PAB Prepared Testimony of Kenyon T. Stubbs Chairman, Executive Committee , Internet Council of Regis

Sascha Ignjatovic ()
Thu, 11 Jun 1998 06:06:51 +0200 (MET DST)

Prepared Testimony of
Kenyon T. Stubbs
Chairman, Executive Committee
Internet Council of Registrars (CORE)

Subcommittee on Telecommunications, Trade, and Consumer Protection
U.S. House of Representatives
Committee on Commerce
June 10, 1998

Mr. Chairman, Members of the Committee:

My name is Ken Stubbs, and I am the Chairman of the Executive
Committee of CORE, the Internet Council of Registrars. I am also
a Principal in Domain Names International, LLC, a domain
registration small business based in Orlando, Florida. It is an
honor to appear before you today.

I would like take a moment to provide you some brief background
on CORE. CORE is a non-profit membership association currently
composed of 87 domain name registration companies of all sizes,
including my own and many others like it.

Reflecting the global nature of the Internet, CORE's member
companies come from 23 different countries. Reflecting the
strength of America's influence in the Internet, the largest
share of CORE registrars, 24, are U.S. companies with a presence
in more than 100 American cities.

CORE exists for the very reason you are having this hearing today
-- the future of the Domain Name System (DNS). CORE originated as
a result of a plan initiated in 1996 by the Internet Society and
the Internet Assigned Numbers Authority (IANA) to add new
structure, free enterprise, and competition to the Domain Name
System. The plan was to create a not-for-profit registry that
would operate in the public trust. Accordingly, CORE was born in
November of 1997. Our membership and support represents the
worldwide scope of the Internet. CORE operates within the
Internet governance framework of the global Memorandum of
Understanding, signed initially by the Internet Society and IANA,
and signed since by more than 200 organizations, including MCI
Communications, Digital Equipment Corporation, Bell Canada,
France Telecom, the Internet Software Consortium, the
International Trademark Association, and a host of others from
the global Internet community. This Memorandum of Understanding
also created a Policy Oversight Committee to oversee registration
of domain names on a global scale, and to introduce new generic
Top Level Domains in addition to those now in use like .com,
.net, and .org. The future of the DNS (Domain Name System) -- and
the ideas supported by IANA, POC, CORE, and the majority of the
worldwide Internet community -- are intertwined.

Growth of the Internet

Mr. Chairman, with the current government-imposed limit on top
level domains, and the accelerating growth of Internet use, the
domain name system is literally bursting at the seams. A good
analogy would be limiting the number of telephone area codes.
Sooner or later, you're going to run out of phone numbers, and
you're going to have to add new area codes. This phenomenon is
happening right now in the Internet's domain name system. The top
level domains are running out of available names that are
relevant and meaningful. The bottom line is, it's obvious the
Internet needs more top level domains.

The growth of the Internet has been explosive, here in the US,
and even more so overseas. It has been estimated that there are
now more than 100 million Internet users worldwide, with the
potential for 100 million more this year. As President Clinton
told the graduating class of MIT last week, 100,000 pages are
being added to the Worldwide Web -- every hour.

For communications, more and more people worldwide are depending
on the speed and reliability of e-mail. Already, Americans send
more messages over the Internet than by traditional hand carried
letters, now often referred to as "snail mail." Estimates are
that in excess of 3 trillion e-mail messages will be sent
worldwide in the year 2000. One in five Americans now rely at
least once a week on the Internet to get news, triple the number
who did so just two years ago.

Originally popular as a research and informational tool, the
Internet is evolving dramatically. Day after day, more and more
people across America and around the world are relying on the
Internet for both business as well as personal use. Just about
any product you can currently buy in a store, you can now buy on
the Internet. I buy many of my plane tickets ... through the
Internet. I got confirmation of my hotel reservation ... on the
Internet. I played golf last week at a course I discovered ... on
the Internet. There are a few companies I probably should have
bought stock in last week ... and I could have done that on the
Internet as well.

As an example, look at the staggering growth in on-line financial
services. As of March 31st, Fidelity Investments had one million
on-line accounts, five times more than it had one year earlier.
According to Charles Schwab Corporation, 48% of its customers'
trades -- 60,000 per day -- are executed on-line. As for travel
services, the Travelocity web site offering travel reservations
has registered 2.5 million members who log more than 45 million
page views per month. One and a half million people in 160
countries have bought books on-line from

The Internet has a commercial use for just about anything you can
imagine ... and plenty of things we have not yet imagined.

Future of the DNS

To accommodate and facilitate the current, and future, growth of
the Internet, the domain name system needs a stable structure
with the flexibility to allow for this expansion.

The Internet is the consummate equalizer, making it possible for
businesses of all sizes and scope worldwide to make consumers
aware of products and services that they can supply. But without
the ability to obtain relevant, user-friendly domain names, these
businesses will find it much more difficult to reach their
potential customer base.

