Trump should stand with Sheriff Joe in Arizona

Oct. 12, 2016, Fairfax, Va.—Americans for Limited Government President today issued the following statement urging Republican presidential nominee Donald Trump to stand with Sheriff Joe Arpaio in Arizona:

“We live in an upside down world, where the U.S. Government is threatening to jail Maricopa County Sheriff Joe Arpaio for following and enforcing our nation’s immigration laws. In the meantime, the same Justice Department has refused to prosecute Hillary Clinton for breaking our nation’s security laws. If I were advising Donald Trump, I’d encourage him to go to Phoenix, Arizona, and stand by Sheriff Arpaio, noting that the same Clinton press corps that has attacked him for saying that Hillary should be in prison at the debate are now silent as Obama attempts to jail Sheriff Arpaio for enforcing the law.

“We have truly gone through the looking glass, where enforcing immigration law is now a crime and breaking that law gets you a free pass into our country.”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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Unemployment rate 9.8 percent when labor participation decline of 16-64 year olds included

Oct. 7, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement on the latest jobs numbers:

“Since 1997, the labor force participation rate for 16-64 year olds, that is, excluding seniors, has declined from 77.4 percent to 73.2 percent, accounting for 8.7 million working age adults who have either left the labor force or not entered on a net basis. These are Americans in their prime working years but are simply not participating, and when some of them do try to participate, the unemployment rate increases, as it did today. If they were included into today’s jobs report in full as unemployed, the unemployment rate would be about 9.8 percent, not 5 percent as reported.”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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59 percent of Virginians agree jobs can be brought back to U.S. by reducing participation in trade deals

Oct. 3, 2016, Fairfax, Va.—Virginians strongly support American sovereignty and voters across the Commonwealth sense that current trade deals do a poor job of protecting American interests, a poll conducted on Americans for Limited Government’s behalf by Norman Research and Analytics finds.

The poll was conducted among 1,062 registered voters telephone surveyed on both landlines and mobile devices from Sept. 2 to Sept. 11.

The ramifications for President Obama’s Trans-Pacific Partnership (TPP) are stark as voters by a 59 percent to 35 percent across all demographic groups agreed with the statement, “We can bring jobs back to America by reducing our nation’s participation in trade deals that make it easy for other countries to flood our markets with cheap goods.”

This sentiment that our nation should adopt a broad set of “America First” policies runs deeply throughout the state with a significant majority wanting lawmakers to worry about the impact to America’s economy when considering or reconsidering trade deals.

Rick Manning, President of Americans for Limited Government argued, “The fact that people from all age, gender, racial and education agree with this basic statement should give strong pause to Congress if it should attempt to pass the TPP during a lame duck session.  While we didn’t micro-target down to this level, it appears that the only segments of the Virginia electorate that might support the TPP are those who are paid to lobby for it by the multi-nationals who would most benefit from the deal.”

The most encouraging aspect of the survey is that it shows the basic American concept of self-determination runs deeply in the electorate with support from conservatives, moderates and self-described liberals.

The polling also explored the general notion of who should make the laws and regulations that impact Americans, with 69 percent to 26 percent agreeing with the statement, “America must have the ability to set its own laws and regulations and not be bound to standards set by foreign nations and international organizations.”

“It is refreshing to see that regardless of political leaning, Virginians are committed to the Constitutional construct that our nation’s laws should be made through the consent of the governed, and not imposed by foreign, unaccountable bodies empowered by trade deals,” Manning continued.

The study clearly demonstrates that the public has little trust that existing trade agreements have been beneficial on the whole, and while respondents do not reject international trade, they are highly skeptical that America’s interests have been served through recent trade deals.

The study concludes by stating, “It is clear that any legislation or proposal that cedes U.S. authority to international bodies and allows those foreign bodies to exert authority over American citizens and commerce will be met with strong opposition. As the debate over various trade arrangements goes forward, these trends and attitudes will be tested in other states.  But using Virginia as a guide, moving to enact the Trans-Pacific Partnership would be a serious political mistake for those advocating it.”

