3/9/98 Submitted DNS Comments

From: Ed Sweeney <ed@capital.net.au>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 2:33am

Here is Capital Networks' (CORE Registrar) response to the Green Paper.

Regards,
Ed Sweeney

March 10, 1998

GREEN PAPER RESPONSE

Introduction

The Green Paper recommends setting up a new Internet Assigned Numbers Authority (IANA) in the form of a US based not-for-profit corporation and handing over control of the "A" root server by the year 2000 or earlier. In the meantime, recognising the urgent requirement for increased competition in domain name registration, the Green Paper proposes entering 5 new gtlds into the root servers and issuing exclusive registry rights to 5 corporations who meet certain technical requirements. Each registry would have to offer, on a non-discriminatory basis, access to all and any qualified registrars. Each registry would serve as a registry for only 1 gtld. The Green Paper states that this plan will satisfy three important objectives:

Stability of the internet
Increased competition in domain name registration services
Protection of trademark holders.

The Green Paper can be read in its entirety at:

http://www.ntia.doc.gov/ntiahome/domainname/dnsdrft.htm.

The stability of the internet

The Green Paper states that by introducing more than 5 gtlds, the stability of the internet could be compromised. While the Green Paper does not expressly define what it means by this, it must only be assumed that what is meant is that not all domain names would be constantly accessible from all ISP’s. The way root servers operate, this would require that there be different gtlds entered into different root servers.

Clearly then, any destabilising factor is dependent on "root server politics" rather than merely the number of gtlds. There are already hundreds of country code tlds in operation yet this has caused no destabilisation as all country codes are entered into root servers as tlds. Once in the root servers, they can then be accessed.

What could compromise stability would be if new "unauthorised" root servers were set up with the result that different root servers recognised different gtlds. Then, not all names would be accessible from all ISPs all the time. This is of course exactly what has happened previously with Alternic and other parties. No doubt these parties would have preferred to add a gtld to the existing root servers but, frustrated by the closed system they set up alternatives to internic. By limiting the number of gtlds to 5 and the number of gtlds that a registry can administer to 1, the incentive to set up a "rogue" root server system will relatively unchanged from what it is now. If the system were opened further (as the CORE model is) so that numerous new gtlds were operated by a non-profit body there would be little incentive to go through this destabilising process. In short, we believe that Internet stability is in no way compromised by having more than 5 new gtlds. Internet stability has always been the most essential concern of CORE and the gtld-mou.

Increased competition in domain name registration

The Green Paper recognises the urgent requirement for increased competition. The US Government should also recognise that they have been heavily lobbied by people with a vested interest in introducing as limited a degree of new competition as possible. Namely, these are Network Solutions Inc (NSI) and large corporations who have already obtained (often at a considerable price) the domain name of their choice and who want minimal competition and thus devaluation of that domain name. The interests of these parties are of course diametrically opposed to the majority of the internet who have been unable to obtain appropriate domain names and will remain unable to do so without new gtlds being opened.

Here the Green Paper suggests that by opening 5 new gtlds, all administered by monopolist corporations competition between gtlds will be enhanced and will force registries to price competitively. This is true only to a very limited extent. The level of competition between gtlds will depend on their perceived substitutability. The experience thus far has indicated that gtlds are not close substitutes for each other- witness the much greater appeal of the .com gtld when compared to .net and others. The appeal of the .com gtld is not, as the Green Paper might suggest, due to any "branding" of the gtld achieved by NSI. It just happened more or less as an industry standard.

There can be no question that a non-profit registry which serves numerous competing registrars will result in a far more competitive price and service for the end user than the Green Paper model. As the Green Paper model will only place limited competitive pressures on registries, they will be have a monopolistic price making ability. Then, further down the chain of course registries will be almost perfectly competitive, but by then a large portion of value of competition will have been lost.

The Green Paper actually concedes that under its proposal, a registry could offer low prices initially to attract custom but then, due to the lack of domain name portability, could increase prices later. Due to the expense to companies of changing domain names, many would be locked in to this arrangement. The Green Paper, somewhat incongruously, concludes that this would be unlikely to occur due to competition between gtlds, but the point is that the competition between gtlds for "churns" is extremely feeble due to the impossibility of domain name portability. In the CORE model, there is absolute domain name portability and so if a particular registrar prices uncompetitively in the future they will lose clients to other registrars. Thus the Green Paper proposal facilitates the "after market" exploitation of captive consumers by monopoly registrars.

Protection of trade marks

The Green Paper alleges that too many new gtlds (more than 5) could unfairly damage trade mark protection. Like the issue of Internet stability, this view confuses two totally unrelated issues.

