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Letter from AT&T to ICANN

AT&T Logo

October 7, 2003

Mr. Paul Twomey
President and CEO
The International Corporation for Assigned Names and Numbers
Marina del Rey, California

Dear Mr. Twomey

The Internet has operated effectively and successfully because of the technical collaborative and consultative processes followed by those entities making up the key infrastructure of the Internet; these entities have historically been committed to the operational stability and reliability of the Internet as the first priority. In assessing the registry service called Site Finder, introduced by Verisign Registry, we have reviewed the concerns of the Internet Architecture Board (IAB) and the Security and Stability Advisory Committee (SECSAC) and believe that their concerns are well founded.

Therefore, on behalf of AT&T, I want to state our support to ICANN's role in ensuring stability and security of the DNS of the global Internet and to the steps recently undertaken by ICANN to ensure that Verisign's Sitefinder service is withdrawn to allow an assessment of the impact upon the stability of the DNS. We further support the need for the establishment by ICANN of a transparent and predictable procedure for the introduction of new registry services by the Generic Names Supporting Organization (gNSO) by January 15, 2004.

AT&T is a global provider of IP networks, Internet connectivity, web hosting, custom applications and a wide variety of business user services. We are a Tier One backbone provider. In addition to the voice and data traffic that we manage for over 4 million enterprise customers - many of whom have presence in numerous countries, we also serve over 40 million consumers - all of whom increasingly look to the Internet for access to information and each other. We ourselves operate many DNS servers and routers, in the course of moving and managing IP and data traffic. We hold one of the world's most well known brands, and we use and register domain names in both gTLD space and in ccTLDs. We are an end customer of the .com and .net registry, as well as an end customer of several other gTLD registries as a registrant of several domain names in each, through the competitive registrars. We are registered in and use several of the country codes as well. The stable, reliable and predictable operation of the Internet is important to our customers, and to us, as a provider of key aspects of the Internet's connectivity. In short, we are a business user with many dependencies upon the Internet's stable and predictable operation.

We want to ensure that ICANN understands the concerns that we have related to the introduction of this service.

When any registry service is introduced into gTLD zones, there must first be notice and comment processes to allow examination by the responsible technical bodies of any disruption or impact to other applications, as well as the impact within the zone itself or upon the overall DNS. This process clearly belongs to the ICANN Security and Stability Advisory Committee and the IAB, and should include a formal comment process. to identify any problems and offer a remediation opportunity. This notice and comment process, and the resulting remediation process, if needed, must take place before a registry service is introduced.

Therefore, we support ICANN's requiring the withdrawal of the service until the assessment by the SECSAC has been completed. The actions to be taken by ICANN must be then be determined by that input, and by other considerations, as noted below.

We also agree that there should be a clear and transparent process by which consideration of the introduction of registry services can be undertaken, taking into account other issues related to the sole source standing of the registry; the impact upon competition, and other issues related to stability of the DNS that may not be solely technical in nature; we therefore support ICANN's efforts to develop such a process.

Governments are increasingly asking if the private sector can address challenges of this nature, related to the operational stability and reliability and security of the DNS. We are all aware that some governments seek a more intrusive role into the Internet's technical coordination. We believe that the private sector's consensus based approach -- working together at ICANN-- with advice of governmental representatives, can indeed resolve this challenge. We agree that these are matters of some urgency to address. We therefore advise the ICANN President, and the ICANN board and other interested parties of our concerns and support for ICANN's making these issues a top priority.


Dave Belanger, Chief Scientist, AT&T Labs

GNSO Council
Chair, Addressing Support Organization
Chair, Security and Stability Advisory Committee

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"""" is not an IDN."