News Review | IANA Transition Unwind? ICANN Nightmare or Fantasy?

Domain Mondo's weekly internet domain news review (NR 2018-01-28) with analysis and opinion: Features •  1) IANA Transition Unwind? ICANN Nightmare or Fantasy? 2) ICANN news: a. As goes France.com so goes new gTLD .AMAZON? b. GDPR & WHOIS Webinar, c. New gTLD .AFRICA Litigation Update, d. NomCom & ICANN Dysfunction, 3) Names, Domains & Trademarks: Q4 2017 $VRSN,  $GDDY, 4) ICYMI: Russiaphobia and more, 5) Most Read.

1)  IANA Transition Unwind? ICANN Nightmare OR Ted Cruz Fantasy?

U.S. Senator Ted Cruz (R-TX) (above left), and NTIA's David Redl (right) at Redl's confirmation hearing June 8, 2017

Fantasy or Nightmare? Will the REAL David Redl please stand up:

Make the internet American again? Trump pick opened the door | Politico.com Jan 23, 2018: "[David] Redl promised the senators [Cruz and Lee] that he would recommend convening a "panel of experts to investigate options for unwinding the [IANA] transition," according to a letter that POLITICO obtained through a Freedom of Information Act request ... Sen. Brian Schatz (D-Hawaii) briefly blocked Redl himself over concerns that he'd cut some deal with Cruz ... Schatz said the idea of undoing the internet transition "may be an interesting political topic" but is ultimately a "fantasy."

Remarks of Assistant Secretary David Redl at CES 2018 | NTIA.doc.gov Jan 9, 2018: "I'll also focus on being a strong advocate for U.S. interests within ICANN. We need to ensure transparency and accountability in ICANN's work. And in light of the implementation of the European General Data Privacy Regulation, or GDPR, we need to preserve lawful access to WHOIS data, which is a vital tool for the public."

Editor's note: Messrs. Redl, Cruz, and Lee, would do well to read on Domain Mondo:

• My submitted comment to the CCWG (WS2) jurisdiction subgroup (pdf)

• News Review | 12 Questions for 2018: Domains, ISOC, Internet, ICANN

• News Review | ICANN Board Executive Committee, Conflicts of Interest

• The Day Jon Postel Freed The Internet Root From US Government Control

After which they would understand how we got to this point, and what the U.S. government needs to focus on going forward. ICANN may have already sown the seeds of its own destruction with its hundreds of gTLD contracts in perpetuity, against the advice and counsel of the U.S. Department of Justice Antitrust Division (pdf) delivered to ICANN by NTIA in 2008 (pdf). If so, the good news is that what comes after ICANN could be a lot better for the global internet community and restore the principles of Jon Postel's RFC 1591 to the governance of the global DNS and root. The bad news is that what comes after ICANN could be as bad, or even worse.

2) ICANN news

a. As goes France.com so goes new gTLD .AMAZON? (or even Amazon.com?)

French government claims back "France.com" (as trade mark and domain name) [from France.com, Inc.] | ipkitten.blogspot.ca comment "the French government interestingly argued that under Art L.3111-1 of the Public Property Code, "the property within the public domain are inalienable and imprescriptible" and that the TM and domain name "France.com" fall within this category."

"this term ["France"] refers to the national territory in [terms of] its economic, geographic, historic, political and cultural identity"--French Court of Appeal ruling in favor of the French government against trademark holder and domain registrant France.com, Inc.  

b. GDPR & WHOIS Webinar: 

Data Protection/Privacy Update Webinar Scheduled for 2 February | ICANN.org:

"The community is encouraged to provide input on the proposed models [PDF, 623 KB] by 29 January 2018. Please send your feedback to gdpr @ icann.org. More information on ICANN's data protection/privacy activities is available here."

Comments submitted: https://www.icann.org/resources/pages/gdpr-legal-analysis-2017-11-17-en

Webinar 2 February 2018 15:30 UTC / 10:30am ET (U.S.) via Adobe Connect Send dial-in requests to gdpr-questions @ icann.org. Dial-in Information. Participant Codes: English – Participant Code: 9001; Français – Participant Code: 9002; Español – Participant Code: 9003; 中文 – Participant Code: 9004; Pусский – Participant Code: 9005; العربية – Participant Code: 9006; Português – Participant Code: 9007.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a regulation by which the European Parliament, the Council of the European Union and the European Commission intend to strengthen and unify data protection for all individuals within the European Union (EU). It becomes enforceable 25 May 2018. EU website: Data protection | European Commission | ec.europa.eu

ARTICLE 29 Data Protection Working Party Letter to ICANN 6 Dec 2017 (pdf): "At first glance it would seem that since ICANN and the registries jointly determine the purposes and means of the processing of personal data for the WHOIS directories, ICANN and the registries are joint controllers. This would mean that both ICANN and the registries must ensure that personal data are processed in accordance with the obligations of the European data protection laws."

17 Dec 2018 Letter from Manal Ismail [GAC] to Göran Marby | ICANN.org (pdf)--Issue: WHOIS Compliance with GDPR--excerpt (highlighting added):

The Internet: 10 predictions for 2018 | DiploFoundation | diplomacy.edu by Jovan Kurbalija: "1. GDPR: Data in the centre of digital politics ....

"The GDPR is likely to have a global impact in two main ways. First, the EU is extending its jurisdiction globally by requesting that the data of European citizens be managed according to European regulation, wherever data processing takes place. Secondly, other countries may follow suit. With a high Internet penetration of 500 million citizens with strong purchasing power, the EU is the most lucrative Internet market in the world. The EU has the digital ‘hard power’ to negotiate with Internet companies on an equal footing." (emphasis added)

The Looming Battle over the GDPR and the Purpose of Whois in ICANN | InternetGovernance.org: ".... The Hamilton report has not identified a viable way forward, neither long term nor short term. The real solution to this problem is to identify a purpose of Whois that is consistent with ICANN’s limited mission ... the analysis in the Hamilton report actually points away from a complicated layered model to continued public access to a far more limited set of data. This is the easier, and most legally correct path to follow. That is where ICANN should go."--Professor Milton Mueller

Europe's GDPR Meets WHOIS Privacy: Which Way Forward? | Electronic Frontier Foundation | EFF.org: ".... There are other cases in which it makes sense to allow members of the public to contact the owner of a domain, without having to obtain a court order. But this could be achieved very simply if ICANN were simply to provide something like a CAPTCHA-protected contact form, which would deliver email to the appropriate contact point with no need to reveal the registrant’s actual email address [or even name]. There's no reason why this couldn't be required in conjunction with ICANN's Model 3, to address the legitimate concerns of those who need to contact domain owners for operational or business reasons, and who for whatever reason can't obtain contact details in any other way."