It is acknowledged in the Green Paper that only a tiny fraction of domain name registrations to date have been challenged as being a breach of a trade mark. The system for protecting a trade mark in reference to domain names has been the same as it is in reference to any other medium- the aggrieved party has access to the courts where they must demonstrate certain legal requirements to obtain relief.

Obviously the problem of trade mark infringement will always be present in domain names, regardless of the number of gtlds in existence. To register the name pepsi.*** will always be an infringement and so the company will always be able to protect against that happening. Of much greater concern to trade mark holders is the proliferation of country code tlds as trade mark holders then must demonstrate ownership of a trade mark in the country in question which could involved companies in going to court in numerous jurisdictions around the world.

CORE has always recognised the importance of ensuring the protection of trade marks and for that reason has worked with the World Intellectual Property Organisation (WIPO) and arranged for them to perform as a body which could hear appeals from aggrieved parties in the new gtlds. Such a system would allow for companies to protect their rights in a much cheaper manner than is currently available, or than would be available in the Green Paper model. The Green Paper proposes that each monopolist Registry should institute its own system of trade mark dispute arbitration which would leave companies trying to deal with 5 different systems.

To repeat, the problem of trade mark infringement will always exist in domain names. Opening more than 5 gtlds will not adversely affect trade mark holders as there are already hundreds of country code tlds in operation. The Green Paper has focussed on protecting trade mark holders who currently hold domains in gtlds too much. There was little or no concern mentioned in the Green Paper for those trade mark holders who do not have an appropriate domain names because their name is already taken. Countless examples could be given of this but a useful one would be our own company, Capital Networks. A name like capital.*** could be rightfully claimed by many companies worldwide but only a couple were lucky enough to get one in a gtld (.com, .net). It can only be beneficial for commerce generally if new gtlds were opened, giving more people the chance to get an appropriate name in a gtld. While there are economic costs associated with Intellectual Property infringements (and CORE has always been mindful of this) there are massive costs associated with the unreasonable restriction of gtlds that exists now and would still exist under the Green Paper proposal.

Conclusion

The facts are that the Green Paper suits a small number of incumbents very well but its proposals are contrary to the interests of the Internet as the whole and contrary to the interests of economic efficiency. The winners from the Green Paper proposal are NSI (which maintains at least a portion of their monopoly), big corporations (which have already got the domain names they want), warehousers (whose investment is devalued less than it might be), large IT corporations (which may be able to get their own exclusive gtld) and the US Government which maintains de facto control over the internet due to the fact that its governing body (the new IANA) is set up according to its wishes and is run in the US under their scrutiny. The Green Paper is conscious of the fact that the internet was started in the US and received Government funding. The Paper ignores the facts that NSI was given a licence to extract a tax which is now thought to be illegal and that the fastest growing areas of the internet are overseas. 90% of the increased growth in NSI’s domain name registration business over the last year came from internet users outside the US.

CORE is a non-proft body made up of companies which reflect the reality of today’s internet rather than the internet of ten years ago. Among CORE members are companies from the USA (25), Germany (13), UK (9), Canada (6), Australia (4), Spain (4), Japan (3), Sweden (3), Switzerland (3), China (2), Taiwan (2), Italy (2), France (2), Israel (1), Denmark (1), South Africa (1), The Netherlands (1), Luxembourg (1), Singapore (1), Bahamas (1), Korea (1) and Mauritius (1). There are members ranging from very large companies to very small. It is an ideal environment for a competitive market place.

CORE was founded on an initiative supported by IANA who have long been trusted with safeguarding the stability of the internet. It is fully supported by IANA and the majority of the Internet community. CORE recognise that gtlds are a "public good" and that they must be administered in an appropriate manner. This is in stark contrast to the manner in which NSI have exploited the existing gtlds for its own benefit.

The most glaring difference between the model proposed in the Green Paper and the CORE model is that the Green Paper model relies on downstream competitive pressures (between registrars) to exert competition upon the upstream monopolists (registries). There are also additional problems associated with no domain name portability. CORE, on the other hand, relies on a classic model of a highly competitive market- a non-profit registry at the top with a large number of registrars at the bottom. Absolute domain name portability, fungibility and freedom to compete make this model a vastly superior competitive outcome.

###

From: Ed Sweeney <ed@capital.net.au>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 2:35am

my apologies. I forgot to mention that attachment is in Office (Word) 97
format.

Here is Capital Networks' (CORE Registrar) response to the Green Paper.

