[NA-Discuss] DRAFT communique to CCNSO working group

Beau Brendler beaubrendler at earthlink.net
Mon Dec 12 17:27:28 UTC 2011

   Greetings.  One of the action items from the last NARALO meeting, as a
   follow-up to the .PR issue, was to prepare a communication from the NARALO
   to the appropriate subcommittee within the CCNSO that is looking at reform
   --  I  believe it is called MAC or some other acronymial thing. Cheryl
   Langdon-Orr has offered to convey this communique, since she is at-large
   liaison to the CCNSO, so I am sure she can tell us the exact name of the
   appropriate recipient group and make sure this gets to them.

   You'll notice some similar language in the draft, I pared down the original
   draft statement to about three paragraphs, and then added some substance
   from  the  Knujon  research.  Please  feel  free to add your comments,
   corrections, etc.



   The  North  American At-Large Regional Organization is concerned about
   the management of the U.S. territory of Puerto Rico's country code top-level
   domain, .pr, following a June 2011 lawsuit filed by The University of Puerto
   Rico against the domain's manager alleging misappropriation of public funds
   and inappropriate ownership claim, among other allegations.

   In 1988, the U.S. National Science Foundation established a program to
   expand use of the Internet outside the United States by establishing a
   domain registration that would allow each country connected to the network
   to offer access through that domain. The University of Puerto Rico, through
   its Gauss Research Laboratory requested the domain ".pr" (institutional
   research number 8818283, "Support for the Participation of the University of
   Puerto  Rico  in  the  NSFNet").  This  proposal was approved in 1989.
   Administration of the .pr domain was designated to the "Gauss Research
   Laboratory" with the university as manager.

   In 2006, the .pr ccTLD's manager contacted the Internet Assigned Numbers
   Authority to request a name change in the sponsoring organization, from the
   University of Puerto Rico to a corporation with the same name, including the
   abbreviations "INC. i.e. Gauss Research Laboratory, Inc." As a result, Gauss
   Research Laboratory Inc. was permitted to remove the .pr ccTLD operations
   outside the university campus, as well as redirect any funds generated by
   domain purchases.

   The NARALO is concerned the apparent "re-delegation" of the .pr domain
   represents  a  potential abuse of public trust and misappropriation of
   Internet resources. In addition, while the controversy over Puerto Rico's
   country-code domain may seem unusual, findings presented in the final report
   of    the    ccNSO   Delegation   and   Redelegation   Working   Group
   clearly indicate it is not.

   Further problematic findings in the ccTLD space were documented by Knujon,
   an  at-large  structure  in  the  NARALO,  in  a  June  5, 2009 report

   We would like to call the ccNSOâs specific attention to pages 9- 10 and
   17-20 in the report, which specifically name ccTLDs frequently used by
   criminals, and other country code domains potentially at risk for the same
   kind of abuse, as well as apparently dormant ccTLDs issued, for instance, to
   islands populated by birds and sea mammals, but no humans.

   NARALO applauds and supports the ccNSO working group's desire, stated in its
   working groupâs report, to "create an environment for making consistent and
   predictable decisions regarding the delegation, re-delegation and retirement
   of ccTLDs while enhancing accountability and transparency."

   We would like to encourage the working group to directly address the issues
   raised in the Knujon report, as well as disclose, for accountability and
   transparencyâs sake, pertinent discussion on the .pr situation. The NARALO
   believes that the public needs to be fully informed about this valuable
   Internet resource, how it is being managed, and what steps are being taken
   to ensure its proper administration in the future.


   1. http://ccnso.icann.org/workinggroups/final-drd-report-02may11-en.pdf
   2. http://www.knujon.com/ccTLD_Research_knujon_052109.pdf

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