### Number: 1 From: Brian Kitchen mr_b@cyberdude.com To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 1:06am Subject: internet domain registration In my Humble opinion, we( internet users) as a group must somehow solve this dilemma. I would like to see ALL x-rated stuff in it's own domain, thank you very much. The internet does now and should reflect real society. We know where the "red light districts" are and we can choose to go or not. Thanks to the first amendment, we are free to speak our minds. But lets do something about the domains and access. Would it not seem easy to somehow classify areas without restricting free speech. As the internet grows, more domains are needed so why not have .xxx ? There has to be a way to control this. I don't mind xxx when I WANT xxx. I really mind searching on hotbot for free and getting a xxx reference in the 31st position. This is bullshit. Regulation of one sort is inevitable. Let's hope for the sake of us all that for the first time in history we the people...on a global scale...can regulate ourselves without a governing body screwing it up. Some independent organization should be set-up, voted on over the internet, (digital certificates)to deal with domains and new domains. This will be a very powerful organization and I.M.H.O. the best way to protect the public would be a democratic body based on the American Bill of Rights, accountable to internet users and the general public. Thanks for the soapbox Brian Kitchen a.k.a. mr_b@cyberdude -- mr_b's CyberWorld http://www.telusplanet.net/public/mr_b http://www.adgrafix.com/info/bkitchen/ http://www.beevy.com/card_search/usa?89-1314 ### Number: 2 From: christopher post cp15@cornell.edu To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 1:07am Subject: Internet Domains Hi!, I am resonding to the request for comment on the internet naming debate. I feel that the adhoc committee has done an excellent job of designing a system to increase the number of top level domains available. Although the new naming system was not developed by a government entity, it was developed with the future of the internet in mind. Sincerely, Christopher Post Graduate Student, Cornell Unversity, 503 Bradfield Hall, Ithaca NY 14853 cp15@cornell.edu ### Number: 3 From: Victor Gavin Victor.Gavin@unilever.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 8:12am Subject: My suggestions for resolving the DNS issues. Hi. Comment #1 ------------- I believe that there should be no special Top Level Domains (as there are at the moment e.g. .com or .uk) handled by a special agency. Instead, I suggest is that anybody should be able to register a Top Level Domain and that the registration process should be handled similarly to patents. The registration would be handled by an international committee with national sub-committes who would vet applications before authorising their creation. There should be a legal obligation on registree's to research ownership of a name before it can be used. Once registered, the owner would/should not be held liable for trademark infringements within the domain. What I mean by that is that sub-domains should be able to incorporate trademarks (accidental or deliberately) without fear of legal proceedings. The rationale behind this is that a domain name is to all intents and purpose an address, and corporations can't sue for damages just because their trademark is used in a street address in another country - e.g. 128 McDonalds Drive, Kirkintillock, Scotland. vic ### Number: 4 From: STriker RedWolf/Kelly Price kprice@physics.umd.edu> To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 10:07am Subject: Input on new domain names At this time, the use of domain names is proliferating wildly, becoming a kaos into itself. I propose the logical organization of those domain names. To illustrate my point, I will theoretically "create" a few names in this mail alone: strlabs.com - a standard company amazonpark.org - for Amazon International Park (saving the Amazon. "We breath for the world") amongus.com - ISP umd.edu - yes, University of Maryland, College Park. Now for the organization of .edu, .org, .com, .net, et al. .edu will always be for educational associations. (umd.edu stays) .net will be reserved to, and should be exlusive for, ISPs. No ISP should have a .com unless it provides another function (strlabs.com would still be stlabs.com, as it's a standard company, but amongus.com would have to be named amongus.net) .org will be for non-profit organizations. amazonpark.org stays the same. Companies would be moved out. In the event that this continues to be "a mess," the below organization may be enacted (so amazonpark.org would become amazon.park.org) .com will be reorganized: News organizations would be moved from .com to .news.com. Therefore, abcnews.com and msnbc.com would become abcnews.news.com (or maybe abc.news.com) while msnbc.com would be stuck with msnbc.news.com. C|Net's news.com would have to be renamed cnet.news.com. Television stations, networks, and shows would be moved to .tv.com. Therefore, cbs.com and local wjz.com would be moved to cbs.tv.com and wjz.tv.com (or wjz.md.tv.com, since it is local). Movies should be moved to .movies.com in similar fashion. batman.com would be batman.movies.com. Similar organizations can be made, like that of the popular web page index "Yahoo". Therefore... strlabs.com may become strlabs.sci.com, depending on it's goals. amazonpark.org may stay the same or use amazon.park.org amongus.com would be forced to become amongus.net umd.edu will always be umd.edu Hopefully, some logical, sensible reorganization of names would only be required for to fix, or delay, this problem. -- p |\ _,,,---,,_ Kelly "STriker" Price -Spiritual Polymorph u /,`.-'`' -. ;-;;,_ http://www.furnation.com/striker r |,4- ) )-,_..;\ ( `'-' Not offical word of AITS/UMCP. Junk Mail r '---''(_/--' `-'\_) fL fined. Never wake sleeping physics majors. ### Number: 5 From: Edwin Hayward info@igoldrush.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 10:08am Subject: Response to Request for Comments on new gTLDs Sirs, Please find attached my response to your RFC on the proposal to extend the current gTLD administration system. The response is in Word 97 format. Edwin Hayward Response to Request for Comments on the Registration and Administration of Internet Domain Names Basis for response: Owner and operator of Internet Gold-Rush [www.igoldrush.com], the Internetfs #1 collection of domain name news and information. Author: Edwin Hayward Date: July 1st, 1997 A. Appropriate Principles The Government seeks comment on the principles by which it should evaluate proposals for the registration and administration of Internet domain names. Are the following principles appropriate? Are they complete? If not, how should they be revised? How might such principles best be fostered? a. Competition in and expansion of the domain name registration system should be encouraged. Conflicting domains, systems, and registries should not be permitted to jeopardize the interoperation of the Internet, however. The