Editor's Note: Read EFF's submitted comment here (pdf), with which I concur.

c. New gTLD .AFRICA Litigation UPDATE: (emphasis added)

Editor's note: Mike Silber was selected for the ICANN Board by the Country Code Names Supporting Organisation in 2009 and elected to a second term in 2012 and a third and final term in 2015, which will expire at the Annual General Meeting in 2018. According to his ICANN bio, he was responsible for the redelegation of the .ZA ccTLD and served a Director and Treasurer of the Authority from its formation in 2004 to 2015. ZA Central Registry is also the registry operator for new gTLD .AFRICA.

d.  2018 Nominating Committee (NomCom) vs ICANN org Dysfunction (pdf)(embed below, highlighting added):

e. New gTLD Program Auctions | ICANN.org 23 January 2018 – Updated Auction Schedule:

f. ICANN Public Comment Periods closing in February 2018 at 23:59 UTC on the dates indicated below (subject to change):

• Proposed Incremental Changes to the ICANN Meetings Strategy: 1 Feb 2018

• Operating Standards for ICANN's Specific Reviews: 2 Feb 2018

• Maximal Starting Repertoire version 3 (MSR-3) for Root Zone Label Generation Rules (RZ-LGR): 26 Feb 2018

3) Names, Domains & Trademarks

a. Q4 2017 Earnings season (domain name industry companies) on DomainMondo.com: 

• Verisign | NASDAQ: VRSN  Feb 8, 4:30pm ET (.COM registry operator)

• GoDaddy | NYSE: GDDY Feb 22, 2018 5:00pm ET (world's largest domain name registrar)

b.  Trademarks: "Infamous troll" Michael Gleissner involved in 5% of all live contested trademark cases in UK | Lexology.com

c. Trump Antitrust Policy after One Year (video) | The Heritage Foundation | heritage.org: "The Trump Administration has brought leadership changes at the two federal antitrust agencies, the Department of Justice Antitrust Division and the Federal Trade Commission."   See also: Trump nominates 4 to FTC: Joseph Simons, antitrust attorney from the Paul Weiss law firm, as new FTC chairman; as well as Noah Phillips, chief counsel for Senate Majority Whip John Cornyn (R-Texas), and Delta Air Lines executive Christine Wilson for a third GOP slot. Trump also nominated consumer advocate Rohit Chopra for a Democrat slot, which will leave one (Democrat) vacancy on the completely revamped Commission.

4) ICYMI Internet Domain News 

Russiaphobia:

• Top Dems call on Twitter, Facebook to investigate Russian bot campaign | TheHill.com: "A source familiar with Twitter's analytics, though, said "the hashtags appear to be organically trending," and not the result of a Russian-led influence campaign."

Privacy and Surveillance:

• How a single line of computer code put thousands of innocent Turks in jail | CBC.ca

• Your Phone Is a Prison | VICE.com: "Han conceives of the digital world as a prison (a “digital panopticon”) in which you are an isolated inmate, sitting there staring at your phone, but can be monitored by a whole host of prison guards, such as Google, Facebook, and Acxiom.com." 
• How Will Macau’s New Cybersecurity Legislation Impact Freedom of Speech? | GlobalVoices.org: "It also mandates that ISPs retain their users’ online activity logs for at least one year."

• NSA "Sincerely Regrets" Deleting All Bush-Era Surveillance Data It Was Ordered To Preserve | ZeroHedge.com: "There is a growing consensus among many observers in Washington that the national security agencies have become completely politicized over the past seventeen years and are now pursuing selfish agendas that actually endanger what remains of American democracy ..." #DeepState

• EFF Asks Ninth Circuit Appeals Court To Strengthen Privacy Protections Of Smart Phones At The Border | Electronic Frontier Foundation | eff.org: "Warrantless Border Searches of Phones, Laptops, Are Unconstitutional"
• Trump signs bill renewing NSA's internet surveillance program | Reuters.com

Censorship:

• Canadian app in the fight for internet freedom in Iran | CBC.ca: "approximately 15 million Iranians were using the Canadian app Psiphon."

• How to hide your IP address with a VPN | TechRadar.com

• U.S. Sanctions Abet Iranian Internet Censorship | ForeignPolicy.com: U.S."should liberalize rules that impede access to cutting-edge tools against repression."

• The Rapid Rise of Censorship in Southeast Asia | TheDiplomat.com: "From Myanmar to Indonesia, governments are clamping down on the internet and social media."

• Digital freedoms: 25 users face trial over online posts | observer.ug

Net Neutrality: It's up to Congress to save the internet | LATimes.com

5) Four Most Read Posts (# of pageviews Sun-Sat) this past week on DomainMondo.com: 

1. News Review | China Disrupts Global Companies’ Web Access (video)

2. Tech Review | Cryptocurrency & Government Regulation (video) 

3. World Economic Forum Annual Meeting 2018, Davos, Jan 23-26 (video)

4. China's Mobile Wallet-Free Lifestyle via WeChat Pay & Alipay (video) 

-- John Poole, Editor, Domain Mondo 

feedback & comments via twitter @DomainMondo
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News Review | Report: ICANN's New gTLDs As Global DNS Malware

Domain Mondo's weekly internet domain news review (NR 2017-08-27) with analysis and opinion: Features •  1) Report: ICANN's New gTLDs As Global DNS Malware, 2) Names, Domains & Trademarks: .COM Still King, Verisign, GoDaddy, Ted Cruz, ICANN & NTIA, New gTLDs Reality Check, .GAY, .MUSIC, 4) ICYMI Internet Domain News, 5) Most Read Posts.

