[RRE]Analysis of Internet By-laws Proposalswriting

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1998-09-26 · 12 min read · Edit on Pyrite

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[RRE]Analysis of Internet By-laws Proposals

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Date: Sat, 26 Sep 1998 12:50:47 -0400 From: "Hans K. Klein"

INTERNET BY-LAWS: AN ANALYSIS AND CRITIQUE OF THREE PROPOSALS

by Hans Klein

Computer Professionals for Social Responsibility (CPSR) Public Policy Track Co-chair, INET-95, INET-96, INET-97, INET-98 School of Public Policy, Georgia Institute of Technology

September 26, 1998

As the Internet governance stakeholder process approaches its September 30 deadline, we have seen three different versions of by-laws proposed for the new corporation ("Newco.") These three proposals are "IANA-NSI" (the August 17 joint proposal of those two players), the "Boston Group" (a group of technical lawyers out of Boston), and "EFF" (the Electronic Frontier Foundation). (Their web addresses are at the end of this document.) These by-laws are difficult to understand, and the implications of their different features are not obvious. In what follows I analyze and contrast them to make them understandable, and I critique them on the basis of the values embodied in CPSR's principles for Internet governance.

The three proposals can be understood in terms of how they achieve basic functions of governance. Governance functions are similar for both nation states and private firms, so they should be familiar to most newspaper-reading citizens. The governance functions considered below concern: 1) representation, 2)transparency, 3) rights, and 4) finances. I compare how the different by-law proposals perform these different functions.

Representation

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Newco's Board of Directors can be compared to the Congress of the United States. Both are both the top authority for their respective "societies." A lot of thought has to go into ensuring that the top authority effectively represents those who are governed. Representation in the US government is accorded by certain categories. These include: 1) geography (seats are reserved for representatives from different localities,) and 2) size (Congress has two chambers, one favoring populous states and another in which little states have equal power.) These categories of representation ensure that different kinds of states all receive representation. Different Newco proposals also have different categories for representation.

The IANA-NSI proposes three categories of representation: function, geography, and membership. Functional representation is accorded to Board members by reserving Board seats for three Supporting Organizations, the Address SO, the Domain SO, and the protocol SO. Much like you will find the "California delegation" in the US Congress, you would find the "Address delegation" on Newco's Board. Each SO would control three Board seats, so 9 (3+3+3=9) of 19 seats are functionally-defined.

Geographic representation is facilitated (but not guaranteed) by the definition of 6 "geographic regions." Really, IANA-NSI only guards again excessive concentration: no one region can have more than 11 of the 19 Board seats (2+2+2+1+4). That doesn't ensure that places like Africa or Central America will have any representation, but it does ensure that a region like North America will not control two-thirds of the Board.

Membership representation is not explicitly defined, but is expected to be defined by Newco's first, Interim Board. So-called "At Large" Board members will be elected by some kind of membership (where the definition of membership remains undefined and is perhaps problematic.) If we think of the SO's Board members as "insiders" with a financial interest in Newco (as many stakeholders seem to think) the At-Large Board members will represent more "outsiders" or end users. There will be 9 At-Large Directors. (The president/top officer of Newco will also be on the Board, so we get 3+3+3+9+1 Directors.)

So that is how IANA-NSI proposes to handle representation. What about the others? Interestingly, EFF proposes exactly the same thing. EFF has not concerned itself too much with issues of representation. Its concern is with rights (below).

In contrast, for the Boston Group representation is the main thing. They are especially concerned that Newco "insiders" -- the Supporting Organizations and the President -- will attain too much influence. To prevent this the Boston Group's proposal eliminates those 9+1 insider Board members, leaving only the 9 At-Large Directors elected by the membership. (This small Interim Board could be increased later.) In the Boston Group's version the Board represents only users. Thus this proposal does away with functional representation by the SOs entirely. The SOs have only advisory power.

The Boston group also proposes a different mode of geographic representation. Instead of setting an upper limit on any one region's representation, they endorse a lower limit, which would guarantee that the Board include at least one director from each of the 6 geographic regions. On a 9-member Board, that means that no region could have more than 4 of nine seats. Were the Board to expand, however, those 6 seats would become less significant (asymptotically approaching zero in the hypothetical case of an infinite Board.) Ultimately, greater geographic concentration might become possible with this plan than with the IANA-NSI proposal.

So, to summarize, when it comes to representation the choices so far are between an insider/functional model and an outsider/user model. How much democracy do stakeholders want?

