To:                 ICANN Board

From:            DNSO ISPCP Constituency

Regarding:              Process of introducing new Top Level Domains


Accreditation: Considering the amount of time it has taken to reach agreement upon the introduction of new gTLDs, the ISPCP constituency recommends the ICANN Board take an adequate period of time when determining the ground rules for the operations of new registries, selecting such registries, ensuring their viability and defining and implementing the appropriate relationships between registries and registrars. The ISPCP constituency particularly feels that a process which leads to the selection of new registries cannot be implemented within the timeframe as set out in the ICANN new gTLDs topic document.


Introduction: In order to ensure the stability and reliability of the Internet are not challenged through the additional load placed on the DNS, the ISPCP strongly recommends that only a very small number of gTLDs are initially introduced. If more than one, then they should also be introduced in a staggered manner to limit the risk of failure.


gold-rush: With respect to the problem of massive registrations upon the introduction of a new gTLD and in light of prior experience with opening new Domain space, the ISPCP constituency recommends that the ICANN Board adopt a method of Domain name registration which allows ISPs to continue to act responsibly as agents/ registrars on behalf of their customers and as operators of the DNS, and which limits the liability for ISPs relating to difficulties arising solely from technical process. This is of particular importance during the preliminary period.


Registries: The ISPCP constituency recommends that the ICANN Board must ensure that new registries for new gTLDs must be viable. Further plans and adequate provision must be made and enforced for continuity in case of a registry’s failure.


Registrars: The ISPCP constituency recommends that security guidelines are set and enforced to protect domain name holders and ISPs from Domain name “high jacking” in which domain names are moved without proper approval. The ISPCP also has concerns about the feasibility of registries being able to quickly and legally transfer domain names if a registrar fails.


Who-is: The ISPCP constituency asserts that accurate and up-to-date access to the who-is database must be maintained by registrars for the purpose of stable Internet operations. At the same time, the registry must provide accurate and up to date registrar information.