1) ICANN's new gTLDs as global DNS malware--see "Statistical Analysis of DNS Abuse in gTLDs" below--ICANN Public Comment periods closing in September:

• Address Supporting Organization (ASO) Review Final Report Close date: 6 Sep 2017 23:59 UTC

• Statistical Analysis of DNS Abuse in gTLDs (SADAG) Report Close date: 19 Sep 2017 23:59 UTC (see chart below)

Figure 23, Report p. 13

SIDN Labs and TU Delft deliver final report for ICANN study | sidnlabs.nl: "... An interesting finding of our study is a clear upward trend in the absolute number of phishing and malware domains in new gTLDs while these numbers remain relatively constant in legacy gTLDs. Also, we discovered that new gTLDs have affected the number of domains used for spam in legacy gTLDs: abused domains in new gTLDs do not increase the number of total malicious registrations. Instead we observe a shift from legacy gTLDs to new gTLDs. Our findings suggest that some new gTLDs have increasingly become a target for malicious actors. For example, Spamhouse blacklisted at least 10% of all registered domains in as many as 15 new gTLDs at the last quarter of 2016. See the report [pdf] for more details ... We conducted the SADAG study for the Competition, Consumer Choice, and Consumer Trust Review Team. The CCT Review Team was established to review how the New gTLD Program impacts competition, consumer choice and consumer trust." (emphasis and links added)

Let's review all the ways ICANN's new gTLDs are now known to be global DNS malware:

1. New gTLDs are known to  "break stuff" and cause "collisions;"

2. New gTLDs are known to "fail to work as expected" on the internet--the so-called "Universal Acceptance" (UA) problem--which ICANN knew about long before (since at least 2003) it expanded the gTLDs from just 22 to over 1200 beginning in early 2014, which is why ICANN tried to absolve itself of liability--even though it has failed to warn consumers (registrants)--see Base Registry Agreement Section 1.2:

1.2   Technical Feasibility of String.  While ICANN has encouraged and will continue to encourage universal acceptance of all top-level domain strings across the Internet, certain top-level domain strings may encounter difficulty in acceptance by ISPs and webhosters and/or validation by web applications.  Registry Operator shall be responsible for ensuring to its satisfaction the technical feasibility of the TLD string prior to entering into this Agreement. (emphasis added)

3. Absolute unlimited monopolistic pricing powers granted to new gTLD registry operators, including the right to unlimited increases in domain name registration and renewal fees--ICANN and its "ICANN community" (which is effectively controlled by registry operators and registrars) rejected the recommendation and advice of the the U.S. Department of Justice Antitrust Division to protect consumers (registrants). New gTLD Registry Operators are free to "rape and pillage" the global domain names marketplace and consumers (registrants) worldwide, thanks to ICANN.

4. The Electronic Frontier Foundation (EFF) has warned registrants to avoid new gTLDs due to ICANN's new gTLDs' flawed and overreaching RPMs.

5. And now, the icing on ICANN's global malware cake, SIDN Labs and Delft University of Technology's report (pdf), characterizing new gTLDs as "phishing and malware domains."

Is it any wonder some desperate new gTLD registry operators have tried giving away new gTLD domain names for free? Is it any wonder that new gTLD domain name registrations are collapsing--new gTLD Statistics by Top-Level Domains | ntldstats.com--new gTLDs' registrations are now "falling off a cliff":

This is what happens when you let special interests (a/k/a lobbyists) run internet governance via a governance model known as "multistakeholderism," limiting and excluding governments from their proper role in protecting the public interest. Add to that the dysfunctional ICANN organization which created for its new gTLDs, a new "Global Domains Division" (try to find any reference to that in the ICANN Articles or Bylaws), primarily staffed by incompetent cronies of ICANN's equally inept ex-CEO who quit 3½ years into a 5-year contract. As I've said before, ICANN has proven to be unfit for the purpose for which it was originally intended.

2) Names, Domains & Trademarks

•  .COM Still King: 10 tips for choosing the perfect domain | SearchEngineLand.com August 22, 2017: "... 3. Go for a .COM [domain name]--If you are serious about building a long-term brand online, there is nothing better than a .com. Using a 301-redirect to drive traffic to a .net or .org is totally fine, but owning the .com or the equivalent TLD for your target market country is critical ..."

•  Verisign: Warren Buffett's Stake In The Internet--"VeriSign [domain: verisign.com, NASDAQ: VRSN] is the manager of the .com and .net domain registers - they serve as a monopolistic gatekeeper to the Internet. There are three catalysts for this company's stock appreciation: pricing powers, the Internet's global expansion, and share buybacks. I believe this stock's long-term risk/reward ratio is greatly weighted towards reward ..."--SeekingAlpha.com  Aug. 22, 2017.

•  GoDaddy (domain: godaddy.com) (NYSE: GDDY) announced Tuesday that CEO Blake Irving would retire effective December 31, 2017, and Scott Wagner, GoDaddy President and COO, would assume the CEO role thereafter. Irving will continue to serve on GoDaddy's Board of Directors through June 2018.

•  Ted Cruz, ICANN & NTIA: Ted Cruz should stop obstructing Trump’s [NTIA] nominee [David Redl] for telecom chief | rstreet.org by Joe Kane, Aug 22, 2017: "... Redl has been the subject of a largely unrelated fight waged by the junior senator from Texas over the Internet Assigned Numbers Authority [IANA]. Cruz continues to raise objections about the now-completed transfer of stewardship of IANA functions from NTIA to the Internet Corporation for Assigned Names and Numbers [ICANN]. ICANN is a private, nonprofit company ..." [Editor's note: Cruz has said he wants "assurances" from Redl, and frankly, I would have expected no less.]

•   New gTLDs Reality Check: The Great Domain Correction of 2017? | pinkybrand.com: "... China. China is HARD. You will not be successful there, as a foreign registry operator, at a minimum, unless you understand that you will likely lose money or barely break even for several years and are prepared to deal with that reality. You must be in it for the long term. Long term, at a minimum, is 5 years of sweating it out (flying back and forth on a near monthly basis) before things *might* work out. Over the short to medium term the domain industry is likely to shed inefficient registry and registrar operators and investors, especially some of those who banked on new domain extensions (new gTLDs) that have no real consumer traction—which are many— and can no longer, or are just unwilling, to fund the basic holding/operating costs, let alone fund any marketing team or person. For sure there is an easily foreseen correction—if not outright registration numbers recession—going on right now for some in the domain industry ... This includes ICANN, that may need to shed some personnel as a result of what may be "The Great Domain Correction of 2017"..."

•  .GAY: Request 17-3: Dotgay LLC | BAMC Recommendation on Reconsideration Request 17-3 | ICANN.org 23 Aug 2017: "BAMC [Board Accountability Mechanisms Committee] recommends that the Board deny Request 17-3."

