You are raising very interesting points concerning the alternative root community.
However, the DNSGA was focusing on the matter of alternative root Registrars advertising practices and their claims that describe alternative root domain names to be the same as .com domain names. Clearly there is a difference in that .com domain names cannot access alternative root domain names unless a workstation computer or ISP is pointing to the alternative root. This appears confusing to the average consumer who registers a domain name. The average consumer understands .com, but does not understand the alternative root domains.
The matter the DNSGA was focusing on in its comment is the United States Federal Trade Commission (FTC) jurisdiction over advertising practices and consumer protection. It appears that the FTC can claim that the average consumer understands .com, but not the alternative root domains. This is all the FTC needs to engage businesses claiming that alternative root domain names are the same as .com domain names. The FTC can claim that alternative root domain names are not equivalent to .com domain names. The FTC is a powerful agency with broad jurisdiction. The FTC could prevent U.S. businesses from selling alternative root domain names to consumers.
It is important for organizations like yours to participate in explaining your opinion regarding how the alternative root community will be compatible with the .com root system.
So, the issue right now are the representation made to consumers regarding alternative root domain names vs. the .com domain names. Arguments concerning other uses of alternative root communities may come later.
If organizations like yours, and interested parties, do not participate in forums now to explain the compatibility issues and develop solutions that can be communicated to government, ICANN may be successful at convincing the United States Department of Commerce ("DoC") and international Government Advisory Committee ("GAC") representatives that ICANN policies and agreements must be accepted or else alternative roots will create chaos and fracture the Internet. This could be enough to convince World governments to consolidate against the alternative root community.
Alternative root community representatives should immediately participate in explaining their position to the industry. The DNSGA is a vehicle that can effectively communicate to the United States Government ("USG") the significant arguments concerning the alternative root community.
The DNSGA is scheduled to file a legal action with the DoC May 2001. The DNSGA will address alternative root issues and other matters and we invite you to participate in submitting your comments or opinion regarding the alternative root community so that we can better understand this matter and the compatibility issues and develop solutions.
DNSGA President and Chairman