addressing scheme should not prevent any user from connecting to any other site. It is important to define what exactly the term gcompetitionh refers to in this context. gCompetitionh could be considered as market forces that combine to bring about conditions in which the cost of administering domain names decreases. gCompetitionh could also be considered in terms of groups and individuals competing for a limited number of domain names. It is essential that the proposal that is adopted is accepted by 100% of the Internet community worldwide. In essence, the .com, .net and .org domains are excellent examples of such acceptance. b. The private sector, with input from governments, should develop stable, consensus- based self-governing mechanisms for domain name registration and management that adequately defines responsibilities and maintains accountability. The problem here is that different elements of the private sector have conflicting interests. For instance, companies that have invested heavily in their domain name [such as Mecklermediafs recent purchase of internet.com for a sum reported to be in excess of $100,000] and companies that have invested a lot of time and money in promoting their domain name [such as the major search engines and companies such as Microsoft and Netscape] have no interest in expanding the domain name system, as this would dilute the value and perception of their domain names. Similarly, companies that make a living from domain names, such as domain name registries [several hundred companies], vanity mail services and domain name brokers have no interest in changing the existing status quo. Individuals and organizations who have invested in domain names, either for current use or future deployment, will not wish the existing domain name system to be expanded. For all the above reasons, reaching a full consensus may prove impossible. c. These self-governance mechanisms should recognize the inherently global nature of the Internet and be able to evolve as necessary over time Correct. I am concerned about the repeated mention of the role of the US Government in this process of revising the domain name system. The US represents an ever-shrinking portion of the global Internet, and any agreement reached in defiance of the will of the international community will be bitterly opposed at best and unenforcible at worst. d. The overall framework for accommodating competition should be open, robust, efficient, and fair These four conditions are irreconcilable. Any truly fair proposal that takes full account of the intellectual rights of trademark holders will not be efficient. Any proposal that does not take full account of such rights will not be fair. This should be redrafted to reflect a best case balance between the four conditions outlined above. e. The overall policy framework as well as name allocation and management mechanisms should promote prompt, fair, and efficient resolution of conflicts, including conflicts over proprietary rights. Yes. Such conflicts must be resolved on a global, rather than national scale. f. A framework should be adopted as quickly as prudent consideration of these issues permits. There is no hurry to modify the current system. Domain names are only running out because of a combination of two things: market forces in the secondary market for domain names, and a failure of the imagination on the part of companies and individuals involved. As I recently explained to Inter@ctive Week, there are an astonishing number of domain names still available in the .net and .org hierarchies. The rules surrounding these domains have recently been relaxed and effectively anyone can register domain names under .org and .net. A further tightening of the rules surrounding speculative domain name purchases, together with a more robust system for looking up domain names will prove perfectly adequate to meet the current demand for domain names. B. General/Organizational Framework Issues 1. What are the advantages and disadvantages of current domain name registration systems? The advantage of the current system of domain name registration is that it is relatively inexpensive and open to anyone at an individual or corporate level. The disadvantage of the current system of domain name registration is that it is shrouded in too much mystique for the average Internet user to fully understand the process behind such a registration. This enables unscrupulous companies to charge usurious fees [$250 to $1000+] for very limited services provided when registering domain names on behalf of clients. 2. How might current domain name systems be improved? The process of domain name registration should be fully documented in less technical terms. The central domain name registry should provide name server services for all domain names it issues. This removes the onus on domain name registries and web hosting companies to provide DNS services, and protects the rights of the domain name holder [There have been numerous cases of DNS abuse; either the company providing the DNS services has refused to change the IP address that a domain name points to, or it has pointed the domain name at its own site] Ideally, the central registry or registries should provide the following minimum services:- A) Simple form-based registration process B) DNS services for the domain name included in the maintenance price for the name C) A mechanism for automating or partially automating the process of submitting intellectual property information in support of a domain name claim The way to solve the shortage of domain names is very simple. Implementation of the following procedures will free up needed domain names and ensure that an adequate supply will be available for the future:- A) Increase the fee for retaining domain names from $50 to $100 per year, effective from the renewal date for current domain names. This serves to discourage speculators. B) Implement a system in which money is demanded up front, rather than the current system in which a grace period of up to 90 days makes it easy for speculation to take place. This has a number of advantages: a guaranteed cash-flow in exchange for the provision of domain names; reduced administration costs [no longer any requirement to send out reminders for individuals and organizations that have failed to meet the deadline for invoice payment]; reduction in domain name speculation [speculation is less attractive when the money must be paid up front] C) Rolling renewal system in which a reminder is sent 8 weeks before the current term of domain name ownership expires. If payment has not been received by the expiry date [a second reminder is issued at 4 weeks] then the domain name immediately defaults and is put back into the pool of available names. D) A more comprehensive method of dealing with domain name disputes, and one which does not penalize the owner of the name from the start, but only removes the right to the given name at the end of the process. E) A clearer explanation of where funds raised by the domain name process will be distributed and used. Mechanisms to ensure that this money is actually used in practice for the stated purpose [more public accountability] F) Open up the .org and .net domain names fully, so that they have the same status as .com G) In conjunction with F), give control of .org and .net to two separate organizations, forming a triumvirate of registrars with the organization chosen to continue the administration of the .com domain name. The above 7 steps will be adequate to solve the problem of the shortage of domain names. They will also be less costly and less difficult to administer than any proposal that involves expanding the number of top level domains. 