•  .MUSIC:  Request 17-2: DotMusic Limited | BAMC Recommendation on Reconsideration Request 17-2 - ICANN.org 23 Aug 2017: "BAMC recommends that the Board deny Request 17-2."

4) ICYMI Internet Domain News 

• What the United States can do to protect Internet freedom around the world | WashingtonPost.com: "Today, U.S. technology companies adhere to a wide array of requirements from repressive governments that undermine Internet freedom and privacy. These demands violate international law, including the right to freedom of expression. But the enormous benefits of market access outweigh the relatively low costs associated with accepting repressive governments’ demands." See also Another reason China censors the Internet | WashingtonPost.com

• China introduces new rules to "purify" online video content | Lexology.com

• India's blurry battle between digital freedom and security | 11-Aug-2017 | nzcity.co.nz: "India is increasingly pulling the plug on the internet in an effort to combat militants and troublemakers organising online. While the action is supported by some, authorities also acknowledge the perils of limiting communication."

• Chinese company Alibaba's UC Browser under govt scanner for allegedly leaking Indian mobile users data | businesstoday.in: "Chinese company Alibaba's UC Browser has come under government scanner for allegedly leaking mobile data of its Indian users and may be banned in the country if found guilty, a senior IT ministry official said on Tuesday [Aug 22, 2017]."

• "We’re currently living in a time digital strategists have deemed the data wild west. The next decade the data policies set could determine the basis of digital rights for the foreseeable future."--TechCrunch.com

• Inciting Violence vs Freedom of Speech | Namecheap.com: "... The real danger in my opinion is what lies invisible yet is the most dangerous force that anyone of us will ever know. That is the insidious and dangerous force of power. The power to control our thoughts, our privacy, our opinions and most importantly our speech that lies within the dark nature of absolute power itself and takes over seemingly well meaning politicians, presidents, governments, movements that then use this power against us. This is the real danger that we must all be watchful for ..."--Richard Kirkendall, Namecheap CEO

[Editor's note: Investing has moved to the weekly Tech Review.]

5) Most read posts (# of pageviews Sun-Sat) this past week on DomainMondo.com: 

1. News Review: Last Round of ICANN New gTLD .AFRICA Litigation?

2. Explaining Swings in Bitcoin’s Price, Cryptocurrency Primer (video)

-- John Poole, Editor, Domain Mondo 

feedback & comments via twitter @DomainMondo
Follow @DomainMondo

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News Review: New gTLDs Registry Rightside Sells eNom, What's Next?

Domain Mondo's weekly review of internet domain news:

Feature •  Surprise announcements by buyer and seller early Friday, Presidential Inauguration Day in the U.S., new gTLDs registry operator Rightside Group, Ltd. (NASDAQ: NAME), sold its domain registrar business operating under the brand name eNom (eNom.com), to Tucows Inc. (domain: tucows.com) (NASDAQ: TCX) (TO.TC), and investors apparently liked the "win-win" deal:

1. Dave Wilson's stock of the day: Tucows NASDAQ:TCX (audio mp3) 
2. Both $TCX and $NAME ended UP Friday, although Tucows had the larger gain:

"These two businesses have been competing for over 15 years. We know and respect each other. Each business also has particular strengths. Following completion of the transaction, we will continue to operate the acquired eNom properties under their current brands and we’ll maintain the existing reseller APIs, as well as the eNom accreditation, which means there will be no bulk migration of names required. We will also maintain the Seattle office."--Tucows CEO Elliot Noss, Conference Call Jan. 20, 2017. See also Tucows SEC filings.

Tucows' CEO Elliot Noss acknowledged eNom's growth prospects were neutral to negative but cited anticipated cost synergies over the next 24 months and the deal's additional cash generation as justification for the acquisition in a conference call and webcast Friday which is available for replay.

UPDATE Jan 24, 2017: $TCX UP 35% since Jan 19th close:

Toronto-based Tucows is a provider of network access, domain names and other Internet services, including Ting (ting.com) mobile phone service and fixed internet access, OpenSRS (opensrs.com) domain registrar services (15 million domain names, a global reseller network of over 13,000 web hosts and ISPs), as well as Hover (hover.com), a domain name registrar. More information can be found on Tucows’ corporate website (http://tucows.com) and on Domain Mondo at Tucows Acquires eNom & Becomes World's 2nd Largest Domain Registrar.  As a result of the deal, Domain Mondo has added Tucows Inc. (TC.TO) to its quarterly earnings coverage list.

What's in the deal for Rightside? Besides the press release which cited the "divestiture" as enhancing "Rightside's ability to make additional investments in the Registry business as the market for new domains continues to develop," we may know more after the Rightside conference call and audio webcast with investors and analysts Monday, January 23, at 4:30 p.m. ET (1:30 p.m. PT): LIVE webcast

Live conference call: (844) 413-1777 (domestic) or (716) 247-5761 (international)
Conference call replay available through January 28, 2017: (855) 859-2056 (domestic) or (404) 537-3406 (international); Conference ID: 57050879; LIVE webcast and archived webcast at http://www.rightside.market.

UPDATE Jan 23, 2017 4:30 PM ET --Listen to webcast and eNom Divestiture Presentation (pdf 338.8 KB). Tucows $TCX closed UP Monday, Jan 23rd, and Rightside $NAME closed DOWN:

Rightside's filing with the SEC in connection with the deal stated, in part:

"On January 20, 2017, Rightside Group, Ltd. (“Rightside” or the “Company”) and its wholly owned subsidiaries, Rightside Operating Co. (“Seller”) and eNom, Incorporated (“eNom”) entered into a Stock Purchase Agreement (the “Purchase Agreement”) with Tucows Inc. (“Tucows”) and Tucows (Emerald), LLC, a wholly-owned subsidiary of Tucows Inc. (the “Purchaser”), pursuant to which the Purchaser will purchase Rightside’s eNom business through the purchase of all of the outstanding stock of eNom from Seller in exchange for $83.5 million, less a net working capital adjustment of $6.8 million, resulting in net cash at closing of $76.7 million (the “Transaction”). The purchase price is subject to customary adjustments following the closing, including a working capital adjustment to the extent such amount is greater or less than the estimated net working capital amount determined at closing. At the closing, the Company will pay transaction expenses of approximately $4.0 million and substantially all of its existing indebtedness. The transaction is expected to close on January 20, 2017."

