I read with interest that ICANN opened up yet another comment period on new TLDs.

I believe that I speak for many when I question whether ICANN is opening up these comment periods in good faith, or instead whether these are smokescreens, mere distractions to pretend that ICANN is “listening” to the public while staff and insiders proceed with predetermined outcomes.

I note that as of today, there are multiple past comment periods where ICANN staff have not yet even summarized/digested the public’s input. This is simply unacceptable. In other organizations, people would get fired for not doing their jobs in a timely manner. At ICANN, such behaviour is not only tolerated, it is seemingly encouraged. It appears to be part of the culture of “willful blindness” of ICANN staff, insiders and the Board, in order that its “top-down” agenda can be imposed upon an unwilling public, rather than actually listening to the public in the “bottom-up” process that it suggests exists.

Furthermore, when ICANN does bother to get around to publishing summaries, it’s clear that they do not even listen to what the public has to say on the topic! The public opposed new TLDs by a great margin. It was a very clear message, yet ICANN kept ignoring what the public had to say, and mischaracterized their words when speaking to others (e.g. politicians in Washington, etc.) about the public “consensus.”

One sees that ICANN continues to speak in that twisted and biased manner in this actual comment period, when it uses loaded phrases such as “carefully crafted, new protections” or “perception” or “perceived need”—the underlying assumption being that the public is simply “stupid” and “doesn’t understand” new TLDs, and if only the public “knew better”, they would “come around” and “love what ICANN is doing.” That is simply preposterous and arrogant. It demonstrates that ICANN is out of touch with reality. The informed public knows that new TLDs will be a disaster, and has said so in clear language at every opportunity. ICANN is not “misunderstood” as some people believe—the public fully understands ICANN, and opposes its plans! Period!

ICANN acts like a greedy politician, asking for a “tax increase” to pay for a new bureaucracy that simply transfers wealth from the public to itself and its insiders. ICANN is not creating new wealth. ICANN is destroying wealth. Taxpayers see through attempts to bamboozle them that the “tax increase” is a good thing. Just as the public sees through attempts by ICANN and its insiders to bamboozle them that this new TLDs plan is “good” for the public. Attempts to dress up their greedy proposal using words like “innovation” fail, because the public is smarter than ICANN and can see through their self-serving proposals.

One need only look at the .XXX rollout, which was a disaster for the public. Millions of dollars were spent by universities, non-profits, individuals and corporations to purchase “protection” so that someone else could not tarnish their image/brand/identity. ICANN and its insiders do not consider this to be a “disaster”, though—they look at this as “innovation”, and pat themselves on the back saying “job well done.” ICANN might pretend “well, no one told us this was going to happen… how were we to know??” That’s utter nonsense, of course. One can go back to the analysis of Tim Berners-Lee on new TLDs, who didn’t mince his words. He said “New Top Level Domains Considered Harmful”. Could one be more clear?? [NB: He was not pointing to just .mobi and .xxx—he was saying this about ALL new TLDs (see the “Title” tag in the W3C page).]

ICANN and its insiders are emboldened by the dot-XXX launch. They want to multiply that “tax” on the public, what many have described as a “protection racket”, a thousand-fold. ICANN suggests that “this time will be different”—keep dreaming! The only thing that will be different is the *degree* to which the public will be damaged. ICANN wants to damage the public a thousand-fold, to the benefit of itself and its insiders.

ICANN instead needs to take a step back, whether willingly or by being forced to do so by the GAC, DOC, NTIA, DOJ or by other agents that are representative of the public interest. I suggest ICANN be compelled to do the following:

(1) immediately suspend the new TLDs rollout, and refund all monies collected to date.

(2) terminate the staff who have pushed forward this new TLDs plan over the objections of the public. It’s clear that these staff have their own agenda that does not reflect the public interest, and it’s time for new blood that is ready to serve the public, rather than staff who want to be masters over an enslaved public.

(3) go back and present true options to the public regarding new TLDs. In our prior recent submissions (see here and here), (which ICANN has yet to summarize, although we repeat much past input) we identified FIVE allocation methods for new TLDs. Five! 5! Yet, ICANN has never presented them all as options to be seriously considered. They simply imposed in a top-down manner their single plan that maximized the benefits to ICANN’s insiders, rather than allow for competing alternatives that maximize the benefits, if any, to the public. One can see some of the options that ICANN failed to allow the public to even comment on, such as:

(i) no new TLDs

(ii) .com domains simply “ascending” to the root (no need for “defensive registration” concerns in that scenario, is there??)

(iii) Ascended TLDs approach (see here for full description) which also reduces the need for defensive registrations considerably.

(iv) regular competitive bidding/tenders for lowest cost to registrants (this was the DOJ/NTIA/DOC proposal in December 2008)

(4) go back and do true economic studies that weigh the benefits and the costs on the public (not just the benefit to ICANN and its insiders) for all alternatives (including the four options presented in point (3) above), not just the self-serving single plan that ICANN wants to impose upon the public. The economic studies must be truly independent, with researchers selected by the NTIA/DOC/DOJ or GAC, and not by ICANN staff/insiders.

In conclusion, ICANN simply acts as if it “knows better” (which it doesn’t) and dismisses all attacks on its extremist and disastrous plans. It is our true hope that ICANN not be allowed to damage the DNS further. As Tim Berners-Lee wrote:

“The second effect is that instability is brought on. There is a flurry of activity to reserve domain names, a rush one cannot afford to miss in order to protect one’s brand. There is a rash of attempts to steal well-known or valuable domains. The whole process involves a lot of administration, a lot of cost per month, a lot of business for those involved in the domain name business itself, and a negative value to the community.”

The existence of this comment period about “defensive registrations” is proof that “Sir Tim” was right! (maybe that’s why he was knighted, due to his brilliance) We ask that the new TLDs plan be terminated, so that further “negative value to community” does not occur. By continuing to ignore the public’s wishes, ICANN is causing DNS instability. A trusted custodian of the DNS would not be causing DNS instability. Yet, ICANN has been doing exactly that. It’s time that the world recognizes that ICANN is no longer a trusted custodian of the DNS and its damaging plans must be opposed.