Regards,
Ed Sweeney

###

From: Karl Auerbach <karl@cavebear.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 2:57am
Subject: My comments on "Proposal To Improve Technical Management Of Internet Names and Addresses"

Here's my comments on the "Proposal To Improve Technical Management Of
Internet Names And Addresses"

I've attached the following:

- The comments in Microsoft Word 97 .doc format

- A .zip file containing the comments in HTML. This file
contains three files (all of which should be in the same directory
on the web server):
a) the main html file
b) a .jpg used as the background
b) a .gif used for bullets

- The comments in Adobe Portable Document Format (PDF)

Please let me know whether this came through without harm.

--karl--

###

From: "Davis, Sally" <sldavis@halldickler.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 3/9/98 9:33am
Subject: CASIE Response to Green Paper

Attached please find the response of the Coalition for Advertising
Supported Information and Entertainment ("CASIE") to the January 30,
1998 draft of the Green Paper. The document is formatted in WordPerfect
7.0.

Coalition for Advertising Supported Information and Entertainment

(CASIE)

Preliminary Comments on the Department of Commerce Discussion Draft Entitled "A Proposal to Improve Technical Management of Internet Names and Addresses"

(Discussion Draft Date 1/30/98)

To: U.S. Department of Commerce, NTIA/OIA, 14^th and Constitution Avenue, N.W., Washington, D.C. 20230 (dns@ntia.doc.gov).

From: Douglas J. Wood, Esq. (dwood@halldickler.com) and Sally L. Davis, Esq. (sldavis@halldickler.com), CASIE Legal Counsel, Hall Dickler Kent Friedman & Wood LLP, 909 Third Avenue, New York, NY 10022. Telephone: (212) 339-5400; Telecopy (212) 935-3121.

Introduction

This response is submitted on behalf of CASIE, a joint coalition of the Association of National Advertisers, Inc. ("ANA") and the American Association of Advertising Agencies ("AAAA"), two trade associations that collectively represent the most major players in the global advertising and advertising agency industries.

The ANA's membership is a cross-section of American industry and most of the major global marketers, including retailers, manufacturers, and service providers -- many of which are foreign-based corporations. The ANA has 229 corporate members and through them represents more than 7,400 separate advertising entities. The members of the ANA own some of the most valuable global and regional trademarks and "brands" in the world.

The AAAA is the largest association of advertising agencies in the world. The AAAA's agencies represent many of today's global marketers, both in the United States and throughout the world. As such, their interests and expertise are essential ingredients in the proper administration of the Internet.

As the Department of Commerce is aware from CASIE's previous submission, CASIE's purpose is to foster the growth of marketing and advertising on the Internet.

CASIE recognizes the complexities of the issues addressed by the Department of Commerce in its Green Paper and applauds the Department's efforts to encourage stable, pro-competitive growth of this new medium. Many aspects of the proposal in the Green Paper could successfully achieve these goals. CASIE appreciates the opportunity to participate in the discussion about the future of the Internet and thanks the Department for its consideration of these comments.

Overview

Overall, the Green Paper is a positive step forward. Namely, it: (1) relieves the immediate fear of uncontrolled change when Network Solutions, Inc.'s contract expires in March, 1998; (2) supports the concept of open competition at some levels of the administration of the Internet; (3) recognizes the significant concerns of trademark owners over the proliferation of new gTLDs; (4) agrees that there must be a domain name dispute resolution process as an adjunct to local courts; and (5) ushers out the oversight of the Internet by the U.S. government.

Unfortunately, however, the overall plan also: (1) leaves intact monopoly ownership of gTLDs (at least for two years), thereby hampering true domain name portability; (2) fails to adequately address the lack of a centralized and efficient domain name dispute resolution process for trademark owners; and (3) may have the unintended result of creating the very chaos in domain name dispute resolution that the entire debate has hoped to avoid.