That SEC filing also disclosed (emphasis added):

" ... On January 20, 2017, the Company entered into a Limited Consent and Amendment No. 4 to Credit Agreement (the “Amendment”) by and among the Company, its domestic subsidiaries Rightside Operating Co. and eNom (together with the Company, the “U.S. Borrowers”), its foreign subsidiaries DMIH Limited, United TLD Holdco Ltd. and Rightside Domains Europe Limited (collectively the “Non-U.S. Borrowers” and together with the U.S. Borrowers, the “Borrowers”), Hot Media, Inc. and Acquire this Name, Inc., as guarantors, and Silicon Valley Bank (“SVB”), as lender and collateral agent. The Amendment revises the terms of the Company’s existing Credit Agreement, dated as of August 1, 2014, as amended (the “SVB Credit Facility”), by and among the Borrowers and SVB, which provided a $30.0 million revolving loan facility with a $15.0 million subfacility for the issuance of letters of credit. The Amendment, among other changes, releases eNom as a party to the SVB Credit Facility and the assets sold in the Transaction from the collateral securing the obligations under the SVB Credit Facility; suspends the availability period for revolving loans, requires the Company to repay the outstanding revolving loans in full and reinstates the availability period once the Company satisfies certain conditions, including further amendments to the SVB Credit Facility and delivery of projections giving effect to the Transaction; lowers the total commitment from $30.0 million to $15.0 million; suspends the application of the financial covenants until the availability period for revolving loans is reinstated; and amends the financial covenants that will have effect once the availability period for the revolving loans is reinstated, including the maximum consolidated net leverage ratio, minimum liquidity ratio and minimum consolidated EBITDA. The Amendment further consents to the Transaction." 

Friday's closing price on Rightside ($NAME) gave it a market capitalization of $178.9 million. Rightside stated Friday in its press release: "Following the transaction, Rightside will be in a strong financial position with approximately $90 million in cash on its balance sheet."  Subtract the $90 million in cash, and the market is valuing Rightside's remaining businesses, principally Name.com registrar and Rightside registry (new gTLDs), at $88.9 million. In July, 2016, Rightside rejected an unsolicited offer from privately-held Donuts to buy Rightside's new gTLDs for $70 million in an all-cash deal.

Question: Is the market overvaluing or undervaluing Rightside's remaining businesses?  See Rightside Q3 2016 financial results. It will be interesting to see the Q4 2016 and Q1 2017 financial results.

Other Internet Domain News:

•   It doesn't matter how many new gTLDs ICANN creates because We're Going to Run Out of Company Names | Bloomberg.com: "There is a numeric limit to the universe of names, the combinations of letters of five syllables or less that are pronounceable, avoid offense in principal languages, and are not someone else’s property."

•   Select ICANN officers and staff may have been busy partying this past week in Davos at the World Economic Forum as in past years when Fadi Chehade was ICANN President and CEO. The ICANN website offered little new "news" and, e.g., the Litigation Documents page has not been updated in weeks.

•  Senator Ted Cruz (R-TX) has not forgotten about ICANN and the IANA transition, nor China, free speech, and tech, raising those issues at the confirmation hearing of  Wilbur Ross, Trump's pick for Commerce Secretary, this week (2:50:33-2:52:52):

•  Fairness & Due Process Require Changes to ICANN's "Updated Supplementary Procedures" to the IRP | circleid.com. See Updated Supplementary Procedures for Independent Review Process (IRP) | ICANN.org: close date 25 Jan 2017 23:59 UTC 1 Feb 2017 23:59 UTC.

•   ICYMI:

• 2016 New gTLD Year in Review (Infographic) | circleid.com: "... Based on today's data, 66% of  [new g]TLDs are projected to operate at a loss for the next year based on conservative, yearly expenses of $150k ..."
• Beware of fake comments on domain blogs | MorganLinton.com
• Don't let your router be a gateway for cybercriminals | USAtoday.com
• ICANN still under US laws, but checks in place to avoid hostile takeover | ZDNet.com
• Owner of .CO & a 2-day old trademark threatens to steal my 10 year old .COM domain | OnlineDomain.com
• Here's Why Hive Bought Hive.com | NamePros.com

•  Author of anti-net neutrality “Internet Freedom Act” gains leadership position | Ars Technica: Rep. Marsha Blackburn (R-Tenn.), who has tried to overturn net neutrality rules and help states impose limits on municipal broadband, will be the new chairperson of a Congressional telecommunications subcommittee, the House Energy and Commerce Committee's Subcommittee on Communications and Technology. She takes over from Rep. Greg Walden (R-OR.). See also: Don't Kill Net Neutrality. It’s Good for People and Business | WIRED.com.

•  Turkey Moves to Block Internet Access | voanews.com: "analysts and civil society organizations say the Erdogan administration has begun moving aggressively to restrict internet and mobile phone access to the rest of the web — and for the first time, is showing no signs of backing off any time soon." See also: Turkey Increases Internet Restrictions | voanews.com.

•  John McAfee’s 3 major cybersecurity predictions for 2017 (via CSOOnline.com):
1. IoT denial of service attacks on major internet companies, like the one carried out on Dyn earlier year will become commonplace, and the severity will be orders of magnitude greater than what we have seen;
2. The anti-virus paradigm will finally been seen as a dead paradigm ... the world must move to proactive systems;
3. Intelligence agencies will finally accept the fact that a sophisticated nation state can perpetrate any hack and make it point to any nation or agency that they choose.

•  4 most popular posts (# of pageviews Sun-Sat) this past week on DomainMondo.com:

1. US Intel Community's 'Nazi-like' Tactics, Media Hysteria & Trump (video)
2. Confirmation Hearings LIVE: Trump's Cabinet Nominees (video)
3. News Review: ICANN Accountability WS2 & Consensus 'ICANN Style'
4. TechReview | Apple Going 'Hollywood' With New Content Plan (video)

-- John Poole, Editor, Domain Mondo 

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DISCLAIMER

ICANN President & CEO Busy Rearranging Deck Chairs on the Titanic

ICANN President & CEO busy rearranging deck chairs on the Titanic:

I’ve made some small changes to the #ICANN org Executive Team, a promotion and a new role. Read more in my blog: https://t.co/Z0Q9Cj6gkr

— ICANN President (@icann_president) October 4, 2016

This is the problem when the ICANN Board of Directors replaced former ICANN President & CEO Fadi Chehade (who quit in March, 2016, 3½ years into a 5-year contract), with a complete stranger to ICANN, Goran Marby of Sweden, who had no prior experience in any aspect of ICANN, nor any of its three "communities"--domain names, numbers (RIRs), protocols (IETF).

