United Against Nuclear Iran (“UANI”) is at it again, and the latest windmill in its quixotic quest at ending all international commerce with Iran is the Internet Corporation for Assigned Names and Numbers (“ICANN”) because, apparently, Iran is still connected to the Internet and it is, apparently, somehow ICANN’s fault. In a ridiculous letter that UANI sent to ICANN, which is long on outrage and short on law, UANI alleges that ICANN is violating U.S. sanctions by permitting Iranian entities to use the .ir country code top level domain (ccTLD), by assigning unique IP addresses to Iranian entities, and by providing name server services to .ir websites which permit alphanumeric web URLs to be associated with the unique IP addresses.

The UANI letter focuses on certain .ir domains held by particular Iranian entities:

Prominent sanction-designated Iranian entities have acquired .ir Unique Internet Identifiers from ICANN/IANA through the RIPE NCC. For example, Iran’s nuclear brain trust, Malek Ashtar University holds the http://www.mut.ac.ir/ address.

Apparently it thinks that ICANN hands out individual web addresses. It does not. It coordinates the assignment of a block of IP addresses to RIPE, a regional internet registry (RIR) covering Europe, the Middle East and parts of Central Asia.  (The original assignment was by the Department of Commerce.)  RIPE, in turn, designates registrars in various areas in its territory to manage and assign domain names within specific top level domains. In the case of Iran, RIPE has appointed the Institute for Research in Fundamental Science in Iran and which set up IRNIC to coordinate assignment of domain names using the .ir extension.   So ICANN isn’t dealing with Iranian website owners or IRNIC and doesn’t have any power to shut down individual domains any more than Apple can recall an iPod that is resold from outside the United States into Iran.

At most, ICANN might be able to shut down the entire .ir domain, although I believe it would need the consent of the Department of Commerce which delegated all of its authority over Internet coordination to ICANN. But our friends at UANI purport to support ordinary Iranian citizens and their rights to access the Internet, so snuffing out the .ir top level domain would seem to be overkill. I think UANI realizes that it’s not going to get ICANN to shut down the .ir top-level domain or any particular domain names in Iran. Instead, UANI’s goal here is more likely simply to get news coverage by throwing around its baseless charges about ICANN.

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