Thanks Luke. Good job.

Thanks to IIA and ADNA for coordinating this important forum and response at
such short notice.

Jordan

___________________________________________
Jordan Green
Commercial Manager - gTLD
Melbourne Information Technologies Australia Pty. Ltd.
207 Bouverie Street
Carlton 3053 Australia
Tel: +61.3.9344-9297              Fax: +61.3.9344-9473
E-mail:  jordan§melbourneit.com.au
URL:    www.melbourneit.com.au
___________________________________________
-----Original Message-----
From: Luke Carruthers <luke&#167;magna.com.au>
To: dns&#167;iia.net.au <dns§iia.net.au>
Date: Monday, 23 March 1998 14:46
Subject: DNS: Response to the US Green Paper on domain names


>At the forum held in Melbourne last Friday to develop a response to the US
>Dept of Commerce Green Paper upon the DNS a brief one-page submission was
>requested from IIA/ADNA that could be both sent on behalf of those
>represented, as well as adopted and sent separately by those interested.  A
>fuller response will be be delivered via NOIE at a later date.  While we
>didn't manage to keep it to one page, the result is attached.
>
>The response can be sent via email to dns&#167;ntia.doc.gov, and must be
>delivered by the end of today, March 23rd.  Further details on submitting
>can be found at
>http://www.ntia.doc.gov/ntiahome/domainname/022098fedreg.txt.
>
>An ASCII copy of the response as well as a Word 97 attached version are
>included below.  Don't forget to change the attribution in the attachment
>if you want to send it under your own name. . .
>
>
>
>Regards,
>
>Luke Carruthers
>Secretary, IIA
>Acting Chair, ADNA
>
>
>-------------------------
>
>
>March 21, 1998
>
>Ms Karen Rose
>Office of International Affairs
>National Telecommunications and Information Administration
>Room 4701
>U.S. Department of Commerce
>14th and Constitution Avenue, N.W.
>Washington, D.C. 20230
>United States of America
>
>
>Dear Ms Rose,
>
>Re:  Improvement of Technical Management of Internet Names and Addresses
>
>This letter is a response to the Green Paper concerning DNS issued by the
>US Department of Commerce.  It outlines in brief some issues that the
>Australian Internet industry has with the content of the Green Paper, and
>some suggestions by which the proposal contained therein could be improved.
> We hope that with these suggestions and those put forward by other
>interested parties, an effective and appropriate system for the management
>of Domain Names can be implemented.
>
>This response is submitted by the Australian Internet industry, coordinated
>by the Internet Industry Association (IIA), Australia's peak representative
>body for organisations commercially involved in the Internet, and
>Australian Domain Name Administration (ADNA), the representative body
>charged with the restructuring of the DNS within Australia.  Further
>information regarding IIA can be found at http://www.iia.net.au.  Further
>information regarding ADNA can be found at http://www.adna.asn.au.
>
>This submission is intended to be brief, with further comment to be
>submitted through the Australian government in due course.
>
>There are four primary issues this submission intends to address:
>governance, competition, self-regulation versus regulation, and
jurisdiction.
>
>
>1. Governance
>It is the Australian Internet industry's view that the body most
>appropriately responsible for the DNS is a newly reformed IANA (Internet
>Assigned Numbers Authority), with a governing board formed both from US and
>international interests.  Australia, by virtue of its place as the fifth
>largest user of the Internet, should be represented upon this board, though
>it is more important that the appropriate processes be put in place than
>the interests of any one country be pursued. Incorporating the new IANA as
>a US company leads to a number of issues regarding jurisdiction, as
>referenced below.
>
>2. Competition
>The function of the registry, the database of Domain Names and associated
>information, must be a matter of public trust, as this is the only way to
>ensure that the interests of the end user are adequately served.
>Accordingly it is not an appropriate place for competition.  It is however
>appropriate that the registrar function, the registration of Domain Names,
>is an area of competition, as this will serve to provide the greatest
>benefit to the end user in both pricing and quality of services.
>
>3. Self-regulation versus Regulation
>The Australian industry is particularly experienced in self-regulation,
>having pursued this approach for a number of years in many fields including
>telecommunications.  It is our view that self-regulation is preferable to
>government regulation.  This enables all stakeholders to be represented in
>discussions, without being restricted by the problem of which country's
>government is appropriate in which circumstance.  Self-regulation needs to
>be backed up by a light regulatory framework however, and where
>international bodies with responsibility for particular areas (such as the
>World Intellectual Property Organisation) exist, these bodies may be able
>to provide this regulatory support.
>
>4. Jurisdiction
>Jurisdiction over registrar operations must be divided between DNS'
>governing body and the country within which the registrar is operating.
>Jurisdiction over the DNS' governing body (assuming, as suggested above, a
>reformed IANA governed by an international board) is a more problematic
>area however, with no clear solution.
>
>
>It may not be practical to have participation by each and every country (or
>party) that may wish to do so. Equally it would be grossly improper for the
>United States to take an overbearing role in such a clearly international
>area. Our suggested approach would be for a model similar to that of the
>United Nations Security Council, with appropriate representation by the key
>players together with implied obligations to those parties not directly
>represented.
>
>As a final point, it is the strong recommendation of the Australian
>industry that wider international consultation must be carried out before
>the implementation of any process that has such a great effect upon
>international industry.  The DNS is one of the foundations of electronic
>commerce, and will have an impact upon billions of dollars worth of future
>revenues for many countries.  It is too important an issue to be decided
>upon without the full involvement of industries in all countries that make
>up the electronic marketplace.
>
>
>Yours sincerely,
>
>
>
>Luke Carruthers
>
>Acting Chair
>Australian Domain Name Administration
>
>Secretary
>Internet Industry Association
>