CORE has supported a plan that would initially introduce seven
new generic top level domains. Internet authorities such as Jon
Postel of IANA have suggested in previous testimony before
congressional committees that the Internet, at this moment, could
comfortably support as many as 150 new gTLDs.

One compelling reason for adding new domain names is to help
preserve some relevance to what a name holder is offering through
the Internet.

If you are selling cameras on the Internet, for example, would be descriptive of and more relevant to
the products and services offered and definitely much more user
friendly then If you are maintaining a site for
tourists with information on Washington, DC restaurants, a name
like would be significantly more relevant and
Internet user friendly.

Make no mistake, the future of the domain name system hinges on
far more than just the number of new TLDs. There are fundamental
principles which are absolutely critical to preserving the
stability, integrity, and consumer benefits that the Internet

Our organization strongly feels:

1) Registries should be not-for-profit, and operated in the
public trust, to preserve cost efficiencies and to avoid the
potential for predatory pricing practices and gouging. As you
know, registries are largely administrative, back-office
operations that manage a domain name database.

2) There should be vigorous, free and fair competition among
registrars -- the consumer's point of contact with the domain
name system -- resulting in lower costs and better service for

3) Consumers should have complete domain name portability --
there should not be a monopoly over any single TLD.

4) There should be no direct government involvement in the DNS --
by the United States or any other government.

5) Oversight of the DNS should be performed by a US-based
non-profit corporation representative of the global Internet
community; and

6) The transition to competition and self-governance should occur
as soon as possible, without any artificial delays.

The policy crafted by Clinton administration senior policy
advisor Ira Magaziner and announced last week, the so-called
White Paper, is a vast improvement on its earlier version, the
so-called Green Paper. The White Paper is a significant step
forward, potentially paving the way for the implementation of all
of these fundamental principles.

CORE supports the White Paper's deferral of important decisions
to a new non-profit corporation with a Board representative of
the Internet community. It is critical that the composition of
the successor organization to IANA truly reflect the global scope
of the Internet. If it does, CORE is optimistic that the new
corporation will make the right calls on the most important
issues: not-for-profit registries, criteria for competing
registrars, and the number and type of new TLDs.

A valuable process for achieving the transition to competition
and self-governance may be through a Domain Names Council, a
concept recommended by IANA's Jon Postel, whom we all believe
should play the major leadership role in this process. CORE would
support the establishment of such a policy-making process if it
is globally accountable, flexible, open, and moves forward with

There's a lot to like in what the White Paper says. It's what the
plan doesn't say -- on important issues such as timing of the
transition -- that remain of concern.

We've all heard the expression "possession is nine-tenths of the
law." Well, if you read between the White Paper's lines, it's
apparent the U.S. Government is reserving the right to approve or
not approve transferring DNS management to a new corporation. The
world Internet community should be concerned about this potential
roadblock, and the criteria the government plans to use in making
such a major decision.

Despite all the positive signals about the government getting out
of the business of the DNS, government regulators appear to still
retain a potentially powerful veto over this entire process. Will
unelected bureaucrats be empowered to determine when, in their
judgment, the Internet is ready to move forward? If so, who are
the government regulators who will have their finger on the
switch? How will they decide when to flip that switch?

Judging from Wall Street's reaction to the White Paper, investors
in the status quo are celebrating the prospect of delay. Everyone
involved in this process says the current monopoly situation is
just unacceptable. Perpetuating the status quo should be equally
unacceptable. We hope that government regulators, as well as
Congress, will stand clear of this process and allow the kind of
rapid and stable transition the Internet community is capable of

Despite CORE'S very real concerns about the implementation and
the timetable of this transition, we are encouraged and
optimistic about launching competition and self-governance. The
White Paper responded to many legitimate criticisms of the policy
outlined in the Green Paper. CORE has always advocated
self-governance by the Internet community based on international
consensus among stakeholders. If this new policy is appropriately
enacted in a timely fashion, the biggest winners from competition
and self-governance will be Internet users and consumers.

Dramatic new choices in domain names, and choice among
registrars, will add up to increased efficiencies, lower prices,
and better service for millions of Internet users worldwide. It's
clear that the White Paper has issued a challenge. It's a
challenge to the global Internet community to come together to
bring competition and self-governance to the DNS. CORE is
confident that the global Internet community is up to the
challenge, and we are prepared to play our part.

Right now, the potential of the Internet is limited only by our
imaginations, our ingenuity, and regrettably, government
regulation. Once the government steps aside, Internet users
across America and around the world should fasten their seat
belts for a great ride into the unlimited future of this
phenomenal global resource.

Thank you for the opportunity to appear before you. I would be
happy to respond to any questions you may have.