Although .net is a generic TLD, it is useful to consider what, if any, public interest obligations should attach to this transfer. Because the NCUC is the one recognized place in the ICANN policy structure for "official" non-commercial input, I hope we will be willing to explore and champion the question of what (if any) explicit obligations should apply to the .net TLD. I cannot speak with any great expertise on international telecom service. I hope others more educated in international telecommunications services will speak from their experiences. I suggest that in conceptualizng the .net TLD, we think of this as a resource similar in many ways to telecommunication numbers. In the United States, we have closely regulated telephone numbers for a number of purposes. First and foremost has been technical stability. The telephone system must, above all else, work. Second, interoperability among systems must be preserved. This includes international interoperability (we want to be able to call other countries) and interoperability between competing networks (wireless phones and wireline phones must be able to call each other). Third, universal service has been an important goal of the United States telephone system since at least the Communications Act of 1934, which established a broad regulatory regime for telephony services designed to facilitate deployment of the telephone to all places in the Unites States. Milton can speak to this with far greater expertise. Regulation of numbers to achieve this goal, rather than regulation of the telephone system as a whole, was limited to the technical coordination under items one and two above. Nevertheless, given the importance of the gTLDs to providing alternatives to ccTLDS in some countries, I recommend consideration of the following aspects to promote a broad concept of universal service for TLDs. a) IDNs. It is high time ICANN got over its Verisign fixation and got into gear on IDNs. The divestiture should therefore require/faciliate more than the promise to obey ICANN decisions on the matter, as was done with .org. Rather, the entity bidding on .net should be required to make a specific commitment of time and resources to working with other TLDs to develop a working IDN system. Arguably, this issue goes beyond .net and should be broadly addressed by all TLDs. Why the TLDs shgould wait for the IETF when a working group among TLDs is what is needed is beyond me. But we must start somewhere and raising the profile on this issue is important. While it is presemptuous for an English-speaking American to champion IDNs as a critical issue for universal deployment, I have heard a number of people make this complaint. b) Cost. Marc is right that, since we seem stuck with centrally controlled pricing, we should urge that the set wholesale price be considered as part of the application. But what about other issues of purchasing domain names? Are those in other countries at a disadvantage because of lack of American currency? Or does the near universality of credit crads address this issue? Is this something that can be addressed at the TLD level? c) Privacy. In the United States, we spend a considerable amount of regulatory effort on protecting the privacy of those who register phone numbers. What kind of commitments can we look for, especially in light of the varioius WHOIS task forces? If nothing else, a commitment to privacy as a normative value (even if it is ultimately evicerated by the intellectual property and law enforcement communities) is useful in and of itself. It is also important to look at the failures of regulation. In the past, the U.S. sought to encode useful user information as part of the number content. e.g., at one point, the three digit area area codes in the United States were the only numbers with either 0 or 1 as the middle number. This was dropped many years ago because it simply did not scale. What concepts are currently embedded in registry agreements that should be dropped? For example, now that Verisign has spun off its registrar, can we please eliminate the restriction on communicating directly with registrants? Arguably, this made sense when a registry controlled a registrar and could use its registry information in an anticompetitive fashion. But now all this requirement does is get in the way of potentially important communications. Harold Feld