[http://intlnet.org ]{.underline}

71 rue Royale -78000 Versailles -France Tel. (33.1) 39 50 05 10
info@intlnet.org

Fiona Alexander Office of International Affairs National
Telecommunications and Information Administration 1401 Constitution
Avenue, N.W., Room 4701 Washington, DC 20230

July 6^th^, 2006

Dear Mrs Alexander,

We noted with interest your Docket No. 060519136-6136-0 : the United
States Department of Commerce's National Telecommunications and
Information Administration (NTIA) seeks comment on the continuation of
the transition of the technical coordination and management of the
Internet do main name and addressing system (Internet DNS) to the
private sector.

INTLNET was created in France, in 1978 to serve as a common secretariat
for the cooperation, information, and catalysis of the development of
public and private systems participating in the international packet
switch services, which were primarily pioneered by Tymnet Inc. under an
FCC value added network licence. Until 1986, INTLNET directly
participated in the development of the international network and of the
name space [(ttp://intlnet.org/intlhist.htm]{.underline}), as well as
the introduction of OSI technology and the international connection of
the Internet. INTLNET publishes a daily status report on the Internet
top zone. It develops a distributed registry architecture in order to
document and support the Multilingual Internet by way of usage.

To best know how to transition a system such as the Internet, one would
need to gather elements about its previous evolutions and transitions,
to better understand what it is, where it comes from, and where it
should go. This is not easy, as most of the experience of the Tymnet and
OSI pre-Internet international network deployment and successive
transitions has been lost, and since plans for the future Internet (NSF)
are slow in their forthcoming. An additional problem for a Government
Agency is that the USA is probably the only country that has issued a
legal definition of the Internet, in which their definition that was
offered is rather confusing. To our knowledge their definition is:

*\"Internet: The term \'\'Internet\'\' means the international computer
network of both Federal and non-Federal interoperable packet switched
data networks.\" 47 U.S.C. § 230(f)(1). *

and is further detailed as follows:

*Internet.\--The term \`\`Internet\'\' means collectively the myriad of
computer and telecommunications facilities, including equipment and
operating software, which comprise the interconnected world-wide network
of networks that employ the Transmission Control Protocol/Internet
Protocol, or any predecessor or successor protocols to such protocol, to
communicate information of all kinds by wire or radio. -Internet Tax
Freedom Act, Pub. L. No. 105-277, Div. C, tit 11, § 1101(e)(3)(C) -The
Children\'s Online Privacy Protection Act, Pub. L. No. 105-277, Div. C,
tit 13, § 1302(6). *

In addition to being technically confuse, this definition, depending on
the way it is understood or use, can be erroneous. This can only result
in confusion, misunderstanding, and most probably inadequate decisions.

Let us observe the reality at hand. There is a human digital ecosystem.

This ecosystem is made of three structural levels of a different nature,
origin, and governance.

-   an ***infrastructure ***made of all the digital links and
    **information **systems of many technologies, with billions of
    owners, and their physical addresses.

-   a ***superstructure ***made of many logics and procedures permitting
    many types of **communications **through that infrastructure, based
    on Ethernet, TCP/IP, OSI, MPEG, etc., of which the end to end
    Internet global networking system is only one part.

-   a ***metastucture ***made of all the different relational **services
    **organised by and for the users, one of which is the DNS (which can
    be used outside the Internet, as is done on some mobile phones).

What the NTIA is now discussing is a vertical approach that could be
labelled an "Internationalized US Internet". It does not consider this
horizontal layering. The risks are unmanageable, rigid, and complex
layer violations, ultimately leading to conflict with other horizontal
approaches such as China\'s as well as grassroots projects' approaches.

In Tunis, the USA demanded to the world to control the Internet. The
world fortunately accepted, and in turn created the IGF. However, it
seems that there is a misunderstanding between what the concerned
politicians think that they discussed and what they actually decided on
in terms of the Internet architecture of usage.

They did not agree to having foreign computers and communications lines
controlled by the USA. They did not agree to allow the USA to have
control over their languages, cultures, societal behaviours, e-economy,
Internet policy, and laws (even though some US Industry consortia feel
they did). They also did not agree that the foreign non-Internet
technologies systems would be controlled by the USA.

They only agreed that three small files, which list the TLDs that the
NTIA wants to protect and the IP address block allocation, to be
retained under the control of the IANA/ICANN. This is because together
with the US datacoms infrastructure, other FCC policies regarding the
other digital issues, US service industries, relations established with
foreign ccTLDs, and the IETF protocols and language oriented solutions
they collectively builds that Internationalized US Internet.