Marby, who started as ICANN President & CEO in May of this year, was previously Director-General of the Swedish Post and Telecom Authority. Shortly after his appointment was announced in February, 2016, the ICANN Board members, and other ICANN insiders, appeared unaware and surprised when Domain Mondo pointed to reports out of Sweden indicating Marby's temperament and leadership style might be incompatible with ICANN's collaborative, multi-stakeholder approach to internet governance, resulting in a press conference--MP3 audio archived here and here--in which a Bloomberg BNA reporter asked Marby (@3:45 in the audio) about one of those reports, quoting a Swedish telecom operator that Marby's style was "lacking in transparency," and "threatening."

Perhaps that is why Marby has kept a low profile at ICANN but for his recent appearance before U.S. Senator Ted Cruz's (R-TX) recent Subcommittee Hearing in Washington, D.C., (video), where Marby, under grilling by Cruz, looked like a "deer caught in the headlights."

Clearly, it will take Marby at least a year, if not two, before he is no longer "wet behind the ears" when it comes to being President & CEO of ICANN. Unfortunately, that has given ICANN insiders, who are part of the organization's culture problem, ample time to indoctrinate Marby, who may be completely unaware of ICANN's systemic dysfunction and other problems, including the fact that it was the "ICANN community" alone (not NTIA, ICANN Board members, management or staff), who insisted on the accountability component of the IANA stewardship transition.

This may be evident in Marby's list of his ICANN Executive Team Members as of October 4, 2016, see list below with asterisks marking members who are a known *crony of former ICANN CEO Fadi Chehadé & ICANN GDD President Akram Atallah. Atallah reportedly got his "old friend" Chehadé the CEO job at ICANN, and in turn, was appointed by Chehadé to the second-highest paying position at ICANN which provides Atallah a total annual compensation + benefits package approaching $1,000,000 in value--who says you can't "profit" from a "non-profit" corporation--move over Bill and Hillary!

ICANN Executive Team Members (Oct 4, 2016):

Göran Marby; *Akram Atallah; *Allen Grogan; *Ashwin Rangan; David Conrad; Diane Schroeder; Duncan Burns; John Jeffrey; Sally Costerton; *Susanna Bennett; Tarek Kamel; Theresa Swinehart; Xavier Calvez.

This list contains many of the same ICANN team members in charge when the ICANN community expressed such dissatisfaction with ICANN leadership and insisted on the ICANN accountability components now known as Work Stream 1 (WS1) and Work Stream 2 (WS2). Compounding the problem, the ICANN Board of Directors has been dysfunctional and failed to properly oversee ICANN management and staff, leading to such embarrassments as the IRP Declarations in the DotConnectAfrica Trust (DCA Trust) and Dot Registry cases.

Maybe ICANN wasn't really ready for the IANA transition.

See also ICANN Management Organization Chart 01Oct2016: management-org-01oct16-en.pdf (pdf) embed below:


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News Review: After Cruz Attack, What Now For ICANN & IANA Transition?

Domain Mondo's weekly review of the news, analysis, and look ahead [pdf]: 

UPDATE Sep 22, 2016:  IANA Transition: Dead or Alive? High drama in D.C. TheHill.com reports that Republican Senate Majority Leader Mitch McConnell (R-KY) has "dopped a provision championed by Sen. Ted Cruz (R-Texas) and backed by Republican presidential nominee Donald Trump to block the Obama administration from ceding oversight of internet domain names to an international body." POLITICO.com confirms that: "Gone is the so-called ICANN provision, an internet-domain issue that had become a top priority for Sen. Ted Cruz (R-Texas) and other GOP senators and just got the seal of endorsement from GOP nominee Donald Trump." However, NYTimes.com reports the short-term spending bill that Congress is set to pass next week "will most likely include a provision championed by Senator Ted Cruz ... While many Democrats oppose the [Cruz] provision, it is not clear how many care enough to make it stop" (emphasis added). POLITICO.com does concede Cruz is urging allies in the U.S. House of Representatives to fight on and stop the IANA transition. We may not know for sure until next week.

UPDATE Sep 21, 2016: It appears the pro-transition lobbyists have either dropped the ball or didn't come to the game ready to play:

1. Trump enters the arena on ICANN | TheHill.com; Press release of September 21, 2016: Trump Opposes President Obama's Plan to Surrender American Internet Control to Foreign Powers | Donald J Trump for President | DonaldJTrump.com by Stephen Miller, National Policy Director for the Trump Campaign; TheHill.com also reports FCC Commissioners Ajit Pai and Michael O’Rielly now also want to delay the IANA transition;
2. Senate leaders say they are close to deal to prevent government shutdown: "The latest GOP offer also included a provision sponsored by Sen. Ted Cruz (R-Texas) that would delay plans for the U.S. government to give up control over a global nonprofit that oversees the internet domain system. Cruz told reporters that he is “cautiously optimistic” that it will be included in the final package."--WashingtonPost.com [Domain Mondo Editor's Note: read the WaPo article and one is left with the impression that Democrats are now willing to "trade away" their stance on the IANA transition for something else.]

UPDATE Sep 20, 2016: U.S. Senate lays groundwork for spending deal--"It's not [time for] a big debate for talking about how we change the internet forever ... It's not a time to try to satisfy Cruz because he doesn't get along with the caucus and they're trying to shut him up."--U.S. Sen. Harry Reid (D-NV), Senate Minority Leader in TheHill.com.

________

Original post of Sep 18, 2016:
Feature •  After Cruz Attack, What Now For ICANN & IANA Transition? For more than a week U.S. Senator Ted Cruz (R-TX) has been dominating the news related to the IANA stewardship transition scheduled to be completed October 1, 2016 (after expiration of the IANA functions contract on September 30). From September 9th's US Senator Cruz Attacks ICANN, Fadi Chehadé, IANA Transition (video) through yesterday's Sen. Cruz Questions NTIA's Strickling, ICANN's Marby & Witnesses (videos), Domain Mondo's coverage has included a daily posting on this topic almost every day.

