Review of fairness of AOL eAddress program

Dear Internet Corporation for Assigned Names and Numbers, VeriSign, Inc., and all others concerned:

AOL LLC, a subsidiary of Time Warner, Inc., hereafter referred to as America Online (its former name) or AOL recently began offering a service dubbed "My eAddress" ( https://domains.aol.com ) letting anyone register an email at any available .com or .net domain free of charge. These domains are registered to AOL with AOL as the registrar and, while initially registered for a year, may be held indefinitely.

There are several questions about AOL's compliance with the Registrar Accreditation Agreement ( http://www.icann.org/registrars/ra-agreement-17may01.htm ) While AOL is an ICANN accredited registrar, they do not register domains to the public and don't even maintain a public website, thus their is absolutely no transparency in the process. Further, by not maintaining a public website (or at least, not the one referenced in whois services) AOL is in violation of section 3.3 of the Registrar Accreditation Agreement. Further, name and address information is not provided in registrations created this way, further violating the agreement. While it is possible that internal money is exchanged, by providing services free of charge questions are raised about accordance with section 3.7 (pertaining to proper records of registration, fixed periods, etc.). While others probably exist, and AOL has flouted these policies before ( http://findarticles.com/p/articles/mi_m0NEW/is_2002_March_22/ai_84873211 ), this is not the real issue.

The real issue is that by offering automatic and free registrations, AOL is unfairly withdrawing domain from the Domain Name System that users willing to pay for and develop thereafter do not have the opportunity to use. Further since arbitrary domains can be registered for free, it is likely that an arbitrarily large number of domains will be registered by people who will not even use them for email services. At present domains registered this way don't even point to servers that return responses to ICMP Echo requests ("pings"); they are effectively removed from the internet and used only for their MX records. This amounts to at best an unfortunate devaluation of owning ones own domain and at worst an unfair trade practice.

This being so, it is our request that AOL's right to provide this service and their accreditation be reviewed and that proper action can be taken to ensure the continued value of domains and proper usage of the DNS