In so doing, the Tunis agreement de facto acknowledged that each country
has the right to operate the same control on its own Internet equivalent
resources. This created a **compartmentalization **framework at the
meta-infrastructural level, which is hopefully able to prevent an
Internet vertical **fragmentation **(also called "balkanization"). This
is what can be described as the "national networks of the network of
networks". This situation is the stable situation of the other
communication areas, and datacommunications known before the blunt
expansion of the Internet due to the advent of the Web application. One
can call it network maturity.

However, that stability will only exist when the US Government
demonstrates that it shares that understanding, through the formulation
of the mission assigned to its Internet Coordination Agency, whether
public or private (ICANN). Until then, we are in an unstable situation
where many things are developing without a clear vision of a common
goal.

The Internet is a global system where there cannot be any win/lose
situations. There can eventually only be win/win and lose/lose
solutions. The issue today is the Multi-Internet (multilingual,
multinational, multilateral, multitechnology, etc.). It can result
either from a consensual evolution, or from an opposition to the
"Mono-Internet" (unilingual/internationalized, unilateral leadership,
one single technology, etc.). The NTIA must provide a clear sign that it
does not want to prevent a "Multi-Internet", even if at this time the
current solutions were able to address all the US needs (what is
probably not the case).

The core of the "Mono-Internet" is the IANA, which is managed by ICANN.
In a distributed Internet, the IANA was a single point of possible
failure but a valuable control tool for names and addresses. The
addition of language registries makes it now a point of contention, and
a planned target for power control. (cf.
[http://jefsey.com/iana-review-060630.pdf]{.underline}).

Vint Cerf recently explained that the authoritative root is the one that
has more users. The authoritative root is now the GSMA root file, which
is supported by NeuStar, including ".gprs", with a potential of 2
billion existing users. To try to artificially maintain ICANN as the
sponsor of the International Network, and to use the Root Server System
and the IANA servers to that end, would be extremely hazardous. These
two key services must become virtual, focusing on the content of the
registries, protecting their leadership through quality rather than by
complementarity exclusion: this would only pave the way to an Internet
split, along with IANA competition and its eventual take over by some
large stakeholder. This most probably would lead to instability and
further splits.

This is why the proposed NTIA ICANN job definition is adequate. The role
of ICANN should primarily be to manage the NTIA root file and ensure
that its TLDs can be accessed worldwide. In so doing it will protect US
interests and help every other country attain that their own TLDs be
accessed in their own language, based on reciprocity. Similarly, it
should ensure that the current Ipv4 and the ICANN Ipv6 are supported by
the RIRs, and should cooperate well with the ITU Ipv6 /3 block for the
countries that would like to deploy it.

To obtain this, ICANN should act as an innovation catalyst. It should
promote IPSec, true Multilingual Internet support, and press the IETF
for the documentation of the transition from a DNS unique authoritative
root to a virtual root matrix, along the lines of the ICANN ICP-3
Document (http://www.icann.org/icp/icp-3.htm ). Otherwise the
multilingual domain names, keywords and private aliases will be
supported in confusion.

An historic pioneer of international datacommunications services, after
the delay created by the deregulation period, the USA used the academic
Internet as their national packet switch network. It easily developed
worldwide, the deregulation being then widespread, when the Web
application came. The existing foreign systems found it appropriate to
back to the e-central US market communication solution. Today, the world
is not US e-centric any longer and can reconsider more national or even
user centric solutions. This could soon become detrimental to the USA
(and therefore to the rest of the world in a global system). The USA
does not have an NIC like all other countries do, they are not ready for
new services/visions of a foreign origin, or to maintain their digital
presence on a Multilingual Internet, where English and even Ascii will
no longer have an advantage.

This must be addressed. Delaying it can only be detrimental to everyone.
If the USG decides that ICANN is in charge, it MUST assist in the
development of US multilingual support, contribute to international
cooperation, ensure that US interests are internationally duly
considered, and document the US government and Congress when reciprocity
is unsupported (what would on the mid-range only deserve US and Global
interests). It is believed that it is only in being more American, and
in clearly supporting the international American interest and security
concerns ([http://whitehouse.gov/pcipb]{.underline}) among the
international cooperation, in turn pushing other countries to do the
same in the common interest, that ICANN can best contribute to the
development, stability, end to end interoperability, and innovation of
the networks of the network of networks.

Yours faithfully,

JFC Morfin Executive Director