These two modes of representation are not above criticism. Both of them ignore some categories of representation that were proposed during the last year. In 1997 the Domain Name Rights Coalition proposed that the Board represent "all major groups on the Internet, including individuals, small businesses and entrepreneurs, political and community organizations, and large companies (Press Release, 1 May 1997). Computer Professionals for Social Responsibility (CPSR) proposed that the Board "should include at least 3 members [of 15] who represent the 'Internet Community' at large ... [and who] should be free from direct financial interests..." (CPSR Proposals, 30 June 1998). These suggestions are not incorporated into any of the three proposals. The Boston Group's emphasis on users/members goes in this direction, but does not reserve a specific number of Board seats for any type of user.

The by-laws could define categories for Board members, such as "for profit" and "educational/non-profit." Language could be included to ensure that a certain number of Board members correspond to each category. (More on this below.)

Transparency

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It is important that people know what their "governors" are doing. For this reason many states, notably California, have "sunshine laws" that prevent public business from being conducted in secrecy. Newco proposals differ in their emphasis on transparency.

The original IANA-NSI proposal favored corporate confidentiality over transparency. Some meetings were to be closed, minutes would be distributed with some delay, etc. Overall, Newco could operate with a fairly high degree of discretion.

Both the Boston Group and EFF reacted strongly against this, proposing procedures for a high degree of transparency. EFF included the most specific language, adapting language from the California "sunshine laws" for Newco's charter. Thus "every portion of every meeting of every [Newco body]" shall be open to public attendance, and "minutes ... shall be made publicly available within one day." In this way Newco's activities are known to all.

Rights

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The Constitution of the U.S. defines a number rights that the Congress may not abridge, most notably the First Amendment right to free speech. As a private entity Newco would not be as strictly constrained by the First Amendment as is the U.S. government (and its current agents, NSI and IANA). Therefore, in the transition to Newco some protections of speech could be lost.

EFF, in keeping with its civil liberties orientation, makes this a centerpiece of its proposal. Rather than referring to U.S. law, EFF incorporates a reference to international law, The U.N. Universal Declaration of Human Rights. This reads: "Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers." Neither IANA-NSI nor the Boston Group proposed special measures to preserve freedom of speech.

It is my guess that the U.N. declaration provides even stronger protections than does the U.S. First Amendment. If that is the case then under the EFF proposal communication rights would be even stronger than under the current U.S. regime.

Finances

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Money plays a big part in governance. To prevent abusive taxation, the U.S. founding fathers placed the power of taxation in that house of Congress that was the most representative of the citizens, maximizing the relationship between taxation and representation. Today money remains a big issue. A majority of Congress current supports campaign finance reform that would limit the influence wealthy groups to "buy" or at least influence elections. The regulation of campaigns is intended to reinforce the principle of "one [person] one vote" and weaken the principle of "one dollar one vote." (Campaign finance reform in the U.S. failed, by the way!)

All Newco by-law proposals also address money issues, and as far as I can see, they are all adopt the language proposed by IANA-NSI. Concerning fees ("taxation," if you will,) Newco will charge enough to cover its expenses and keep some money in the bank. Undoubtedly, the big business players who will pay these fees will keep a close eye on them.

One allowable expense for Newco is to pay the costs that Directors incur from Board service. This means that personal or organizational wealth is not an absolute prerequisite for Board service, a set-up that makes it easier for non-profit organizations to participate on the Board.

All three Board proposals contain the provision that the "resources of the Corporation will not be expended in support of any nominee's campaign." However, there are no other restrictions on campaign financing. This provision could favor wealthier individuals and members who can expend considerable funds in election campaigns. That is what happens in public elections.

The final by-laws might want to include funding and expense provisions that level the playing field for rich and poor Board members. Allowable expenses could include reimbursement of the value of a Board members' time expended on Newco business. Campaign spending could also be limited. An upper spending limit might be defined, or candidates could be limited to campaigning via a common web location on the Newco web site.

Finally, start-up funding for Newco could present tricky issues. The money needed for start-up could be substantial. Currently some particularly wealthy stakeholders have offered to donate money to cover its initial costs. At the very least such funding would create the strong impression of industrial dominance of Newco through this financial dependency. If Newco is to get off to a clean start, a neutral start-up funding source should be identified (e.g. a bank loan against future revenues.)

Odds and Ends ============= Pre-existing contracts: The IANA-NSI proposal contained a controversial provision that would bind Newco to pre-existing contracts. The EFF proposal does away with this.

Location: All proposals foresee the corporation being incorporated in Los Angeles County. This may contribute to continuity of staffing in the IANA-Newco transition, in efffect "bringing the mountain to Mohammed." On the other hand, a new location could help make a clean break with the past. Some have also said that California's laws of incorporation provide fewer free speech protections than do those of Deleware.

