- comments-o-com-single-char-10may18@icann.org

[Comments-o-com-single-char-10may18] NO to premium fees / premium renewals / ownership transfers on .com domain names! (Aka, NO to special restrictions for any domain in the .com extension.)
by Keven Dabney June 20, 2018

June 20, 2018

ICANN, As the current proposal stands, there is zero chance of gaining my support for the release of O.com. While this proposal might be warm and fuzzy at the high level, this proposal is clearly made to give VeriSign an opportunity to ask to amend the .com contract. And not for the general good. Instead of being forced to charge realistic prices for .com domain names, VeriSign is trying to introduce premium fees, premium renewals and ownership restrictions into what is a straight forward and agnostic top-level-domain. In the end, if VeriSign is successful, this proposal would open Pandora's box for allowing such things on more .com domain names in the future. And then for more groups of domain names in the future. And then ... who knows. Existing domains? All .com domains? Domains of major trademarks? This is clearly VeriSign trying to push limits. It is using the charity portion of this auction as a clutch to push for altering the .com contract to its long-term benefit. I AM ABSOLUTELY AGAINST THIS. I GIVE A RESOUNDING *NO* TO PREMIUM PRICES AND RENEWALS ON ANY .COM DOMAIN NAME(S)!!! INCLUDING, BUT NOT LIMITED TO THE PROPOSED AUCTION OF O.COM. I ALSO GIVE A RESOUNDING *NO* TO OWNERSHIP RESTRICTIONS ON ANY .COM DOMAIN NAME(S)!!! THIS PROPOSAL GOES AGAINST THE ENTIRE SPIRIT OF THE .COM DOMAIN NAME EXTENSION AND INTRODUCE UNNECESSARY COMPLEXITIES. I submit that this proposal was made in bad faith. And here is how I know it: If this proposal were in good faith, it would have simply stated, "we, Verisign, would like to allow the auction of O.com. The auction will be conducted by a third party, all profits from said auction will be donated to charity. After that, this domain will abide by the exact same rules of all 133 million other .com domain names in existence." However, VeriSign did not do this or make this auction anywhere near so simple. VeriSign has made this extremely convoluted and complicated. Verisign is suggesting premium renewal fees and ownership restrictions. This is merely VeriSign's indirect plan. The proposal was not made with open arms. This proposal is an excuse to meddle with the longstanding .com contract! It is trying to carve out special requirements for certain domain name(s). If successful with O.com, what next? Obviously, the other single character and single letter .com domain names. But then what? Microsoft.com? Google.com? Diamonds.com? Mortgage.com? Bank.com? Search.com? Two-letter domains? All .com domains? The three already delegated single-character domains? Where would it end? ICANN should also realize the very dangerous precedent it would be setting if it entertained such a proposal. Entertaining this proposal as-is would mean subsequent rounds of "we want this" and "we want to auction that" and then "we want the profits" and then "we want premium renewals on existing domains." It sets up a dangerous precedent for ICANN to have to answer to all sorts of random carve-out requests in the .com contract by VeriSign. This is something ICANN is neither financially prepared for, nor should ICANN be putting any resources into! VeriSign should be managing the extension as the monopoloy it is, not trying to dictate special terms into specific domain names within the extension! I gladly support the release of the O.com domain name if it came with the exact same renewal prices every year going forward as every other .com domain name in existence, and as long as there are no limitations of ownership transfer. Essentially, if the domain were to act and abide by all rules and regulations already in place for ALL other 133 million .com domain names. I also support all proceeds of an O.com auction going purely to charity. But I only support such an auction *only* if the auctioned domain name(s) have no special restrictions which require meddling and altering the .com contract. A live O.com should be treated as every other .com domain in the world. VeriSign should *not* be allowed to alter the already monopolistic, most successful, most well-known extension for this one domain. To have a special section just for this domain in the contract. VeriSign should not be allowed to introduce carve-outs in the contract for ownership restrictions and premium renewal prices. And for what? Fir this one domain? For a group of 23 domain names? Think of it this way: There are 133,000,000+ .com domain names in existence. And Verisign is trying to alter the .com contract over ONE DOMAIN NAME. If this proposal is even considered, I propose VeriSign finally be forced to put the .com contract out for public tender once and for all. VeriSign, through this proposal, is trying to introduce changes into the .com contract for 1 domain name out of 133,000,000 domain names. This is absurd and insanity! Verisign, if foolish enough to pursue this, would wind up spending more on legal fees than the auction would net in the end. Why is it making such a request? Because Verisign is trying to use charity as an excuse to alter the .com contract. At the cost of ICANN, at the cost of the Internet community, and at an ultimate cost to .com domain name owners worldwide. In the end, the real cost is