trademark attorneys. Such a random approach would maximize rather than minimize the potential for litigation.

Under the gTLD-MoU, dispute resolution can be handled quickly and effectively with binding arbitration administered through the Domain Name Arbitration and Mediation Center under the World Intellectual Property Organization. The WIPO provides a Domain Name Challenge Panel so intellectual property owners have the ability to exercise their rights in a world forum through an independent process. The process involved full and repeated consultation with relevant public sector and private sector stakeholders in the trademark field, public vetting and applying the rules decided by POC under the advice of the PAB. By working with WIPO, the International Ad Hoc Committee laid the foundation to deal with the complex worldwide issues surrounding copyrights, patents and other intellectual property issues. The jurisdiction should lie with country of the registrar as is noted in Appendix C of the MoU. This solution best enables registrants to be subject to their own laws while leaving room for competition and oversight (registrants must be in countries that are bound by basic international treaties regarding intellectual property).


The Green Paper outlines a transition program that adds many intervening factors, delays the transition and perpetuates the monopoly for almost three years.

The NSI Agreement

It is regrettable that the Green Paper calls for perpetuating the NSI monopoly over three TLDs -- .com, .org and .net – and limits competing registries to single TLDs.

On the NSI Agreement, there is no need for a ramp down. The U.S. Government can easily end the agreement March 31, rather than delay the transition to self-governance. NSI can propose to IANA to operate a not-for-profit shared registry system. The domains of .com, .org and .net could also be administered through CORE, which would increase efficiencies and lower costs for registrants.

Delaying the Process

The Green Paper notes that the proposed new IANA corporation cannot be established overnight and suggests that it probably wouldn’t be fully operational before September 30, 1998. It uses a traditional business-oriented model for the new corporation, with a CEO and board of directors.

As noted earlier, IANA can operate during the transition period exactly as it is. Rather than creating the new corporation with a U.S. business model, with board and CEO, invoke the bottom-up program from IETF. The U.S. Government hasn’t been involved in the DNS in the past, doesn’t need to be in the future and only needs to take no action to be successful.

In terms of potential liabilities for IANA in the transition process, CORE announced in January that it would indemnify IANA against liabilities so the transition process can move forward unabated.

Decidedly Non-Level Playing Field for Registries and new gTLDs

The U.S. Government has given favored status to NSI for the past five years and the Green Paper preserves NSI in the commanding position of being Registry and Registrar with a thin veil between them, managing three highly-valued gTLDs as a monopoly. NSI has its own oversight authority and conflict-resolution body. Giving NSI these incompatible roles would be the equivalent of giving a securities exchange a monopoly to trade the most liquid stocks, letting it own some of its members and allowing it to run its own Securities and Exchange Commission.

That done, the GP then proposes to create five weak net entities, each limited to one hitherto unknown gTLD, to also be managed as monopolies.

It would be difficult to imagine creating a more effective system to assure the success of NSI and the failure of most if not all of the new registries. The U.S. Government, in essence, is providing a continuing subsidy and sponsorship of a private corporation while limiting, or delaying, the introduction of competition.

Competing Registrars and Policy Oversight

The Memorandum of Understanding, hammered out over many months by the stakeholders, provides a solid standard for ethical and professional performance. IANA, POC and PAB can establish an ongoing review process for further requirements, if needed at all.

CORE Registrars are strictly prohibited from warehousing or cybersquatting, specifically "registering SLDs for their own account or for accounts of an Affiliate for the purpose of trafficking in SLDs for sale, resale or transfer to applicants." CORE believes that such a provision is essential to the self governance of the Internet. The regulatory oversight of the gTLD-MoU process provides for self-regulation of the Internet through international consensus of the stakeholders, a broader and more efficient process than could be accomplished by any government.

The Root Server System

The Green Paper suggests that IANA and the U.S. Government, in cooperation with NSI, the IAB, and other relevant organizations, will undertake a review of the Root server system to recommend means to increase the security and professional management of the system. Further, the recommendations of the study should be implemented as part of the transition process to the new corporation.

As with other recommendations of the Green Paper, there is no need for government involvement in this process. Nor is NSI a stakeholder in the Root server. The processes and procedures of the IETF, IAB, and IESG as non-profit, open-membership, consensus-oriented volunteer organizations can oversee this process for the ultimate benefit of all concerned.

The Process

CORE applauds the U.S. Government for recognizing "that its unique role in the Internet domain name system should end as soon as is practical" and in a responsible manner that preserves the stability of the Internet. Its stated goal is to seek as strong a consensus as possible so that a new, open, and accountable system can emerge that is legitimate in the eyes of all Internet stakeholders. However, it proposes to take over the process.

Summary and Recommended Action Plan

The Green Paper talks about self-governance and the U.S. Government stepping down, but its recommendations do the opposite. It proposes to end U.S. Government stewardship over the Domain Name System (DNS) and open the Internet to self-governance and international competition. Instead, the Green Paper would insert the U.S. Government into a policy oversight role over the worldwide DNS system and create new and unnecessary regulatory bodies and artificial market mechanisms. It would also perpetuate the NSI monopoly and give NSI significant competitive advantage with three domains, while limiting other Registries to one each.

