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[comments-dotorg] Comments from ACM-IGP

Comments of the Association for Computing Machinery's Internet
Governance Project
To the Names Council's Dot ORG Task Force Report

The Association for Computing Machinery's Internet Governance
Project (ACM-IGP) wishes to express its strong support for the
comments of the NC Dot ORG Task Force, and its Report placed on
public notice on January 18 ("Report").  In our comments below,
ACM-IGP will first express some general concerns regarding the
future of .ORG, and then comment directly on sections of the

General Concerns:
Overall, ACM-IGP is very concerned that the .ORG space will be
restricted as it is spun off to new technical and policy management.
Unlike any other gTLD delegation to date, .ORG is not a new
creation.  It is an existing community; it is a valued noncommercial
space.  Whatever the initial intentions of the National Science
Foundation in creating .ORG two decades ago, it has exceeded all
expectations and bounds.   Dot-ORG is the place for political and
personal commentary, community organizing and family pages, as
well as important organizational communication.

Dot-ORG is the place for organizational communication online on
the Internet, but organizational communication is not done solely by
organizations.  It is the communication of communities, families,
schools, libraries, unincorporated associations, and formal
organizations.  The .ORG domain name space offers an opportunity
for online participation by the most diverse group online. 

There is rumored to be a move to restrict .ORG to perhaps even its
most narrow definition, e.g., to allow only organizations to register
.ORG domain names in the future.   Such a restriction on .ORG
would disenfranchise entire classes of communication online. Where
.COM, .NET, .BIZ and .INFO are top level domains open for
general commercial domain name registration; .ORG is the only top
level domain open for general noncommercial domain name
registration.  To assign new management for the purpose of
breaking up Verisign's monopoly is a fine idea; to establish new
rules that excommunicate entire classes of noncommercial
communication is not.

Specific Comments on Task Force Report:
ACM-IGP agrees generally with the full report.  We thank the Task
Force for all its hard work, and the Names Council for its support of
this work.  We note the particular importance of the following

     A.   "[A]pplicant organizations should be able to demonstrate
     international support and participation from a significant
     number of noncommercial .org registrants." [Report, Section

     As discussed above, the .ORG delegation involves an
existing, diverse and robust domain name space.  It would not make
sense for one organization (however international) or one region to
dominate or win exclusive management of .ORG.  An international
coalition of noncommercial organizations from many countries and
regions will reflect existing .ORG registrations and move forward to
lay the foundation and set the policies for positive further growth of
.ORG  for the benefit of their countries and regions. 

     B.   "The definition of the relevant community should be much
     broader than simply formal nonprofit organizations.  It must
     also include individuals and groups seeking an outlet for
     noncommercial expression and information exchange,
     unincorporated cultural, educational and political
     organizations, and business partnership with non-profits and
     community groups for social initiatives." [Report, Section

     The words above were carefully chosen, and provide the
core of what ICANN must protect, preserve and expand.   They
should be adopted in their entirety in the final ICANN proposals.

     C.   "Dot org will continue to be operated without eligibility
     requirements... the registrars should rely entirely on end-user
     choice to determine who registers in .org." [Report, Section

     The Noncommercial Community has proven itself.  In
overwhelming numbers, it flocks to .ORG to register its domain
names.  It is a successful example of self-selection in the domain
name space.

     But the Task Force Report goes a step further.  It asks
ICANN to require that the new registry adopt a "definition of the
served community" and put into place "appropriate marketing
practices" [Report, Section 2b].  We have seen that even with the
inappropriate marketing practices of today (encouraging companies
to register commercial domain names in .ORG), companies disdain
.ORG, and the Noncommercial Community overwhelmingly register
in it.  Self-selection will only become better as the new registry
(under the Report's proposals) actively markets to the
Noncommercial Community.

Again, our support for the Report runs to all its points and
proposals.  Our thanks again to the Task Force, to its chairman, and
to the Names Council.  We urge the ICANN Board to adopt the
principles and recommendations of the DNSO in this Report.

Respectfully submitted,
Kathryn A. Kleiman
Director, ACM-IGP

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