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[ga-roots] Re: New.Net-WhitePaper
A Proposal to Introduce Market-Based
Principles into Domain Name Governance
The following paper addresses competition in the domain name industry.
New.net hopes that this paper will stimulate discussion regarding the name
space and help bring all points of view to the table. New.net may publish
other papers in the future concerning issues affecting the domain name
industry, which could include issues regarding intellectual property rights,
privacy, and international domain names, among others. In the spirit of
fostering an on-going dialogue, New.net welcomes suggestions for future
topics.
A Proposal to Introduce Market-Based
Principles into Domain Name Governance
We believe that the current Domain Name System (DNS) - the system that
enables persons to use easy-to-remember, common language names instead of
numerical Internet Protocol (IP) addresses to locate other computers and
users on the Internet - suffers from an artificial scarcity of names that is
detrimental to Internet users worldwide. The current system, administered
by the Internet Corporation for Assigned Names and Numbers (ICANN), is one
that hampers the release of top level domains (TLDs) and is the product of a
legacy, consensus-based system of governance that inherently cannot serve
the diverse and large groups that have varying and even diametrically
opposed stakes in how today's Internet is operated. As a possible solution,
we propose a hybrid consensus/market-based system in which the technical
aspects of the DNS are run by consensus through a central organization such
as ICANN, but the political and economic aspects of the DNS - those involved
in choosing which TLDs to use and who will operate them - are best served by
companies competing in an open marketplace. (For those who are new to
issues relating to the DNS, we present as background a brief history of the
DNS in the attached appendix.)
In understanding the DNS, one must keep in mind the difference between
naming and addressing. As Dr. Jon Postel, who had coordinated different
Internet protocols including the assignation of names and numbers in the
DNS, stated with admirable clarity, "A name indicates what we seek. An
address indicates where it is." In other words, naming allows one to find a
given computer more easily; addressing refers to the way in which a computer
is identified.
This distinction is not academic: there is a clear difference between (1)
the decisions regarding addresses - which relate to the way in which
machines function on the Internet including the assignment of IP addresses,
the establishment of Internet protocols and the manner in which names are
mapped to addresses; and (2) decisions regarding names - which relate to
exactly what names should be used by humans to locate the machines within
the system as well as who should administer those names. One set of
decisions - addressing and its attendant issues - is technical; the other -
naming - is political and economic. For example, why must a TLD be ".COM"
or ".INFO"? The answer is simple: it need not. There is no technical
reason for that choice. As Paul Vixie, the author of the DNS server
software BIND, has stated, "A million names under "." isn't fundamentally
harder to write code or operate computers for than are a million names under
"COM"."
Currently, however, one organization administers both the addressing and the
naming space of the DNS, and as such it must try to balance all three
areas - technology, politics and economics - in its work. In so doing,
ICANN has attempted to preserve the consensus-based decision-making model
out of which the technical parameters of the Internet grew. Along the way,
ICANN has faced criticisms and questions regarding its administration,
decision-making procedures, rules, and even its legitimacy. It is no
surprise that any such administrative body would encounter these issues when
trying to address political and economic matters, and especially so when
trying to apply a consensus-based decision process to such matters.
Indeed, those who originally laid out the parameters for moving the control
of the DNS out of the U.S. Department of Commerce were aware of the benefits
of a competitive marketplace. Specifically, in setting forth the
"Principles for a New System" (a key section of the Statement of Policy
entitled "Management of Internet Domain Names and Addresses" -- commonly
known as the "White Paper"), the Department of Commerce stated:
Competition. The Internet succeeds in great measure because it is a
decentralized system that encourages innovation and maximizes individual
freedom. Where possible, market mechanisms that support competition and
consumer choice should drive the management of the Internet because they
will lower costs, promote innovation, encourage diversity, and enhance user
choice and satisfaction.
In keeping with the White Paper's principle of competition, we propose that
a market-based approach in conjunction with a consensus approach will allow
the DNS to achieve high efficiency and broad representation. This result is
possible because such a combination allows the technical aspects of DNS to
be separated from the political and economic questions concerning the
creation of new TLDs. Under such a system, technical matters would be
decided using a consensus-based decision-making process, and political and
economic matters would be determined by market forces. Accordingly, under
this proposal, consensus- and market-driven decision-making processes are
used where they are best suited rather than forcing one into the other's
realm. This hybrid approach will allow the DNS to serve best the group with
the most at stake: Internet users.