5. Should generic top level domains (gTLDs), (e.g., .com), be retired from circulation? Should geographic or country codes (e.g., .US) be required? If so, what should happen to the .com registry? Are gTLD management issues separable from questions about International Standards Organization (ISO) country code domains? Quite frankly, that is the most preposterous suggestion I have read for a very long time. There are over 1,000,000 .com domain names in circulation, most of them paid for. This means that there are as many as 1,000,000 potential lawsuits over the loss of .com names. In addition, .com has become firmly ingrained in the publicfs consciousness as the gconventionalh form of an Internet site address. Domain names appear as part of site addresses in a wide range of situations, from advertisements in trade magazines to indications at the foot of posters and even in television advertisements. .us is a good idea. The US is one of the few countries that does not fully regulate its domain name system. The .com registry can remain in its present form, a completely global registry not subject to localized rules and regulations. The .net and .org domains should be further promoted and opened up, potentially nearly tripling the number of domain names available. In addition, a process should be instigated to regulate the .us domain, or a new alternative to the .us domain, along the lines of the .uk domain in the UK. There, the central registry demands various forms of proof that the registrar is a genuine company, including the companyfs deposition at Companies House in London. A similar system for the .us top domain would ensure that its use be limited to companies. This will easily solve much of the congestion around existing domain names, which are mainly being bought up by speculators and investors. 6. Are there any technological solutions to current domain name registration issues? Are there any issues concerning the relationship of registrars and gTLDs with root servers? Yes. They should be one and the same. The registrars should be sub-contracted by the organization running the root servers. Only one set of root servers should be sanctioned at the international level, and the money to pay for the upkeep of these root servers should come from part of the funds collected to pay for the domain names. This prevents the ludicrous farce that has been perpetrated recently around the attempts of the eDNS coalition and AlterNIC to form their own alternate domain name system. AlterNIC pulled its support for eDNS, and its name servers, meaning that the eDNS domain names were effectively rendered worthless. No company or organization should be allowed to exert that kind of control over another. 8. How should the transition to any new systems be accomplished? In two stages. First, disseminate clear, simple details about the new system after it has been finalized. Ensure that members of the Internet public have a chance to consider and understand the implications of the new system before it is put into practice. Second, refuse all applications for new domain names until a random interval of several days or weeks has elapsed. This eliminates much of the stress that would be put on the new system by domain registration companies queuing up gpre-registrationsh ready to fire at the central registryfs computers as soon as the new domain names become available. Also, implement a system to restrict the number of domain name purchases through any one organization to a low number, say 100 a week, for an initial gteethingh period of a few weeks or months to effectively curb any potential for a wave of speculation in the new domain names. C. Creation of New gTLDs 10. Are there technical, practical, and/or policy considerations that constrain the total number of different gTLDs that can be created? Yes. The intellectual property disputes surrounding a case such as parallel registration of gibm.comh and gibm.neth by two different organizations pale into insignificance next to the problems that might arise if a single company can purchase a g.ibmh address. Thus, any proposals that effectively allow an unlimited number of top domains, such as PGPMediafs name.space plan, should be blocked immediately. There is also the problem of perception. Domain names are only useful as long as they are memorable. They serve as mnemonics in place of IP addresses. If the domain naming system is unduly complicated to the point of having several dozen possible top domains, it will be extremely difficult for individuals to easily remember internet addresses. Some people already get confused between XYZ.com and XYZ.org; the situation becomes unimaginably worse if they also have to choose between XYZ.ABC, XYZ.CDE, XYZ.EFG etc. 11. Should additional gTLDs be created? No. There is absolutely no need for any new gTLDs. All that needs to happen is a gradual but firm tightening of the rules surrounding the existing gTLDs, coupled with a better exploitation of a country domain for the US. D. Policies for Registries 15. Should a gTLD registrar have exclusive control over a particular gTLD? Are there any technical limitations on using shared registries for some or all gTLDs? Can exclusive and non-exclusive gTLDs coexist? Yes, but the costs and profit level should be regulated by an international body. A good example of such a system in the offline world is the running of the UK National Lottery. The lottery is run by a private organization, Camelot, but with government-specified levels of profit. By exercising this type of partial control over the domain name registrar, any possible abuse of the monopoly over a given gTLD can be avoided. 16. Should there be threshold requirements for domain name registrars, and what responsibilities should such registrars have? Who will determine these and how? Yes. They should have sizeable assets and the technical know-how to guarantee that they can maintain their systems in full working order at all times. They should be responsible for providing DNS services for domain names under their control. They should be able to INSTANTLY issue domain names [even though the update could be reflected periodically in the central DNS databases, such as once a day as per the current InterNIC system] 17. Are there technical limitations on the possible number of domain name registrars? Yes. The InterNIC database is already extremely slow due to the number of queries being sent to it. If registrars need to query the databases held by all other registrars, or alternatively need to all share a centralized domain name registry database, the system will slow to a crawl. One domain name, one registrar, one database. 