that the .com contract would become more complicated, split, and murky with special edge-cases, giving VeriSign more opportunities to try and put restrictions on more domain names in the future, which indirectly would lead to better bottom-line profits for the company. But would not be in the benefit of the world, a benefit to any .com domain name owners, and would take more and more of ICANN's time and resources going forward. I propose James Bidzos and Verisign simply donate the $35 million to charity on good accord (or whatever such auction might net) instead of trying to pull a fast one like they are doing here. The nuance of what they are doing might seem subtle at first, but it is clearly Verisign's intent to push the boundaries. Because if VeriSign wanted to be charitable it would have just given to charity. And if it wanted to be charitable, it would have simply proposed auctioning off O.com, with no strings attached. Instead, VeriSign has proposed premium renewal prices be introduced to the .com contract, that ownership rights restrictions be put into the contract. Over time VeriSign would love to start to introduce premium fees and ownership transfers on more .com domain names, put in more controls, and ratchet up the profits even more. Do not be fooled. This is 100% not about charity! It is VeriSign testing what limits it can push, so that eventually it can reap more profits from owners of .com domain names worldwide. Remember, this is a corporation that has proven to do such things. Remember when VeriSign forced its upper hand in the .com contract by means of Regulatory Capture? And remember when VeriSign upped the prices of .com domain names at every opportunity it was able to do so, until the NTIA said it could not do so anymore? What an embarrassment to the company that is supposed to be the steward for the .com extension, yet is it now proposing to muddy the .com contract over ONE SINGLE DOMAIN. To pave the path for more carve-outs in the .com contract in the future. VeriSign is always working to be more profitable and make things better for itself, worse for domain name registrants. Better for VeriSign. At a higher financial cost to the world. I am absolutely against the proposal to alter the .com contract for just one domain. Even if the argument is made they could do this for all other 23 one-letter .com domains currently not delegated, that is only 23 domain names out of 133,000,000 in existence. As a decimal this is 1.72932331e-7. Or in more readable format, Verisign is proposing altering the .com contract for only 0.00000017% of .com domain names in the world!!! This is stupid and should *not* be considered. If it were done, it would only be time until VeriSign then tries to alter the contract again, then again, then again. Only to push for what eventually gives the company the highest possible profits. This is their clear and obvious long-term plan. It is so abundantly obvious and all-for-profit. Not "charitable". VeriSign threw charity into the mix only try and make this sound like a good idea. Do not jeopardize the more than 132,999,974 .com domain names in existence by entertaining such a radical deviation from how the .com gTLD always has run with special pricing! Again, VeriSign is only using this as an excuse to try and modify the .com contract to its future financial benefit, and in no way should this one domain hold more important rights than the 132,999,974 COMBINED domain names that proceed it. The .com contract should *not* be altered for any specific domain or group of domain names!!!!! To do so would be a slap in the face of every .com domain name registrant worldwide! Should Verisign want push for the release of single character domains, the single most important thing is that these extremely few domains are bound by the exact same rules of all other .com domain names in existence today. To do otherwise is just too murky, and for what reason? Only to push the envelope and allow VeriSign to modify the .com contract? At a huge legal cost to ICANN and to VeriSign. And at the cost of splitting the .com contract for every single person and/or company who owns a .com domain name and this does in fact affect. To make management of domain names more complicated than it should be. This is very problematic to the other 133 million other owners of .com domain names in the world! This is AN EXTREMELY BAD IDEA which should be totally dismissed on behalf of the other 133 million .com domain name owners, whose contract (the .com contract) is potentially going to be altered and tarnished and muddied ... over ... one single domain name. And this would only introduce carve-outs which go completely against the defacto standard the other 133 million .com domain names are bound by. Finally -- why should I, Keven Dabney, have a say in the matter? Not only am I a citizen of the Internet and a domain name professional looking out for the common good, I myself own many domain names and this proposal affects me tremendously. It potentially jeopardizes each and every one of the .com domain names I own and operate, and I thus am completely against this proposal. I am also quite fearful that VeriSign would even consider such a move, and to me only indicates VeriSign is in this for ultimate long-term profit, and not to be the best steward to the .com namespace in the end. Thank you for listening. Keven Dabney Internet and Domain Name Professional

