From: Reality is a point of view <gjohnson@season.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 9:29am
Subject: Comments on the January 1998 draft proposal.

History

I have been playing with computers for over a decade and have
spent time working in the industry. When the Internet accepted
commercial interests, with resulting growth, I decided it was
time to 'stake a domain claim'.

Because I am an individual the .edu, .org, and .net TLD's were
not appropriate and .us is geographically specific. Left with
choosing a .com domain name I worked toward finding an
available name that was suitable, acquiring and testing the
hardware and software that would support the use of the domain,
finding an ISP I could afford, and finally registering the
domain.

The season.com domain has been online for over two years. In
that time I have worked to create name recognition while
planning for future growth. At this time season.com does not
conduct commercial transactions but such transactions are an
eventual goal. Whether or not that goal is achieved; I do hope
to maintain season.com for decades to come. It is my feeling
that season.com is not unique in this regard.

Reaction to the current proposal

I am concerned by the wording of the draft proposal released at
the end of January, 1998. In particular

http://www.ntia.doc.gov/ntiahome/domainname/domainname130.htm

"NSI will continue to operate .com, .net and .org but
on a fully shared-registry basis"

does not clearly state that the role of registrar for .com will
also be open to competition. The current $50 yearly fee is not
a great hardship. There seems to be little in the way of
assurances or requirements that may keep the fee reasonable.
In other parts of the draft there is language that allows for
the possibility of competition but nothing clearly and
succinctly states the planned registry and registrar status of
.com; the TLD most responsible for the pending policy changes.

This lack of clarity leaves doubt. As an individual
participating in a youthful industry, an industry that has
already seen two influential corporations investigated for
anti-trust, I am worried that exposure to rising fees related
to keeping season.com online may serve as a competitive
disadvantage. Not only are mail addresses and URL's at risk,
but also software.

The specification for Java, a popular programming language from
Sun, suggests the use of reversed domain names as a way to
avoid name collisions for vendors, organizations and
individuals. I have great interest in the commercial potential
of Java, in particular Java packages coming from the season.com
domain. Both as stand alone products and as com.season.*
packages that others may use to build Java products.

Forced domain migration could result in not only mail and URL
legacy issues but also in loss of control of name spaces built
upon DNS name spaces. While it is unlikely that large
corporations will be exposed to this risk, smaller entities are
if a .com monopoly were given to the first, and only,
commercial administrator of the .com TLD. A TLD that was the
only choice for many early adopters. It is my hope that there
is time left to address this issue.

Thank you for your time.

--

Gary Johnson gjohnson@season.com
Privacy on the net is still illegal.

###

From: Felipe Grajales <grajales@octonline.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 3:16pm
Subject: Request Information

To Whom It May Concern:

Dear Sir/Madam

Hi my name is Felipe, and I'm just wondering where can I register a
domain name?

Could you please explain me what do I need to do in order to have a
domain.com.

Thanking you in advance for your expertise

Sincerely,

Felipe Grajales

###

From: Simon Rowland <simon@eagle.ca>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 9:55pm
Subject: .moon or .luna Top-Level Domain Name

I have followed with great interest the current proposal to increase the
number of top-level domain names on the Internet. I would like to
suggest
another name that will help usher in an exciting new future during the
dawn
of the 21st Century.

I propose that .moon or .luna become a top-level domain name. The right
to
assign addresses with .moon or .luna would be given as a prize to the
first
organization that places a fully-functional Internet server on the Moon,
a
feat that is technically feasible today. The winning organization would
be
given the right to sell addresses in these domains for whatever the
market
will bear.

Currently the only products that earn a profit in space is the
collection,
creation, and transportation of data, video, and telephony information.
Because information has no mass, it is easily transported in space to
its
destination. Telecommunications satellites are a very profitable
enterprise.

By expanding this profitable paradigm to the Moon, the Internet can help
pave the way by encouraging the creation of the first profitable business
on the Moon: the transportation and/or storage of data to and from any
point on the Earth. At the same time it will open a prestigious arena
for
all people with an interest in developing space and its limitless
resources.

The cost to your organization to implement this prize program is
vanishingly small in the face of the prospective gain that all humanity
will reap, as the Space Frontier is expanded beyond Earth Orbit.