18. Are there technical, business and/or policy issues about the name space raised by increasing the number of domain name registrars? Yes. Increasing the number of registrars increases the possibility of conflicts between different groups seeking to register a single domain name. 19. Should there be a limit on the number of different gTLDs a given registrar can administer? Does this depend on whether the registrar has exclusive or non-exclusive rights to the gTLD? Yes. 1. All rights should always be exclusive. 20. Are there any other issues that should be addressed in this area? No. E. Trademark Issues 21. What trademark rights (e.g., registered trademarks, common law trademarks, geographic indications, etc.), if any, should be protected on the Internet vis-a-vis domain names? All trademarks should be given weighting when considering domain name disputes, IRRESPECTIVE of the country of origin of the domain name. This is vitally important: US trademarks should not be given any kind of precedence over trademarks issued by other countries. 22. Should some process of preliminary review of an application for registration of a domain name be required, before allocation, to determine if it conflicts with a trademark, a trade name, a geographic indication, etc.? If so, what standards should be used? Who should conduct the preliminary review? If a conflict is found, what should be done, e.g., domain name applicant and/or trademark owner notified of the conflict? Automatic referral to dispute settlement? Yes, for the new .us or similar country domain that I outlined earlier. In this case, the trademark should be a US trademark only. An independent body should be set up to monitor such disputes. A cost could be levied on the disputee and on the disputer; the successful party in the dispute would have the cost refunded, and the losing partyfs cost would pay for the review process. NO ACTION should be taken until the process has completed and a decision is reached. The current system that DNS services are suspended to the domain name holder UNTIL a settlement is reached is completely unacceptable, and is not conducive to promoting the use of the Internet as a tool for global business. .com, .org and .net names should be allocated on a first come, first served basis. Any resultant disputes should be handled by a similar, independent body. Because of their global nature, any pre-review process would be unsuitable for such domain names. 23. Aside from a preliminary review process, how should trademark rights be protected on the Internet vis-a-vis domain names? What entity(ies), if any, should resolve disputes? Are national courts the only appropriate forum for such disputes? Specifically, is there a role for national/international governmental/nongovernmental organizations? An international organization should be formed with the specific aim of resolving such disputes. A framework of rules should be laid down to make all but the most complicated of cases a mere formality. 24. How can conflicts over trademarks best be prevented? What information resources (e.g. databases of registered domain names, registered trademarks, trade names) could help reduce potential conflicts? If there should be a database(s), who should create the database(s)? How should such a database(s) be used? Trademark databases already exist. Patent databases can also be considered when resolving such disputes. An organization could be set up to integrate these databases in some form, possibly via a unified query mechanism to provide a front- end interface to these various databases. 25. Should domain name applicants be required to demonstrate that they have a basis for requesting a particular domain name? If so, what information should be supplied? Who should evaluate the information? On the basis of what criteria? Yes, for the new .us domain name reserved for companies. Proof of company ownership should be required. Small businesses and self-employed people, and individual domain name applicants should content themselves with other domain names such as .com, .net and .org. If this new top domain becomes widely used as THE domain for US companies, then problems such as conflicts between IBM.com and IBM.org [for example] will be of much lesser significance. 26. How would the number of different gTLDs and the number of registrars affect the number and cost of resolving trademark disputes? Every time you add a gTLD, you add another potential battleground for companies to fight over the rights to a domain name, and another potential domain name that can be hijacked away from its rightful owner. 27. Where there are valid, but conflicting trademark rights for a single domain name, are there any technological solutions? No. First come first served is the fairest system if both claims are valid. One additional partial solution would be to have a standardized glinking systemh that sites would be required to display on their top page to dispel confusion. So for example, IBM.com would be required to display the information: gIf you are looking for International Bowling Members, please go to IBM.net. If you are looking for Interior Bazaar Malls, please go to IBM.org.h at the foot of its main page [standardized font size and a high-contrast colour] In the above example, the site belonging to IBM.net would have to display the following: gIf you are looking for International Business Machines, please go to IBM.com. If you are looking for Interior Bazaar Malls, please go to IBM.org.h Finally, in the same example, the site belonging to IBM.org would have to display: gIf you are looking for International Business Machines, please go to IBM.com. If you are looking for International Bowling Members, please go to IBM.net.h 28. Are there any other issues that should be addressed in this area? No. -- Edwin Hayward, Tokyo, Japan info@igoldrush.com Internet Gold-Rush [ http://www.igoldrush.com ] The premier source of free domain name news and info *** LIST A DOMAIN NAME FOR SALE FREE / BROWSE NAMES *** ### Number: 6 From: Christopher QuinnTo: "Paula Bruening, NTIA" Date: 7/1/97 11:20am Subject: gTLD: UTI - no! NSF - yes! I utterly mistrust and object to Secretary General Pekka Tarjanne's and the International Telecommunication Union's (UTI's) attempt to hijack the Internet. The proposed plan to transfer control of the Internet from the U.S. government to an intergovernmental organization in Switzerland is not in the best interests of Americans (like me) or the Internet. The ITU, the United Nations agency responsible for coordinating telecommunications policies of governments, not the U.S. government's National Science Foundation (NSF), would become the worldwide central depository for new Internet domain names, and the World Intellectual Property Organization (WIPO) would administer the arbitration and appeals mechanisms. Utter folly! Americans paid for and