Comments

1. Portability and Competition

Under the proposal, monopoly at the Registry level remains intact, at least for the next two years. Each in the first group of Registries will have only one of the new gTLDs. NSI will presumably retain its monopoly on .com, .org, and .net gTLDs. Unless there is clear agreement that NSI eventually will transition its monopoly as a Registry of its gTLDs and that the five original new Registries will administer all of the gTLDs on a shared basis, a truly competitive playing field will not have been created.
If the Registries do not share the gTLDs among one another, an Internet user who becomes dissatisfied with a particular Registry, regardless of who its Registrar is, will have to change its domain name if it wants to move. It is unclear in the Green Paper how this problem will be solved. Clearly, however, at least during the transition period, the problem remains.
The decentralized dispute resolution proposal (discussed in greater detail below) is a good example of how a trademark owner could become dissatisfied with a Registry if its procedures do not prove responsive to trademark rights, prompting the trademark owner to want to move to a different Registry with more favorable dispute resolution policies. Doing so, however, would require a change in the gTLD, thus defeating the whole concept of portability.
The process for selection of the five new gTLDs is left to the new corporation. The determination of the names for the new gTLDs will significantly impact the strength of the monopolies enjoyed by the new Registries and will directly impact the competition at both the Registry and Registrar levels. For example, if the new gTLDs are very industry specific, e.g., .arts, .retail, .air, and do not include "general" descriptors, e.g., .firm, .inc., .corp, the singular value of .com remains paramount to commercial users and strengthens NSI's monopoly. It is, therefore, critical to determine what the new gTLDs will be and the philosophy that should be applied in that determination.

2. Dispute Resolution -- Main Report

On page 8 of the Green Paper, the proposal states, "We also do not propose to establish a monolithic trademark dispute resolution process at this time, because it is unclear what system would work best.... Therefore, we propose that each name registry must establish minimum dispute resolution and other procedures related to trademark considerations."

CASIE's concern with a patchwork approach is that it may exacerbate the trademark owner's dilemma caused by the "global" nature of the Internet, the conflict among trademark laws in different countries and a lack of any centralized, efficient mechanism to resolve disputes. Without centralizing and harmonizing the dispute resolution process, trademark owners will face substantial expenses in policing their marks. CASIE believes that the new corporation, working with the six initial Registries, could adopt a unified process. While competition is a laudable goal for many aspects of the Internet, it can only lead to further inconsistencies and confusion in the domain name dispute resolution process.

Positives:

The Green Paper suggests that a registrant will have to agree on a jurisdiction whose laws will govern resolution of domain name disputes on the basis of, e.g., where the Registry is domiciled, where the Registry's database is maintained, or where the "A" root server is located.

Concerns:

Dispute resolution is decentralized and apparently determined by each individual Registry (subject to minimums established in the Appendix). Thus, there could be six different procedures (NSI's and those individually adopted by the five new Registries). This creates a shopping forum for would-be infringers, cybersquatters, and hijackers to use the Registry that least protects trademarks.
The Green Paper asks for comments on the need for a mechanism for clearing famous marks across a range of gTLDs. With all due respect, the issue has been debated fully and fiercely for the last two years and it is hard to imagine any comments that would add substance to those already made concerning this issue. In short, CASIE believes owners of famous marks must have the ability to consistently and efficiently protect strong and famous marks throughout all of the relevant gTLDs. This need is intensified if additional gTLDs are introduced.

3. Dispute Resolution -- Appendix 2

Positives:

Paragraphs 1 and 3. Detailed information on the registrant and an affirmation of its rights to the SLD are positive recommendations consistent with CASIE's previous comments to the Department, Congress and the Policy Oversight Committee. What might be added, however, is a requirement that a registrant use the gTLD within a minimum period of time or otherwise lose it. This policy will help prevent warehousing.
Paragraph 2. The requirement of a "more robust and flexible search tool," as urged from the inception by CASIE and others, and the criticism of NSI's present "Whois" searchable database is welcomed. It has been CASIE's consistent position that well engineered and designed directories and search engines would solve many of the problems earlier and, as a result, more economically.

Paragraph 4.1. CASIE supports the notion that any dispute resolution system should not involve the Registrars.

Concerns:

Paragraph 4.2. This paragraph leaves two issues unresolved:
While there is recognition that trademark owners will have to resort to courts, the purpose of an alternate dispute resolution system is to avoid courts. Trademark laws among various countries are simply too diverse to expect competition to solve the problem. Moreover, it is questionable that any true resort to local courts could remain under these circumstances. For example, how could a foreign court's decision regarding one Registry bind a Registry based in another jurisdiction?
The proposal states that, "Registries/Registrars will abide by the decisions resulting from an agreed upon dispute resolution process..." This statement raises critical questions for the owner of a famous trademark. If Registry A adopts a dispute resolution process that recognizes famous trademarks as unavailable within SLDs except when used by the trademark owner, will the other Registries be bound by a ruling within their administered gTLD? Thus, if The Coca-Cola Company rightfully establishes its exclusive rights in .com to all variations of "coca-cola" via NSI's to-be-adopted dispute resolution process, will that ruling be binding upon the .firm Registry (assuming .firm is one of the new gTLDs)? Furthermore, how will inconsistencies between dispute resolution processes be resolved if each Registry is bound by the decisions of the other Registries' dispute resolution processes?
Paragraph 4.3. This provision for automatic suspension of a domain name upon challenge adopts a proposal that has been roundly criticized by many sectors of the Internet community, including CASIE. Nothing should be automatic. Anyone trying to suspend a registration should have to meet certain minimum legal standards, object within a restricted period of time, and, where appropriate, post a bond of sufficient amount to thwart would-be reverse domain name hijackers.