Simon Rowland
Local Contact and Officer,
Artemis Society International
Member of Canadian Space Society and
Students for Exploration and Development of Space

###

From: <RCard68865@aol.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 9:47pm
Subject: becoming a registrar

I am inquiring about information on becoming a registrar. Is is going to be
a free application? Do I have to go through the CORE agency? Please respond

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:41pm
Subject: #1 Inter-related, Logical Factors which Impact the Future of DNS Users

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND

ADDRESSES DISCUSSION DRAFT 1/30/98

#1 TITLE: Inter-related, Logical Factors which Impact the Future of DNS

Qualifications of the Commentator:
Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.
Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).
Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.
His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.
He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

i. Preface
The fundamental principles which are required in order for DNS to
be transitioned to a benevolent system which continues to work for all
individual Internet users, are found in the U.S. Constitution and Bill of
Rights (Refer to 8/18/97 Brief to NTIA: DNS, Language, and the Constitution
by Stephen J. Page.)

To guide the future of the DNS as a valuable and integral service
to individual Internet users requires that a balanced governance system be
built from a self-organizing activities of active participants, within the
framework of law. Therefore, a respect for law, and a respect for the
rights of individuals to speak freely, to own property, and to do business,
is required to build a solid future for a commercial Internet.

If each of these Constitutionally supported principles can
interlaced under the banner of "pursuit of happiness", and aimed at all
citizens of cyberspace "netizens", then NTIA's envisioned transition from a
governmentally-controlled DNS (through DARPA's contracts with IANA, etc.)
to a self-organizing net-ocracy will be accomplished smoothly and for the
benefit of all present and future Internet users.

ii. Introduction to the Comments of Stephen J. Page <usdh@mail.ccnet.com>
The key to understanding the issues which are at stake in the DNS
debate which can lead to a vision of the DNS future which is beneficial to
individual users, is to apply mathematics and logic to the facts pertaining
to the Internet, to commerce, to telecommunications. Once applied, a high
level understanding to a future governance system which recognizes the
rights and freedoms of individual users can be accomplished with greater
ease.

Inter-related, Logical Factors which Impact the Future of DNS:

1. The Internet = a Network of Networks (public and private) designed to
enhance the communications between individual users in their daily work or
play.

2. The Domain Name System (DNS) = a hierarchical list of top level,
secondary level, tertiary level...(TLDs, SLDs) of specifically addressed
directories (public and private) networks.

3. Public networks will have generic addressing structures because they are
made freely available to all Internet users. Private networks may or may
not have generic addressing structures because they have owners whose
interest is in providing a return on investments which have been made in
the private network. The *choice* of private networks to employ
proprietary addressing DNS schema should rest with the private network.

4. The Domain Name System (DNS) list = a hierarchical directory of TLDs,
SLDs, etc. organized by geographic locality (abbreviated or not), or by
topic (abbreviated or not), or by symbol (symbol, character, abbreviation,
syllable, word...) which can be applied to either public and private
networks.

5. The Top Level Domain (TLD) is the highest level address identifier for
helping people organize their search to find addresses of whatever or
whomever they need to find in their daily work or play, for either public
or private networks.

6. Individuals organize their searches in a variety of ways: by geographic
locality, or by topic or category (domain), alphabetically, by applying
Boolean queries or randomness (go here and see what we get).

7. Locality-based search structures have been traditionally organized by
IANA (DARPA) using the two-digit (.xx) country code TLDs (ccTLDs).

8. Topical, domain-specific search structures have been traditionally
organized by IANA (DARPA) using three-digit (.xxx) abbreviations (.COM,
.NET, .ORG, .EDU...) which are very general and non-specific.

9. Human activity is driven by *specific* human needs. A need for food
will cause one to go buy food. An illness will cause one to go find a
doctor. A need for cash will cause one to go to a bank. A need for fun
will cause one to watch TV, play a game, or go to a park.

10. The specific activity of individual human beings is the root of all
commerce, which can be defined as a communications-based transaction of
value (goods and/or services) from one entity to another.

11. Commerce is dependent upon the ability of buyers or sellers to 1)
identify, 2) locate, and finally 3) communicate with interested parties,
prior to making 4) a transaction to exchange value.

12. Human activity which leads to commercial transactions involves search
methods which are ranked in order of importance: topical (domain-specific),
alphabetical, and Boolean, which are used by most online Encyclopedias.
Geographical searching is an artifact of the geo-political franchising
process which has been sponsored by IANA across the globe.

