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On behalf of Network Solutions, I am pleased to submit a paper entitled "How
New, Internet Top-Level Domains could be Introduced Rapidly on a Sound Basis
".  The purpose of this paper is to illustrate how ICANN could proceed
quickly and responsibly to introduce new, top-level domains (TLDs ).
 This concept paper is not intended to answer all of the many questions that
arise as new TLDs are considered and introduced.  It  does, however,
illustrate basic concepts that can be used to permit the rapid and careful
introduction of new TLD's.   We developed it mainly by asking the question
"How could ICANN proceed with the introduction of new TLD's with the least
delay and controversy?" Obviously, no approach could avoid some controversy
or realize immediate implementation.  But we believe that by using the
approaches outlined in our concept paper, we could all see new TLD's
operating in the marketplace within a matter of months.
This is important because we, like many others, believe that in order to
reach a genuine consensus on the introduction of new TLD's, ICANN should
proceed with some "proof of concept" TLD's, which will generate results that
everyone can study and evaluate, before reaching conclusions about
additional steps.  For this evaluative approach to work, however, ICANN
needs to move from a focus on abstract principles to a focus on what would
make good "proof of concept" TLD's.  This is what is addressed by our
concept paper.  We believe that it describes how ICANN could contribute to
the launch an open ".shop" TLD, and a closed ".banc" TLD, both carefully and
rapidly; so that we can begin to generate real world experience.  
To that extent, the TLD names that we suggest in this paper are far less
important than the approaches that would permit ICANN to move from
discussion of the abstract to discussion of the practical.  
We seek no action by the Council on this concept paper, but hope that it
will stimulate a more focused discussion on how to proceed with the first,
proof of concept, round of TLD's.
 Roger Cochetti
gTLD Constituency

How New Internet Top-Level Domains could be Introduced Rapidly on a Sound

NSI believes that the competitive marketplace will benefit from new TLDs and
that these benefits can be realized at the earliest possible time if ICANN
proceeds rapidly to establish at least one new TLD of each type:  one open
and one chartered that would operate as proof of concept TLD's. Doing so
will give the Internet community valuable experience on which to base future
decisions and could avoid months or even years spent in further analysis,
debate about abstract criteria, and lengthy, complex and contentious
procedures and negotiations.   

A decision to start now with at least two new "proof of concept" TLDs, by
means that allow careful yet rapid deployment, will not in any way limit
ICANN's approach to future namespace expansion. Instead, this type of quick
start will give everyone involved real experience with which to evaluate
proposals over the longer term and a basis on which to build a lasting
consensus .

Regarding an open TLD, to introduce a proof of concept with the least delay,
while still assuring sound operations and stable application of established
policies, ICANN could contract with a registry that is created and operated
by all willing ICANN accredited registrars on a cooperative basis.  The new
registry and ICANN could enter into a registry agreement substantially
identical to that between ICANN and the current gTLD registry, creating a
level playing field, saving everyone time, and assuring the application of
policies that have been widely accepted within the ICANN community. The new
registry could then enter into agreements with registrars substantially
identical to those now in effect. Registrars could use the open standard
RRP, thereby simplifying their operations and allowing a quick start. All
accredited registrars would be eligible to participate in the new registry,
perhaps based on their level of usage, and no single registrar would be
permitted to control it. All registrars would be free to establish their own
prices and policies, subject only to the constraints already established by
ICANN consensus polices and existing contracts.

To avoid controversy regarding intellectual property matters, the existing
uniform Dispute Resolution Policy would apply and some form of a sunrise
period could be provided, during which certain trademark holders would be
permitted to register domain names that reflect their trademarks. If a
sunrise approach were applied to a first pair of new domains on an
experimental basis, it might be easier to achieve broader agreement to
introduce these TLD's.  And it should be easier  for various contending
groups, who are now debating in the abstract, to later point to real data to
support any needed changes in policy in connection with future expansions of
the name space. 

There is clearly no perfect answer to selection of a name for a first open
TLD. As an example, however, we believe that ICANN could  start with
".shop". This name is relatively multilingual and could appeal to many
owners of small, off-line businesses, thereby encouraging new users, who
might not otherwise do so, to come onto the Internet.. 

 In the spirit of gaining new experience and as a reflection of the rapid
global growth of the Internet, we believe that it would make sense for the
new registry organization for ".shop", or whatever name is selected for such
an initial TLD, to be located in Europe.

By establishing a registry through the efforts of all registrars with whom
it already has contractual relationships, ICANN would be providing an
opportunity for participation in the administration of the Internet by
Internet communities in all parts of the world. Registrars would be provided
with a low cost and uncomplicated way to begin the competitive registration
of names in a new TLD. And ICANN would be assured that the new registry
would be managed by an open group, whose members collectively have the
largest stake in establishing sound technical operations, preventing
wrongdoing and achieving a rapid launch.

 A second, chartered (or "closed") TLD should also be established as a proof
of concept as soon as possible. Like many others who have looked at the idea
of chartered TLD's, we believe that its greatest benefit occurs when such a
chartered TLD is available to a limited and well-defined set of registrants.
In this way, consumers could readily understand the meaning and value of the
namespace.  A key challenge in this context, however, is to identify such a
well-defined group of eligible registrants on a global scale.  Similarly, it
will not be easy to find a collection of trusted organizations that could
readily establish and enforce eligibility requirements  for a chartered TLD
that serves users globally.  Nonetheless, we believe that it is important
for ICANN to move ahead with a proof of concept, chartered TLD and we
believe that ".banc" could offer an attractive opportunity for such a
chartered TLD   While we understand that the worldwide banking industry is
quite diverse and, in many areas, in the midst of rapid  change, it is a
well-organized industry segment that relies on recognition by consumers. A
TLD like ".banc" could be made available only to recognized, banking
institutions, thereby helping both consumers and the on-line banking
A key element in any such chartered TLD is coming up with the proper
structures to serve as the registry and the gatekeeper. Here, we would hope
that ICANN could rapidly act in concert with banking industry
representatives to bring together a core group that would develop into these
structures.  Such a group would not need to be able to operate the technical
aspects of registry -- those could be supplied by others under appropriate
contractual arrangements. As with the open TLD, all accredited registrars
would be eligible to offer registration services to registrants in ".banc"
under existing arrangements. All registrars would set their own prices to
end users for registration. Existing dispute resolution policies,
obligations to provide Whois services, and other contractual obligations
would be resolved in the currently standardized way. This would further
reduce delays and start-up costs -- and focus the proof of concept on
creation of the new means of forming, articulating and enforcing a charter.
In the case of both the open and the chartered TLD's, in order to get the
new registries rapidly up and running, NSI would be willing to provide
support and back office services on a contractual basis. 

For both ".shop" and ".banc", we believe that the important point is not the
name of the new TLD as much as it is the use of available infrastructure to
get the proof of concept phase under way rapidly and with a high level of

In short, the use of the approaches described above for an initial rollout
would  greatly accelerate the collection of experience that the Internet
community needs in this area; provide maximum benefits from new competition
in the short term;  significantly expand global participation in the
management of the Internet namespace; save time and effort for all
concerned;  and allow ICANN to make better informed decisions in the future.


Roger J. Cochetti
Senior Vice President-Policy
Network Solutions, Inc.
(703) 326-2585