Over the past several years a widespread myth was that adding new Toplevel Domains to the internet would cause the net to break. The reality is and has been for five years now that the net is already broken by NOT adding the new TLDs that have existed since 1996. In a word, censorship by "default". There are places that exist on the internet that most of the world can't see because they are artificially and arbitrarily excluded from publication in the global ROOT--the top of the ³domain tree² that identifies all the available top level domains to the rest of the internet.

Many new toplevel domains have been added to the ROOT just as smoothly as any new "dot-com" domain is added to the "COM" domain. On a daily basis sometimes 10,000 or more new entries are added to "COM" with no ill effects. At its most basic level, adding one or more entries into the ROOT domain database (or ANY level of the domain tree) is nothing more than a mundane administrative task, essentially copying or typing some lines into a file and saving it. With a simple "copy and paste" the internet can be richly enhanced with these new domain extensions. A very simple and incredibly inexpensive operation that results in the enabling of vast economic opportunities, making the best use of the existing ubiquitous and essential DNS technology while at the same time extending the benefits of expanding the spectrum of expressive and uniquely descriptive names to support a growing, commercially and culturally diverse global network.

What should be an everyday mundane administrative task has turned into the most expensive text edit in history, and one that is delayed more than five years!

Name.Space has been working toward introducing new TLDs since the company was formed in 1996 predating ICANN by more than two years. Since that time Name.Space has been listening to its customers and users of the internet at large and responding to their desire for new domain names besides ".com" and over the years out of all the customer requests selected over 540 new extensions and published them on a distributed DNS infrastructure, (see attatched) available to all for free. We listened to our clients demands and have worked hard to bring them the services and quality of service that they were not getting elsewhere, building useful new tools as we needed them along the way to improve the security and capabilities of the Name.Space root domain registry. We would like to share our work with the rest of the world and of course profit by it so we can create jobs and spinoff opportunities. The barrier in front of us is a very expensive text edit that my company paid dearly for and which has yet to happen.

To answer the question raised by this Committee, Is ICANN thwarting competition? The answer is unmistakedly yes.

Name.Space has been ready to serve the internet with new domains since 1996 and has been repeatedly denied access to the market by an artifical and arbitrary exclusion from the ROOT. ICANNs decision to exclude Name.Space and other qualified applicants unjustly delays the introduction of true diversity of business model, competition and consumer choice to the domain industry. It directly harms our business at Name.Space by the loss of revenues that we have suffered over the years that most of the world could not resolve our domains, and it harms individual internet users and non commercial organizations by depriving them of free speech and consumer choice.

I respectfully request that this Committee reject the ICANN board selection of 7 TLDs and their operators and ask that the NTIA reconsider all applicants who were excluded by ICANN and resolve the terms of inclusion of existing new TLDs into the global ROOT so this "most expensive text edit in history" can finally bring about the logical evolution of the domain name system that is more than five years in the making--in "internet time" five years is an eternity.