13. The use of DNS with categorical and alphabetical addressing should be
implemented for the future so that individual users can more naturally make
use of the Internet in their daily work or play. Encouraging categorical
granular searches should be encouraged because they are familiar, because
they save time, and because they can increase the chances of commercial
activity, ecommerce.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved. Excerpted
from a forthcoming book, entitled "How the World of DNS Works."

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:42pm
Subject: #2 A Proposed Mission Statement for the Non-Profit Cooperative

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND
ADDRESSES DISCUSSION DRAFT 1/30/98

#2 A Proposed Mission Statement for Focusing the Non-Profit Cooperative

Whereas, the Internet = a Network of Networks (public and private)
designed to enhance the communications between individual users in their
daily work or play,

Whereas, its addressing system, the Domain Name System (DNS) = a
hierarchical list of top level, secondary level, tertiary level...(TLDs,
SLDs...) organized by geographic locality (symbols, abbreviations, words),
or by category/topic (syllables, words), or by symbol (characters)
specifically addressed to add logical structure to the network directories
(public and private) which can be used by individuals to navigate where
they choose,

Whereas, the DNS design can be most valuable to users when
structured to encourage the use of a addressing system by individual users
in their daily work or play.

Whereas, it is clearly recognized by all educated people that human
activity and behavior is driven by *specific* human needs (A need for food
will cause one to go buy food. An illness will cause one to go find a
doctor. A need for cash will cause one to go to a bank. A need for fun
will cause one to watch TV, play a game, or go to a park...),
Therefore, human behavior (specific activities) are the root of all
commerce (transactions of valued goods and/or services from one entity to
another),

Therefore, facilitating commercial transactions between entities in
cyberspace involves simplifying search methods which aid individuals, to
alphabetically, topically (domain-specifically), or geographically search,

Therefore, the development of a rich Internet addressing system
used by individuals in their daily work or play can and should be
encouraged as a formal activity of the DNS governing structure, because
simplifying and familiarizing the communications from one person to another
and one entity to another will make the Internet more understandable and
therefore more useful to people,

Therefore, the future DNS will save people search time and increase
their ease of use which will increase the value of the Internet medium, as
these factors will result in an increase in the commercial activity across
the network, so called 'ecommerce', which will become more and more adopted
over time into the unforeseen future.

Qualifications of the Commentator:

Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.

Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).

Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.

His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.

He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved. Excerpted from
a forthcoming book, entitled "How the World of DNS Works."

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:42pm
Subject: #3 Recognizing the Chain of Responsibility Flows Under the Rule of U.S. Law

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND
ADDRESSES DISCUSSION DRAFT 1/30/98

#3 Recognizing the Chain of Responsibility Flows Under the Rule of U.S. Law

While this paper is a very welcome addition to the process of
creating a more useful DNS system for individual users, it comes at a very
late date for those of us who have understood how DARPA has traditionally
stimulated commercialization of defense-funded technology like
DARPANET/NSFNET/INTERNET.

In October of 1996, IANA (Mr. Jon Postel) had mailed a document to
me which outlined the principles for the transition of the DNS to a
competitive system. IANA as a contractor to DARPA, the research and
development arm of the U.S. Department of Defense. IANA was operating
under the authority of the U.S. Government to sponsor a system for creating
competition, which led to the (unaccountable) IAHC process
(POC/CORE/PAB...) which had implemented the process leading to a
non-competitive, non-U.S. controlled, TLD-delegation cartel. The enhanced
Domain Name System (eDNS) was formed as a free market response to the
IANA-driven, IAHC process.

eDNS' First Meeting in Atlanta. The attendees included Karl
Denninger (MCSnet, .BIZ, .NPO, .K12...), Eugene Kashpureff (Alternic, many
TLDs), Jay Fenello (Iperdome, .PER), myself (representing Internet .A-.Z*
Name Registry, .A-Z*, .A*, .B*, .C*...) as well as others. The lone
conference call attendee was Chris Ambler of Image Online Design (.WEB).
This meeting was the actual first step in the self-organization of a truly
competitive DNS system envisioned by anyone who recognized that increasing
choices would be beneficial to Internet users. The substance of the
meeting was focused on implementing an operating process. It should be
formally recognized for this significance as it is the historical precedent
of eDNS 'process' that the DNS Plan Discussion Document of 1/30/98
reflects:

1) the first formally recognized benefits of separating of the Root
Service (absent the proposed non-profit cooperative), from the Registry
Service (initially called Registration Authorities), from the Registrar
Service (called 'Registries' using eDNS terminology). Each of these
functions had previously been integral to Network Solutions' performance
under its contractual agreement (monopoly) with the NSF, coordinated by
IANA's contracts with DARPA/DoD.