3. Governance

CASIE supports the idea of a non-profit corporation proposed in the Green Paper. It is important to further explain how the fifteen members of the Board will be identified, screened, and chosen, particularly, from CASIE's perspective, since only five of the members come from the commercial sector, a sector far more diverse than any other and spread throughout the world. In addition, the next draft of the Green Paper should address the terms members would serve and what rotation would occur.
CASIE supports the proposal on page 5 that the new corporation be headquartered in the United States and incorporated under U.S. law.
The Green Paper rejects the notion that the Board of Directors of the new corporation should include inter-governmental organizations. It is not clear to CASIE why such a restriction is necessary without further discussion and would appreciate if the next draft could explain the reasons for this conclusion

Conclusion

The comments included in this submission reflect CASIE's preliminary review of the Green Paper. As the debate progresses, CASIE intends to submit further comments as warranted. Again, CASIE thanks the Department for this opportunity to comment.

###

From: Jacques <bernier@mediafusion.ca>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 11:58am
Subject: Mediafusion's response on the Green Paper

To: IRA MAGAZINER
DEPARTMENT OF COMMERCE
U.S. GOVERNMENT
WASHINGTON, D.C.

Dear Ira Magaziner:

Being one of the 87 Registrars of the CORE, Mediafusion is greatly
interested and concerned about the US Department of Commerce Green Paper
that consists of "A proposal to improve technical management of Internet
names and addresses". The US draft states that the DNS should be
administered by a number of Registries having each the specific mandate
to control one assigned gTLD. Mediafusion, like all members of the CORE,
strongly argues and believes that this US proposal would not solve the
real issue of the problem, being the monopolistic and administrative
upper hand of the American Government on the major root servers of the
Internet. Presently, NSI controls the DNS for the main gTLD's (.com,
.org, .net), moulded and structured exclusively for the American
enterprises. This not only favours the latter but reduces considerably
the chances for the 30% Internet users outside of the United States to
obtain an equivalent French and Spanish version of Internic's
Registration System. Considering these realistical facts mentioned above,
not to mention it's inaccuracy with Internet's international mandate, The
gTLD-MoU seriously believes that the DNS should be administered by one
stable, transparent, international and not-for-profit Registry. This
would allow a shared database as well as a competitive realm and low cost
maintenance among the Registrars.

THE gTLD-MoU INITIATIVE

Realizing that the Internet Society represents the most important
international community in the means of communications today and
understanding that the Internet community does not belong to one entity
but to the whole world, it is urgent that the administrative and
technical functions of the new DNS be conducted in the same manner. The
CORE/gTLD-MoU's initiative is to bring forward an international
organization based on self-governance and effective representation of all
stakeholders that would manage the DNS and root servers of the Internet
community. This reform is urgent considering the fact that considerable
technological initiatives have been brought forward from researchers
outside of the United States: the World Wide Web was primarily conceived
in Switzerland and the W3 Consortium is not only based in the United
States but in Europe and Japan as well. It is important to note that the
Internet users outside of the US are increasing rapidly. Approval of CORE
propositions would then allow a more global and coordinated approach to
the governance and administrative structures of the Internet.

Moreover, CORE stresses the importance of a competitive free market among
the Registrars for the administration of Top Level Domain Names and the
registration of the new Domain Names. Mediafusion and CORE strongly
believe that the US proposal based on competition among Registries would
only weigh down on the Registrars regarding the establishment of
different database interfaces, rising cost of implementation and
complications related to global operations on trademark management. In
regards to that effect, the CORE/ gTLD-MoU proposes a solution concerning
the trademark litigation procedures. WIPO, worldly renowned and
responsible for international Intellectual Property protection and
management, is recognized by the gTLD-MoU as the Mediator and Arbiter for
any trademark dispute concerning the Internet Domain Names. Through their
model for trademark litigation and arbitration (ACP), WIPO has
established a framework and process for litigation resolution. The Green
Paper broadly expressed its view points concerning the trademark
litigation procedures, presently too long and complex. Furthermore, the
draft has promoted local laws instead of an international law which would
be much more appropriate and compatible with the true essence of the
Internet. Unfortunately, these well-established gTLD-MoU propositions
have not been mentioned or taken into account by the Green Paper.

