Comments on usTLD Policies and Requirements NOI

Comments of the INTA Internet Committee

From: Claudio Di Gangi [mailto:cdigangi@inta.org]
Sent: Wednesday, March 06, 2013 3:23 PM

Dear Fiona Alexander:

I am writing to provide the comments of the Internet Committee of the International Trademark Association (INTA) in connection with NTIA’s Notice of Inquiry (NOI) on: “Country Code Top-Level Domain (ccTLD) for the United States; Policies and Requirements".

Thank you for the opportunity to comment.

Best regards,

Claudio Digangi

Claudio Digangi
External Relations Manager - Internet & the Judiciary International Trademark Association
T: +1-212-642-1720; F: +1-212-768-7796
cdigangi@inta.org, www.inta.org

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ARI Registry Services Comments

From: Sebastien Ducos [mailto:sebastien.ducos@ariservices.com]
Sent: Tuesday, March 05, 2013 2:08 AM
 

Fiona M. Alexander
Associate Administrator, Office of International Affairs
National Telecommunications and Information Administration
1401 Constitution Avenue NW., Room 4701, Washington, DC 20230

Dear Ms Alexander,

Please find attached Adrian Kinderis’ comments on behalf of ARI Registry Services  in response to your request.

Please do not hesitate to contact me should you have any questions.

Best Regards,

SEBASTIEN DUCOS
Client Services Manager

ARI REGISTRY SERVICES
Melbourne | Los Angeles
P  +61 3 9866 3710 | M  +61 449 623 491 
E  sebastien.ducos@ariservices.com
W  www.ariservices.com

 

ARI Registry Services is an evolution of AusRegistry International.
Follow us on Twitter

 

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GoDaddy Comment

From: Jill Titzer [mailto:jtitzer@godaddy.com]
Sent: Monday, March 04, 2013 7:25 PM
To: USTLDNOI
Cc: James Bladel
Subject: .US ccTLD Comment Request- Docket No. 130124072–3072–01

 Fiona, 

Attached is the .US ccTLD comment for your review.  Thank you.

______________________
Jill Titzer

ICANN Policy Manager
GoDaddy.com



 

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NASCIO Comments on usTLD Policies and Requirements

From: Mitch Herckis [mailto:MHerckis@amrms.com]
Sent: Monday, March 04, 2013 7:10 PM

Dear Ms. Alexander,

Please find the attached comments on behalf of the National Association of Chief Information Officers (NASCIO).  Should you have any questions or require additional information, please feel free to contact me via the information provided below, or you may contact NASCIO Executive Director Doug Robinson at (859) 514-9171 or DRobinson@AMRms.com.

Thank you for the opportunity to comment on the future of the United States country code top-level domain.

Sincerely,

Mitch Herckis
Director of Government Affairs

National Association of State Chief Information Officers (NASCIO)
444 North Capitol Street NW, Suite 642, Washington, DC  20001
O 202.624.8477  |  F 859.514.9166  |  mherckis@AMRMS.COM  |  www.nascio.org

 

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Comments of Neustar, Inc.

From: Burr, Becky [mailto:Becky.Burr@neustar.biz]
Sent: Monday, March 04, 2013 4:31 PM

Ms. Fiona Alexander, Associate Administrator
Office of International Affairs
National Telecommunications and Information Administration
1401 Constitution Ave. NW
Washington DC 20230

Dear Ms. Alexander:

Please find attached the comments of Scott Blake Harris on behalf of Neustar, Inc. in response to the above referenced NOI.  Please do not hesitate to contact me if you have any questions.