2)defining the technical limitations of the future of competitive
Registry Industry (prior to the meeting the eDNS Charter limited any TLD to
between 3-13 digits), which are recognized as being one digit (.x) to an
upward limit of 24 digits (.xxxx...) because at the meeting the issue was
raised about the single-digit level and the sequence of language elements
(alphabetical characters a-z) which had never before been used as TLDs. It
was recognized by all of the engineers present, and confirmed later in the
week by the technical experts, that no such technical limitations existed
with the DNS.

3)actual business transactions were made by entrepreneurs who had
taken the U.S. Government-sponsored IANA's (funded by DARPA) stated
intentions at face value...to create competition. Having been a Principal
Investigator for a DARPA-funded Network Architecture Project, submitted in
1993 and funded in 1994, sponsorsed by Smart Valley, the technology
division of Joint Venture Silicon Valley, I had witnessed how DARPA
functioned as an organization dedicated to helping transfer
Government-funded technologies to the private sector. A more competitive
DNS, like a more competitive telecommunications system (legislated by
Congress in its Telecommuncations Act of 1996) would help accelerate
electronic commerce into existence.

At the time of our award, JVSV had also sponsored CommerceNet (also
awarded a DARPA grant for commercializating of the Internet) which had been
funded $6 million to build commercialization momentum. That process
directly led to the creation of Netscape, Yahoo, and other companies, and
created the new Internet Industry. After witnessing the workings of DARPA
and its effect on the process of commercialing new industries, it was very
clear to me that with the backing of DARPA, IANA's process was clearly
going to be another piece of the puzzle called the Commercial Internet,
where "ecommerce", the flow of monetary value in exchange for goods and
services over electronic networks, would be enabled by a commercial DNS,
creating a new Registry Industry.

5)Recent meeting in New York by a number of eDNS attendees and subsequent
Press Release showed how closely the DNS Plan of the NTIA was being shaped
by the eDNS process. However, if the U.S. government-sponsored NTIA, a
department of the Dept. of Commerce, is to facilitate the process of stably
implementing a more competitive Registry Industry, it should not violate
the principles of the organization which controls IANA (DARPA) nor the
principles which have been historically used by DARPA to stimulate
commercialization.

The principles which are tried and true are 1)uniqueness and
simplicity of design, 2)development of prototypes, 3) recognize
demonstrated investment toward commercialization, which means that risks
have been taken (a higher probability of commercial success when risks have
been taken) 4) a focus on the creation of long term value 5) a focus on
maximum consumer accceptance.

Qualifications of the Commentator:

Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.

Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).

Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.

His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.

He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved. Excerpted from
a forthcoming book, entitled "How the World of DNS Works."

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:43pm
Subject: #4 Specifically Defining Competition: a Meta Level Problem to Solve

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND
ADDRESSES DISCUSSION DRAFT 1/30/98

#4 Specifically Defining Competition: a Meta Level Problem to Solve

Before tackling the definitions of the operating entities
(registrar and registry), it is important to define competition, since
clearly the absence of a common meaning prevents there from being a
"consensus", therefore leading to a disagreement. Once one defines
competition, one can apply it at the "Set" level (using Geometry) to the
Internet (or Internet=Universal Set).

Since DNS is a core element of the design of the Internet (a part
of Internet=Universal Set's structure), if competition is going to be
applied to the Internet=Universal Set, it will be applied like the forces
of physics are applied throughout the Universe...across all distances,
applied to all things which exist within the Set. If one does not wish to
apply competition, then the word competition should not be used. A better
word to use would be regulation. (In the case of regulation, the highest
level of regulation would be total controlled economic activity or
monopoly, and the lowest level of regulation would be an absence of state
control or free market economy.)