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[Comments-o-com-single-char-10may18] We urge ICANN to reject this proposal in its current form
by Don Smith June 20, 2018

June 20, 2018

Please review the attached PDF regarding VeriSign's Proposal for Release of Registration of one .COM Domain Name with a Single-Character Label: O.COM - Donald Smith

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[Comments-o-com-single-char-10may18] BC comment on Release for Registration of the Single-Character Label O.COM
by Steve DelBianco June 20, 2018

June 20, 2018

Attached is the comment of the ICANN Business Constituency (BC) regarding the proposed Release for Registration of the Single-Character Label O.COM This comment was drafted by Zak Muscovitch, with edits by Andrew Mack, Claudia Selli, Marilyn Cade, and Steve DelBianco. It was approved in accord with the BC Charter. Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency

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[Comments-o-com-single-char-10may18] Three points on single letter domain names
by John Berard June 20, 2018

June 20, 2018

> As a member of the Commercial and Business Users' Constituency, I support the comments filed by that group. > But as a small business person, I feel there are some points that are both more central to my sector of the Internet economy and important enough that I am filing this individual comment on the release of O.Com. > > First, it is often hard for a company to plow new ground. I have been doing it for 10 years and it seems I have at least 10 more to go. The effort and evidence of my business-building is always in jeopardy of being undercut by someone with deeper pockets and wider reach. > That why I believe it is, as they say at Mass on Sunday, “truly right and just” to take not just prior rights, but prior use & market investment into account in awarding all single-letter second-level domain names. > To do so also inoculates ICANN against potential failure. > > Second, too few times does ICANN have the chance to test a hypothesis. As with the new gTLD program, it is often an all-or-nothing policy decision. > In the case of O.com, ICANN has the chance to view the availability of the domain name as a grand experiment; getting to learn from its release so as to better shape those in the future. > I realize that other registries have released single-letter domain names, but, in terms of market power and potential, none match .com. For this reason, special care should be taken. > > Finally, while I am grateful that Verisign has agreed not to benefit from the O.com auction proceeds, I am uneasy about whether any of these funds might find their way into ICANN's operating budget. > Best would be for the funds (which we anticipate but cannot guarantee) to be used to support the organizations who ought to be involved in ICANN -- or involved more! > > So there it is. My view is that, as in the U.S. Patent Office, prior art ought to count, that the auction be viewed as a test of our assumptions, not their roll-out and the benefits go to those who can most benefit ICANN by doing their work not just at three meetings but all year. > John Berard Credible Context Sent from my iPhone

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[Comments-o-com-single-char-10may18] My organization uses o.com, this will mess up our network. Please do not do this!
by Stephen Paul June 20, 2018

June 20, 2018

The organization I work for is very much against this. We have used non-delegated single letter and single number domain names as server names for over a decade now. One of the servers we operate is literally named “o.com.” Due to this, delegation of this domain, and any other single character non-delegated domain would cause very big technical issues for our company. I am sure that our organization is not the only organization in the world that does this. I once talked to another individual who did this via host files in order to create shortcuts for himself to his most visited sites. In my own world, that is one company and one individual I know who already uses o.com and this proposal would negatively affect both my company and this other individual. How many other organizations will be adversely affected? What will the accumulated cost be to these people and organizations who are affected by the release of single letter domain names which have never been released before, and be forced to make costly changes? I am sure the combined cost to the world will wind up being more expensive than the proceeds from such an auction, therefore making this opposite of the desired result. For these reasons our organization is against the release of o.com or any other currently non-delegated single character domain. Stephen P.

