Ms. Burr-

In the DOC's Memorandum of Understanding with ICANN, Article V
Section A(2) states: "The parties agree that mechanisms, methods,
and procedures developed under the DNS Project will ensure that
private-sector technical management of the DNS shall not apply
standards, policies, procedures or practices inequitably or single
out any particular party for disparate treatment unless justified by
substantial and reasonable cause and will ensure sufficient appeal
procedures for adversely affected members of the Internet
community".

Are you aware that three out of five testbed registrars accredited
by ICANN are in CORE? Is this your idea of an equitable policy? One
must assume that all 34 applicants that passed fulfill the technical
and financial criteria for accreditation, so how were the five
chosen for the testbed? Did you know that one - AOL - has never
functioned as a registrar before, whereas a number that have been
performing the equivalent of registration for years were not among
the five and are suffering a loss of business due to the unfair
price competition imposed by the testbed? What appeals procedure, as
ensured in the MoU, is in place for the adversely affected members
of the Internet community?

Michael Sondow

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International Congress of Independent Internet Users (ICIIU) 
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