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Message from Tucow's Elliot Noss to Paul Twomey

From: Jacqui Cook
Sent: Friday, October 03, 2003 2:29 PM
To: Tina Dam
Cc: Elliot Noss; blazare@xxxxxxxxx
Subject: Letter from E. Noss re:SiteFinder

3 October 2003

Via email and Canada post

Mr. Paul Twomey
President and CEO
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601

Dear Paul;

I am writing to express Tucow's support and gratitude for the position ICANN has taken in its letter to Verisign and its advisory to the Internet community both dated today.

From the time that the SiteFinder service was announced, Tucows has been deeply concerned about Versign's unilateral changes to the operation of the DNS for .com and .net.

The Internet, at a fundamental level, functions because individuals, organizations and corporations co-operate to develop and implement operating specifications that are well understood. Because of the distributed nature of the Internet, maintaining stability is critical. Changes to these specifications have always happened in a process that includes notification, consultation and assessment of the impacts. Many changes have required the consensus of the key stakeholders. We believe that all material changes to the DNS should be required to meet a verifiable standard.

No member of the Internet community should be allowed to make unannounced, unilateral changes that impact the stability of the system. The greater the power that a member controls, the greater its responsibility for maintaining the system's stability. It is, and has always been, Tucows' view that the .com/.net contracts were delegated solely for the operation of the registry function. The contracts set forth the registry operator's obligations to perform a specific function, for a specific time, for a set fee.

Tucows has been closely monitoring the impact on both our and our customers' operations. As the largest wholesale provider of .com and .net domain names and the supplier of domain name registration services to more than 5,000 ISPs, webhosting companies and other Internet firms around the world, it is our responsibility to represent the concerns of Tucows and its resellers.

Implementation of SiteFinder and the resulting negative impacts on organizations and businesses were presented in detail in ICANN's advisory of 3 October 2003 and the formal letter to Verisign mentioned above. Tucows' resellers experienced these negative impacts immediately following the unannounced changes.

On 26 September 2003, Tucows polled its resellers to measure the extent of the operational disruption. The results are conclusive.

- 69% of respondents have experienced negative operational impacts

- 50% are responding to calls from their end customers. The disruption caused to the system extends beyond Internet service organizations to the end user. The most common systems that are disrupted are: spam filters, email servers and DNS servers. These are critical applications to Internet users.

- Fully 96% of them consider it important or very important to resolve the issue.

- Over 90% do not believe that Verisign should offer the SiteFinder service.

Tucows shares ICANN's concerns about the impacts of Verisign's imposed changes and Verisign's procedural failures. The best interests of all the members of the Internet community - the various registries and registrars, the intermediary service providers and the end users - will be well served by your decision and a speedy clarification to the procedures that should enable us to incorporate useful enhancements to the DNS.

Sincerely,

Elliot Noss
President & CEO
Tucows Inc.

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as""icann.org"" is not an IDN."