Finally, the new international bodied system should be based on
stability, competition, coordination and representation. Mediafusion
finds it quintessential that these allegations brought forward by CORE be
taken seriously by the US Government. Mediafusion strongly supports the
CORE/gTLD-MoU's initiative to better respect and serve the world wide
users of the Internet.

Jacques Bernier
Mediafusion Inc.
bernier@mediafusion.ca

###

From: "Tim Howell" <timothy.r.howell@boeing.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 12:10pm
Subject: Attention: Ira Magaziner

Re: Discussion Draft,

Keep politics out of commerce, freedom of speech, and the exchange of knowledge. Give the little guy a chance and push on with the new domain names.

###

From: The Avanti Group <info@avantigroup.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 12:43pm
Subject: domain name policies

Dear Madam/Sirs:

The February issue of EC.COM Magazine shows that you are suggesting ways to
improve the DNS process. The purpose of this email is to share a brief
encounter with InterNic that I think you'll find of value.

As you are aware, InterNic only respects the Admin contact. In November of
1995 our president violated his fiduciary responsibilities and registered a
domain using himself as admin contact and our company as billing. One
month later, he resigned. When our two year renewal notice came due, we
were horrified to learn that InterNic would not recognize Avanti as owner
of the domain - in effect they willingly supported a thief (former
president). Furthermore, when we ask to receive our $50 renewal fee
returned, they refused - in effect they stole from us - by taking our money
and not delivering.

After seven facsimiles and several unanswered phone calls, we determined
that our government has enabled InterNic to be arrogant and unresponsive.
As to our former president, we are a small company without funds to fight
such a battle.

Nobody said life was supposed to be fair - but we hope that your
recommendations somehow tilt the scales in that direction.

Truly - Chuck Scott
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--------------------------------------------

###

From: <DKnowles@po.asm-intl.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 4:10pm
Subject: gTLD-MoU

I support the gTLD-MoU and urge you to also.

W. Douglas Knowles, Ph.D.
Director, Information Systems & Technology Planning
ASM International, Materials Park, Ohio 44073 USA
DKnowles@po.asm-intl.org; (440)338-5151; Fax (440)338-4634
http://www.asm-intl.org/ My opinions, not ASM's.

###

From: "bedlamite" <bedlam@gte.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 4:17pm
Subject: the internet

please mister government man, stay out of the internet's business...why as soon as someone makes it...the government is so bent on controling them....feeding off of them...any intention by the government to regulate the internet is purely...motivated...by...a need to get a piece...you exepct us (the people) to treat you guys like some well oiled machine (ha,i wish) too many people treat the governmemt as tho there we no real people in it...real people being so easily motivated by there own agendas...yr all a bunch of febile minded dinosaurs...and we believe yr time has passed...yr inabilty to regulate the internet is all the evidence you should need to see,that the america that those rich landowner's stole from the locals....is dead...protect us...don't control us...it's yr job ya know...i pay you to do it...

ben hamilton
disgrunteled VOTER and internet user

###

From: Paul Happ <yhp@sover.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 4:24pm
Subject: Comments (Word 97 SR-1)

I have read the draft and a random sampling of responses. I was heartened
to see responses that agree with my opinion: Do not break a working system
that only needs a little tuning.

I was surprised in that I felt the draft suggested consensus or a majority
of responses in favor of competition. I trust you have used some method of
tabulating and classifying responses that proves more accurate than my
random sampling.

I have provided Internet based sales and marketing service to approximately
30 clients since early 1995. In that time, not only have I not experienced
problems in registering domain names, but I am truly impressed with, am
completely confident in, and happy with how well the system, as
administered by Internic, works. This is particularly true in light of
recent automation and improvements of their registration and renewal system.

Generally, I believe in less government and capitalism and free-markets.
However, domain registration is one case where I am very much against using
the free-market and opening it to competition. I would much rather see
InterNic continue to provide registration services, and perhaps adding or
changing them into a new non or quasi-governmental, not-for-profit
organization that would answer to your proposed representative,
not-for-profit corporation.

I would have to assume that those crying loudest for competition are those
who would wish to profit. Simply speaking, the goal of these entities and
individuals is to make money. There is nothing wrong with that.
Nevertheless, it is much more appropriate to such an important and
far-reaching system as the registry and registrar process to have it in
managed by an entity whose goal it is to manage the registry and registrar
process. I believe the DNS is one of those areas where a quasi-governmental
agency would be best.