But now with less than two weeks left before September 30, the chance that Republicans in the House and Senate will actually derail the IANA transition is unlikely, for the following reasons:

1. The fact that this is an election year works in favor of the IANA transition--Republicans are looking to leave Washington soon to return to the campaign trail, reports TheHill.com.
2. The IANA transition is not a hot-button issue in this campaign season. Most Americans don't even know who or what ICANN is, much less the IANA transition, and don't care. The headline in the Washington Post sums it all up: Ted Cruz has made an obscure Internet agency his first post-presidential crusade. In Election 2016, it's about the economy, stupid:



Election 2016 top issues in search by state, past week | Google Trends 

3. Ted Cruz is a pariah even in his own party. Cruz was invited and spoke at the Republican Convention in July but refused to endorse the Republican Party's Presidential nominee. Subsequently he was deemed persona non grata at the GOP gathering and even barred from entering GOP mega-donor Sheldon Adelson's suite at the Convention hall.
4. Cruz's grandstanding this past week may have been the "kiss of death" to the effort to delay the IANA transition. Although four key House and Senate Chairmen have indicated a preference  to extend the IANA functions contract for one year, how much political capital will they be willing to expend when it comes down to the wire?
5. Washington runs on lobbying money. I noted Friday that "preventing a 'competing' internet root may be the most compelling reason to not delay the IANA transition despite misgivings about ICANN or the IANA transition plan." None of the tech giants in the world, including those in China, want a competing root and everyone is looking to the U.S. tech giants (Google, Facebook, Amazon, etc.) who are hardwired into K Street to "get the job done" (i.e., get the IANA transition completed).
6. Trump has no love for Cruz and now Trump is leading in the Presidential Race according to several polls: Trump cracks the Electoral College lock | POLITICO.com Sept. 15, 2016: "A new round of state polls shows Donald Trump suddenly has a path to 270 electoral votes [to win the Presidency] ... state polling averages, which can be lagging indicators, are beginning to show Trump in the lead."  Trump has never stated his position on the IANA stewardship transition and there is no reason for him to now. As I have previously noted, the Trump campaign's lawyer is Jones Day Partner Don McGahn (Jones Day is also legal counsel for ICANN). Perhaps even more important, Trump's go-to guy on tech matters is Peter Thiel who certainly doesn't want a competing internet root. If asked, Thiel would probably say ICANN, after 18 years, must have reached minimal viable product stage, so don't delay the IANA transition--see Can Monopolies Save The Internet? | BigThink.com at Harvard's Berkman Center: Peter Thiel vs. Jonathan Zittrain on globalization, monopolies, internet, Facebook, etc. (April 13, 2009). See also: Bilderberg People: Elite Power and Consensus in World Affairs | books.google.com. Under this reasoning, if ICANN falters post-transition, the U.S. government has an implied right to step back in as "historic steward of the internet" and do whatever is necessary to "right the ship." A key to this may have been the testimony of NTIA's Larry Strickling at the Cruz hearing that the U.S. did not want a registry agreement with ICANN for either .MIL or .GOV because the U.S. government did not want to concede or give up its "sovereignty" in those TLDs (top-level domains).
7. The most powerful person in the Republican Party right now may be Reince Priebus, Chairman of the Republican National Committee (RNC). The Trump campaign's national finance chairman (and likely future Secretary of the Treasury should Trump win) is Steven Mnuchin who has a lean staff but is using the RNC and all of its resources to raise money, not only for Trump, but for the Republican Party and all its candidates in all 50 states. While Hillary Clinton's campaign is running a separate huge fundraising operation out of the campaign headquarters in Brooklyn, Trump's fundraising flows through the RNC in Washington, D.C. They know all of this on Capitol Hill, and as Churchill said, “Never let a good crisis go to waste.” For that reason, you may continue to hear "noise" about the IANA transition but the real question is: "To whom should we make the checks payable?" See U.S. technology companies lobby for ICANN transition | SeekingAlpha.com.

Other ICANN, Internet Governance, and Domain Name News:

•  The Catalyst For The IANA Stewardship Transition: New Film Tells the Story of Edward Snowden; Here Are the Surveillance Programs He Helped Expose | TheIntercept.com.

•  DNS Forum | InternetPolicyForum.com: On September 14-15, Public Interest Registry, CENTR, LACTLD, i2Coalition, and ISOC-DC brought together a diverse group of experts to discuss the impacts of policy on DNS (domain name system) technical operators.  Panelists and audience members discussed the implications of privacy, security, and content policies for these technical operators and how the technical community can best engage in the evolving multistakeholder model of Internet governance. For complete agenda, video replay, and more information, go to the link above.

•  Verisign Inc. (NASDAQ: VRSN) reported this week that at the close of Q2 2016 (June 30, 2016):

• The total number of registered domain names rose to 334.6 million worldwide across all top-level domains, of which new gTLDs (ngTLDs) domain names comprised only 22 million or 6.6% of all TLDs' domain names, and the top 10 ngTLDs represented 61.5 percent of all ngTLD domain name registrations.
• 7.9 million domain names were added to the Internet in Q2 2016: • This increase globally equates to a growth rate of 2.4% over Q1 2016 • Domain name registrations have grown by 38.2 million, or 12.9 percent, year over year.
• The .com and .net TLDs reached a combined total of approximately 143.2 million domain names in the domain name base in Q2’16 • The base of registered names in .com equaled 127.5 million names, while .net equaled 15.8 million names • Verisign processed 8.6 million new domain name registrations for .com and .net, as compared to 8.7 million domain names for the same period in 2015.
• Verisign’s average Domain Name System query load was 130 billion across all TLDs operated by Verisign, with a peak of 179 billion.
• Total ccTLD domain name registrations were approximately 149.9 million in the first quarter of 2016, with an increase of 1.4 million domain name registrations, or a 1.0 percent increase compared to the first quarter of 2016. ccTLDs increased by approximately 11.7 million domain name registrations, or 8.5 percent, year over year. Without including .tk, ccTLD domain name registration growth quarter-over-quarter was 1.2 percent and growth year-over-year was 10.7 percent. 
• The top 10 ccTLDs, as of June 30, 2016, were .tk (Tokelau), .cn (China), .de (Germany), .uk (United Kingdom), .ru (Russian Federation), .nl (Netherlands), .br (Brazil), .eu (European Union), .au (Australia) and .fr (France).
• As of June 30, 2016, there were 292 global ccTLD extensions delegated in the root, including Internationalized Domain Names (IDNs), with the top 10 ccTLDs composing 67.3 percent of all ccTLD domain name registrations. 