Competition can be viewed hierarchically, with pure competition at
the Top Level, and absolute regulation at the Bottom Level, with varying
degrees of competition in between. Traditionally, the historical
Internet=Universal Set was a completely regulated space, functioning at the
Lowest Level of competitive freedom (command and control through DARPA
contracts). However, in 1993 when DARPA funded commercialization of the
Internet=Universal Set, it was clearly intending to function as a
stimulator of free market competition, by funding private companies and
entrepreneurial activities to transfer technological asset to the private
sector (under the Technology Reinvestment Project or TRP).

The fundamental conflict between the DARPA-controlled contractual
historical past and the DARPA-funded 1993-forward TRP-stimulated "future"
(a Commercial Internet stimulated by a $6 million investment in
CommerceNet), has created the meta-level "disagreement" between the two
parties and their differing world views. On one extreme, tied contractually
to the past to IANA's legacy, and on the other extreme believing in the
inevitable reality that true competition exists within and between
worldwide economies and aggregations of human energy, which cannot be
controlled without damaging effects, because one cannot control or bottle
up human energy.

Qualifications of the Commentator:

Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.

Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).

Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.

His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.

He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved. Excerpted from
a forthcoming book, entitled "How the World of DNS Works."

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:43pm
Subject: Part 1. Comprehensive Commentary of Stephen J. Page (rep. Internet .A-.Z* Name Registry)

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND
ADDRESSES DISCUSSION DRAFT 1/30/98

Qualifications of the Commentator:

Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.

Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).

Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.

His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.

He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

i. Preface

The fundamental principles which are required in order for DNS to
be transitioned to a benevolent system which continues to work for all
individual Internet users, are found in the U.S. Constitution and Bill of
Rights (Refer to 8/18/97 Brief to NTIA: DNS, Language, and the Constitution
by Stephen J. Page.)

To guide the future of the DNS as a valuable and integral service
to individual Internet users requires that a balanced governance system be
built from a self-organizing activities of active participants, within the
framework of law. Therefore, a respect for law, and a respect for the
rights of individuals to speak freely, to own property, and to do business,
is required to build a solid future for a commercial Internet.

If each of these Constitutionally supported principles can
interlaced under the banner of "pursuit of happiness", and aimed at all
citizens of cyberspace "netizens", then NTIA's envisioned transition from a
governmentally-controlled DNS (through DARPA's contracts with IANA, etc.)
to a self-organizing net-ocracy will be accomplished smoothly and for the
benefit of all present and future Internet users.

ii. Introduction to the Comments of Stephen J. Page <usdh@mail.ccnet.com>

The key to understanding the issues which are at stake in the DNS
debate which can lead to a vision of the DNS future which is beneficial to
individual users, is to apply mathematics and logic to the facts pertaining
to the Internet, to commerce, to telecommunications. Once applied, a high
level understanding to a future governance system which recognizes the
rights and freedoms of individual users can be accomplished with greater
ease.

Important Factors which Impact the Future of DNS:

1. The Internet = a Network of Networks (public and private) designed to
enhance the communications between individual users in their daily work or
play.

2. The Domain Name System (DNS) = a hierarchical list of top level,
secondary level, tertiary level...(TLDs, SLDs) of specifically addressed
directories (public and private) networks.

3. Public networks will have generic addressing structures because they are
made freely available to all Internet users. Private networks may or may
not have generic addressing structures because they have owners whose
interest is in providing a return on investments which have been made in
the private network. The *choice* of private networks to employ
proprietary addressing DNS schema should rest with the private network.

4. The Domain Name System (DNS) list = a hierarchical directory of TLDs,
SLDs, etc. organized by geographic locality (abbreviated or not), or by
topic (abbreviated or not), or by symbol (symbol, character, abbreviation,
syllable, word...) which can be applied to either public and private
networks.

5. The Top Level Domain (TLD) is the highest level address identifier for
helping people organize their search to find addresses of whatever or
whomever they need to find in their daily work or play, for either public
or private networks.

6. Individuals organize their searches in a variety of ways: by geographic
locality, or by topic or category (domain), alphabetically, by applying
Boolean queries or randomness (go here and see what we get).

7. Locality-based search structures have been traditionally organized by
IANA (DARPA) using the two-digit (.xx) country code TLDs (ccTLDs).

8. Topical, domain-specific search structures have been traditionally
organized by IANA (DARPA) using three-digit (.xxx) abbreviations (.COM,
.NET, .ORG, .EDU...) which are very general and non-specific.

