IANA Report on Redelegation of the .DM Top-Level Domain
The Internet Assigned Numbers Authority (IANA) function of ICANN, as part of the administrative tasks associated with management of the Domain Name System root zone, is responsible for receiving requests for the delegation and redelegation of top-level domains, investigating and reporting on the circumstances pertinent to those requests, and, when appropriate, implementing the redelegations.
In accordance with ICANN’s performance of these functions, IANA received a request for the redelegation of the .DM top-level domain. This domain is designated in the ISO 3166-1 standard for Dominica, a Caribbean country with a population of approximately 70,000. The application for redelegation was received on 20 February 2007.
The initial delegation information IANA has available shows that the earliest assigned administrative and technical contacts were Belina Junquera and Felix G. Ramos respectively, both of the University of Puerto Rico (UPR).
In January 2001, IANA received a redelegation request from Ramos. The request also included a letter from the Office of the Prime Minister of Dominica. The letter endorsed the transfer of the .DM top-level domain “from the University of Puerto Rico to the Government recommended administrative and technical contacts.” The letter also stated that the initial delegation should have been made to the Government of the Commonwealth of Dominica. The redelegation request was not fully concluded, with only the name server changes of this request were executed. IANA continued to have discussions with the ccTLD managers regarding the other changes.
The same redelegation request was resubmitted to IANA in June 2003. This was followed by a protracted evaluation, which similarly did not result on a redelegation. According to the records IANA has at hand, this does not appear to be due to a defect in the application. We believe that it was due to delays caused by contractual negotiations.
In October 2006, IANA was approached by UPR about updating the root zone database to reflect that they are no longer involved in the management of the domain. As a result, on 20 February 2007, a new redelegation request was lodged with IANA. The request seeks delegation of .DM be altered to DotDM Corporation (DMC). It is proposed that the Chief Executive Officer of DMC, Jennifer Aird, fill the administrative contact role, and the Chief Technical Officer of DMC, Hilkiah Lavinier, fill the technical contact role. It is worth noting that the request to assign the DMC as the manager of the .DM domain has been consistent in all of the redelegation requests submitted to IANA.
By all indications, the management of the .DM top-level domain has already been transferred to DMC. On 1 January 2001, UPR and DMC entered into an agreement to delegate all the “duties, obligations and responsibilities associated with being the designated manager for the DM Domain” to the DotDM Corporation. The agreement was signed by Ramos of UPR on 3 May 2001 and Aird of DMC on 22 May 2001.
Included in the previous redelegation request submitted to IANA is a formal letter from the Honourable Reginald Austrie, Minister for Communications, Works and Housing dated 4 June 2003. The letter states that DMC has the full support of the government to administer and manage the .DM country code top-level domain.
Given the amount of time that had elapsed since the letter of government support was received, IANA wrote to the same minister, Reginald Austrie, who is now serving as the Minister of Housing, Lands, Telecommunications, Energy and Ports. In its letter, IANA stated that it intended to proceed with the redelegation, and gave the government an additional opportunity to share their views on the request.
While processing prior change requests for .DM, IANA attempted to contact the Administrative and Technical Contacts associated with the domain name to obtain their assent. The Administrative Contact (Belina Junquera) no longer works for the Supporting Organisation, appears unreachable, and is no longer involved in the day-to-day administration of the organisation. The Technical Contact, however, has consented to the reassignment as requested in response to questioning by IANA.
In its role as investigator of delegation and redelegation requests, IANA is guided by the practices summarized in:
“Domain Name System Structure and Delegation” (RFC 1591). This document describes IANA’s practices relating to delegations at its publication in 1994. See http://www.rfc-editor.org/rfc/rfc1591.txt
“Internet Domain Name System Structure and Delegation.” (ICP-1). This document represents an update of the portions of RFC 1591 dealing with ccTLDs and reflects subsequent evolution of the policies followed by the IANA through May 1999. See http://www.icann.org/icp/icp1.htm.
The Governmental Advisory Committee Principles for Delegation and Administration of ccTLDs (GAC Principles). This document serve as “best practices” to guide governments in assuming proper roles with respect to the Internet's naming system. See http://www.icann.org/committees/gac/gac-cctldprinciples-23feb00.htm.
In considering the delegation or redelegation of a ccTLD, IANA seeks input from both the requesting party as well as from persons and/or organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated. As noted in ICP-1, the parties affected include the relevant government or public authority: "The desires of the government of a country with regard to delegation of a ccTLD are taken very seriously. The IANA will make them a major consideration in any TLD delegation/transfer discussions."
Taking these factors into consideration, the burden of proof required to permit a delegation involves determining facts that relate to the applicant’s capacity to meet the following criteria:
Operational and technical skills
Operator in country
In meeting these criteria, the IANA requests information from the applicant. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, IANA asks for various documentation describing: the views of the local Internet community on a change; the competencies and skills of the organisation to operate the registry; the legal authenticity, status and character of the proposed operator; and the nature of government support for the proposal.
After receiving these documents, IANA analyses the input it has received in relation to existing zone management procedures, seeking input from parties both related to as well as independent of the applying organization should the information provided by the applicant in their request be deficient.
Once all the documentation has been received, IANA will also perform various technical checks on the proposed operator’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries for the top-level domain being requested. Should any anomalies be detected in the applicant’s technical infrastructure, IANA will work with the applicant to address the issues.
Assuming all technical issues are resolved, IANA will compile a report, providing all relevant details regarding the applicant, its suitability for operating the top-level domain being requested, and any other information pertinent to the application and submit that report to ICANN’s Board of Directors for its determination on whether to proceed with the request.
This report is being provided under the contract for performance of the IANA function between the United States Government and ICANN. Under that contract, ICANN performs the IANA function, which includes receiving delegation and redelegation requests concerning top-level domains, investigating the circumstances pertinent to those requests, and reporting on the requests. Pertaining to the obligations described in the evaluation procedure, in summary IANA has assessed the applicant’s credentials to be as follows:
The operator will be DotDM Corporation, which has been performing the registry function for .DM for a number of years.
DotDM Corporation is located in Dominica, and its administrative contact is the Chief Executive Office of the company based in country.
The applicant has made undertakings to IANA that registrations will be performed on a first-come first-served basis that is fair and equitable.
The Government of Dominica has expressed their support for the change request.
The current operator is the de facto operator for a number of years, and seems to have considerable support for that role. However, it was not deemed appropriate to substantially engage the community on their opinion of this transfer when UPR has already fully transferred operations to DMC several years prior, and the redelegation request is designed to reflect the status quo.
According to RFC 1591 and ICP-1, IANA needs to respect the ability for a local Internet community as well as local law and local government to make decisions about the operation of a TLD.
In its research, IANA believes that there are strong grounds for reassignment of the domain name under the relevant criteria. The current operators have clearly stated that they are no longer managing the domain and that the proposed operators have been the entity in charge for a number of years already.
IANA therefore concludes that the .DM domain should be redelegated to the DotDM Corporation as per their request.
On August 14, 2007 the Board of ICANN passed the following resolution:
Whereas, the .DM top-level domain is the designated country-code for Dominica.
Whereas, ICANN has received a request for redelegation of .DM to DotDM Corporation.
Whereas, ICANN has reviewed the request, and has determined that the proposed redelegation would be in the best interest of the local and global Internet communities.
It is hereby resolved (07.64), that the proposed redelegation of the .DM domain to DotDM Corporation is approved.
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