Sincerely,

Becky Burr

J. Beckwith Burr
Neustar, Inc. / Deputy General Counsel and Chief Privacy Officer
1775 Pennsylvania Avenue NW, Washington, DC 20006
Office: + 1.202.533.2932  Mobile:  +1.202.352.6367  / becky.burr@neustar.biz / www.neustar.biz

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usTLD consultation

From: abc1 [mailto:dotcallb@yahoo.com]
Sent: Monday, March 04, 2013 1:32 PM

I am an individual who has invested in the usTLD and has developed several .us sites for the benefit of Americans.  My comments in respect of those items sought are as follows:

  1. The primary concern I have with existing policies of the usTLD is the almost total lack of promotion or awareness.  A ccTLD is a precious national resource for the benefit of any country, and without active, continuous promotion it will continue to languish, denying a vast namespace that Americans are entitled to utilize and benefit from.  Please see the advertising and promotion done by other ccTLDs, such as CIRA in Canada.  They have a far higher profile and as a result enjoy far greater penetration and mind share.  A ccTLD should stand side by side in importance with .com, as .ca does in Canada.  But it requires active, routine, top level marketing to achieve that parity.
  2. See above.  Currently, for instance, the usTLD functions from an outdated site that looks unprofessional.  Users must be able to access easily their needs in a compelling way.  strong efforts have to be taken to incent registrars to more prominently offer .us domains.
  3. Please see above regarding marketing and promotion required.  There is at present no ‘community, of usTLD users/owners and that should be changed, via association of owners etc.  Ownership of a .us name should result in membership as a defined group, and that group can then make their voice know as to required changes or issues, provided the applicant awarded this contract to run the usTLD is required to heed recommendations from owners. 
  4. I would strongly require transparency as to marketing and promotion efforts, that can be tracked and enforced.  I would suggest that X% of all usTLD domain sales or renewals be earmarked specifically for such promotion and marketing.
  5. I do not think the nexus requirement serves any purpose but to limit registrations.  By definition, the usTLD clearly and unmistakably promotes the USA and goods and services relating to the USA so that is enough of a constraint.  This is unlike for instance the caTLD where nexus requirements are perhaps more necessary to prevent the namespace form devolving into a California registry.  US is unmistakable and should be open as with most other ccTLDs.
  6. Unknown.
  7. The .kids space should be deprecated.  The fragmented nature of the internet makes ‘walled gardens’ unworkable, and there is no logical connection or policy to maintain a ‘kids’ space incumbent upon the US.  Content providers and parents do that.
  8. Unknown.      

   An additional comment:

All government or city urls should be simplified to second level domains.  There exists a tremendous brand and awareness opportunity if city names were simplified.  Nobody can remember or benefit from say (city.county.state.us) whereas (city.us) or (town.us) in simplified format is a memorable and powerful incentive for others to adopt this namespace.  The internet is based upon ease of use from a consumer perspective, and prior rules about hierarchical naming no longer have any valid role.

Best regards,

A private citizen.

US ccTLD Request for Comments

From: Webmaster [mailto:webmaster@almondny.us]
Sent: Sunday, March 03, 2013 6:32 PM

Docket Number: 130124072–3072–01
US ccTLD Request for Comments

This is in response to your question number 1.  "In general, what are your views on the current policies and requirements that govern the usTLD space?"

Most of us are familiar with the locality-based usTLD space where domain names look like "<organization-name>.<locality>.<state>.us" and with the expanded usTLD space where domain names look like "<example>.us", but - according to Neustar - there is a third category called the .us reserved domain where domain names also look like "<example>.us".

Information about this category is extremely hard to find and it seems to be a unique creation of Neustar.  I can find this subject mentioned in two places in the specifications for the current 2007 contract:

(1) In section C.3 A.6 (page 12) those specifications outline, among other things, that the former contractor (Neustar) reserved certain domain names, how much they charged for registering those names, and where one should be able to find a list of those names.

(2) In section C.4.1 (c) (page 17) those specifications state that the new contractor (which turned out to be Neustar as well) should implement a policy for the release of certain names that are currently reserved.

I am bringing this up because I have been trying to change registrars for four years and Neustar consistently claims that due to the fact that our domain name is 'reserved' they are bound by their contract with the Department of Commerce to remain our registrar.

They claim that our name is on the list of reserved names but they have ignored every request on our part to see the list.  A link to the list in the contract specification leads to their website, but not to a list that contains our domain name.  I happen to have a copy of the list (obtained a few years ago) and our domain name isn't on it. 