9. Human activity is driven by *specific* human needs. A need for food
will cause one to go buy food. An illness will cause one to go find a
doctor. A need for cash will cause one to go to a bank. A need for fun
will cause one to watch TV, play a game, or go to a park.

10. The specific activity of individual human beings is the root of all
commerce, which can be defined as a communications-based transaction of
value (goods and/or services) from one entity to another.

11. Commerce is dependent upon the ability of buyers or sellers to 1)
identify, 2) locate, and finally 3) communicate with interested parties,
prior to making 4) a transaction to exchange value.

12. Human activity which leads to commercial transactions involves search
methods which are ranked in order of importance: topical (domain-specific),
alphabetical, and Boolean, which are used by most online Encyclopedias.
Geographical searching is an artifact of the geo-political franchising
process which has been sponsored by IANA across the globe.

13. The use of DNS with categorical and alphabetical addressing should be
implemented for the future so that individual users can more naturally make
use of the Internet in their daily work or play. Encouraging categorical
granular searches should be encouraged because they are familiar, because
they save time, and because they can increase the chances of commercial
activity, ecommerce.

A Proposed Mission Statement for Focusing the Non-Profit Cooperative

Whereas, the Internet = a Network of Networks (public and private)
designed to enhance the communications between individual users in their
daily work or play,

Whereas, its addressing system, the Domain Name System (DNS) = a
hierarchical list of top level, secondary level, tertiary level...(TLDs,
SLDs...) organized by geographic locality (symbols, abbreviations, words),
or by category/topic (syllables, words), or by symbol (characters)
specifically addressed to add logical structure to the network directories
(public and private) which can be used by individuals to navigate where
they choose,

Whereas, the DNS design can be most valuable to users when
structured to encourage the use of a addressing system by individual users
in their daily work or play.

Whereas, it is clearly recognized by all educated people that human
activity and behavior is driven by *specific* human needs (A need for food
will cause one to go buy food. An illness will cause one to go find a
doctor. A need for cash will cause one to go to a bank. A need for fun
will cause one to watch TV, play a game, or go to a park...),
Therefore, human behavior (specific activities) are the root of all
commerce (transactions of valued goods and/or services from one entity to
another),

Therefore, facilitating commercial transactions between entities in
cyberspace involves simplifying search methods which aid individuals, to
alphabetically, topically (domain-specifically), or geographically search,

Therefore, the development of a rich Internet addressing system
used by individuals in their daily work or play can and should be
encouraged as a formal activity of the DNS governing structure, because
simplifying and familiarizing the communications from one person to another
and one entity to another will make the Internet more understandable and
therefore more useful to people,

Therefore, the future DNS will save people search time and increase
their ease of use which will increase the value of the Internet medium, as
these factors will result in an increase in the commercial activity across
the network, so called 'ecommerce', which will become more and more adopted
over time into the unforeseen future.

Words or sentences bound bounded by asterisks (*s) or parentheses <> are
included as comments as well as suggestions for increasing clarity of the
proposed solution. (below)

Summary of Comments:
I. RE: Under the heading: Assignment of numerical addresses to Internet users.

"Every Internet computer has a unique IP number. The Internet Assigned
Numbers Authority
(IANA), headed by Dr. Jon Postel of the Information Sciences Institute
(ISI) at the University of
Southern California, <*functions as the trustee of all cyberspace and *>
coordinates this system by allocating blocks of numerical addresses to
regional IP registries (ARIN in North America, RIPE in Europe, and APNIC in
the Asia/Pacific region), <*under the laws of the United States and *>
under contract with DARPA. In turn, larger Internet service providers,
<*functioning as cyberspace version of cmmercial real estate developers *>
apply to the regional IP registries for blocks of IP addresses. The
recipients of those address blocks then reassign addresses to smaller
Internet service providers the <*cyberspace version of small independent
office or home builders*> and to end users who are the <*cyberspace
version of real estate buyers and sellers (the marketplace).*>

II. RE: "2) Management of the system of registering names for Internet users.

The domain name space is constructed as a hierarchy. It is divided into
top-level domains (TLDs),
with each TLD then divided into second-level domains (SLDs), and so on."

