Name: Adam Coughlin

Organization: Dyn

Submission ID: 34

Please find attached an official comment from Dyn on ICG proposal for IANA transition.
Any questions, please do not hesitate to contact me.
Thank you for this opportunity.
Adam-Adam Coughlin
Director, Corporate Communications
Dyn(C): REDACTED(T): REDACTED
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Dyn appreciates the opportunity to comment on the IANA Transition Stewardship Coordination
Group (ICG) “Proposal to Transition the Stewardship of the Internet Assigned Numbers
Authority (IANA) Functions from the U.S. Commerce Department’s NationalTelecommunications and Information Administration (NTIA) to the Global MultistakeholderCommunity” (henceforth, “the proposal”). We thank the Internet community and the ICG for thetremendous collective effort the proposal represents.
To begin with, Dyn wishes to express strongly its general view that now is the correct time forthis long-planned transition. The current mechanisms are working. If anyone had doubts thatthe global, multistakeholder Internet community is prepared to undertake the oversight andstewardship of these important but clerical functions, the development of the proposal ought toput those doubts to rest. The system has been working for about 15 years, it has grown up, and
it is time to get any government out of the direct oversight of these functions. The Internet isand always has been made up of various enterprises (many and today mostly private) that use
loose coordination for smooth operation of the whole system. Government should not interfere
in that function.
Dyn also wishes to express its overall support for the proposal from the ICG. It has beendeveloped according to the criteria that the National Telecommunications and Information
Administration (NTIA) outlined in its original announcement.
At the same time, Dyn notes that there are, as expected, several pieces of the proposal thatneed elaboration and finalization during the implementation phase. As a result, Dyn supports
the extension of the Internet Corporation for Assigned Names and Numbers (ICANN)
agreement with NTIA for an additional year, while those details are worked out. Dyn’s view isthat the process of such implementation should include checkpoints during which the Internet
community may confirm the details for coherence with the community’s shared understanding.
Below are some particular issues that Dyn believes need special attention during theimplementation phase.

Specific issues for protocol parameters and number resources
Dyn’s business depends on the stable, secure, scalable, and smooth operation of Internet
infrastructure. Therefore, Dyn depends on the IANA protocol parameters and number
resources registries. Dyn’s view is that the overall plans for protocol parameters and number
resources are in very good shape, and are very nearly complete. We nevertheless observe
some details that need to be sorted out.
●●

●The protocol parameters data must be affirmed to be in the public domain.
The protocol parameters section of the proposal requests that any transition of theprotocol parameters registries will be adequately supported; this affirmation needs to bemade by the IANA functions operator (ICANN).
The numbers section of the proposal expects that the ownership of various intellectualproperty, including the domain name iana.org and the trademarks in IANA, be moved to●some independent third party; we believe this is an important future safeguard and must
be completed.
An agreement between the various Regional Internet Registries (RIRs) and theincumbent IANA functions operator (i.e. ICANN) is needed to ensure the policy
independence of the (currently functioning) number resources policy bodies.

Dyn believes that these details will be easily worked out, and therefore the transition will not be
blocked by any of them. Dyn nevertheless takes these to be crucial, and expects they will becompleted by the time of transition. We would call a transition that did not include theseelements incomplete.
In the NTIA announcement, there is no suggestion that the different pieces of IANA mighttransition at different times. Dyn observes, however, that sound engineering often involves
undertaking work in stages. It seems possible to Dyn that the protocol parameters and number
resources functions transitions could be undertaken as discrete phases of the overall transition
using the plans in the proposal without any damage to the unified IANA.

Specific issues for names
Dyn’s business relies on the stable, secure, and scalable operation of the global DNS. That
includes the DNS root, and it is primarily that business interest that motivates our view. Dyn
also participates in the domain name registration market, but this is mostly a supporting functionof its overall business activities.
Dyn understands the diverse interests in the domain name community, and appreciates the way
the names portion of the proposal balances those many interests in a way that responds to thevarious needs. At the same time, Dyn observes that this portion of the proposal is in someways the most detailed, and yet that seems to have the most significant gaps. In part, this isbecause several pieces of the proposal are dependent on accountability changes to ICANN.
Those changes are not specified in the proposal, and Dyn shall comment on them in theappropriate venue.
Setting aside the accountability issues, however, Dyn notes that the arrangements in the names
portion of the proposal are something of a change from the existing state of affairs. It is entirely
possible that the new arrangements can be implemented without significant changes to theexisting state. For instance, if the Post Transition IANA (PTI) is implemented by a simple
transfer of all staff and operations to a new entity, and if that entity truly has no new policy
capabilities or discretion to make decisions outside the existing IANA names functions, then thetransition will impose very low risk while yet disentangling the registry operation and root zone
policy functions (which both reside today in ICANN). It is, however, extremely difficult toevaluate the prospects of such an implementation without a detailed implementation plan. That
is not what is available today.
The names portion of the proposal also creates some new mechanisms within ICANN that will
require community participation and effort. Dyn has two concerns: the complexity of these newmechanisms is perhaps greater than one might like, and the details of the implementation of thenew mechanisms could close them to the Internet community.
Dyn recognizes, to address the first point, that the community needed to develop a number of
new mechanisms quickly. The new mechanisms, including the creation of PTI and all theassociated oversight, are all subject to community review. Dyn believes that the community
review in the future will provide opportunities to simplify and make clearer the interactions of thevarious mechanisms. It is therefore important that any implementation include early andfrequent review, so that complex mechanisms may be simplified when the Internet interest isthereby better served. Note that this is the interest of the Internet as a whole, and mostespecially the smooth operation of the IANA names function; it is not to ensure preferences forexisting arrangements in the names community or to prefer a current state of affairs over(possibly commercially threatening) alternatives that might emerge over time. Dyn believes thisis achievable through existing ICANN processes, assuming they are not restricted by new
accountability measures.
On the second issue, Dyn is more worried. Participation in existing ICANN processes andbodies already constitutes a burden for organizations with a commercial interest in thatparticipation. For people and organizations without such a direct commercial interest, itrepresents an unaffordable luxury. It is therefore of great importance that the implementation ofthese new, somewhat complicated mechanisms be undertaken with an eye to keeping overhead
low, to ensuring little synchronous activity (this includes minimizing meetings andteleconferences), and to operating as far as possible via publicly auditable mechanisms such as
mailing lists. Regular attendance at ICANN meetings in far-flung locations should, especially,
not be built into the implementation. Most of the new mechanisms ought to be able toaccommodate this mode of work: if the Open Source or Free Software communities canproduce an entire operating system by using mailing lists, surely the oversight of a fairly modest
clerical function (the IANA names function) can work the same way.

In conclusion
Dyn remains strongly supportive of the stewardship of the IANA functions moving away fromany direct government oversight, so that the Internet community -- which includes national
governments -- may ensure the continued growth and health of the single, global Internet. The
Internet is an engine of enormous growth and opportunity. All of the stakeholders on theInternet, including but not only governments, have a critical role to play in that continued growthand health. The Internet is too important for any one body -- even the US Government -- to holda special stewardship role. We must all do our part, and Dyn believes that the ICG proposal is away to ensure that.