Unfortunately (I think), many critics of ICANN are reluctant to voice their criticisms to NTIA or the USA government, out of fear that the USA would use the need for oversight (which the USA has been loathe to exercise, lest it bring into question the basic idea of privatizing governance of the Internet) of ICANN's fairness and procedural due process (openness, transparency, accountability, oversight, etc.) as an excuse for USA government meddling in the substance of ICANN's decisions (of which the USA has a well-established track record).

But I don't think we should refrain from criticizing ICANN just because some of the alternatives to ICANN might be worse. If ICANN is the best available model for Internet governance (of which I'm not persuaded), or at least is likely to be what we are stuck with, it's important to call attention to its faults and to try to get them corrected.

Accordingly, I've submitted comments (HTML, PDF) to NTIA summarizing ICANN's lack of openness, transparency, accountability, oversight, or compliance with its own Bylaws or its MOU with NTIA."