The widely held view among the world Internet community is that instead of getting the U.S. Government out of the Internet quickly and painlessly, the Green Paper inserts its agencies more deeply than ever before and puts unnecessary road blocks in the way of deregulation and global growth. Some in the international Internet community view the Green Paper as an attempt by the U.S. Government to claim ownership of the Internet. This has been documented in papers from the European Union, government of Australia, France Telecom and others.

In summary, no one owns the Internet. The Internet Architecture Board described it: "The Internet, a loosely organized international collaboration of autonomous, interconnected networks, supports host-to-host communication through voluntary adherence to open protocols and procedures defined by Internet Standards." The Internet has grown exponentially and thrived from consensus-building and cooperation and without government intervention.

The Evolution is Already Under Way – By Consensus

Many of the issues raised by the Green Paper have been addressed and resolved through the gTLD-MoU process over the past 18 months. These include: adding competition to domain name registration; establishing a mechanism for resolving conflict between trademark holders and domain name holders; recognizing the growing percentage of users outside the U.S. and giving them a larger voice in the process; developing a system that is accountable to the Internet community; and supporting the evolution of the Internet as a commercial medium.

The technical and mechanical aspects have been handled professionally and well, with global consensus and cooperation and through volunteer groups, such as the IETF, IAB, IESG and others. The existing Internet Standards Process ensures an open, public debate on the issues and wide review before modifications occur. IANA has proposed a transition plan, which is widely supported and moving forward in the Internet tradition -- without the need for government involvement.

The U.S. Government has been a silent financial partner in the DNS. Its has funded activities for administering the authoritative Root server through the Internet Assigned Numbers Authority and Network Solutions, Inc. (NSI). IANA has managed the DNS for some 15 years without government oversight. The U.S. Government launched the Green Paper process because it will cease funding IANA and NSI and will not recompete the five-year contract with NSI which ends March 31, 1998.

Potential Legal Challenges to Government Intervention

The U.S. Government has no authority to regulate the DNS system. The references to the U.S. Code in the Green Paper relate to government policy on domestic and foreign commerce in general and don’t authorize regulation of a global system such as the Internet.

The steps proposed in the Green Paper to regulate the DNS, if implemented, would be subject to immediate legal challenges and create chaos instead of cooperation. The concept of protecting an existing monopoly and creating new ones also raises many constitutional and anti-trust issues, which would be better dealt with by constitutional and anti-trust attorneys.

The draft discusses the Administration's proposed transition from government oversight to private enterprise and largely outlines a process already completed by the International Ad Hoc Committee (IAHC), the Policy Oversight Committee (POC), the Policy Advisory Body (PAB) and CORE to develop competition.

End Government Involvement, Don’t Start It

As noted in the Green Paper, the President directed the Secretary of Commerce to privatize, increase competition in, and promote international participation in the domain name system. The U.S., as the global champion of free enterprise, can achieve this by making one of the most difficult decisions facing any regulatory body: ending, rather than initiating, government involvement.

The U.S. Government can ensure the rapid transition to competition and greater choices for users everywhere. It can provide leadership in creating a new system with not-for-profit Registries and broad choices of domain names immediately available in a competitive environment. It can facilitate the end of the monopoly situation on March 31, 1998, and the smooth transition to a level playing field, with technical oversight provided by a new non-profit IANA.

Based on input from Internet and regulatory experts around the world, CORE recommends the following eleven steps that can be taken for immediate evolution of the Domain Name System to a new era of self governance and competition. The steps involve cooperation on many levels and continuing the processes already under way. If adopted, the plan will enable the U.S. Government to achieve its stated goals efficiently, effectively, quickly, with minimum interference and within the spirit of global consensus.