Manning concluded, “That is something for Congress to consider should Speaker Ryan and Leader McConnell push forward with President Obama’s attempt to rewrite the rules of the world’s economy by jamming the TPP down the public’s throats after the election. Every member of Congress should tell their constituents now, how they would vote in a lame duck session and be held accountable to that promise.”

Attachments:

Voter attitudes toward trade in Virginia, Norman Analytics on behalf of Americans for Limited Government, Sept. 2-Sept.11, at https://getliberty.org/wp-content/uploads/2016/10/TradePollVa10-3-16.pdf

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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Ryan deals with Pelosi for $170 million for Flint, Mich. water, gets nothing in return

Sept. 28, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement blasting House Speaker Paul Ryan (R-Wis.) for a deal to fund the Flint, Mich. water supply with $170 million and not getting anything in return:

“So, Democrats block the continuing resolution, demand money for the Flint, Mich. water supply. House Republicans led by House Speaker Paul Ryan relent and agree to add it to the House water bill after that proposal was defeated in the House Rules Committee, and got nothing in return.

“Republicans have majorities in both houses of Congress, Democrats were actively demanding extra add-ons for these bills, and they couldn’t even get a rider stopping the irreversible transition of U.S. oversight of the Internet’s domain name system. That, even though the Department of Justice has repeatedly failed to respond to the House and Senate Judiciary Committees on a number of outstanding legal concerns with the Internet transition of U.S. oversight of the domain name system. These issues risk either creating an unaccountable global Internet monopoly or a potentially fractured domain name system if antitrust does come into play. The transition proposal contemplates neither scenario, and these issues cannot be addressed once the transition occurs on Oct. 1.

“Did they even try? Ryan and McConnell have not issued any public statements on the matter, so we must assume they actively agree with surrendering U.S. oversight of the Internet. They didn’t even put up a fight. House and Senate Republicans are not what they say, they are what they do. And what they are doing is allowing President Obama to give away the Internet to the international community, threatening the American people’s vital Internet freedoms. And don’t let any Republican tell you different.

“Moreover, now former defense and Congressional officials, national security professionals and cyber experts are warning that the transition of the domain name system threatens our national security, which depends on private sector infrastructure, by exposing the nation to new cyber vulnerabilities. This lapse in U.S. oversight of the domain name system and IP addresses then not only threatens censorship on the Internet, but also poses new dangers to U.S. communications in the event of an attack. What could go wrong?”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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ALG joins with conservative groups urging Congress to adopt zero for zero sugar policy

Sept. 27, 2016, Fairfax, Va.–Americans for Limited Government President Rick Manning today in a joint letter with the Hispanic Leadership Fund, the Institute for Policy Innovation, the 60 Plus Association, the Institute for Liberty, Citizen Outreach and Less Government urged Congressional Republicans to adopt the zero for zero sugar policy to eliminate sugar subsidies when the rest of the world does proposed by U.S. Rep. Ted Yoho (R-Fla.), which stated in part:

“U.S. sugar producers, like all farmers and most businesses today, are part of the global economy and are sensitive to the actions of governments around the world.  Those governments are currently ratcheting up sugar subsidies to levels well above those seen in the United States, and the world sugar market is fluctuating wildly as a result.

“Countries like Brazil, Thailand, India and Mexico are flouting global trade rules and distorting free-market prices with billions a year in handouts designed to keep inefficient producers afloat.  The subsequent dumping of subsidized surpluses has made sugar the world’s most volatile commodity market.

“Market-distorting policies abroad are the main reason that America has a sugar policy in the first place.  Unilaterally disarming U.S. policy without addressing the larger problem of rampant global subsidization will lead to the outsourcing of yet another efficient U.S. business and will leave American consumers dependent on unreliable foreign suppliers.

“The true free-market solution to this problem is being championed by Congressman Ted Yoho (R-Fla.).  His zero-for-zero sugar policy would direct U.S. trade negotiators to achieve sugar subsidy reforms abroad, and would require sugar policy elimination in the United States once the free market forms.

