We, the undersigned organizations and individuals of OFISP, consider our duty to express our opinion about the current situation with "SU" country code Top Level Domain (ccTLD).

Historically the SU domain was registered in 1990 to form the domain name space of the USSR. The latter ceased to exist in 1991. In 1993 the SU domain administration was redelegated to The Russian Institute for Public Networks (RosNIIROS, also known as RIPN) as to a neutral and non- commercial organization.

Due to collapse of the USSR, the countries forming it faced with a question to register ccTLDs of their own. In 1992 the ccTLDs for Estonia (EE), Lithuania (LT), Georgia (GE) and Ukraine (UA), were registered. In 1993 Latvia (LV) and Azerbaijan (AZ) got their domains. In 1994 the ccTLDs for Moldova (MD), Russia (RU), Belarus (BY), Armenia (AM) and Kazakhstan (KZ) have been registered.

When registering the RU domain, the SU domain was frozen accordingly, as a domain of nonexistent country, and the obligation to remove the SU domain smoothly was undertaken by IANA and personally by John Postel, IANA's head. By the end of 1997, all the countries members of the former Soviet Union had got their ccTLDs, so there are no more administrative or technical reasons for the SU domain to exist.

Nowadays the SU domain administrators, contrary to the former obligation made, are trying to change the domain's regulations and start commercial activities there.

Thus, the violations present in the SU domain situation, are as follows:

1. There are attempts of commercial activities in the domain which is frozen, has no definite status, does not conform to the regular structure of ccTLDs (http://www.iana.org/cctld/cctld-whois.htm) and in fact is subject to removal.

2. The SU domain administrators have not discussed their activities neither with ICANN nor with the Internet community and virtually have declared their "ownership" of the SU domain.

3. The renewed regulations for second level domains in the SU domain were kept hidden from the Internet community and ICANN as long as possible. This fact clearly demonstrates the adventurism of the SU domain administrators and their expectations to produce an outstripping effect, leading activities in the SU domain to grow up to a level where they will be recognized legitimate de-facto.

This situation is qualified as sole violation of the Internet progress principles formulated by IANA ccTLD regulations (http://www.iana.org/cctld/icp1.htm, (b), (c), (e), & (i) paragraphs), so we advance the following proposals to ICANN:

1. To oblige the SU domain administrators to keep the domain in strict compliance with the earlier established regulations and to prohibit the future expansion of the second level domains list.

2. In case of denial of RosNIIROS (RIPN) to keep status quo, redelegate the SU domain administration to an independent third party, preferably of educational activities (e.g. - Moscow State University, MSU).

3. To define ccTLD SU status. If the decision to remove domain is in force, clearly define the deadline (at least 3 years, our forum discussion estimates).

October 2001

Signed

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OFISP: http://www.ofisp.org - The Open Forum of Internet Service Providers was formed to join Russian members of the Internet Community to work collectively on the tasks of the Internet Community. The primary objective of the Forum is to provide a certain meeting and discussion space standing outside of business and aimed to solve common problems jointly. The idea of the Forum's activities is to coordinate active members of the Community. The Forum relies on responsibility and professional competence of its members.