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[Comments-o-com-single-char-10may18] Comment on Release for Registration one .COM Domain Name with a Single-Character Label: O.COM
by Timothy Flanagan June 19, 2018

June 19, 2018

I write to submit my opposition to the proposed Release for Registration one .COM Domain Name with a Single-Character Label: O.COM. The proposed release and amendment to the .COM Registry Agreement are troubling for a number of reasons, specified below, and I would encourage ICANN to reevaluate the proposed release to take into account alternatives that would be consistent with existing policy, as well as to enhance the public benefit of any prospective change. Specifically, my concerns are as follows: · The proposal appears to set up a preferential exception to the current ICANN rules for no apparent objective reason by virtue of the fact that only one of the possible single character domain names is addressed. It is not clear why just the letter “O” is singled out so as to justify a rule specific to it alone rather than any other single character domain name or all single character domain names, absent the appearance of outside influence. · The proposal sets up the potential for either (a) a questionable precedent for handling release of other single character domain names or (b) inconsistent handling of all single character domain names. · The proposal does not afford any protection for trademark owners who may have existing rights in the specified single character. o Preferential protection of existing trademark owners is accounted for in other new TLD offerings o Inclusion of existing trademark owner precedence in this case would permit consistent protection of trademark rights across all domain name classes. · The charities to receive proceeds should not be deemed confidential and should be identified by name for public review and scrutiny in order to establish accountability and transparency with funds acquired by means of a public service. Transparency is especially important in this case given the extremely narrow tailoring of an exception to long-standing rules, which can easily raise questions about the motivations and influences behind the decision to amend. I appreciate the opportunity to comment on this proposal, and I urge the Commission to thoroughly evaluate the ramifications of this proposed amendment and to modify it to promote sound public policy. Please note that I am writing this opposition in my personal capacity as an intellectual property attorney and not on behalf of my employer, and it in no way is intended to reflect the views or legal position of the University of Notre Dame. Timothy J. Flanagan Associate General Counsel Concurrent Professor of Law University of Notre Dame

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[Comments-o-com-single-char-10may18] Personal Comments of Ayden Férdeline
by Ayden Férdeline June 19, 2018

June 19, 2018

To Whom It May Concern: I support moving forward with the auction of O.com. I would like to see the funds from the sale of this domain name support the public good of the Internet community, in particular, those from non-commercial backgrounds who contribute towards the development of Domain Name System (DNS) policy. I would like to see these auction funds going to support the kind of activities that benefit and the support the legitimacy of ICANN's multistakeholder model, enabling ICANN community members who advance public interest-oriented contributions in DNS policy to engage more at the national and regional levels in broader Internet governance activities that directly and indirectly benefit ICANN. Thank you for considering my input. Sincerely yours, Ayden Férdeline

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[Comments-o-com-single-char-10may18] Support for the proposed auction of O.COM as is proposed in the RSEP.
by Garland McCoy June 18, 2018

June 18, 2018

I was involved in the very early days of ICANN’s existence through my work with others from the business community and see the evolution of ICANN into a more mature international organization, which seeks to be truly accountable to the broad community of Internet stakeholders around the world. I do not attend ICANN meetings, but I do follow some of the key issues through my participation at the IGF-USA and the IGF both of which I have been very involved sponsoring workshops and helping recruit speakers. When possible I have sought out ICANN speakers and many of my workshops directly or indirectly touched on ICANN issues so I have been a keen follower. However, several years ago, I was aware of the Working Group on Reserved Names related to single letters and that they proposed the auction of single letters in the initial gTLDs, like .org; .net and .com. I saw that single letter auctions moved ahead in some of the initial gTLDs but nothing happened in .com Seeing now that at last the single letters in .com are being auctioned is good news, as already there are 5-6 of those single letters in use. I am especially interested in the commitment that the auction funds not go to the auction house, nor the registrar or the registry or ICANN, but go to benefit the broader ICANN community. ICANN can be negatively affected by decisions at many other events, like the ITU or the IGF. So active engagement of different stakeholders is critical to ICANN’s fulfillment of its core mission, As an active participant in the global IGF, and in the IGF-USA I want to lend my support to the importance of the use of the auction funds for the trial of O.COM <http://o.com/> to benefit engagement and participation, especially for participants from developing countries – both in ICANN meetings; security and stability training events; and also in the IGF and the national IGFs, where many at the national level, who won’t even attend an ICANN meeting, learn about what ICANN’s core activities and mission are – along side engaging with other of the technical community, but also with civil society, and governmental agencies. Recently, I have been devoting significant time to the importance that without electricity (both generation and storage) , the Internet cannot advance to the unconnected and underconnected. While ICANN’s remit is not necessarily about bringing power sources to support the connectivity challenges that the developing countries still face, understanding what ICANN does do, and how security and stability at the national level for networks that are part of the Internet can only be a positive. I was impressed at the commitment that the auction funds will not benefit the registry, registrar, ICANN but benefit the broader ICANN community. I support the proposed auction of O.COM <http://o.com/> as is proposed in the RSEP. Garland T. McCoy, President Technology Education Institute

