Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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The proposed changes to Section 2.7 of Appendix 8 of “Proposed Renewal of the Registry Agreement for .NET” represent a deprivation of the registrant of reasonable due process. No single entity, whether a government or even the registrar themselves, should have the authority to interfere in the domain name system except as broadly and internationally agreed to. Governments and private companies (including Verisign) routinely act in bad faith towards citizens and customers respectively and make decisions based on whimsically changed policies which are later altered or reversed. Any action that would deprive a registrant of control of their domain name should be done in accordance with internationally agreed upon standards that respect individual and smaller entity's rights and privileges against the eager overreaches of larger entities. Government policies and even court orders should not be universally acceptable for the actions described and registrar actions to such ends should be even more stringently restricted so as to protect from the manipulations they might attempt in line with their corporate interests.
Expressing opposition to the overly broad language of proposed changes to Section 2.7 of Appendix 8 regarding agreements by registrants to accept unilateral confiscation of domains at the request of governments. Due process is not adequately protected against government agencies that have demonstrated a willingness to act in bad faith ways, or for policies adopted that violate international standards and expectations. No single entity, government or otherwise, should have such broad and unrestrained ability to interfere with the domain name system, including the registrar.