Hi PABers,
Attached you'll find the letter sent by ETNO (European telecom networks
organisation) to the Head of the Directorate-General for
Telecommunications at the Eurpean Commission (DGXIII).
It is highly supportive of our efforts. When the gTLD-MoU was launched
some months ago ETNO was really not that supportive of our efforts.
We've done a good way in letting everybody to understand our goals and
raise (partial but significant) consensus.
If you want more info on ETNO, got to http://www.etno.be. You'll find
the websites of tis members at http://www.etno.be/mwebsite.html.
Amadeu
PS: ETNO has given its authorisation to circulate its letter
***************
Brussels, 16 February 1998
Mr R Verrue
Director General
DG XIII
European Commission
Rue de la Loi, 200
1049 Brussels
Dear Mr Verrue,
US Department of Commerce Green Paper on the technical management of
Internet names and addresses
I am writing to outline ETNO's reactions to the above-mentioned Green
Paper as issued on 30 January 1998.
ETNO Members have made and will continue to make significant investments
in Internet infrastructure and services. Consequently, ETNO has a
considerable interest in ensuring that decisions on governance issues
are directed at promoting an appropriate commercial environment.
ETNO welcomes the US government's commitment to end its direct
involvement in Internet governance. The declared objective of
establishing a stable, comprehensive and transparent framework for
Internet governance will be a crucial factor in encouraging commercial
and consumer confidence in the Internet as an effective medium for
electronic commerce. It is important that a governance framework should
maintain a clear separation between coordinating policy, and commercial
functions which should operate on a competitive basis. Given the
potential global impact, it is equally important that any plans for a
stable reform of the Internet should be based on a consensus of all
stakeholders, internationally.
Against this background, the US paper raises a number of serious
concerns:
· The Commerce Department proposes that a non-profit corporation should
be established to handle coordination of Internet governance. Taking
account of the need for global development of the Internet,
internationally independent self-governance and effective representation
of all stakeholders within the global Internet community, ETNO considers
that there is a strong case for such a body to be established as an
International Organisation or consortium, rather than as a US
corporation.
· As far as dispute resolution relating to trademark issues is
concerned, the role of the World Intellectual Property Organization and
the comprehensive efforts made on developing Administrative Challenge
Panels and on-line dispute resolution in cooperation with gTLD-MoU
bodies has been substantially ignored by the Green Paper. ETNO strongly
regrets this omission.
· The Commerce Department proposals for proprietary Registry operation
effectively perpetuate the de facto monopoly of Network Solutions Inc in
Registry functions with respect to the existing gTLDs (.com, .net,
.org). Regarding NSI's role, it is important to guarantee separation of
Registry and Registrar functions, conformance of NSI to requirements set
by new regulation, and non-discriminatory access to the Registry
database that is currently owned by NSI. ETNO believes that further
consideration should be given to the alternative, shared registry model
and management of the namespace as a public resource in accordance with
the gTLD-MoU principles.
Regarding the gTLD-MoU, this initiative represents a significant step
towards definition and implementation of some basic principles of
Internet governance:
· administration of the namespace as a public resource
· competition in the management of registrations (ie, between
Registrars)
· fair representation of all worldwide stakeholders in the coordination
functions
· provision of a flexible system for on-line dispute resolution under
WIPO supervision.
The advanced status of the gTLD-MoU initiative, the selection of new
Registrars in line with CORE procedures, and the on-going deployment of
a platform for management of a shared repository are important assets
that should be taken in consideration in any development relating to
Internet governance. ETNO considers it would be preferable to adopt the
best features from existing systems and initiatives such as the gTLD-MoU
so as to harmonise guidelines and adapt the Commerce Department's plans
to provide a consistent framework which accords with best international
practice.
ETNO would welcome action by the European Commission to ensure that
these concerns are brought to the attention of the US authorities. More
generally, ETNO is pleased to express its support for the European
Commission's efforts to ensure that European interests are properly
represented, and that the US Administration takes due consideration of
the concerns of the international community when implementing any
changes to Internet governance.
Yours sincerely,
Hans Kraaijenbrink
Chairman, Executive Board
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