The system is too important and too inter-connected to allow economic
Darwinism to operate. I really can do without the hassle, aggravation and
monetary loss that would entail if my registrar or registry turned out to
be incompetent or simply decided they weren't making enough money and got
out of the business. This is most decidedly an area where we DO NOT want
for-profit entities to be in charge.

Instead of risking breaking a system, that for me has worked extremely
well, I would much rather see it tuned. I have experienced some problems
and fully agree there are areas in need of improvement, particularly TLD's
and trademarks.

I would like to see the addition of the proposed TLD's. I think this will
help organize the Internet. I would also like to see a much more clearly
defined policy and resolution plan for trademark disputes.

In closing let me restate that I would strongly oppose opening the registry
or registrar functions to competition.

###

From: Rick Tuinenburg <webmaster@csg-i.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 4:43pm
Subject: Internet DNS

Please let the private sector handle domain registration, I truly think
our market place will find the best providers to handle DNS needs. Lets
not get the federal government involved in such issues. The Federal
Government has already delay our new DNS system long enough, the people
on the Internet need more names that is the bottom line. We need a
efficient system that can deliver that to us the people.

Thank you,
----------------------------------------------------------------------
Rick Tuinenburg WWW: http://www.csg-i.com
Web Master mailto:rtuinenburg@csg-i.com
CSG Interactive LLC
180 E. Main Street, Suite 120 Phone: (714) 573-2900
Tustin, Ca. 92780 FAX: (714) 573-2160
----------------------------------------------------------------------
"I think the future of free software will increasingly belong to people
who know how to play Linus's game, people who leave behind the
cathedral and embrace the bazaar." - Eric S. Raymond

###

From: "Scott G. White" <sgwhite@paranet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 5:25pm
Subject: Domain Names

In regard to the green paper recently released,

I have been working with the Internet since the early 80's. Presently,
I am opposed to an extensive polical infrastructure being deployed
into the internet. Its a very complex system and weighing its management
down with multiple organizations is very foolish.

Thank you,
Scott White
Sr. Technical Analyst
Sprint Paranet

###

From: "Paul Stahura" <stahura@enom.com>
To: Larry Irving
Date: 3/1/98 10:07pm
Subject: Domain Names

Dear Mr. Irving,

The internet name space is much like the electromagnetic spectrum.

Your group must have also thought of this analogy,
which is why I'm having a hard time understanding why the
Green Paper proposes an exclusive registry system.

As you know, companies own chunks of the EM spectrum,
but *nobody* owns the *visible* part of the spectrum.
This part is shared. The visible part of the spectrum is the part that
we all commonly use most of the time. This part of the EM spectrum is
like the generic TLD part of the name-space and,
radio frequencies are like the country-code TLD
part of the name-space. There is an infinite number of colors,
just like there is an infinite number of generic names.
Just like generic TLDs, some colors are "better" or
more useful than others (i.e.: "red" vs. ".web", "blue" vs ".biz",
or "cyan" vs ".nom", "magenta" vs ".rec", and "puke-green" vs ".puke")

The green paper, via 5 exclusive registries,
will grant an entity ownership of the
equivalent of the color "red", another entity "white",
and another "blue", etc.
Colors are so common (generic) that it would be completely
ludicrous for a government (ours or some other government)
to grant the "green" concession to someone.
Someone who would like to have something emit the color green
(a potential "green" user, who may want to plant grass, for example)
would have to pay a fee to the "green" concession holder.

Would there be competition among color concession holders?
Does red substitute for blue? Imagine this: our flag might have been
red, white, and red, because blue was too expensive!

This, in effect, is what the discussion draft proposes.

Having one person own "green", another own "red" and
another own "mauve" does not increase competition among
them or provide efficiencies or diversity to color users.
The color concession holder cannot add value by changing
the perception of the color (i.e. he cannot change "puke-green"
to give the same emotional response or meaning as "hot-pink").
The concession holder only provides access to the owned color.
The same is true with the gTLD conecession holder: the
registry only provides access to the owned TLD.

Even the most uninformed netizen can understand the
implications of someone owning the color "blue".
This "exclusive ownership" flaw (under the guise of competition!)
in the proposal is so glaring, it reduces the credibility of the rest of it.

What is the motivation for having an exclusive ownership model?

Please support a single, shared, open, non-profit, registry for the
generic part of the name-space.
The CORE shared registry is the best alternative.

I am available if you (or someone you designate)
wish to communicate with me further regarding this subject.

