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Sep. 10, 2001

Dear ICANN Board,

After ICANN issued the two documents on "A Unique, Authoritative Root for the DNS": discussion draft published on May 28th and the finalized version on July 9th, Japan Network Information Center (JPNIC) and Japan Registry Service Co., Ltd. (JPRS), who are administering JP domain names, reviewed them and have expressed their views as the JP registry in the following comments.

The comments have been published today via JPNIC's website for the local and global Internet community.

We sincerely hope ICANN would take in consider these comments for future policy development and its management.

Yours Sincerely,

Jun Murai
President
Japan Network Information Center (JPNIC)


Comments on Alternate Roots

It is vital that the name space be unique, as Internet users rely on domain names to identify sites and other users. Therefore, competition of name spaces should be avoided. In this context, there is a clear need for some sort of central organization or coordination body. ICANN is one such organization.

However, ICANN's recent introduction of the new gTLDs was less than swift, and cost no little expense. This is one of the main reasons to stimulate alternate roots activities. ICANN should accept the criticisms it is receiving from outside the organization and reflect them on its activities.

Whatever the faults of the current ICANN, a central organization or coordination body of some sort is needed. If we push ahead along the path of reconciling ICANN and alternate roots, we will later strike the recurring problem of needing a higher level ICANN-like organization or coordination body. We will then have to tackle yet again the type of difficulties that we have experienced in building ICANN, and this could result in delays in the continued healthy growth of the Internet. We feel a situation of this sort would be a major obstacle in ensuring the stability of the Internet and its continued development.

In light of this, we propose the following:

  1. There should be a mechanism to ensure the uniqueness of name space for all Internet users. Currently, the root servers managed by ICANN/IANA are the best available mechanism for ensuring the name space uniqueness. Measures to counter any practice that could hinder the operation of this mechanism should be urgently researched and implemented.
  2. ICANN should work to speed up all procedures, including decision making and the implementation of those decisions.
  3. ICANN should swiftly review the new gTLDs, not limiting this to an evaluation of the introduced gTLDs, but also including an evaluation of the entire gTLD introduction process.
  4. ICANN should devote more energy to educational programs. Greater effort should be made to publicize the current advantages and drawbacks of the Internet and to promote an accurate understanding of such among Internet users.

Jun Murai
President
Japan Network Information Center (JPNIC)

Koki Higashida
President
Japan Registry Service Co., Ltd. (JPRS)

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