COMMENT #2 For further clarifying the understanding of DNS structure and role:
<*The letter-character output (divided into alphabet,
abbreviations, syllables, words, sentences, etc.) of human language is both
constructed and consumed by each speaker/listener, writer/reader, and typer
as a hierarchy.*> The DNS is divided into top-level domains (TLDs), with
each TLD then divided into second-level domains (SLDs), and so on. <*Each
TLD represents a language hierarchy (alphabet, abbreviations, syllables,
words). Therefore, domain name space is constructed as a hierarchy of
language hierarchies*>.

III. RE: "A small set of generic top-level domains (gTLDs) do not carry any
national identifier, but denote the intended function of that portion of
the domain space. For example, .com was established for commercial users,
.org for not-for-profit organizations, and .net for network service
providers.

COMMENT #3: To clarify the understanding of DNS relationship to real world
experiences...
"A small set of generic top-level domains (gTLDs) do not carry any
national identifier, but denote <*topically*>the intended <*meaning*>of
that <*segment*> of the domain space.
<*In addition, to add more clarity, "A TLD can be understood to be
similar to a STREET, an SLD can be viewed as the name of a building on a
street. Inside the building one might find many businesses. So, the
address of a particular entity, for instance, NTIA.DOC.GOV, can be
understood as the virtual NTIA department of the Department of Commerce
building, located on GOV Street.*>"

IV. RE: "More than 200 national, or country-code, TLDs (ccTLDs) are
administered by their corresponding governments or by private entities with
the appropriate national government's acquiescence."

COMMENT #4: Similarly following along the STREET Metaphor of one global
community...a way of explaining the ccTLDs would be...
"Within domain name space, more than 200 national (Streets) or
country code TLDs or ccTLDs are administered by their corresponding
governments, <*and they are managed/leased/rented/sold by private or public
entities*> with the appropriate national government's acquiescence."

V. RE: "Operation of the root server system." Following the real world real
estate metaphor...

"The root server system contains authoritative <*TLD*> databases listing
the TLDs <*(streets)*>so that an Internet *mail or information <*message
can be routed *similar to postal mail*> to its destination. Currently, NSI
operates the "A" root server, which maintains the authoritative root
database and replicates changes to the other <*backup*> root servers
<*which hold identical data*> on a daily basis. Different organizations,
including NSI, operate the other 12 root servers, <*all which function
together as one distributed database spreading the server responsibility
geographically.*> In total, the U.S. government plays a direct role in the
operation of half of the world's root servers. Universal connectivity on
the Internet cannot be guaranteed without a set of authoritative and
consistent roots."

VI. RE: "Protocol Assignment."

The Internet protocol suite, as defined by the Internet Engineering Task
Force (IETF), functions as the navigational system standards which allow
cyberspace drivers to navigate the streets using their browser-mobiles,
contains many technical parameters, including protocol numbers, port
numbers, autonomous systemnumbers, management information base object
identifiers and others...

VII. RE: The Need for Change

From its origins as a U.S.-based research vehicle the Internet *has been
used by select markets for education and communication. Specifically since
the funding of CommerceNet by DARPA in 1994*, the Internet is rapidly
becoming an international medium for commerce <omit: education and
communication>. The traditional means of organizing its technical functions
need to evolve as well. The pressures for change are coming from many
different quarters:

-There is widespread dissatisfaction about the absence of
competition in domain name
registration.

<*Barriers to entry to competition have been impossible to hurdle, due to
the command and control over the hierarchical structure of DNS.*>

<snip>

-Many commercial interests, staking their future on the successful
growth of the Internet,
are calling for a more formal and robust management structure <*with
a foundation based upon existing U.S. law.*>

-An increasing percentage of Internet users and <*cyberspace street
navigators*> reside outside of the U.S., and those stakeholders want a
larger voice in Internet coordination.

-As Internet <*addresses mature into a commercially viable name
space, domain*> names increasingly have commercial value. The decision to
add new top-level domains cannot continue to be made on an ad hoc basis by
entities or individuals that are not formally accountable to the Internet
community, <*or accountable to U.S.law.*>

<snip>

VIII. RE: PRINCIPLES FOR A NEW SYSTEM

Our consultations have revealed substantial differences among Internet
stakeholders on how the
domain name system should evolve. Since the Internet is changing so
rapidly, no one entity or
individual can claim to know what is best for the Internet. <*However, we
recognize that successful principles from physical world's commercial
development process can be applied to the development of a more valuable
commercial Internet.*> We certainly do not believe that our
views are uniquely prescient. Nevertheless, shared principles have emerged
from our discussions
with Internet stakeholders.

