Name: Byron Holland

Organization: Canadian Internet Registration Authority (CIRA)

Submission ID: 134

Please find attached CIRA’s response to the draft proposal from the IANA StewardshipTransition Coordination GroupRegards,Byron

Alissa Cooper
Patrik Fältström
Mohamed El BashirCo-­‐chairs of the IANA Stewardship Transition Coordination Group (ICG)
September 8, 2015
Re: Response by CIRA to the draft proposal from the IANA Stewardship Transition Coordination Group(ICG)
The Canadian Internet Registration Authority (CIRA) is the private, not-­‐for-­‐profit corporation responsiblefor the operation of the .CA country code top-­‐level domain. CIRA is a member of the Country CodeNames Supporting Organisation (ccNSO) and a member of CENTR, the Council of European National Top
Level Domain Name Registries. I offer the following comments on the ICG’s draft proposal on behalf ofCIRA.
I commend the members of the ICG on the considerable work they have completed to date. The task set
out for them is as challenging as it is important, and I am pleased to see that the members of the ICG
have demonstrated the level of commitment necessary to achieve their mandate.
Overall, I believe the ICG’s proposal provides a thorough and implementable process to transition thestewardship of the IANA functions from the U.S. Government to the global, multi-­‐stakeholder
community. In terms of process, I would like to highlight the ICG’s foresight by providing the ‘Request
for Proposals’ in 2014, thereby facilitating a process to integrate the three community proposals in atimely and effective manner. I would also like to commend the ICG on its commitment to the multi-­‐stakeholder model, as evidenced by the diversity of stakeholders consulted with in the development ofthe proposal.
Intellectual Property Rights
In recent weeks, there has been considerable attention given to the issue of intellectual property rights.
I do not believe this is an issue that should hinder the progress of the IANA Stewardship Transition
process. To this end, I agree with the remarks provided by CENTR in its comment on the draft ICG
proposal; that there is no incompatibility between the proposals from the Names, Protocols andNumbers communities with respect to IP rights. I also agree with CENTR that the interim solution
provided in the ICANN Board of Directors’ statement on the topic of IP rights is an acceptable one.
Furthermore, I fully support the position expressed by the CWG-­‐IANA chairs in their September 2, 2015
comments to the ICG chairs, wherein they state:1

“Accordingly, the CWG hereby formally confirms that its position is consistent with that of theother two respondents to the ICG RFP in that it has no objection to the IANA trademarks and theIANA domain names (iana.org, .com and .net) being transferred to an entity independent of theIANA Functions Operator. For the avoidance of doubt, we view the CWG position as also
consistent with the ICANN board statement of 15 August 2015 on the same subject.”
Criteria set out by the NTIA
CIRA believes that the proposal as presented by the ICG meets all of the criteria set out by the National
Telecommunication and Information Administration in March 2014.
In particular, I would like to highlight those criteria set out by the NTIA that most directly relate to CIRA’soperations. CIRA is confident that the mechanisms as presented will not affect the security, stability andresiliency of the Domain Name System (DNS), and will, in fact, result in increased service levels for thenames community as the process to make changes to the Root Zone will be streamlined.
ICP-­‐1
In my capacity as chair of the ccNSO, I recently wrote to the ICG regarding the need to update certain
aspects of their proposal, and make certain other changes to the reference to ICP-­‐1. As the president
and CEO of CIRA, I would like to re-­‐iterate these points. That is, that the reference to the status of theFramework of Interpretation Working Group Report be changed from ‘pending’ to ‘accepted in full by
the ICANN Board of Directors’. Furthermore, I request that references ICP-­‐1 be removed from paragraph1036 of the ICG report and that this removal be documented in a footnote as it, and News Memo 1,
were never accepted as policy by the ccTLD community.
Once again, I commend the members of the ICG for their hard work and diligence in the development of
this proposal. I believe this to be one of the most important initiatives ever undertaken by the global
multi-­‐stakeholder community. As such, I encourage the community to implement it in a timely manner.

Byron Holland
President and CEO
Canadian Internet Registration Authority

2