Verisign had previously reported that at the close of Q1 2016 (March 31, 2016), the base of registered names in .com equaled 126.6 million names, while .net equaled 15.9 million names. Accordingly, .net registrations decreased by about 100,000 (net) in Q2 2016, while .com registrations increased by about 900,000 domain names (net) in Q2 2016. For more information, copies of the Q2 2016 DNIB, or to view past reports, go to VerisignInc.com/DNIB.

•  ICANN's new consolidated page for community feedback on various issues: Operational Consultations | ICANN.org.

•  ICANN published its Global Registrant Survey Final Phase Results (pdf). More information here. Results may be questionable based upon methodology alone:

ICANN Global Registrant Surveywave 2 | AUGUST 2016, p. 5

Apparently ICANN commissions these kinds of studies to generate a mostly useless report in an attempt to justify ICANN's mistakes or reinforce existing policies. Vendors, like Nielsen, usually understand this. Manipulation ("adjustment") of methodology and data are well known techniques. In this case, the report did confirm a few things we already knew:

• Reported registration of new gTLDs is highest in the Asia Pacific region.
• ".COM continues to be the most favored legacy domain name among registrants. Declines are seen for several of the less common gTLDs but these already have very low reported registrations." (p.22 of 182)
• Many would-be registrants choose alternative identities (e.g., social media handles) over domain names.
• About 17 percent of the respondents said they did not renew a domain in favor of using an alternative method for managing an online identity.

•   TheDomains.com reports Frank Schilling's North Sound Names is dropping 230,000 new gTLD domain names from its portfolio, which probably accounts for the decreases we are seeing in Uniregistry's new gTLDs' registration numbers like .FLOWERS and .PROPERTY.

•  No Comments close this coming week at ICANN.

Tech News:

1. Fans cheer, but iPhone 7 gets a subdued welcome--Reuters.com. See also Apple Japan unit ordered to pay $118 million tax for underreporting income: media | Reuters.com.
2. Coaltion for Better Ads (IAB, Google and others), formed as a direct response to ad blocking, the coalition will act as a "kind of regulator for internet ads"--BusinessInsider.com.
3. The Internet’s Own Instigator | BackChannel.com: "Malamud can’t abide 112's waffling on the copyright issue, saying that “to the extent the material is subject to copyright protection, the agency must get authorization…for public access to that material.” To Malamud, if the standard is part of the law, there can be no copyright. Period."
4. Project Sand Hill: Google’s Unknown Campaign to Track the World’s Hottest Startups | WIRED.com. See also: Thoughts on Alphabet, one year in | BusinessInsider.com: So far it's been a BIG Loser but see The Wall Street Veteran Who's Helping Google Get Disciplined | Fortune.com.
5. The blockchain industry is either hugely under-resourced or hugely over-optimistic. Probably both--Blockchain's Numbers Don't Add Up | Bloomberg.com.
6. GM Bolt vs Tesla Model 3? Metrics Make The Difference | SeekingAlpha.com.
7. Deal of the Month: HP Enterprise [US] strikes $8.8 billion deal with Micro Focus [UK] for [HPE's] software assets | Reuters.com.
8. Yahoo Inc. ("RemainCo") after the Verizon sale? Cash + marketable securities + shares in Alibaba, Yahoo Japan, other minority equity investments + IP assets held in Excalibur, AND it will be a company with a new ticker.--SeekingAlpha.com 

Four most popular posts (# of pageviews Sun-Sat) this week on DomainMondo.com:

1. News Review [11Sep]: IANA Transition Drama in D.C. and ICANN & Zika
2. IANA Transition Hearing: Implications of Ending US Oversight of the Internet
3. U.S. Senator Ted Cruz vs ICANN and IANA Transition: Veni, Vidi, Vici ?
4. US Senator Cruz Attacks ICANN, Fadi Chehadé, IANA Transition (video)

Macro view:

1. Deutsche Bank will most likely be bailed out by the German government or the ECB. It will not be allowed to topple and shatter the global financial system but its shares and CoCos will be “bailed in” before taxpayers get hit.--Deutsche Bank’s CoCo Bonds Speak of Fear of the Worst | WolfStreet.com
2. Federal Reserve policy affecting elections is hardly a novel concept. At the recent central banker’s summit in Jackson Hole, former Democrat Congressman Barney Frank, told the Fed, “Don’t raise rates before the election.”--Why The Fed Destroyed The Market Economy | ZeroHedge.com
3. Tax Avoidance Is Part of the Recipe for National & Global Income Inequality: 1) The less affluent must pay their payroll taxes and income taxes in full; 2) The more affluent utilize tax avoidance schemes conveniently provided by governments, that also allow corporations to utilize offshore companies to "hide" or "transfer" profits to low-tax and no-tax jurisdictions; 3) Total effect of the taxation system is regressive, even without adding the inherently regressive effects of sales and value-added taxes. "The phenomenon of rising inequality in affluent societies may not need much additional explaining – and it hardly matters if those were tax-avoidance or tax-evasion trillions."--Hidden assets from the Panama Papers | the-tls.co.uk.
4. Central Bankers, Savers & Investors: Martin Lück, strategist at Blackrock: the ECB's actions are having the opposite effect of the spending spree intended. Falling interest rates cause people to save more rather than less in order to secure their pensions, while investors, including insurers and pension funds, have to enter ever higher risks to secure ROI.--Deutsche Bank CEO Warns Of "Fatal Consequences"...| ZeroHedge.com

4 Other Reading Recommendations:

1. Peter Thiel in the WashingtonPost.com: "The establishment doesn’t want to admit it, but Trump’s heretical denial of Republican dogma about government incapacity is exactly what we need to move the party — and the country — in a new direction. For the Republican Party to be a credible alternative to the Democrats’ enabling, it must stand for effective government, not for giving up on government."
2. "Two basic principles of management, and regulation, and life, are: 1. You get what you measure. 2. The thing that you measure will get gamed ... "--Wells Fargo Opened a Couple Million Fake Accounts | Bloomberg.com.
3. Why One Hedge Fund Is Once Again Preparing For The End Of The Euro | ZeroHedge.com
4. What successful and happy people focus on: "They don’t let anyone limit their joy. When your sense of pleasure and satisfaction are derived from comparing yourself to others, you are no longer the master of your own happiness."--weforum.org

-- John Poole, Editor, Domain Mondo 

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