Name: Zhang Zuan

Organization: China Organizational Name Administration Center (CONAC)

Submission ID: 50

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 thecombined proposal specified in sufficient detail such that it can be evaluated against the NTIA criteria?

CONAC believes this integrated proposal includes complete principles and mechanisms, but details must still beprovided. For example, in the workshop regarding the IANA’s function stewardship transition held by theChinese community in Beijing on August 31, the Chinese community expressed concern regarding thecomposition and selection mode of IANA (PTI) Board members after the transition, with the hope that PTI Board
members would remain relatively independent with the ICANN Board, adding that PTI Board members should
be selected from operational communities in a fair, open and transparent manner, with attention paid togeographical diversity and balance. Chinese TLD registries/registrars and other operators focused more on thecomposition and selection mode of Customer Standing Committee (CSC) members, and how CSC would protect
the interests of TLD operators. The Chinese community hopes this integrated proposal can be enriched with details
on the foregoing.

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

CONAC believes all the proposals submitted by operational communities can be integrated into a separate
proposal in order that any conflict that may arise through the operation of various IANA functions may beresolved through the international legal system framework without being subject only to the legal system of theUnited States.

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 inoverall accountability under the single proposal?

CONAC believes the integration of all the proposals submitted by operational communities can provide
appropriate, applicable, independent accountability mechanisms for the operation of IANA functions. However,there are some vulnerabilities in the overall accountability mechanism. For example, various Supporting
Organizations and Advisory Committees (SO/AC) determined in this proposal are ICANN participants in the“single member” mode, which is ultimately governed in accordance with the law of the United States. What you
should note here is that NTIA will transfer the IANA stewardship to the global multiple-stakeholder community;
therefore, the overall accountability mechanism of ICANN should not be subject only to the United States legal
system but should resolve all issues under the international legal system accepted by all parties. CONAC suggeststhat the multiple-stakeholder community hold sustained, in-depth discussion regarding jurisdictional issues afterthe IANA stewardship transition.

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

CONAC is currently fine with that.

Questions Concerning NTIA Criteria

5) Do you believe the proposal supports and enhances the multiple-stakeholder model? If yes, please
explain why. If not, please explain why and what proposal modifications you believe are necessary.

CONAC believes this proposal supports and enhances the multiple-stakeholder model. From the proposal pointof view, IANA function stewardship will eventually be carried out by the global multiple-stakeholder community,
and the whole community has discussed and established the appropriate operational mechanisms andaccountability mechanisms through a fair, open, transparent process of policy development that can ensure thesafe, stable operation of IANA functions.

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 you believe are necessary.

CONAC believes this proposal maintains the security, stability and resiliency of the DNS. This proposal agreed bycommunities is based on the operating mechanism of IANA functions, which currently works well and issatisfactory to all the parties. This greatly ensures that the IANA functions after transition will not change theoperation of the existing IANA functions. Moreover, this proposal sets a mechanism to replace the IANA
functions operators when the communities are not satisfied with the operation of IANA functions and thus
effectively protect the effective operation of the IANA functions.

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 and what proposal modifications
you believe are necessary. Please indicate if you are a customer or partner of the IANA services.

CONAC is a registry of new gTLDs, ".政务" (government affairs) and ".公益" (public interests) authorized by
ICANN, and is a customer served by IANA. CONAC believes this proposal basically meets the needs andexpectations of the global customers and partners of the IANA services. This proposal, as agreed bycommunities, is based on the operating mechanism of IANA functions that currently work well and aresatisfactory to all parties, so the IANA functions after transition will not significantly change the operation of theexisting IANA functions. Therefore, CONAC believes this proposal can continue to meet the needs andexpectations of the global customers and partners of the IANA services.

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 are necessary.

CONAC believes this proposal maintains the openness of the Internet. After transition, the functions of theIANA will be carried out by the post-transition IANA (PTI) selected by the global multiple-stakeholder
community, whereby all parties of this community will come to an agreement on the mechanisms to ensure thePTI operation. These mechanisms ensure the participation of all stakeholders so as to maintain the openness ofthe Internet.

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

CONAC believes this proposal will not replace the NTIA role with a government-led or inter-governmentalorganizational solution. When NTIA announced that it would transfer IANA functions to the global multiplestakeholder community, it clearly stated that it would not accept the post-transition IANA led by a government
or an inter-governmental organization. And this clear statement has been recognized and accepted by the globalmultiple-stakeholders. In the negotiation course of this proposal, the global multiple-stakeholder community
deliberates based on this firmly established idea, and consequently it will no longer be controlled by any single
specific political force.

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

CONAC believes the implementation of this proposal will, in the future, continue to follow the criteria put forward
by NTIA. The criteria put forward by NTIA are accepted worldwide, thus ensuring the safe, stable operation of theInternet. We believe that in the course of future operation, the global multiple-stakeholder community willcontinue to maintain the good operation of IANA functions based on these criteria.

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

CONAC believes the ICG report and executive summary accurately reflect all the necessary information of theintegrated proposals.

General Questions

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

During the past 11 months, the global multiple-stakeholder community has held extensive discussions about theissues of IANA functions stewardship transition. CONAC has been continuously concerned about thesediscussions. We have expressed our appreciation for the efforts made by the community and experts, and wecongratulate the community for the results achieved. First, we very much appreciate that ICANN provided theChinese version of this proposal in a timely manner, as it is essential and useful for the Chinese community to keep
abreast of the entire proposal content and participate in the discussion. We appreciate the excellent improvementof the language services that ICANN made. Secondly, the transition proposal has put forward the idea ofestablishing the post-transition IANA (PTI) and the Customer Standing Committee (CSC), but the relevant details
about the PTI and CSC have not been described. We suggest that the Names Community explain the relevantmechanisms and principles of the PTI Board and CSC operations in the proposal, and that it describe the selectionand composition mode of CSC and PTI members to ensure its openness, fairness and transparency. Furthermore,
we think that, for the PTI director candidates, we should select the appropriate governing representatives basedon the number of Internet users within each geographic region in order to adequately represent the interests ofthe Internet users within these representatives' regions. Thirdly, we suggest that when PTI signs any agreementwith ICANN it should specify in the agreement that when any dispute arises between PTI and ICANN it should bearbitrated under the international law system but should not be subject only to the law of the United States, so as
to ensure fairness to other countries. CONAC appreciates that the U.S. government transfers the IANA
stewardship to the global multiple-stakeholder community. We believe this transition will be made successfully.
We will continue to monitor the follow-up implementation process of the proposal measurements, and actively
participate in the community discussions.