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[Comments-o-com-single-char-10may18] My personal comment on O.com proposed release
by Mary Uduma June 18, 2018

June 18, 2018

These comments are submitted in my personal capacity and are based on my experience and understanding of ICANN. I am a long time participant in ICANN processes, in many roles, including long standing engagement in the GAC, ccNSO and in the broader community; and as a member and participant in various CCWGs including the CCWG- IG and CCWG-AP. I only highlighted my experience in order to mention that I have a broad understanding of ICANN, its mission and core values, moreover its importance to the developing countries engagement as an informed and active participants. When I attended my firs ICANN Public meeting not many years from when it was founded, there were very few African participants on the Internet. Today, the Africans still have much progress to make, but I can see there is such a strong commitment in all African countries to engage fully, getting informed and advancing the growth of the Internet. In Africa, we understand and support ICANN's role and we want to see more engagement supported from across our entire region, and of course, other least developed countries, in being able to engage in ICANN, As I reviewed the posted comment, I note some areas that I can personally support: 1. Progress with the single letters in .com, just as all the other earlier gTLDs have already done, like .info and .biz and .org. 2. The commitment of VeriSign to not take the auction funds for themselves, or to give them to ICANN, but to make sure that they are available to support the broader Internet community. I wish to note the challenges of travel costs to attend technical training at national, or regional levels, or to attend the ICANN meetings for many from developing countries who really need the expertise to help to keep the Internet secure. This is a real barrier, and funds from the O.COM auction could support such participation from developing countries. As an advocate of child online protection in Nigeria, I can see these funds helping developing countries to develop programs that address child online protection -- awareness and education of teachers, guardians and parents, creation of help and advocacy centres, stakeholders engagements -- a vitally important area for many of the developing countries. Utilising these funds for capacity building is brilliant, it could support national level engagement in sessions where ICANN community and technical resource come together to address technical skills, as well as policy issues that affect the Internet, and by extension, the ICANN. The National Regional Initiates, (NRIs) where I spend a good deal of my time are a convening mechanism both nationally and sub-regionally and supporting participation by the disconnected internet communities in such events could be a very cost-effective use of auction funds. I therefore support the trial release of O.COM as proposed, and I hope that a broad definition of capacity building can be acknowledged. I also hope that if the trial is successful, then further single letters in .com will follow this model and contribute to benefit the broader ICANN and Internet communities. This is much needed support and can help to achieve access for all of those who are not yet connected to the Internet. BR Mary Uduma Sent from Mail for Windows 10

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[Comments-o-com-single-char-10may18] Comments from AfICTA
by Olusegun H. Olugbile June 18, 2018

June 18, 2018

Dear Everyone, I have been following discussions and comments on the release of o.com. Thanks to the BC volunteers for helping in drafting the BC comment. Contributing on behalf of AfICTA, AfICTA has been engaged in ICANN since 2012 representing the views and perspectives of concerned African ICT Associations and professionals. AfICTA supports the release of the trial of o.com as proposed in the RSEP and .com Registry amendment. We understand the need to recognize prior rights to ensure that the allocation of single letters can progress and that the use of the auction funds should support and contribute to the broader ICANN community. While AfiCTA supports the general areas identified by the original Working Group on Reserved Names, we also note that capacity development should be defined broadly to also support participation in ICANN and related activities. Thank you. Segun Olugbile

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