Name: Mike Chartier
Organization: Intel Corporation
Submission ID: 122

Please accept Intel’s comments on the IANA Stewardship Transition Proposal
Thanks,Mike Chartier

IANA Stewardship Transition Proposal - Public Comment Form
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First Name Mike
Last Name Chartier
Email Address REDACTEDCountry/Economy US
Organization Intel Corporation

Questions Concerning the Proposal as a Whole1)

Completeness and clarity: Is the combined proposal complete? Each of the operational
community proposals contains aspects to be completed in the future when the proposal
is implemented. Is the combined proposal specified in sufficient detail such that it can beevaluated against the NTIA criteria?

Intel is pleased to provide these comments on the proposal to transition the stewardship of the Internet
Assigned Numbers Authority (IANA) Functions from the U.S. Commerce Department’s National
Telecommunications and Information Administration (NTIA) to the Global Multistakeholder Community.
Intel is the largest semi-conductor company in the world and for over forty years, as steward of Moore’slaw, has designed and manufactured the computing power of the Internet. Intel is not a contracted partyof ICANN but the uninterrupted performance of the IANA functions that “maintains the security, stabilityand resiliency of the DNS” is critical to our business. We rely on the IETF to produce protocols that webuild into technology to allow for that connectivity; we rely on the global Internet Protocol addressing
system of the Regional Internet Registries (RIRs) to allocate addresses so networks can grow anddemand more of our products; and, we expect domain names to resolve to a single root location so thatusers and businesses across the globe see the same information. Without these functions, connected
devices will not fully realize their value to improve the lives of everyone on earth.
Intel supports the ICG proposal; we believe it is a solid plan, and find no fundamental flaws that would
prevent it being eventually being transmitted, and subsequently approved by the NTIA. We do, however,note a small number of points for improvement and clarification:
Concerning the overall proposal, Intel supports the creation of a new, separate legal entity, PostTransition IANA (PTI), as an affiliate (subsidiary) of ICANN. However we believe the ICG

proposal should clarify whether the Numbers and Protocols communities, and Root Zone
Maintainer will contract with ICANN or the PTI. It should also be made clear to what extent theNumbers and Protocols communities will participate in the IFR and CSC processes.
With regard to the domain name community, Intel applauds the hard work and diligence devoted
to this proposal. Concerning the Root Zone Maintainer, we agree with the ICG that an “agreement
between the IANA functions operator and RZM that clearly defines the roles and responsibilities
of both parties is essential for the secure, stable and resilient operation of the Root Zone of theDNS when the NTIA withdraws from the Root Zone Management process” and look forward to
the development and publishing of the agreement. Intel notes a transition mechanism has been1developed by VeriSign and ICANN “that outlines a technical plan and testing regime for phasingout the largely clerical role NTIA currently plays in this process.” While the development of thistechnical plan was “conducted in confidence at Verisign’s request, for commercial businessreasons,” the development of the IANA functions operator-RZM agreement should be developedin the same multi-stakeholder process as the other agreements such as the ICANN-PTI
agreement, for which a draft statement of work (Annex e) and term sheet (Annex s) wereattached to the current proposal.

2)Compatibility and interoperability: Do the operational community proposals work together
in a single proposal? Do they suggest any incompatible arrangements wherecompatibility appears to be required? Is the handling of any conflicting overlaps between
the functions resolved in a workable manner?

The Numbers and Protocols proposals remain essentially unchanged from their development in January
and as such reflect their maturity and soundness. As mentioned above the relationship of the numbers
and protocols communities to the PTI needed to be clearly defined to allow for the conclusion of theprerequisite service level agreements and MOUs.

General Questions
1See “An Update on the IANA Transition”; August 17, 2015 by Assistant Secretary for Communications andInformation and NTIA Administrator Lawrence E. Strickling; http://www.ntia.doc.gov/blog/2015/update-­‐iana-­‐transition12)

Do you have any general comments for the ICG about the proposal?

With regard to implementation and timing, we note that the NTIA plans to extend their IANA contract with2ICANN for one year to September 30, 2016 . We believe that a year should be adequate time for thetransition if ICANN concentrates on implementing those elements, including adopting the requisite bylaw
changes identified by the community and NTIA as being preconditions for the transition to occur.
However, Intel also recognizes the interdependency of some elements with the work of the CCWG on
Enhancing ICANN Accountability. We also will be submitting comments in that consultation

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