developed the Internet; and only Americans, due to our Constitution, our economic and military strength, are in a position to safeguard the privacy of American citizens and free flow of information and commerce on the Internet. Not some selfordained United Nations bureacracy and a fragile balkanized coalition of vested international interests. You don't see Apple, IBM, Microsoft and Netscape Communications rushing to endorse the Geneva plan; and even if those major players got stupid, an increasing number of smaller organizations are actively campaigning against the proposals, afraid that the UTI takeover could lead to the splintering of the Internet into rival domain-name groupings. The proposal has, in fact, already provoked legal action from Internet services companies in the United States. These companies are justifiably angry at what they see as the hijacking of the Internet by an unelected international body; Richard Beaird, the U.S. government representative, would thus be best advised to make sure the absurd proposal is vetoed. A protest meeting on the domain-name issue organized by the Association for Interactive Media will take place in Washington, D.C. on July 9; so the American protest against the Geneva plan should be in full roar by August. Having Vint Cerf, known as the "father of the Internet", MCI and 80 other organizations with less than sterling motives endorsing such a anti-American plot will not sway the majority of Americans, once they find out what is really being proposed. Not so much the idea of adding seven new generic top-level domains to the five established domains, which include .com, .edu and. gov, or even the complex registration, payment and appeal process, but the idea of the world dictating what Americans can and cannot do with an American technology and architecture is galling. Pekka Tarjanne's defense of rushing this through, by saying his organization had to act quickly so as not to miss the opportunity to reform the Internet, is specious at best. The UTI is secretly salivating over future tariffs (taxes) on American Internet commerce and being able to acquire covert data on American interests. Americans will no longer stand for our own government overtaxing us and methodically diminishing our freedoms; so we sure as heck aren't going to take it from beyond our borders. I know I won't! Tarjanne and Cerf can stuff it; and so can any American administration that plays into their hands. Christopher Quinn ### Number: 7 From: Tommy Lakofski To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 12:35pm Subject: Possible solutions to gTLD clutter. Sir, The document at http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm raises many valid questions. I'm not in a position to comment on most of them, but it would seem that a fairly obvious solution to the overwhelming growth of gTLD domains would be to restrict the allocation of such domains to one per company, organization, body, or individual. This, I believe, was the original intent of the hierarchical nature of DNS zones -- any organization could subdivide its namespace as it saw fit in a hierarchical manner. This indeed is the manner in which most reputable companies on the Internet manage their DNS -- cf. Digital, IBM, Apple, Microsoft et al. In my (humble) experience, it is only those less 'worthwhile' companies which undertake domain registration en masse, for the purposes of speculation, vanity DNS naming, etc. I believe that these activities must be the chief factor in the cluttering of the generic namespace, and its eventual non-operability -- and it would sem that these activities would be the easiest to eliminate, via a change in the registration process for generic domains which would require proof of identity -- corporate or individual. I'd also like to throw in a brief word on the retirement of the gTLDs: This would seem to be perfectly justified, and by reducing the 'glamor' of the gTLDs, would eliminate the registration of gTLDs by organizations outside the US, further reducing pressure on the namespace. As the Internet seems to be becoming a more global than exclusively US-centric domain, the incorporation of the gTLDs into the .us namespace seems entirely appropriate. It would also make room for the possibility of global gTLDs for multinational organizations (although this is provided for currently by .int). In any reorganization of the DNS, there should be competition between the registries of names (and with IPv6, numbers) on the Internet, as well as the continuing minimal interference of governmental organizations, which will never be able to keep pace with the dynamic evolution of this global network. I hope these comments prove useful. Thank you for your time. Thomas Lakofski. ### Number: 8 From: To: NTIADC40.NTIAHQ40(dns) Date: 6/30/97 8:28pm Subject: New domain naming system My main concern on domain naming is that the owners of domain names be required to submit real contact information, that the registries be required to verify the contact information and that there be substantial penalties for providing incorrect or nonfunctional contacts, e.g., telephones that are never answered, E-mail routed to /dev/null. The reason for this is that currently the major spam domain have bogus contact information in order to avoid having to listen to complaints. Shmuel (Seymour J.) Metz shmuel@os2bbs.com ### Number: 9 From: Daniel Prather <10ebm3s3ipcm@mci2000.com> To: NTIADC40.NTIAHQ40(dns) Date: 6/30/97 8:44pm Subject: Internet Domain Registry Structure Hello. My name is Daniel Prather, and I'd like to share a few of my ideas on the future Internet Domain Registry Structure and workings. I have tried to structure this in a sense that I feel will best benefit you, the reviewer, and answer any questions that you may have. Also, if something in this document is not thoroughly explained, and you'd like a more detailed explanation, feel free to e-mail me at the address at the end of this letter below. Thanks! Daniel Prather Panama City, Florida (850)784-1253 mystic.one@mci2000.com The following section of this message contains a file attachment prepared for transmission using the Internet MIME message format. If you are using Pegasus Mail, or any another MIME-compliant system, you should be able to save it or view it from within your mailer. If you cannot, please ask your system administrator for assistance. ---- File information ----------- File: internet.txt Date: 1 Jul 1997, 0:43 Size: 4716 bytes. Type: Text -- Internet Domain Registry Infrastructure and Workings --- Introduction: First hand, I would like to say that this request is not organized in the way that comments were expected. Mainly, I feel that the preconceived format is not adequate to describe the ideas and thoughts which I will soon depict in this document. I have organized it in a way that I feel will make it easy to read, and easy to understand. If you have any questions, please refer to the e-mail address towards the end of this document. Overview: Due to the sudden growth of the Internet, many of the previously conceived systems