They ignore the fact that the contract does not state or even imply that they are to remain our registrar but instead it states that they are expected to implement a policy that facilitates the release of reserved names, which would in effect permit them to unlock our domain and thus provide the possibility for us to use a different registrar.

There are over 50,000 domain names on the (currently inaccessible) reserved list.  That's a lot of potential income that Neustar is guaranteeing themselves by not implementing the release policy required by the terms of their contract.

Here are some quotes from their Emails which will give you an idea of their attitude:

"This ia[sic] a .us reserved domain name and it's non-transferrable. We are the only registrar for the .us reserved domain."

"As we informed you originally this domain name is NOT TRANSFERRABLE. We will remain the sponsoring registrar of the name indefinitely."

"Policy changes relative to the reserved list are subject to Department of Commerce review and approval prior to implementation."

"It appears that DoC would want these domains to stay under Neustar management to prevent from general public registration since they are subject to additional rules, restrictions or processes."

Here is some contradictory information from Neustar.  In one Email they informed us that:

 "the "reserve" program is a special program that protects affected domains from ever being inadvertently released into the general registration pool"

Yet when they send their renewal reminders they threaten that:

"If you do not renew your names they will be deleted and available for use by the general public domain name pool."

In this statement they claim to be protecting us from unscrupulous practices:

"This arrangement is different than the standard registrar practice where expired domains are either deleted and re-registered by domainers without consideration for the registrant's needs, or put up for auction once the registrant has missed the renewal deadline, and only released back to the registrant after payment of whatever "auction" price the registrar sets."

In my estimation retaining control of a domain name and then demanding registration fees several times greater that those available from competing registrars is a practice just as unscrupulous as that of the 'domainers' that they claim to be protecting us from.  In other words: "If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck."

I would also like to bring up the fact that it is well known that domain names can be registered for a maximum term of 10 years.  In section K (page K-3) of the .us Contract 2007 - NeuStar Proposal, which is part of their current contract, it even states:

"Domain names may be registered for terms from 1 to10[sic] years, inclusive. A domain may never have a term exceeding 10 years."

Yet with each renewal reminder there is the following statement:"

As a valued customer, we are now offering three renewal options:

" 3 years at $168
" 5 years at $180
" Lifetime at $395*- Best Buy!
...
* All options are available for purchase. The Lifetime option at $395 provides the maximum savings at this time.

So, how are they implementing this 'lifetime' registration?  It seems that any implementation would actually have to be by means of sequential registrations for a fixed period of time to continue for the lifetime of Neustar, which is not necessarily the same as the lifetime of their customer.

Although Neustar may be doing an acceptable job as far as the National telecommunications & Information Administration is concerned they certainly have not been doing an acceptable job in our estimation.  It is my opinion that for any new contract the concept of a .us reserved domain should be thoroughly reviewed and its elimination should be considered.

Donald Weiman
webmaster@almondny.us

.us comments

From: z [mailto:czouzas@gmail.com]
Sent: Thursday, February 21, 2013 6:49 PM

PS>

do yourselves a favor

put me in charge of the .US 

christian zouzas

@US   

On Thu, Feb 21, 2013 at 6:29 PM, z <czouzas@gmail.com> wrote:

comments for .US contract

april 24,2002 the public could register .US domains

to date the average US citizens has NO idea
dot us exists.

other cctld's are more know in america then .US
ie: .co ,columbia .me montegro etc.. 

.us needs a registra that will make .US a household
name ,,and if .us is know to the general public
they will choose .US  even over.com ,if educated
with a choice.

American's are the most patriotic in the world
but have no idea .us exists.

It's not enough for business to promote American jobs, American
products , "Made In America", but also take advantage of .Us as
<US captures all of that with a extension. 

who ever is given the contract needs to commit to
resources on  not only on super bowl ads
but other highly viewed programs.If they are unwilling
or not able to do so they should not be given the privlege
of controlling .us

setting up free accounts or simple websites to promote .us
ain't going to cut it.   

respectfully submitted

christian zouzas    @US on twitter