Thanks for your time in reading this plea.

Sincerely,

Paul Stahura
eNom, Inc.
stahura@enom.com
Redmond, WA
425-558-4887

###

From: "Niall McDonough" <mac16@globalnet.co.uk>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 9:22am
Subject: Domain names

I am very pleased to see that the US government actually values the
opinions of net users by asking them for their opinions over the future
of domain names - it obviously in safe hands. But the problems I see
with the proposed new TLDs are that they aren't well classified - thus
leaving them open to confusion, for example, what is the difference
between .firm and .shop. Also, the idea that a web site has to decide
between .rec, .arts, and .info may be akward in some cases as a lot of
sites combine all of these three factors. So, since the proposals aren't
definite yet, I would like to put forward a few of my own thoughts.

1) Sadly, with the growth of the internet, the pornography industry has
flourished too. And it is very easy for somone to do a search and to
stumble upon offensive material. This may be a daft idea, but would it
be possible to designat a .sex, or .adult (which could be abbreviated to
.adul, .adl, .adt) domain name which would make the lives of censorship
software producers much easier, and improve society generally because
less people would accidentally visit them. By categorising these sites
together they would be easier to avoid, easier to monitor, and better
regulated.

2) Possibly the greatest point of the internet is that everybody has a
voice - the meer fact that the US goverment is allowing people to speak
over the introduction of TLDs is a resounding success. More and more
sites are springing up the concern social issues from the KKK to
Greenpeace - but to classify them under .org itself reduces the number
of people willing to visit them (we all know that .org is the black
sheep of TLDs). I think that .info won't cover social issue sites, nor
.rec, but a .soc would be better suited. Yet again, this is very clear
and precise, and will benefit those who use a .soc domain nam

3) Another view of mine is that too much emphasis is placed on big
'amoral' corporate fims who seem to rule the rest of us. Now if the
plans of .firm is joined to .com (and I presume .shop will only be used
for internet shopping), it would become confusing as the difference
between the two is not clear. Why don't we set up .plc for public
limited companies and .ltd for limited companies. This would not only
lead to more protection for small firms, but to a better playing field
to advertise. These domain names would lead to a relaxing of the overuse
of .com where everybody wants a piece of the market whether .com suits
thier purpose or not.

I hope that these three points I have brought up aren't completely
useless, and maybe will be considered in the plans to set up new TLDs -
especiall the .soc and .adult registrations. Cheers very much for
creating an environment where people's views are at least considered.

Niall McDonough (mac16@globalnet.co.uk)

###

From: MKKavana <MKKavana@aol.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 7:58pm
Subject: Re: TLDs

I Hereby request,
that the U.S. government fully endorse the gTLD-MoU, the Policy Oversight
Committee's plan to roll out 7 new top level domains. The CORE solution is a
well thought out plan that is available today that would serve as a great
first-
step in the government's transition out of Internet domain name management. I
would like to see the government endorse this plan during the
"transition" phase to complete privatization of the Internet. Thank you.
Mark Kavana
Kavatech Corporation

###

From: "Luke A. Stedman" <stedman@nixonfoundation.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 8:02pm

I would simply like to say that we are interested in seeing the seven new
top level domains roled out!

Luke Stedman
The Richard Nixon Library & Birthplace Foundation

###

From: Adoption Online Connection <crc@adoptiononline.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 9:39pm

Hello,

I am a small business owner with his ENTIRE business based on the Internet, I have a big stake in seeing the CORE internet domain system become operational. The system seems fair, and in this global economy in which the US is a member, we should not let one governemnt or entity control access for homesteaders like me.

I have staked the future of my company on the new GTLD's, as have many others. I respectfully request that the U.S. government fully endorse the gTLD-MoU, the Policy Oversight

Committee's plan to roll out 7 new top level domains. The CORE solution is a
well thought out plan that is available today that would serve as a great first-
step in the government's transition out of Internet domain name management. I would like to see the government endorse this plan during the
"transition" phase to complete privatization of the Internet, or as a permanent solution.

Sincerely,

Charles Chidekel

Owner, President

Adoption Online Connection

==========================================================

<color><param>8080,8080,0000</param><bigger>Adoption</bigger></color><bigger>
<color><param>8080,0000,8080</param>Online</color> <color><param>0000,8080,8080</param>Connection</color> http://www.adoptiononline.com

</bigger>The World's <bold><color><param>ffff,0000,0000</param>FIRST</color></bold> and most successful Internet registry that
helps prospective adoptive families and birthmothers meet.

###