which control Internet traffic have become greatly overworked. Not to mention, many things have become disorganized, creating a very difficult to navigate network. The text that follows are my ideas on it's solution. In writing this, I have primarily addressed the main problem of domain registration. I shall begin by giving a somewhat general overview of what I think may solve several problems in the current system, and further along, I shall go into more specific detail. New Internet Domain Infrastructure: First of all, the domain registration should be administrated by one organization. It would be preferably a federally funded operation, which is also supported by the fees of domain registration. This organization would also be the home of the few domain nameservers. New protcols would need to be enacted to allow for the use of 128-bit IP addresses as well. These few nameservers would be the only ones operational. I say this because most of the Internet clutter is created by the popular "static IP" which usually includes a domain such as "username.domain.ext" ... although this 3 field URL is not particularly disorganized, sometimes they grow to take up 5 or 6 fields. This is completely ridiculous, and wasteful. In keeping with a few nameservers, running on high-speed connections (multiple OC-3s or OC-12s) we could provide domain lookups for the world's Internet community, and manage it easily. The servers would be linked so that if one goes offline, another may take on its load, as well as its own. This would created a continious domain service. It would be advisable, though, that a few of these nameservers be located in different locations as to minimize the chance of a failure. Caching servers may be setup as they are now, but may only be modified by the main servers. This would allow them to still recieve queries, and still direct users to desired sites, but not allow useless data to be entered by a user. When a company or individual registers a domain name, there should be a set cost. This cost would include a block of rougly 5 IPs, instead of the blocks of 256 given now. Extra IPs may be purchased at a set cost, and all DNS entries and "static IP" domains would need to be approved by the new registry. To be approved, they would have to submit a form detailing the intended use of the domain, as well as information regarding the user. This would minimize the amount of "nonsense" domains currently residing on the network nameservers. Only domain administrators (working for the new domain organization) will be able to make changes to the registry. Domains would need to have longer extensions. .com, .edu. .gov, etc, usually are sufficient, but with more and more sites appearing with different social orientations, these extensions will eventually become unusable. In place, I'd suggest something a little more descriptive and restricted, .com domains would only be given to commercial sites, and they would have to show proof of their business stance. .edu isn't sufficient for all of the educational resources available. Possibly creating a .highschool, .college, .university, etc would be more sufficient. Government organizations could be categorized in a similar way. .localgov, .federalgov, etc. Locations need not be required in domain names. These tend to be pointless, in my opinion. But geographic information SHOULD be stored, so that if a query is performed (by dnslookup or finger) on a site, geographic information can be obtained, as well as other information submitted to the primary registry. Essentially this is most of my suggestions. If you have any questions, please e-mail me or call me at 1-850-784-1253. This new organization should be called something such as "Worldwide Domain Services" (www.worldwide-domain-services.system) ... the .system extension referring to a critical component of the Internet. Please send me your comments on the above documents. Thank you. written by Daniel Prather e-mail: mystic.one@mci2000.com ### Number: 10 From: To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 1:47pm Subject: Trademarks Network Solutions apparently with the blessing of the NSF has an absolutely reckless policy as it pertains to registration of trademarked names by third- party registrants. Their "dispute policy" is so irresponsible that it appears to encourage lawsuits for the enrichment of their attorneys. I have a valid subsisting, unique and famous federal trademark that has been used in commerce since 1983. Now, because of Network Solutions policy I will have to spend a $150.00 filing fee, spend a day writing the complaint, and wait two years for a federal court to order the transfer of the .com registration back to the trademark owner. The system is in need of change. Sincerely, Darrell J. Bird, 3070 Southdale #D, Dayton, OH 45409 Financia@aol.com ### Number: 11 From: Lori Henk To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 4:16pm Subject: Creation of New gTLDs #11 11. Should additional gTLDs be created? Definitely. The following ideas were proposed at an international level more than a month ago regarding new gTLDs and the U.S. should remain consistant with that proposal where possible. There is only one gTLD proposed that I question and that is .store for retail sites. A more appropriate gTLD, keeping with 3-4 letters would be .shop. The following gTLDs were proposed: .firm - business .store - retail (alternative .shop) .web - web related services .rec - recreation .info - resource/information .nom - personal sites .arts - art related sites thank you for your time, Lori Henk Web Designer lori@acton.com ### Number: 12 From: Nickolai Zeldovich To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 5:09pm Subject: Comments on Policies for Registries See the attached file. -- Policies for Registries Domain name registries should not charge excessive amounts of money from individuals and/or companies and/or organizations registering domain names, except for what's absolutely needed for the operation of the servers. Obviously the current $50/year fee generates much more money for InterNIC than they need for normal operation of the nameservers and other registrations. -- +--------------------------+----------------------+--------------------------+ | Nickolai Zeldovich | ZEPANET | UCF Math Department | | http://www.kolya.ml.org/ | http://www.zepa.net/ | http://www.math.ucf.edu/ | | nickolai@kolya.ml.org | nickolai@zepa.net | nickolai@math.ucf.edu | +--------------------------+----------------------+--------------------------+ ### Number: 13 From: Jim Cerny To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 5:22pm Subject: comment on adding DNS top-level domains. Dear NTIA: In following the attempts by Internet groups to expand the number of top-level domains in the last six months, I think the following clearly emerges regardless of who runs the registries and regardless of just how many new domains are added and what they are called: Legal counsel for companies will regard it as their duty to recommend, for any corporate names that have trademark or copyright status, the