“It is essentially a global subsidy cease-fire, and it is the only truly free-market solution on the table that puts efficient U.S. businesses in a position to succeed.”

Attachments:

Letter to Congressional Republicans on Zero for Zero, Sept. 27, 2016 at https://getliberty.org/wp-content/uploads/2016/09/ZeroforZeroLetter9-27-16.pdf

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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ALG urges no vote on any CR that does not stop Internet surrender

Sept. 27, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement urging Congress to reject any continuing resolution that fails to stop the Internet surrender:

“It is now or never to stop the Internet surrender. Given the Department of Justice’s failures to respond to the House and Senate Judiciary Committees on a number of outstanding legal concerns with the Internet transition of U.S. oversight of the domain name system, delaying the transition for at least a year while these issues are addressed and letting a new Congress and Administration take a look is in order. These issues risk either creating an unaccountable global Internet monopoly or a potentially fractured domain name system if antitrust does come into play. The transition proposal contemplates neither scenario, and these issues cannot be addressed once the transition occurs on Oct. 1.”

Attachments:

“Last chance to save the free and open Internet,” By Robert Romano, Sept. 27, 2016 at http://netrightdaily.com/2016/09/last-chance-save-the-free-and-open-internet/

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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House Rules Committee should kill the Kildee amendment on Flint, Mich. water funding

Sept. 26, 2016, Fairfax, Va.–Americans for Limited Government President Rick Manning today issued the following statement urging the House Rules Committee to block any amendment to the water bill that funds Flint, Mich. water:

“If House Republicans approve dollars for Flint, Michigan in the water bill today, they will lose any leverage they possess to block the Internet surrender in the continuing resolution and fuel perceptions that the fix is in. House Republicans should vote down any rule that includes the Kildee amendment to fund Flint, Michigan water. This is not out of animus to the Kildee amendment but rather the inappropriateness of giving Senate Democrats their last spending want in the continuing resolution without their agreeing to stop the Internet giveaway. Dumping the water bill rule that includes Flint spending is the only leverage the House may have over the Senate continuing resolution, since no amendments will be allowed on the House side on the spending bill. It is somewhat stunning that House Democrats are allowed to offer and pass amendments for their priorities but House Republicans are not, including stopping the Internet surrender. It’s almost as if we’ve returned to 2009 with Nancy Pelosi in charge.”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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Obama de facto veto threat on CR offers opportunity to stop Internet giveaway

Sept. 26, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement in response to the de facto veto threat issued by President Barack Obama via White House Press Secretary Josh Earnest, who said, “I had an opportunity to talk with the president in the Oval Office about this proposal, and after that conversation it’s not at all clear to me that he is prepared to sign this bill because he believes that Congress has got some work to do”:

“If we’re just going to be back at the drawing board the next few days because President Barack Obama is going to veto the continuing resolution, it is better if Congressional Republicans go back and rework the language to stop the Administration from giving away oversight over Internet governance.  It is clear that there is no agreement on the funding bill. Any attempts to tie changes to the Ex-Im Bank to blocking the Internet giveaway represent a false choice. The House needs to enter the game and modify the Senate bill, sending compromise language that incorporates language directing that the Commerce Department not transition the Internet, but instead extends the ICANN management contract for a period of not less than two years.”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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Blocking Internet surrender helped unite Trump, Cruz and GOP

Sept. 23, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement in response to Ted Cruz’ endorsement of Donald Trump for President, where he cited as one reason, “Internet freedom. Clinton supports Obama’s plan to hand over control of the Internet to an international community of stakeholders, including Russia, China, and Iran. Just this week, Trump came out strongly against that plan, and in support of free speech online”:

“Donald Trump doing a statement on the Internet giveaway helped facilitate Ted Cruz’ endorsement of Trump just two days later, in turn helping to unite grassroots Republicans nationwide in the sprint to November. This makes it all the more important that House and Senate Republicans unite in their resolve to stop the Internet giveaway in the continuing resolution before the end of the month. It would be tragic that an issue which unites Republicans would be scrapped just to pass a bill that funds the Obama administration’s priorities, including surrendering U.S. oversight of the Internet’s domain name system to foreign powers and multinational corporations, creating an unaccountable global monopoly and risking censorship of every American’s vital Internet freedoms.”

