Dear VI WG,

Now is the time to rollout new competition and new gTLDs that will service the growth and future of the Net.  Now is not the time to tamper with tried and true systems.

The subprime mortgage crisis in the United States was led by cries for innovation and unwinding of the regulations that had long held a steady hand in the financial markets. Few relatively small experiments ultimately had the unintended, unanticipated and domino-like effect of the collapse of multiple financial institutions.  As one failure precipitated another, it soon became evident that the damage could not be constrained, or easily reversed.  In the end, the public trust was lost in not only in the institutions themselves but also in the regulatory bodies which had heard but not heeded the call for restraint.   

With stakes high for serving the public interest, and preserving the security and stability of the Internet, tampering with a proven model is not an option – not for us, nor for the millions of registrants, websites, listserves and other systems which depend on the domain names we offer.  It is far easier to determine the right structure to drive behavior, than to police conduct after the fact.

PIR hereby submits a proposal which relies on the most basic of principles, as well as some innovative ideas.  In the interest of delivering this proposal to the Working Group by today’s deadline, we provide a framework here, and will follow with further details and explanations. We look forward to the discussion today, and in the days and weeks ahead. Please find our new proposal for our discussion attached.

Best,

Kathy Kleiman

Director of Policy, PIR