  1. Recognize the existing IANA as the ultimate authority over the Root; allow it to continue operating as it has historically with no involvement of the U.S. Government and to evolve to a not-for-profit corporation with global consensus and without government hindrance
  2. Create a board of directors for IANA from the world Internet community, based on the open, consensus-building process and standards promulgated by the Internet Engineering Task Force (IETF), Internet Architectural Board (IAB), Internet Engineering Steering Group (IESG) and the Internet Society (ISOC), without government involvement
  3. Fund the new corporation through fees from domain name registries, regional registries, registrars and other mechanisms approved by its board; specifically exclude governmental funding
  4. For future administration and marketing of the Domain Name System (DNS), IANA would oversee a two-tiered structure: a non-profit Registry for the administration of new generic Top Level Domains (gTLDs) and country codes; and Registrars, either for-profit or not-for-profit, which will provide retail registration services to registrants worldwide in a competitive environment (NOTE: a shared registry can handle multiple gTLDs. This ensures that the DNS is operated in the public trust and without the potential for ownership of gTLDs through new, parallel monopolies)
  5. Through the IANA board of directors, use the Internet Standards Process as outlined in RFC 2026 to establish technical and other standards for Registries based on the goals of: technical excellence; prior implementation and testing; clear, concise and easily understood documentation; openness and fairness; timeliness; and ethical standards as outlined in the gTLD Memorandum of Understanding (www.gtld-mou.org)
  6. Use the gTLD-MoU and CORE MoU as the foundations for ethical standards to be agreed to by all Registries and Registrars; encourage comment and maintain an open process for its ongoing evolution and improvement
  7. IANA completes its commitment under the gTLD-MoU and immediately adds seven new gTLDs to the Root and administers registration through the Shared Registry System (SRS) developed by the non-profit CORE Registry and currently undergoing acceptance testing; add more gTLDs as approved by IANA
  8. To encourage stability, efficiencies, economies of scale and common standards among registries, CORE can provide Registry services to other gTLD Registries and country codes; CORE intends to make its SRS software available to any other non-profit organizations approved by IANA as a Registry for TLDs
  9. The U.S. Government should end the Network Solutions, Inc., monopoly on March 31, 1998. IANA can then determine how Registry services will be administered for the gTLDs of .com, .org and .net without offering further monopoly protection or favored treatment to NSI
  10. Immediately convert .com, .org and .net registry services to not-for-profit status; require that these gTLDs be operated through a SRS open to competing registrars on a cost recovery basis and operate within the same standards as all other registries; and require that NSI immediately hand over the authoritative Root database, the IP address subnet containing all of its Root servers and all coordination of the Root server network to the control of IANA (NSI could use CORE for the non-profit Registry functions while continuing as a for-profit Registrar)

Introduction to CORE

The Internet Council of Registrars (CORE) is a non-profit organization established to provide domain name registry services in a new era of deregulation, competition and self-governance.

CORE was created as part of the long process toward self-governance and anticipated end to U.S. National Science Foundation funding of the Domain Name System (DNS). The process preceded the current efforts of the U.S. Department of Commerce to support competition and began in late 1995 when Network Solutions, Inc., under contract to the National Science Foundation, was allowed to begin charging for registering domains, a service that had previously been free. The Internet community was upset, but there was no recourse because NSI was a monopoly operating under contract to an agency of the U.S. Government. A plan proposed by Dr. Jon Postel, head of the Internet Assigned Numbers Authority (IANA), sought to break the monopoly and add up to 150 Top Level Domains to the Internet. He presented his concepts to the Internet Society (ISOC) and their joint efforts led to the formation of the International Ad Hoc Committee (IAHC), which launched a rigorous public process in fall 1996 to solve the logjam and lead the Internet toward self-governance.

CORE and the Policy Oversight Committee (POC) evolved from this IAHC process and have developed protocols, procedures, systems and software to administer competitive domain registration. CORE is a non-profit open membership association funded by its members and developed with global consensus. In anticipation of the end of the NSI monopoly and the start of competition in domain name registration, CORE has completed development and acceptance testing of a shared registry system (SRS) with working infrastructure and well-defined operating standards. CORE currently lists 87 registrars in 23 countries, including 24 U.S. registrars with a presence in more than 100 American cities.

The gTLD Memorandum of Understanding

For governance, the gTLD-MoU model has drawn widespread support from the Internet community, major corporations and organizations worldwide. The rigorous process and quality of input from many sources and interests resulted in the generic Top Level Domain (gTLD) Memorandum of Understanding (MoU). There are more than 200 signatories to the MoU, including: MCI Communications, Bell Canada, Digital Equipment Corp. (DEC), Internet Society (ISOC), Internet Assigned Numbers Authority (IANA), Internet Policy Oversight Committee (POC), Internet Software Consortium, European Telecommunications Standard Institute, France Telecom, Internet Society of Australia, International Trademark Association, Swiss Federal Institute of Intellectual Property, Tokyo Internet Corp. and the Internet Societies of Geneva, Vienna, Israel, Japan, Ghana, Norway, Mexico and Thailand.

Guide to Abbreviations


ccTLD Country Code Top Level Domain

CORE Council of Registrars

DNS Domain Name System

gTLD generic Top Level Domain (not associated with country code)


MoU Generic Top Level Domain Memorandum of Understanding

IAHC International Ad Hoc Committee

IANA Internet Assigned Numbers Authority

IETF Internet Engineering Task Force

IESG Internet Engineering Steering Group

ISOC Internet Society

MoU Memorandum of Understanding

NSF U.S. National Science Foundation

NSI Network Solutions, Inc.

nTLD National Top Level Domain (also ccTLD)

PAB Policy Advisory Body

POC gTLD-MoU Policy Oversight Committee

RFC Request for Comments

SRS Shared Domain Name Registration System

TLD Top Level Domain

USG U.S. Government

WIPO World Intellectual Property Organization

# # #

For further information, see the CORE Web site (www.gtld-mou.org) or call:

Tom Gable (tomg@gablegroup.com)

Dianne Gleason (dianne@gablegroup.com)

The Gable Group


Judy Whittlesey (judithhw@aol.com)

Clarkson Hine (cchine@aol.com)

Catharine Dickey

Sheila O’Neil

Susan Davis International