Interview Availability: Please contact Americans for Limited Government at 703-383-0880 ext. 106 or at media@limitgov.org to arrange an interview with ALG experts including ALG President Rick Manning.

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No Internet transfer without DOJ answers to antitrust concerns

Justice, Commerce Depts. stonewall House, Senate Judiciary Committees on Internet antitrust questions

Sept. 23, 2016, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement urging Senate and House negotiators to defund the transfer of U.S. oversight of the Internet domain name system, as the Departments of Justice and Commerce still have not adequately addressed antitrust and other outstanding legal concerns facing the Internet Corporation for Assigned Names and Numbers (ICANN) post-transition, and have even failed to respond to repeated requests for these legal analyses by the House and Senate Judiciary Committees:

“The failure of the Justice and Commerce Departments to provide the Obama administration’s views to the House and Senate Judiciary Committees on the very real antitrust questions facing ICANN post-transition is unacceptable and strongly advises that Congress delay the transition until at least December, to in the least provide more time for this oversight to be performed and for Congress to evaluate the proposal on its merits. Instead, the Internet transition question is falling through the cracks of haggling over the continuing resolution. Unfortunately, the continuing resolution remains the only vehicle available to obtain this delay and perform the proper oversight.

“The lack of cooperation by the Obama administration on the antitrust question casts serious doubt on whether the administration wants these questions vetted at all, otherwise clarity would have already been provided to Congress and in response to Americans for Limited Government’s now numerous Freedom of Information Act requests on legal and policy analysis performed or received by the Commerce Department on these questions. To date, it appears no analysis was conducted prior the June 9 when Commerce approved the framework for the transition. This is unacceptable and we applaud Chairmen Grassley and Goodlatte for continuing to demand answers to these questions before any transition can even be considered by Congress. These questions must not go quietly into the night, because once the Internet transition is performed we won’t get it back.”

Attachments:

For Immediate Release

Thursday, September 22, 2016

Grassley, Goodlatte Seek Details on DOJ’s Role In Proposed Transfer of Internet Stewardship Authorities

WASHINGTON – Senate Judiciary Committee Chairman Chuck Grassley and House Judiciary Committee Chairman Bob Goodlatte are calling on the Justice Department to explain its role in advising the Obama Administration in its plan to relinquish authority of key internet domain name functions.  In a letter to Attorney General Loretta Lynch, the chairmen express concern about the proposal, given an abundance of unanswered questions regarding internet openness, control of government domains, the disposal of government property and antitrust considerations.

“With so many outstanding questions remaining, especially in the areas in which DOJ would seem to have direct subject matter expertise, we believe it is important to understand what input and contributions the Attorney General and the DOJ made in blessing this transfer and in answering many of the specific questions that were raised by other agency participants during the process,” the chairmen said in the letter.

The chairmen raised specific concerns that the proposal relies upon a non-binding letter between the U.S. and the Internet Corporation for Assigned Names and Numbers (ICANN) to safeguard Top Level Domains such as .gov and .mil.  They are also seeking details of any legal analysis of the constitutionality of relinquishing ownership of U.S. government property, such as the root zone file, without congressional approval.  Finally, the chairmen are seeking details on any analysis DOJ conducted regarding the antitrust implications of terminating the U.S. government’s contract with ICANN.