Conclusions and Recommendations

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If these three proposals express the range of stakeholder opinion in the Internet community (and this is a big "if"!), then consensus may not be far away. The three proposals have more in common than they differ. Reconciling them into one set of by-laws that can garner consensual support may well be possible.

The Boston Group and EFF's proposed safeguards on transparency could be adopted. These seem likely to be preferred by most stakeholders, who will ultimately be outsiders looking in at Newco's activities. These provisions are also consistent with the June 1998 White Paper's original principles.

EFF's proposal on rights also seems likely to attract wide support. It is consistent with the libertarian philosophy of many stakeholders participating in the White Paper process. Even those stakeholders concerned exclusively about management issues might approve of this provision: a non-negotiable commitment to non-interference in communications might help keep Newco out of disputes over content control. On the other hand, free speech protection may be anathema to trademark holders, who own many of the words we use. (Don't have a cow!)

The fundamental difference between the three versions is the definition of representation and the associated problem of membership. IANA-NSI and EFF's proposals for functional representation give considerable power to "insiders" in the SOs. If this is something to be avoided, something like the Boston Group's proposal is needed.

As described above, the Boston Group makes Newco completely accountable to users/outsiders, granting the SOs only advisory status. But this proposal suffers from problems of representation.

The first problem of representation concerns geographic equity. The Boston Group's proposal only guarantees one seat per region -- even though the Board size may vary. As the Board size increases, the significance of a single seat declines. Instead of guaranteeing one seat to each region, the by-laws could set minimum and maximum percentages of Board seats. For example, the by-laws could mandate that no region have less than 10% of Board seats (1 out of 9 seats, 3 out of 30) or more than 45% (4 out of nine seats, 13 out of 30). Alternatively, were the Board size to be fixed, distribution could be guaranteed with specific numbers (as in the numbers just mentioned.) Currently, a guarantee of one fixed seat is unsatisfactory.

The second problem of representation concerns diversity. The Boston Group's Board size of 9 is too small to allow diversity (although the final Board size is not specified.) quantitative changes in Board size have qualitative impacts: a bigger Board has more seats with which to allocate, so it can accommodate more diverse constellations of user types. On a small Board, a single Director may have to represent all telecommunication firms combined or all non-profits combined or all of Europe combined. On a larger Board Directors might represent more distinct user types. For a body that hopes to represent all the world's Internet users a larger Board might well be appropriate. What number? The Internet Society's governing body has 20 members. For Newco a bigger number, say 30, could be appropriate.

The final problem of representation concerns sectoral equity. If no differentiation is made between user types, then one type may come to dominate the Board. This type would probably be for-profit firms who have an immediate financial interest in Newco's activities. To prevent this the by-laws could define user-type categories. For example, the by-laws of the Internet Society include three categories: industry, education/non-profit, and government. Since Newco is to be a private firm, its Board categories could be just industry and education/non-profit.

Each Board category could have a percentage of seats reserved for it. This has a long tradition in Board design. For example, back in the 1960s when the COMSAT Corporation was created, 20% of its Board seats were reserved for representatives accountable to the American people (these Board members were appointed by the President.) Other Board members were accountable to their respective company stockholders. What percentages could be reserved on Newco? Like COMSAT, should it be 20%? Or is the Internet more of a "people's technology" than a satellite? Maybe one-third of the Board could be reserved for non-profit and educational institutions.

Even if the IANA-NSI and EFF "insider" model were preferred over the Boston group's "outsider" model, these Board categories could apply. Percentages of At-Large members and SO-based members could be reserved for industry and for educational/non-profits.

In summary, the three by-law proposals currently in circulating could be combined into a single consensual set of by-laws. The combined set of by-laws could adopt the highest standards for transparency. They could guarantee individual rights. And they could include categories to ensure that both industry and non-profits receive representation in sufficient number to ensure diversity.

Boston Working Group http://www.cavebear.com/bwg/ IANA and NSI http://www.iana.org/intro-coop.html EFF http://www.eff.org/ CPSR http://www.cpsr.org/onenet/

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Hans K. Klein Assistant Professor Phone: 404-894-2258 School of Public Policy, MC:0345 Fax: 404-894-0535 D.M. Smith Building, 313 Email: hans.klein@pubpolicy.gatech.edu Georgia Tech Atlanta, GA 30332-0345 ==============================================

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Paul Duguid Social & Cultural Studies University of California, Berkeley duguid@socrates.berkeley.edu Tel: 510 848 1843 Fax: 510 540 0347 ```

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