Greetings. One of the action items from the last NARALO meeting, as a follow-up to the .PR issue, was to prepare a communication from the NARALO to the appropriate subcommittee within the CCNSO that is looking at reform -- I believe it is called MAC or some other acronymial thing. Cheryl Langdon-Orr has offered to convey this communique, since she is at-large liaison to the CCNSO, so I am sure she can tell us the exact name of the appropriate recipient group and make sure this gets to them. You'll notice some similar language in the draft, I pared down the original draft statement to about three paragraphs, and then added some substance from the Knujon research. Please feel free to add your comments, corrections, etc. DRAFT ----------------------------------------------------------------- The North American At-Large Regional Organization is concerned about the management of the U.S. territory of Puerto Rico's country code top-level domain, .pr, following a June 2011 lawsuit filed by The University of Puerto Rico against the domain's manager alleging misappropriation of public funds and inappropriate ownership claim, among other allegations. In 1988, the U.S. National Science Foundation established a program to expand use of the Internet outside the United States by establishing a domain registration that would allow each country connected to the network to offer access through that domain. The University of Puerto Rico, through its Gauss Research Laboratory requested the domain ".pr" (institutional research number 8818283, "Support for the Participation of the University of Puerto Rico in the NSFNet"). This proposal was approved in 1989. Administration of the .pr domain was designated to the "Gauss Research Laboratory" with the university as manager. In 2006, the .pr ccTLD's manager contacted the Internet Assigned Numbers Authority to request a name change in the sponsoring organization, from the University of Puerto Rico to a corporation with the same name, including the abbreviations "INC. i.e. Gauss Research Laboratory, Inc." As a result, Gauss Research Laboratory Inc. was permitted to remove the .pr ccTLD operations outside the university campus, as well as redirect any funds generated by domain purchases. The NARALO is concerned the apparent "re-delegation" of the .pr domain represents a potential abuse of public trust and misappropriation of Internet resources. In addition, while the controversy over Puerto Rico's country-code domain may seem unusual, findings presented in the final report of the ccNSO Delegation and Redelegation Working Group ([1]http://ccnso.icann.org/workinggroups/final-drd-report-02may11-en.pdf) clearly indicate it is not. Further problematic findings in the ccTLD space were documented by Knujon, an at-large structure in the NARALO, in a June 5, 2009 report ([2]http://www.knujon.com/ccTLD_Research_knujon_052109.pdf). We would like to call the ccNSOâs specific attention to pages 9- 10 and 17-20 in the report, which specifically name ccTLDs frequently used by criminals, and other country code domains potentially at risk for the same kind of abuse, as well as apparently dormant ccTLDs issued, for instance, to islands populated by birds and sea mammals, but no humans. NARALO applauds and supports the ccNSO working group's desire, stated in its working groupâs report, to "create an environment for making consistent and predictable decisions regarding the delegation, re-delegation and retirement of ccTLDs while enhancing accountability and transparency." We would like to encourage the working group to directly address the issues raised in the Knujon report, as well as disclose, for accountability and transparencyâs sake, pertinent discussion on the .pr situation. The NARALO believes that the public needs to be fully informed about this valuable Internet resource, how it is being managed, and what steps are being taken to ensure its proper administration in the future. References 1. http://ccnso.icann.org/workinggroups/final-drd-report-02may11-en.pdf 2. http://www.knujon.com/ccTLD_Research_knujon_052109.pdf