USTR Notorious Markets Comment

CDT filed brief comments to the United States Trade Representative regarding its 2015 Special 301 Out-of-Cycle Review of Notorious Markets. CDT expressed its concern that the listing of foreign domain registrars who have not taken actions inconsistent with U.S. law unfairly punishes those registrars and implies obligations beyond those set out in either law or the registrar’s accreditation agreement with the International Corporation for Assigned Names and Numbers (ICANN). CDT also noted that arguments that use the Registrar Accreditation Agreement to implement domestic policy objectives is in tension with the Department of Commerce’s approach to the Internet Assigned Numbers Authority (IANA) transition.