To:       Esther Dyson, Interim Chairma
          ICANN Initial Board of Directors

From:     Eric E. Menge, Assistant Chief Counsel for
Telecommunications, Office of Advocacy, U.S. Small Business Administration

Date:     August 25, 1999

Re:       ICANN At-Large Membership

     The Office of Advocacy of the United States Small Business
Administration supports most of the recommendations in the
Staff's Report on ICANN At-Large Membership.  For full discussion
of the Office of Advocacy and the role of small business on the
Internet, please see our comments filed in response to the DNSO
WG-A's Final Report to the ICANN Board, filed with ICANN on
August 25, 1999.
     
     Advocacy would like to address directly two of the proposals
contained in the staff report.

     Advocacy believes that membership criteria contained in
Recommendation III.1 must be carefully considered because of the
impact it will have in determining membership.  Advocacy agrees
with staff's recommendations on the first four criteria
presented, but the requirement to support the cost of ICANN
membership could create a barrier to participation for
representatives from individuals and small businesses.  If a
membership fee is to be accessed, Advocacy urges ICANN to keep
the fee low or to provide a waiver process for either the entire
fee or a part of the fee.

     In response to Recommendation IV.2, Advocacy offers its
assistance to the ICANN staff in its efforts to attract
membership.  Advocacy has extensive contacts with individual
small businesses and with small businesses associations and could
facilitate ICANN's outreach efforts.

     Thanks you for consideration of these issues.