A History of Consensus-Based Decision-making
Since the early days of the Arpanet, most questions of Internet architecture
have been resolved using a consensus-based system. Indeed, the very nature
of the Internet allows a consensus-based system to work extremely
effectively in situations where technical issues can be carefully considered
by knowledgeable parties across the world. The evolution of the RFC
(request for comments) process - which allows individuals or groups to
publish technical proposals for the rest of the Internet community to
comment and build upon - has been and continues to be an essential component
in resolving technical issues quickly and efficiently.
It is also clear that consensus works well in certain situations but is
unwieldy -- if not impossible -- as the numbers of persons engaging in the
consensus process grow large. Indeed, a consensus process loses its
effectiveness as it tries to function beyond a fairly homogenous group. In
the case of domain names today where a heterogeneous group seeks to govern
technical, political, and economic matters, consensus administration becomes
unworkable and often produces undesirable results. Accordingly, it may be
that the natural limits of consensus-based decision-making prevent it from
achieving an efficient and broadly representative result.
Appreciating the limits of consensus-based governance may be difficult for
many involved in the continuing administration of the Internet. It involves
reassessing, with an open mind, the state of the success or otherwise of a
consensus-based approach to Internet naming as a whole. We assert that the
evolution of the Internet has resulted in such a wide diversity of parties
having an interest in the naming space that the current approach, applying a
consensus-based process to all aspects of naming, is no longer the best way
to ensure maximum efficiency and consumer benefit.
From early 1982, decisions as to how the domain name system would work (and
the attendant modifications to the technical aspects of the system) used the
RFC process, as did many other aspects of the Internet's operation. This
process issues standards, informational pieces and commentary. The
standards do not create a law per se in that someone can choose to operate
outside the standards, but deviating from the standards obviously makes it
harder to work with those who have adopted them. Insofar as changes to
these technical matters are required, the tested method of the
consensus-generating RFC makes sense and is desired. This process brings
the benefits of the appropriate group, the technical community - which is
focused on and passionate about making the Internet operate well from a
technical standpoint - vetting protocols and giving each other input.
Technical innovation is positively encouraged rather than stifled.
Limits of Consensus
In contrast, we and many other groups feel that the current naming process
falls short of such interaction and constructive procedures. Regardless of
the various actions that brought about ICANN as the current body governing
the name space, suffice it to say that no single body could use the process
described above for TLD naming issues today. The TLD name space is not
comprised of a small independent group as was the case with Internet
Assigned Numbers Authority (IANA) with its rules and procedures regarding
adding extensions that meet a minimum specification threshold, or the
Internet Engineering Task Force (IETF) consisting of engineers developing
protocols via occasional meetings and email discussion groups to discuss and
evaluate those protocols. Rather, the TLD name space consists of numerous,
disparate interests, and thus any governing body must always attempt to
serve many masters at once. In so doing, it attempts to resolve political
and economic issues relating to which TLDs should be created, how they
should be run, who should reap the economic benefits of running them, and so
on.
Any organization addressing political and economic matters runs into
questions of legitimacy and related questions of representation and due
process. As such, it is easy to understand why ICANN, whose regulatory or
commercial nature has been debated, faces numerous questions regarding
legitimacy, fairness, undue influence and accountability, to name a few.
Indeed, it is no surprise that ICANN, in an attempt to get anything done at
all in the non-technical policy arena, has, according to its critics and
even neutral observers, chosen to marginalize many of its constituencies and
heed the counsel of a relatively like-minded, more homogeneous subset of
affected groups. Whether well founded or not, all of these issues and
questions surrounding ICANN further hamper the process of creating new
generic TLDs. In fact, many of these questions need not have arisen and
will actually be ameliorated by opening up the naming space to competition
and moving away from a position of artificial scarcity of names.
The Market/Consensus Approach
Something more than consensus-based decision-making is required when
addressing the non-technical aspects of the name space and trying to expand
it. We believe that the market can serve that purpose. In a market-based
name space, while ICANN keeps guard over the manner in which the Internet
evolves on a purely technical level, the market invites individuals and
companies to innovate regarding how those technical gifts are used. To be
clear, anyone trying to innovate would by necessity have to comply with the
technical parameters for the portion of the Internet in which they operate
in order to achieve commercial acceptance.