Text of the Grassley-Goodlatte letter follows:

September 21, 2016

The Honorable Loretta E. Lynch
Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C. 20530

Dear Attorney General Lynch:

The National Telecommunications and Information Administration (NTIA) has indicated that it intends to transfer key Internet domain name functions, known as the Internet Assigned Number Authority (IANA) functions, to a global multi-stakeholder community at the end of Fiscal Year 2016. As you are aware, when announcing this proposed transition on March, 2014, the NTIA specified that such a proposal must have broad community support and maintain the security, stability, and resiliency of the Internet Domain Name System (DNS), meet the needs of the multi-stakeholder community and enhance the multi-stakeholder model, and maintain the openness of the Internet.  Further, NTIA affirmed that it would “not accept a proposal that replaces the NTIA role with a government-led or an inter-governmental organization solution.”[1]

We’re sure you would agree that the openness, security, and stability of the Internet are of paramount importance to all Internet users, and yet a number of outstanding issues related to this proposed transition have yet to be answered, threatening these very values.  These include how the transfer will effect free speech and the openness of the Internet, if U.S. control of the .mil and .gov domains will be compromised, if the transfer will open the Internet to undue influence from foreign nations, if the transfer will lead to the improper conveyance of United States government property, or if the transfer affects any existing antitrust immunity and increases the likelihood of significant antitrust litigation.  Further, a recent Declaration by the Internet Corporation for Assigned Names and Numbers’ (ICANN) Independent Review Panel calls into question the credibility of ICANN’s ability to carry out basic duties of board self-governance.[2]  This document reveals that ICANN’s Board Governance Committee has “failed several transparency obligations,”[3] engaged in the “cavalier treatment”[4] of constituent requests, and failed to undertake an examination of whether ICANN staff or contractors complied with their obligations under the Articles and Bylaws of incorporation (finding that this failure is “itself a failure by the Board to comply with its obligations under the Articles and Bylaws.”).[5] These failures raise serious concerns about the ability ICANN to exercise proper corporate oversight and call into question ICANN’s organizational maturity.

Simply put, with so many unanswered questions and from what available evidence we do have, this transition is not in the best interest of a free, open, and secure Internet – nor is it in the best interest of the United States. Ending the United States contractual relationship with ICANN is dangerous and it is bad policy.

According to NTIA, the Department of Justice (DOJ) has participated in a “DNS Interagency Working Group” of U.S. government agencies who have been tasked with developing a methodology to assess whether or not the NTIA’s criteria are met. Specifically, the DNS Interagency Working Group has convened at least monthly to “coordinate and develop policies and positions related to DNS issues” and engage on “matters related to the IANA Stewardship Transition, including proposal review and assessment.”[6] NTIA recently announced that it expects the transition proposal will meet the agency criteria set forth in 2014, presumably with the support of the DNS Interagency Working Group, and plans to allow NTIA’s contract with ICANN to lapse.

As a key agency participant in the discussion surrounding the transfer of the IANA functions, we are interested in DOJ’s substantive input concerning the decision to transfer the IANA functions and to allow the federal government’s contract with ICANN to lapse.  With so many outstanding questions remaining, especially in areas in which DOJ would seem to have direct subject matter expertise, we believe it is important to understand what input and contributions the Attorney General and the DOJ made in blessing this transfer and in answering many of the specific questions that were raised by other agency participants during the process.

We are deeply troubled that DOJ’s Office of Legal Counsel (OLC) has not provided a formal legal opinion concerning these issues, including the constitutional questions. As you know, OLC provides authoritative legal advice to the President and all Executive Branch agencies, including legal advice on all constitutional questions. It is quite frankly shocking that the Commerce Department would fail to seek such an opinion before proceeding down this path.

NTIA has acknowledged widespread concerns related to the potential loss of control of U.S. governmentally administered domain names such as .mil and .gov.  In an attempt to allay these concerns, NTIA has stated that the operation of these Top Level Domains (TLDs) are not impacted by the transition and that “per the policies, procedures, and practices in place, .mil and .gov cannot be transferred without explicit agreement from the current administrators of those domains – namely, the U.S. government.”[7] Yet, the only mechanism NTIA has enacted to affirm that the United States is, and will remain, the administrator of .gov and .mil TLDs is through the exchange of non-binding letters with ICANN. As such, the only true assurance the United States has regarding the important .mil and .gov TLDs comes from a non-legally binding, two paragraph letter from ICANN CEO Goran Marby that calls on ICANN to honor and maintain its commitments with respect to the U.S. governmentally administered TLDs.  These assurances are certainly are not legally binding and could lead to the loss of the TLDs despite the declarations of NTIA and ICANN.