registration of these names in EACH new domain. That will, of course, tend to undo many of the benefits of expanding the namespace. The solution, at least from the point of U.S. law, would seem to be national legislation that prohibited that kind of multiple registration. I have no idea if it is possible to argue for this from some parallel situation that has already been legislated. Some would suggest a pricing mechanism as an alternative to legislation, with sharply escalated fees for extra registrations. If it were just a matter of charging $100 (say) for the first registration and $10,000 (say) for each additional one, that would be hard to administer with competing registries and would discriminate strongly against small companies (for a large corporation the $10K would be a trivial cost of business). Jim Cerny Web manager, University of New Hampshire jim.cerny@unh.edu ### Number: 14 From: Dennis Fazio To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 7:26pm Subject: On the Registration and Administration of Internet Domain Names Comments in response attached as ASCII text. My full contact info: Dennis Fazio Executive Director Minnesota Regional Network 2829 University Ave SE Minneapolis, MN 55414 dfazio@mr.net (612) 362-5850 -- Dennis Fazio Minnesota Regional Network -- Gabnet: (612) 362-5850 Comments in response to a Request for Comments on the Registration and Administration of Internet Domain Names, Docket No. 970613137-7137-01. Section A. Appropriate Principles I agree with all six principles Section B. General/Organizational Framework Issues Questions 1-9: The current domain name system has been overrun by the growth of the Internet; it no longer scales with the need. Generic Top Level Domains should be retired and the use of the US Domain, as currently defined in RFC 1480, should be mandated for the United States in its place. Detailed explanation and justification follows: I believe any scheme predicated on an extension of the current, essentially flat naming system is doomed to failure. The recent proposal by the International Ad Hoc Committee (IAHC) to add a limited number of new Top Level Domains does not seem to be a scaleable solution and will not likely ameliorate the major issues of trademark infringement. It seems the key problems are: a. Demand by several parties for the same name b. Use of the domain name system as a directory service c. Technical and operational management of the growing Domain Name System Most all of the rest of the issues and problems are a result of these three. It would be easiest of these had apparent technical solutions. Unfortunately, they all don't. The second problem could be solved with a mix of policy (adhere to a standard) and technical (implement a separate, easy-to-use directory service). The third is partly policy (agree on some practices; again, standards) and implement them (mostly technical/operational.) It's that first one that is the real source of all the ruckus. One path to a possibly easier solution would be to look at the world we had pre-Internet and see how we dealt with those issues of similar naming and trademarks. We deal with them now by allowing the use of the same name as long as they are in different areas of activity or in different states. This leads us to a solution that doesn't perturb the current setup all that much: mandate the use of the US domain. First, it's heirarchical and does not suffer the scaling problem of the current proposals, even as they are themselves increased with more top-level domains. There are 50 states and thousands of localities in which to fit your organization's name. Second, it allows for either a single registration authority or the logical division to any number of registration authorities, each of different size and scope of operation according to their capabilities. Third, it permits multiple organizations to have the same name. Acme.Minneapolis.MN.US and Acme.Los-Angeles.CA.US can both exist and keep their names if they are in different business lines. In those cases where the same name is to be used in the same community, categorical names could be slipped in: Acme.Paints.Minneapolis.MN.US, Acme.Towing.Minneapolis.MN.US. Fourth, it provides some semblence of a limited directory service. Right now, if we know the name of a prominent company and add .com, we can go to its web server. However, that only works for one company with that name. With an heirarchical US domain, we only need know the company name and where it is to find their web site. Note that we will still have need of a good directory service to really make the system work, but it's always nice to have some shortcuts. Fifth, and most important, it helps leverage the existing practice we now use to keep trademarks manageable because it provides a system very much like the real world we now are familiar with. It's not a perfect match, and some new policies, procedures and perhaps new law will have to be created to make it really work well, but nowhere near the mess and seemingly insurmountable task we now see before us with the current system. There have been many objections to the use of the US domain, some specious, the rest, nonconsequential. 1. The names are too damn long: This is just a fact of life when so many are now involved. You need more characters to differentiate organizations when you get into the thousands and millions. The best solution is to use already familiar names that are easy to remember. There are plenty of features in email (aliases) and web programs (bookmarks) that make it unnecessary to type in the actual name very often. Most email is a response to another email; the address is never entered in those cases, but automatically entered by the email client. We deal with long names in our lives all the time anyway. Many of us use long street addresses or long town names that we have to write time after time on our applications, documents, forms, etc. or US Mail letters. We deal with it. This objection is specious. 2. People and organizations move and would have to change their domain names: What happens when a person or organization moves now? First you have to get a new telephone number (though this necessity may change in the future). You perhaps need a new driver's license as an individual. You need to print tons of new stationary. You need to send out large quantities of "change of address" postcards. On the Internet, it's a 5 minute job to send "change of address" messages to all your correspondents (all of whom are conveniently cataloged with nice short aliases in your mail client) and mailing lists. I hardly think that sending out some email change notices adds all that much to the overhead necessary when you move your household or your business. What if you graduate and get a job? What if you get a new job? Your email address will change. It happens all the time to lots of us now anyway. Life means change. We change schools, homes, workplaces, favorite foods, spouses, family size. A major portion of the population still changes their names at some time in their lives. Businesses move, change products, change their corporate names. What can be so difficult about changing an email address or corporate domain name once in a while. Change is good for us. We should all seek any opportunity to change something about ourselves often. This objection is also specious. 