Name: John Poole
Organization: DomainMondo.com (editor), Expri Communications LLC
Submission ID: 53

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 isimplemented. Is the combined proposal specified in sufficient detail such that it can beevaluated against the NTIA criteria?

Numbers: Complete; Protocol Parameters: Complete; Names community: INCOMPLETE due to its"dependencies" upon the final work product of WS-1 of CCWG-Accountability, which at this point
appears to be unacceptable or inadequate in its present form as contained in the "2nd draft report"
published for a comment period ending Sept 12, 2015.

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 work together as a single proposal, with ICANN as the IANA
functions operator (IFO). The names proposal is incompatible and inconsistent and results increating a second IFO (for the "Names community") called PTI, a to-be-created corporation. This iscreating unnecessary complexity, incurring unnecessary costs (CWG-Stewardship has reportedly
incurred millions of dollars in legal fees, with more to come), and deriving little, if any, net benefit
for the names community or the global Internet community. All of this could have been handledinternally to ICANN through new bylaws whereby the gTLDs and ccTLDs could comprise a CSC andprovisions providing for the selection of a different IFO than ICANN should that need arise. Theirony in all of this is that the IANA department within ICANN has always performed its job well as
far as I have been able to determine. Certainly numbers and protocols think so. Unfortunately, as theICG is well aware, CWG-stewardship or "names community" is a dysfunctional group (described byone ICG member, the esteemed Prof. Mueller, as "a collection of warring interests"), who wasted
months trying to develop an overly complex "turnkey" proposal referred to as "Contract Co." only tojettison that concept for a "compromise" "hybrid" "solution" now called PTI. This is all indicative ofwhat Nassim Taleb refers to as the "fragilista" who “make you engage in policies and actions, allartificial, in which the benefits are small and visible, and the side effects (are) potentially severe andinvisible.” Unfortunately this is also consistent with the tendency of many of ICANN's "names"
stakeholders in ICANN policymaking processes to prefer complex dysfunctional solutions over
simple functional solutions, in order to increase their "insider" knowledge and status, increase costs,and form barriers to any effective participation by "outsiders" from the global Internet community.
Can we (ICANN and the global Internet community) live with this incompatibility and the potential"conflicting overlaps?" As far as the ICG proposal is concerned, I am confident the ICANN Board,
management and staff, can jury-rig the "workarounds" necessary to "make it work."

3) Accountability: Do the operational community proposals together include appropriate
and properly supported independent accountability mechanisms for running the IANA

functions? Are there any gaps in overall accountability under the single proposal?

Numbers and Protocols proposals have accountability built-in, consistent with years of experience
working with ICANN as IFO. Names proposal? Unknown. CWG-Stewardship claims its new
structures' accountability mechanisms will work. Time will tell. See also #6 below.

4) Workability: Do the results of any tests or evaluations of workability that were includedin the operational community proposals conflict with each other or raise possible concerns
when considered in combination?

I covered this in #2 above.

Questions Concerning NTIA Criteria
5) Do you believe the proposal supports and enhances the multistakeholder model? If yes,please explain why. If not, please explain why and what proposal modifications you believe
are necessary.

For better or worse, I think the proposal is consistent with the multistakeholder model.

6) Do you believe the proposal maintains the security, stability, and resiliency of the DNS?
If yes, please explain why. If not, please explain why and what proposal modifications youbelieve are necessary.

No. Read Verisign's 10-Q, July 23, 2015 (p.29): "Under its new gTLD program, ICANN intends torecommend for delegation into the root zone a large number of new gTLDs potentially within acompressed timeframe. On October 23, 2013, NTIA began to authorize, and Verisign beganeffectuating, the delegation of the new gTLDs. In view of our role as the Root Zone Maintainer, andas a root operator, we face increased risks should ICANN’s delegation of these new gTLDs, which
represent unprecedented changes to the root zone in volume and frequency, cause security andstability problems within the DNS and/or for parties who rely on the DNS. Such risks include
potential instability of the DNS including potential fragmentation of the DNS should ICANN’sdelegations create sufficient instability, and potential claims based on our role in the root zone
provisioning and delegation process. These risks, alone or in the aggregate, have the potential tocause serious harm to our Registry Services business. Further, our business could also be harmed
through security, stability and resiliency degradation if the delegation of new gTLDs into the rootzone causes problems to certain components of the DNS ecosystem or other aspects of the global
DNS, or other relying parties are negatively impacted as a result of domain name collisions, such asexposure or other leakage of private or sensitive information. Additionally, DNS Security Extensions(“DNSSEC”) enabled in the root zone and at other levels of the DNS require new preventative
maintenance functions and operational practices that did not exist prior to the introduction ofDNSSEC. Any failure by Verisign or the IANA functions operator to comply with stated practices,such as those outlined in relevant DNSSEC Practice Statements, introduces risk to DNSSEC relying
parties and other Internet users and consumers of the DNS, which could have a material adverse
impact on our business."
http://files.shareholder.com/downloads/VRSN/368398346x0xS1014473-15-68/1014473/filing.pdf

7) Do you believe the proposal meets the needs and expectations of the global customers
and partners of the IANA services? If yes, please explain why. If not, please explain why andwhat proposal modifications you believe are necessary. Please indicate if you are acustomer or partner of the IANA services.

Yes, unless one or more "customers and partners of the IANA services" state differently during thiscomment period.

8) Do you believe the proposal maintains the openness of the Internet? If yes, please
explain why. If not, please explain why and what proposal modifications you believe arenecessary.

Yes, subject to the reservations expressed in #1 and #6 above.

9) Do you have any concerns that the proposal is replacing NTIA's role with a governmentled or inter-governmental organization solution? If yes, please explain why and what
proposal modifications you believe are necessary. If not, please explain why.

No.

10) Do you believe that the implementation of the proposal will continue to uphold theNTIA criteria in the future? If yes, please explain why. If not, please explain why and what
proposal modifications you believe are necessary.

I think all of this is probably just a temporary iteration, necessary in order to end US government"oversight." After this is finished and implemented, I don't think anybody will mention or evenconsider "NTIA criteria" in the future.

Questions Concerning ICG Report and Executive Summary11) Do you believe the ICG report and executive summary accurately reflect all necessary
aspects of the overall proposal? If not, please explain what modifications you believe arenecessary.

No modifications necessary, provided the provisions for transfer of the IANA trademarks and domainnames to the IETF Trust (see numbers proposal) is implemented in a way that ICANN may continue
to use the IANA marks and domain names as a licensee so long as it or its controlled entity andaffiliate, PTI, performs IANA functions.

General Questions
12) Do you have any general comments for the ICG about the proposal?

ICG should steer clear of the CCWG-Accountability proposal even though the "names proposal" has"dependencies" that might be affected. That CCWG-Accountability process looked like a "rush job"from my close observation, and now the ICANN Board is engaged and proposing changes. I haven't
seen any Board specifics, but in any event, that is not within ICG's remit (be thankful). I also agreewith the sentiments expressed by Brian Carpenter (Submission ID: 2) in regard to #3 and #6:#3--"I don't see any way that ICANN itself is held accountable for the consequences of its policy
decisions (e.g. creating large numbers of unnecessary gTLDs for no discernible motive exceptmoney)."#6--"I've been concerned since 1998 that unchecked expansion of the number of gTLDs will
eventually take us into uncharted territory from a technical resilience point of view. I see notechnical and operational feedback mechanism to protect us against this operational risk in theproposal."Also, while I do not agree with some of the specifics, I am sympathetic to the frustration expressedin the comments submitted by Parminder Jeet Singh (Submission ID: 19).