As you are likely aware, concerns continue to exist regarding whether or not the administration has the constitutional authority to conduct the IANA transition without the authorization of Congress because of the United States property interests in the root zone file – or other similar components of the Internet that were created and financed by the United States.  Under Article IV, Section 3 of the Constitution, Congress has the exclusive power “to dispose of and make all needful rules and regulations respecting the territory or other property belonging to the United States.”

Additionally, should NTIA end its contract with ICANN, any antitrust protections that ICANN currently enjoys as an organization operating under government control would end.  ICANN may then be vulnerable to a dramatic increase in antitrust suits and could be compelled to seek the protection of other governmental or quasi-governmental entities to limit this exposure.  Should ICANN seek a new antitrust shield in this manner, ICANN could be subject to limitations on political freedoms that come from groups such as the United Nations International Telecommunications Union.

With these issues in mind, please provide answers to the following questions:

  • With regard to the security of the .mil, .gov, and U.S. governmentally administered TLDs, does the Attorney General and the Justice Department believe that the mere exchange of letters between NTIA and ICANN is preferable to a binding legal agreement? If so why?  Please provide the Department’s rationale?
  • Did the DOJ advise NTIA regarding this resolution of government administered TLDs?
  • Should ICANN delegate U.S. government administered TLDs, contrary to current assurances, what action will the DOJ take?
  • With the lack of certainty over the disposition of government property in the IANA transfer, has NTIA ever referred this issue to DOJ for analysis or has DOJ ever conducted an analysis of this question on its own?  If so, what are its findings?
  • Does the Attorney General believe that there is no possibility that NTIA’s planned transition of the IANA functions may potentially relinquish ownership of United States property? What analysis did you conduct to come to this conclusion?
  • As a member of the DNS Interagency Working Group or otherwise, has the DOJ conducted a review of the antitrust implications of NTIA’s termination of its contract with ICANN?  If so, please provide a copy of this review.  If not, why not?

This unalterable action poses serious ramifications for the security and openness of the Internet.  As a member of the DNS Interagency Working Group, we’d like to know what role that you and the DOJ played in this transition. We appreciate your timely responses to these important questions no later than September 27, 2016.

Sincerely,

Charles E. Grassley
Chairman
Senate Committee on the Judiciary

Bob Goodlatte
Chairman
House Committee on the Judiciary

CC:

The Honorable Shaun Donovan
Director, Office of Management and Budget

 

 

[1] National Telecommunications and Information Administration, U.S. Department of Commerce, “NTIA Announces Intent to Transition Key Internet Domain Name Functions,” (March 14, 2014) available at https://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions.

[2] Dot Registry, LLC. V. Internet Association Corporation for Assigned Names and Numbers (ICANN), ICDR Case No. 01-14-001-5004, Declaration of the Independent Review Panel, International Centre for Dispute Resolution (July 29, 2016) available at https://www.icann.org/en/system/files/files/irp-dot-registry-final-declaration-redacted-29jul16-en.pdf.

[3] Id. at 40.

[4] Id. at 44.

[5] Id. at 47.

[6] National Telecommunications and Information Administration, U.S. Department of Commerce, IANA Stewardship Transition Proposal Assessment Report 14 (June 2016) available at https://www.ntia.doc.gov/files/ntia/publications/iana_stewardship_transition_assessment_report.pdf.

[7] National Telecommunications and Information Administration, U.S. Department of Commerce, “Q and A on IANA Stewardship Transition,” (August 16, 2016) available at https://www.ntia.doc.gov/other-publication/2016/q-and-iana-stewardship-transition-0.