There are numerous examples of innovation in the name space that have
occurred without ICANN's official sanction, but which have been widely
embraced by Internet users and provide significant consumer benefit. These
include: (1) New.net's introduction of domain names with more descriptive
and useful TLDs that are accessible by users that choose to support New.net,
(2) VeriSign's sale of multilingual domain names that require use of a
client application to enable resolution, (3) AOL's use of "keywords" that
are accessible only by AOL users, and (4) RealNames' offering of key words
that can be resolved by many, but not all Internet users.
By having ICANN focus on its core technical competency, Internet technology
can continue to use consensus to keep it technically vibrant and stable.
The market, in turn, will drive private companies to address the name space
in a manner that is both efficient and responsive to Internet users' needs,
thus keeping the name space vibrant.
The market side of the equation allows groups to find new ways to work
within the current DNS, thus providing consumers with more options. As with
any innovation, adoption by consumers will drive growth of the product and
related commerce. Insofar as those options are limiting on how the consumer
interacts on the Internet, any innovator must inform the consumer of that
issue and demonstrate its offerings' value if there will ever be widespread
adoption. Consumers thus can make the choice as to whether they wish to be
part of a certain naming system within the Internet or not.
Perhaps the simplest analogy is to the cable television industry in the
United States. For some time, a home cable subscriber was beholden to his
or her cable operator. Programming was broader than with broadcast
television, but one could not deviate from the set of channels offered by
the cable operator. As new cable channels launched, the economics of the
marketplace, either through direct incentives or customer demand, allowed
the new channels to gain better carriage. Cable channels often bought
advertising educating potential viewers about the benefits of their
programming, thus encouraging viewers to call their cable operator and ask
that the channel be part of the line-up. The most famous of these
advertisements may be MTV's "I Want My MTV" campaign. In addition,
competition introduced through the emergence of satellite television further
accelerated the cable television industry's efforts to be more responsive to
its user market.
Similarly, companies with new TLD or "alternative naming" strategies can use
incentives to persuade ISPs to "turn them on" and reach Internet users. In
addition, Internet users can ask that their ISPs enable their domain name
servers to recognize New.net's or others' TLDs. The ISPs will be able to
choose whether to do so based on the incentives in place and the demands of
their customers. Yet unlike the cable situation, users can switch ISPs
fairly easily (admittedly with some potential switching costs such as
changing email addresses) to get access to domain names that the users want
to access. Users also are empowered by the availability of software that
enables them to use alternative domain names if they happen to use an ISP
that chooses not to provide the user with access to such domain names.
Accordingly, users are given a large amount of freedom of choice and control
over how they wish to use the Internet.
ICANN's current insistence on a constrained set of TLDs is analogous to a
user being locked into a single cable operator that decides that it alone -
absent any pressures from economic forces or consumer demand - should choose
what channels the user can view, claiming that too many choices would be
confusing to consumers or break the delivery system. It's clear that the
facts don't support the latter claim, and we believe that the former is
overly paternalistic at the least.
The benefits of a market-based approach are clear. By allowing companies to
develop new ways of working within the DNS technical system, to raise
capital, to market their products, and to do everything in their power to
serve their users, ICANN and Internet users will benefit in two ways.
First, ICANN will be able to conserve its resources and focus on developing
better technical standards to enhance the DNS. Second, if a company is
trying to serve customers without the shield of the virtual monopoly of
being an ICANN registry, it will by necessity be more responsive to serving
its users to gain acceptance.
In a market-based/consensus name space, ICANN would no longer use its
test-bed procedure and no longer need to issue new TLDs. Innovators could
introduce their TLDs and develop them to the best of their abilities.
Though inclusion in ICANN's or another root is not necessary, once an
innovator achieved success with its TLD, it ought to be included in the root
servers controlled by the U.S. Department of Commerce as a matter of course.
A more broadly representative ICANN could assist in setting an objective
standard for inclusion in the root servers, which might include minimal
technical operating standards and a minimum number of domain names being
used by disparate users. Once the standard is established, there would be
little room left for discussion (and thus politics), and the process would
be essentially an administrative one. ICANN could return to spending more
of its time and resources on setting appropriate technical standards,
fulfilling its originally intended role.
In other words, by allowing companies to rely on their own resources to
develop new ways of using the DNS, the root system can essentially deploy an
ongoing test-bed with little political or economic cost to the root system.
