Ministry of Information and Communications
P.O. Box: 291, Khartoum Sudan
October 15, 2002
Dr. M. Stuart Lynn
President and Chief Executive Officer
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292
Dear Dr. Lynn:
I am writing to you on behalf of the Sudan government concerning the
.sd country code top level domain. In addition to reiterating that we
designate the Sudanese Internet Society (SIS) "as the appropriate
entity to hold the delegation of authority by the ICANN for administrative
authority of the .sd country code top level domain (ccTLD)," this
letter is to provide ICANN with additional details regarding that designation.
The Sudan government's recognition of SIS is subject to it operating
within the provisions of its organization constitution and to the fulfillment
by SIS of the conditions outlined (please see attachment A),
which are summarized again here:
- Given that the Internet naming system is a public resource and the
exercise of a top level domain (TLD) delegation must be in the public
interest, SIS recognizes that the management and administration of the
.sd ccTLD are subject to the ultimate authority of the Ministry of Information
and Communication of Sudan;
- SIS agrees to comply with ICANN developed policies, and to ensure
payment of its contribution to ICANN's cost of operation.
- Should there be a redelegation of the .sd ccTLD, SIS agrees to cooperate
and comply with the requirements of the Ministry of Information and
Communication and/or ICNNN in order to facilitate the transfer and redelegation
of authority for the .sd ccTLD from SIS to another party.
The Sudan government through Ministry of Information and Communication
commits to fulfill its role as envisioned in the "Principles
for the Delegation and Administration of Country Code Top Level Domains"
adopted by the ICANN Governmental Advisory Committee (GAC) on 23 February
2000. As you know, Ministry of Information and Communication supports
the GAC as the appropriate vehicle for governments to participate in the
Under clause 8.1 of the GAC Principles, the Sudan government designates
SIS as the delegee of the .sd ccTLD and requests that ICANN enter into
the three-way communication-based regime, as envisioned by the GAC Principles,
to provide a framework of accountability for the management of the .sd
The designated point of contact within the Sudan government is:
AbdelDafi Mohammed Elhassan ElKhateeb
Ministry of Information and Communication
P.O.Box: 291, Khartoum Sudan
The point of contact for the delegee is:
Yassir Hassan El Amin
President, Sudan Internet Society
P.O.Box: 13713 Khartoum, Sudan
In matters concerning the .sd top-level domain the Sudan government,
as noted above, will require that SIS manage the .sd top-level domain
according to the interest of the Sudan public and particularly its Internet
community. Within this framework, the relevant communications between
the Sudan government and SIS consist of:
- Letter from Ministry of science and Technology to SIS (March, 23 2002)
- Letter from SIS to Ministry of Information and Communication (No.
02.1.03 October 9, 2002)
We believe that this agreement embodies the terms and conditions set
out in clause 9 of the GAC Principles (see
- Clause 8.2 of the GAC Principles calls upon the relevant government
or public authority to communicate to ICANN how it will require the
delegee to abide by terms of the terms and conditions outlined in clause
9 of the Principles. The Sudan government's ongoing endorsement is subject
to SIS continuing to meet its obligations outlined in Letter from SIS
to Ministry of Information and Communication (No. 02.1.03 October 9,
2002) and this letter.
As contemplated by the GAC Principles, the Sudan government and SIS wish
to work cooperatively with ICANN to ensure that SIS fulfills its responsibilities,
to both the Sudan and global Internet communities, as delegee of the .sd
ccTLD. As envisioned by clause 5.1 of the GAC Principles, the Sudan government
recognizes its role of ensuring that the .sd ccTLD is administered in
Sudan’s public interest, taking into consideration public policies, laws,
and regulations. At the same time, Sudan recognizes ICANN’s function to
establish, disseminate, and oversee implementation of the technical standards
and practices that relate to the operation of the global domain-name system.
(GAC Principles clause 6.1.) The Sudan government considers ICANN to be
the appropriate international entity to oversee the technical coordination
of the Internet in a manner that will preserve it as an effective and
convenient mechanism for global communication and commerce.
In view of the dual responsibilities, from different perspectives, of
the Sudan government and ICANN for ensuring that SIS operates appropriately
as delegee of the .sd ccTLD, we believe that it is vital that there be
close governmental/ICANN coordination in connection with the delegation.
In this regard, we suggest the following procedures be followed:
1. Coordination of Policy Requirements.
The GAC Principles recommend that ICANN should ensure, through an appropriate
communication with the delegee, conformity to "ICANN developed
policies concerning: interoperability of the ccTLD with other parts
of the DNS and Internet; operational capabilities and performance of
the ccTLD operator; and the obtaining and maintenance of, and public
access to, accurate and up-to-date contact information for domain name
registrants." (Clause 10.2.5.) There is the theoretical possibility
that, in seeking to ensure that SIS operates the .sd top-level domain
in the interest of the Sudan community, the Sudan government might give
SIS directions that in some way conflict with ICANN policies. Such a
conflict would be undesirable, and all parties should work together
to minimize the possibility of such a conflict. In this regard, the
Sudan government would alert ICANN upon discovering a possibility of
conflict and to seek to coordinate its supervision of SIS with that
of ICANN through appropriate means, with the goal of avoiding any situation
where the SIS faces conflicting governmental and ICANN requirements.
We understand and appreciate that ICANN intends to do likewise.
2. Termination Procedures.
The GAC Principles envision (clauses 7.1 and 7.3) that a delegee's
status may be terminated in the event that it breaches the requirements
of its communications with the relevant government and ICANN. To promote
coordination in this area, ICANN and the Sudan government should consult
with one another concerning any contemplated termination due to breach
of SIS responsibilities as delegee.
In particular, we note that Sponsorship Agreements ICANN has entered
into provide ICANN the ability to terminate upon notification "by
the Governmental Authority that the Sponsoring Organization has contravened
the terms of the Governmental Communication, or the term of the Governmental
Authority's designation of the Sponsoring Organization as manager of
the Delegated ccTLD has expired." (Section 6.2.4 of JPRS -ICANN
ccTLD Sponsorship Agreement and auDA-ICANN Sponsorship Agreement.) The
Sudan government believes provisions of this type will assist in appropriate
coordination of actions in the event termination is appropriate, and
expects ICANN to exercise its right of termination under a similar provision
in a SIS -ICANN agreement upon notification by the Sudan government.
Likewise, we note that the Sudan government commits to a similar type
of coordination in the event of a breach (see GAC Principles clause
3. Designation of a Successor Delegee.
The GAC Principles recommend that, in the event that a delegation is
terminated, a successor delegee should be designated by the relevant
governmental authority, subject to that designated successor’s ability
to meet the technical and other requirements embodied in an ICANN-delegee
communication. (See GAC Principles clauses 3.5, 7.3, and 7.4.) Consistent
with this recommendation, Section 6.3 of the recent ICANN-JPRS ccTLD
Sponsorship Agreement provides that any reassignment of a ccTLD will
be done "in coordination with the Governmental Authority."
The Sudan government believes this provision provides an appropriate
mechanism for the designation of a successor manager of the .sd ccTLD.
If you wish to discuss any aspect of the above designation of SIS delegee
of the .sd ccTLD, please do not hesitate to contact me.
AbdelDafi Mohammed Elhassan ElKhateeb
Ministry of Information and Communication
P.O.Box: 291, Khartoum – Sudan
1) Analysis under
clause 9 [see attachment A]
2) SIS .sd Registration
& administration policies & procedures [see attachment B]
the layout, construction and functionality of this site
should be sent to email@example.com.
©2002 The Internet Corporation for Assigned
Names and Numbers. All