To: Secretary, Federal Trade Commission
From: Michael Sondow, Chairman ICIIU

Re: U.S. Perspectives on Consumer Protection in the Global Electronic Marketplace---Comment,P994312

As a conscientious member of the worldwide community which, while not deriving primary income from it, are the Internet's true end-users and thus the most interested parties in changes to Internet governance, I am very concerned by the lack of public representation on the various discussion groups, councils, and boards presently deciding the future structure of the Internet. I believe that I am far from being alone in this concern.

Throughout the information promulgated thus far by the NTIA, ICANN, and the other Internet authorities on the subject of the creation of policy, recurrent reference is made to the "public good" as that central authority's purpose, yet nowhere, not in the U.S. Government's white paper nor in ICANN's communications, is mention made of representation by members of the public, much less of any mechanism to assure that the decisions of the new authority - certain to have widesweeping effects upon the public - will be made in their interest and for their good.

Until now, the Internet has been conducted in the public interest because its founders and coordinators have been educators and civil servants rather than representatives of industrial and other concerns with a commercial stake in it. This authority is now being transferred almost exclusively to commercial "stakeholders".

What will the effect of this be? Without doubt precisely the same that commercialization in other communications media has been, a transfer from the public good to private gain, only on an even larger, more international scale. We have seen this happen with radio, films, and especially television, where control has been allowed to fall into the hands of entrepreneurs whose sole interest is the sale of mediocrity, by definition the only thing that can be sold and consumed massively.

The Internet was founded on the principle of diversity, like all that is best about America, and not on privately-controlled mass communication and the conformity it brings, which is the opposite of diversity. The diversity of the Internet is now to be reversed, if something is not done to stop it.

Privatization of the Domain Name System - which will lead ultimately to commercialization of the domain name assignments that permit full Internet integration, at rates prohibitively expensive for non-commercial public persons and entities - is incompatible with control of the Internet by a not-for-profit organization for the public good. In his Suggestions for a New Organizational Structure (07-12-98), Dr.

Jon Postel, head of the Internet Assigned Numbers Authority (IANA), expressed hope that each member of the new controlling Board "should represent the interests of the Internet community as a whole. Once he or she takes a Board seat, they should not be a representative of a specific group, but rather a fiduciary for all those interested in and affected by the operation of the Internet". That hope is forlorn.

Board members from corporations, commercial networks, telecommunications conglomerates, Internet service providers, and other commercial entities represent first and foremost the entities that pay their salaries, and therefore cannot represent the public.

If they are the totality or even the majority of members of the new Internet authority, it will be ruled by commercial interests and will not function for the public good.

Nevertheless, most countries using the Internet on a broad scale abound in public interest groups. These include community lobbies, consumer protection organizations, international, national, and local educational, scientific, and public welfare institutions, libraries, and public sector Internet groups such as user groups, student networks, and senior citizens' networks. Has a place - a controlling place - been made for their representatives on the new Internet councils and boards? If this is not done, and quickly, the Internet will cease to exist in the public interest.

We still have a chance, perhaps our last, to reverse the insidious process of privatization and commercialization of the Internet. Let no one who, through indifference or fear, neglects to speak out now and demand public control of the Internet complain on the day, coming soon, when the great promise of the Internet will have been betrayed and lost.