Internet users would gain by having innovators strive to find new ways in
which to serve Internet users using the DNS while complying with the
technical standards set by ICANN and other Internet engineering bodies. As
innovators succeed, Internet utility is increased, and users gain from
broader ways in which they can use the Internet. After a company has proven
itself, ICANN could bring that company into its system and thus reward the
innovator with lower costs for further adoption on the Internet. In
addition, ICANN would be liberated from the financial and political drains
associated with non-technical policy matters and that raise questions
regarding its legitimacy.
Competition Will Enhance the Internet, Not Harm It
It is our belief that the benefits of innovation in the name space outweigh
any perceived costs. As discussed above, innovators within the name space
include those issuing new TLDs as well as those seeking to use DNS
functionality to expand the way in which we find information through
browsers or other means. When suggesting that innovation or competition in
the name space or the deployment of new roots be allowed, the cost most
often offered as the reason not to do so is that those actions will somehow
"break the Internet." This argument is sometimes called splitting the root.
At bottom, the argument equates universal resolvability with stability, but
the two are not inherently the same. Put simply, one can have stability
without universal resolvability. A system can be stable in that it works
for those within that system. The system may not be universally resolvable
until it performs well enough that it gets accepted as a standard, but it is
still stable.
Enabling more competition is not likely to result in many competing
companies releasing numerous conflicting top level domains. A competitor
choosing a TLD that conflicts with a widely registered TLD would have to
commit resources to an economic battle that it would most likely lose, or
win only at a high price, rather than choosing a TLD with few or no
collisions. Though choosing a conflicting TLD is a possibility, assuming
that Company A has achieved some success in establishing a user base with
ISPs and software distribution, Company B would be hard pressed to convince
ISPs, users, and the market in general that its offering of the same TLD as
Company A should be recognized or is worthwhile. Faced with such a
decision, rational market players would choose developing new TLDs. That
decision in turn, would have the result of further opening up the name space
and producing further consumer choice, thus enhancing the Internet rather
than harming it.
Another way of looking at the issue of competitive systems is to consider
the current situation regarding operating systems and Internet browsers. If
all users used Microsoft Internet Explorer, then Web design would be easier
and less expensive. Yet, we are all better off with choices. Even in the
case of having only a few options, consumers get some ability to choose
between competitors. In the case of browsers, we have gone from Viola and
Midas to NCSA Mosaic to Netscape Navigator and Internet Explorer. Along the
way, certain browsers supported some features such as the use of frames
while not supporting the Marquee, or scrolling function, and vice versa.
Today, however, to be competitive, browsers tend to support more rather than
less functionality. The presence of competition and consumer choice pushed
the browsers to provide functionality they might not have otherwise
supported. Accordingly, despite dominance by one player, the existence of
competitors forces the dominant player to maintain a higher level of service
and utility than if it were the only option. Of course, should one player
or a small group of players get so dominant as to be anti-competitive,
antitrust laws would act to limit such control.
To summarize, competition within the name space will enhance the Internet
and does not threaten the existence of a root system. At worst, competition
may threaten the existence of the current means of governing the name space
in what is currently the dominant root. Yet, even that possibility is
remote - to have the chance to be successful within that name space, a
company must adhere to the technical rules of the name space and avoid
conflicting with other widely used TLDs. At best, by encouraging more
players to develop either new ways to use the current system or encouraging
them to develop entirely new functionalities based on the current system,
competition and innovation in the name space only threaten to put the
Internet back into a creative, user-oriented posture. In the end, by
letting the consensus and market approaches each thrive in the arena in
which it is most effective, we open the way to a more vibrant Internet that
delivers more benefits to a ready and willing world.
APPENDIX 1: Background
This section provides a brief overview of the development of the Domain Name
System (DNS).
1971-1994 - IP addressing and the development of the DNS.
In the early days of the Internet, relatively few computers were part of the
network that comprised the Internet. As such, the administration of how
computers were identified and found on the network was a fairly
straightforward process. Computers on the network were given an identifying
number called an Internet protocol (IP) address. If a user knew the
address, he or she could simply use that address to contact that computer.
Early users of the Internet typically would look up the IP address for a
particular computer from a white pages style list that was stored on every
computer. This process worked well in the early days of the Internet, but
became overly cumbersome as the numbers of computers on the network grew
significantly. Just keeping the list up to date, let alone finding the
computer within the list, became quite difficult.