3. In Cyberspace, names shouldn't be tied to physical location: Most of those arguing for the abstraction of a "Cyberspace" as a new "lifespace" seem to be denying or attempting to put aside the real world. I think it is more important for us to encompass the real world in this new virtual world. Seeing that someone is associated with a particular university or corporation, or is located in a particular place humanizes the message or the information. All I have in front of me is a screen full of words or images. The organizational or geographic mapping in their return address or the web site gives a small amount of identity to the person who wrote those words or placed those pictures. The tendency to respond rudely and viciously is amplified when there is no real person looking you in the eye. We've all seen evidence of that on the Internet. If there was no shred of identity association at all, the messenger becomes even more abstract and dehumanized. Discourse can degenerate quickly when all you debate with are disembodied words. Cyberspace is floating too freely as it is. It needs some anchors in something now existing so that newcomers feel welcome and not just lost in a strange new world with absolutely no familiar touchstones. If we want this new and growing facility to be used by the greater population, then we have to make it accessible, we have to build it having an association with the familiar REAL WORLD that we all live in. We are all real people in real physical places. With few exceptions, almost all of our sense of community comes from our geography: school, church, neighborhood, social organizations, civic organizations, government participation, etc. It is what helps make us human and social beings. We don't need the concept of an abstract "cyberspace" to bring new people together on the Internet. The concept of a diverse set of people geographically dispersed over great distances, yet brought together by electronic communications can be a powerful draw. A locality/geographical-based naming system helps us to build that concept. This objection is inconsequential. Let us think about what we are trying to accomplish and the best way to encourage that. The best new things are those that have some sort of usefulness or tie that people can tie to something already familiar to them. It is what helps new things grow and flourish most rapidly. In summary, we can probably futily attempt to pull and stretch and warp a current system that was never intended to scale to this size and scope, or give up and adapt something entirely different, very familiar, and staring us in the face all along. Section C, D, E: I have no supplementary comments on these sections beyond what has been already covered above. -- Dennis Fazio, Minnesota Regional Network --|||-- Gabnet: (612) 362-5850 ### Number:15 From: Ringmaster To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 7:46pm Subject: About InterNIC... Well I just have a little comment, the system InterNIC is using right now is way to stoneage. For ex. if you wanna update your profiles it takes days to get it done and e-mails has to be sent back and forward to the hostmaster (or whatever), wouldn't it be easyer if they just could get a real system up and running where you can update your info on-line, internet is commercial and not only the "old" computer nerds are using it anymore... My two cents...(or is it one cent?) [minimjuk] Ringmaster - http://www.geocities.com/~gcring/ - minimjuk@geocities.com ### Number: 16 From: Charles To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 10:15pm Subject: REGISTRATION OF INTERNET DOMAIN NAMES To whom it may concern, I am inclined to aggree with the executive summary on almost all aspects of included content. I am strongly in favor of the internet being regulated by the public sector, leaving legal enforcement matters to the government agencies. As far as domain names are concerned they should open more domains for the use of public as well as business concerns, cost of which should be absorbed by the users. Business should pay their part as well as the private sector. As a private user of the internet I have found it increasingly difficult to log on to my service due to the rising amount of usage, as well as the many larger servers being brought down due to the massive hits to their systems. These facts alone are proof something need be done and very soon. I can see a major failure happening within the next few years due to the steady rise in traffic and stress on an already taxed system. Regards Charles Leffler -- For quik contact= Mailto:leffler@okeechobee.com Home Page= http://www.okeechobee.com/~leffler/index.html Truckers Page= http://www.okeechobee.com/~leffler/index.html/bookmark3.htm CC: NTIADC40.SMTP40("jerry@southeast.net") ### Number: 17 From: Jesse Kornblum To: NTIADC40.NTIAHQ40(dns) Date: 7/1/97 11:40pm Subject: Comments on DNS issues B. 1. Problems with current DNS system: Under the current system, if a person registers for a DNS entry, but later another company that holds a trademark to that name (e.g. www.superbowl.com) wants that domain name, the first person is stripped, without compensation, of the name. I believe that trademark holders should be able to purchase the domain names of trademarks they hold, but at a fair market value. (Perhaps the cost of the registration fee for as long as the person held the name...) 5. The existing gTLDs should not be retired, but new ones should be created. It might be a good idea to have a .us domain, and then the US could administrate everything in that domain, but who would decide other country codes? And how would those debates be decided? I like the idea of InterNIC, a semi-autonomous organization that runs the whole deal. Like the UN, only for the Internet. (Please note that the Internet should NOT be under control of the UN.) :) 7. Well, I'm going to get a little technical here. Remember that DNS names (e.g. www.whitehouse.gov) are only nicknames for the *real* addresses, which are IP addresses that look like this: 18.233.0.21, etc. It may very well be necessary to expand IP addresses to five blocks. (Each block can range from 0-255) Having existing systems work with these new systems would require updating the Internet, a daunting task, but nonetheless necessary... C. New gTLDs 1. Yeah. Nothing should be banned. If you want a site www.profanity.#!@#??, then you should be able to get it. 2. YES! The current system is too restrictive. For example, .isp for service providers, .store for well, stores, .adult, for sites with adult content (great for filtering software!) Thanks for listening, Jesse D. Kornblum | Even if the voices aren't real, 403 Memorial Drive - DKE | they have some good ideas Cambridge, MA 02139-4397 USA 617-494-8250, ext. 114 http://mit.edu/jessek/www/ ### 07-01-97