The Internet started as a scientific project and was managed by the people
using it the most: scientists and academics. This group used the Request
For Comment (RFC) process to circulate proposals, comment on them and
finally issue a standard as to how a certain portion of the Internet should
function. As a response to the problem of locating computers on the
Internet, a group of scientists at the Institute for Scientific Information
(ISI), including Dr. Jon Postel, used the RFC process to develop the "domain
name system" (DNS). The domain name system was designed to use a
hierarchical database structure, which enabled different people on different
computers to manage different parts of the naming hierarchy. The initial
top level domains (TLDs) included seven generic TLDs, designed to identify
the type of host, such as .com for commercial organizations, .net for
network providers, .org for not-for profit organizations and .mil for the
military root domain name servers. In addition, there were two-letter
country code top level domains such as .jp, .us, and .fr to identify
geographical locations.
1994-1998 - the DNS gains in commercial value; Postel and others advocate
the introduction of competitive forces into the running of the addressing
and naming space.
From around 1994, the combination of the introduction of the World Wide Web
and a useful Internet browser, Mosaic, fueled recognition of the commercial
value of the Domain Name System as the potential of the Internet became
clear to a community increasingly made up of commercially-minded players.
At this point, the National Science Foundation (NSF) who had taken over
funding the Network Information Center, entered into a cooperative agreement
with Network Solutions, Inc. (NSI). Under the agreement, NSI took over the
registration services previously run by the Stanford Research Institute.
This meant that NSI ended up registering second-level domains in .com, .net,
.org, and .edu and administrating the main root server, or the "A" root
server. Policy authority however, remained with Postel and the Internet
Assigned Number Authority (IANA).
By 1995, many more people around the world outside of the scientific
community were using the Internet and the World Wide Web for an increasing
amount of non-research activities. Domain name registrations were
correspondingly increasing. In response to this change, the NSF decided to
no longer pay for registrations and executed an amendment to the cooperative
agreement with NSI that allowed NSI to charge a $50 annual fee to each
domain name registrant. This change was a fundamental shift in the
operation of the Internet addressing system. Rather than only a group of
scientists interested in and running the DNS for researchers and scientists,
an outside corporation with a distinct financial interest became involved
and now served an international community using the Internet for a wide
variety of non-research purposes.
Consequently, there was growing unhappiness in certain sectors with the new
fees being charged by NSI and the structure of the DNS. Some wondered why
they should be stuck with the service provided by and fees charged by NSI
when registering domain names with generic top level domains. NSI also
generated animosity with its domain name dispute policies, under which it
asserted the right to (and did) suspend any domain name upon receiving a
complaint from a registered trademark holder, without regard to whether the
registered trademark holder had a superior legal claim to the domain name.
This same period saw the beginning of a scarcity of easy-to-remember domain
names as domain name sales increased dramatically. At the same time, Postel
and others in the technical community began to agree that many more TLDs
were technically possible and needed to address increasing demand. Indeed,
in 1996, Postel suggested that IANA authorize up to 150 new generic top
level domains to be operated by new registries. Postel's view was clear:
".positive market forces dictate that diversity [in the top level domain
space], obtained through free competition, is the best means available to
insure quality service to end-users and customers."
As Postel's proposal regarding adding new TLDs was developed, IANA and the
Internet Society created the "Internet Ad Hoc Committee" (IAHC) to consider
the question of adding new top level domains. IAHC members included
representatives from several international organizations representing
corporate interests, including the International Telecommunications Union,
the International Trademark Association (INTA), and the World Intellectual
Property Organization, which marked the introduction of corporate influence
into DNS policy-making. In one example of this corporate influence, the
INTA representative, worried about the effect of new TLDs on trademark
interests, argued that the number of new domains be limited rather than
broadly expanded as Postel and others had suggested. The trademark lobby
was successful, and the IAHC proposed that only seven new top level domains
be added as an initial matter.
At around the same time, the U.S. government established a working group
that included representatives from numerous government offices, including
the National Telecommunications and Information Administration (NTIA), the
Patent and Trademark Office, and the NSF, among others, to determine what
should be done with the administration of the burgeoning Internet naming and
addressing space. As a result of that working group, in July 1997, the NTIA
issued a request for comments addressing the best way in which to govern the
Internet and the DNS. At the same time as it developed the request for
comment, members of the working group began negotiating with Postel
regarding turning IANA into a more structured, corporate body with greater
accountability to the international Internet community.
1998 to the present day - The U.S. Government and the Creation of ICANN.
In January 1998, the U.S. Government released a paper entitled "A Proposal
to Improve Technical Management of Internet Names and Addresses," which
became known as the "Green Paper." By the time the Green Paper was issued,
the IAHC process had stalled, having run into resistance from NSI regarding
adding new TLDs to the "A" root server without express approval from the
U.S. Government, which the U.S. Government had not provided. As such, the
Green Paper made no reference to the IAHC process.
The Green Paper proposed the creation of a new not-for-profit corporation,
"operat[ing] as a private entity for the benefit of the Internet as a
whole," to administer the DNS. To allow this new corporation to have such
control, the Green Paper proposed that the IANA staff would be folded into
the new organization with the U.S. Government handing over existing IANA
functions, the root system, and the appropriate databases to the new
corporation and "participat[ing] in policy oversight to assure stability"
for up to two years. The Green Paper made clear that the new organization
and its board "must derive legitimacy from the participation of key
stakeholders," envisioning a continued process of consensus as the best
means to run both the addressing and the naming space. To achieve this goal,
the new organization's board was to consist of representatives from various
membership organizations relating to the technical aspects of the DNS, such
as IP addresses and Internet technical standards, as well as representatives
of "the direct interests of Internet users"-including individual, corporate,
and non-profit interests.
Four months later, after extensive consensus-based commentary on the Green
Paper, the U.S. Government issued its "White Paper." In a broad non-specific
document, the Department of Commerce acknowledged the value of introducing
competition into the name space: "The pressure of competition is likely to
be the most effective means of discouraging registries from acting
monopolistically."
Yet the White Paper did not give exact details regarding how the new
corporation would be formed. It offered the U.S. Government's support for a
new organization that was created by "private sector Internet stakeholders"
in the form of contracting with it, advocating for it internationally, and
guaranteeing that NSI would give the necessary access to its databases and
software. The actual creation of the corporation was left an open issue.
Shortly after the U.S. Government's release of the White Paper, the
International Forum on the White Paper ("IFWP") formed and met often to
discuss the way in which this new corporation should be run. Indeed the
U.S. Government's key policy adviser on domain names, Ira Magaziner,
attended two meetings and " 'blessed' the IFWP process." At the same time
as the IFWP was meeting and discussing how to implement the mandate of the
White Paper, IANA, the Internet Society (which comprises the Internet
Engineering Task Force (IETF) and the Internet Architecture Board (IAB)
among other groups), ISOC, Postel, attorney Joe Sims, IBM, Magaziner, and
some foreign governments met and drafted their own plan for the new
corporation. Following those discussions, Postel sent the Department of
Commerce the articles of incorporation for a newly incorporated company, the
Internet Corporation for Assigned Names and Numbers (ICANN), as well as
biographies of the board of directors and bylaws for the company. Postel
described the materials as representing "the consensus judgment of the
global Internet community as to how to form a corporation that will include
the IANA function." Postel died two weeks after delivering the corporate
documents to the Department of Commerce. After reviewing three proposals
regarding the new corporation, the Department of Commerce accepted the ICANN
proposal despite controversy regarding which proposal was the best.
The White Paper called for the new corporation to have "the functional and
geographic diversity of the Internet and its users." To meet this mandate,
ICANN currently has a 19-member board that operates with the help and advice
of three supporting organizations, the Address Supporting Organization,
Domain Name Supporting Organization and Protocol Supporting Organization and
the At-Large Membership. The organizations are in turn made up of
constituencies ranging from business to intellectual property to addressing
groups such as the American Registry for Internet Numbers to the IETF.
Individuals are represented through the At-Large Membership. All four
groups get seats on the ICANN board with the supporting organizations
getting three seats each and the At-Large Membership getting five seats.
The organizations establish working groups to address questions regarding
the DNS by gathering information and then making recommendations to the
board.
Despite ICANN's efforts to be representative, the structure has met with
some criticism that ICANN's structure is too complex; its operations are not
truly representative; its decision process does not work; and that ICANN
itself is illegitimate. The paper to which this history is appended
presents a solution that would address many of these criticisms.
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