1. Stability.

The U.S. government should end its role in the Internet number and name
address systems
in a responsible manner. This means, above all else, ensuring the stability
of <*the foundation supporting the Internet's roads, tunnels, streets,
bridges, and highways.*> The Internet functions well today, but its current
technical management is probably notviable over the long term, <*because a
top-down style command and control system of allocation for names and
numbers does not represent the commercial interests of stakeholders.*> We
should not wait for it to break down before acting. Yet, we should not move
so quickly, or depart so radically from the existing structures, that we
disrupt the functioning of the Internet. The introduction of a new system
should not disrupt current operations, or create competing root systems.

2. Competition.

The Internet succeeds in great measure because it is a decentralized system
<*of roads and streets*> that encourages innovation and maximizes
individual freedom <*of navigation.*> Where possible, market mechanisms
that support <*low barriers to ever-increasingly diverse*> competition and
<*therefore greater*> consumer choice <*for international consumers*>
should drive the technical management of the Internet <*toward building
systems which function to increase the value of the Internet as a valuable
medium*> because they will promote innovation, preserve diversity, and
enhance user choice and satisfaction.

<snip>

4. Representation.

Technical management of the Internet should reflect the diversity of its
users and their
needs, <*recognizing the Internet architecture extends all the way through
the human eyes to the human brain into the storage level of vocabulary and
memory. Therefore, formally recognizing and including experts in visual
information processing, cognitive perception, linguistics, human behavior
(human factors) *> is in everyone's interest. Mechanisms should be
established to ensure broad representation of human factors as well as
broad international input in decision making.

IX. RE: The Proposal

Coordinating Functions
<snip>
We propose the creation of a private, not-for-profit corporation (the new
corporation) to manage the coordinated functions in a stable and open
institutional framework. The new corporation should
operate as a private entity for the benefit of the Internet as a whole
<*and benefit of individuals in the aggregate.*> The new corporation would
have the following authority:

1. to set policy for and direct the allocation of number blocks to
regional number registries
for the assignment of Internet addresses; <*while also promoting and
disseminating education to all stakeholders of their policies,
deliberations, and decisions.*>

<snip>

3. to oversee policy for determining, under the advisory of a Human
Factors Advisory Board comprised of experts from a variety of
person-centric disciplines, based on objective criteria clearly established
in the new organization's charter, the circumstances under which new
top-level domains are added to the root system; and

<snip>

The new corporation will be funded by domain name registries and regional
IP registries <*for the purpose of...physical infrastructure
(hardware/software), network maintenance and operations,. (If limited to
technology-operations only) also the corporation will be funded by the
registries to manage the integration of the Internet as a unified name
space, a cyber space community and develop programs which can offer value
to individual users. The corporation should be focused on insuring the
rights of all individuals to access the roads, to freedom of navigation,
to increasing use of guides and maps useful worldwide.*>

<snip>

<*Recognizing that the Internet exists for the benefit of individual
computer users who navigate its roads and streets and that all name
registries and registrars number registries and registrars and the
technical community's sole purpose is to serve the Internet user*>, the
board of directors for the new corporation should be balanced to equitably
represent the <*interests of the stakeholders in proportion to the amount
of value represented, adjusted over time*> IP number registries, domain
name registries, domain name registrars, the technical community, and
Internet users (commercial, not-for-profit, and individuals).<*The value of
the agreegate number of Internet users can be determined by counting the
amount of "eyeball impressions" as measured by the number of sites visited
by the total number of users. This equals the total number of visual and
cognitive impressions which have an economic value in commerce. This
value, which can be calculated statistically, is the total investment made
by the 60 million+ Internet users. This economic value far outweighs the
financial investment of ARIN, RIPE, APNIC, registries, and registrars.*>

Initial Board Membership: <*24*> <*to start at a minimum, but over time
rising to represent the number of TLDs and registries/registrars supporting
them*>.

1.-three directors <snip> ARIN, RIPE, APNIC...

2.-two members designated by the Internet Architecture Board (IAB)...<snip>

3.-two members designated by a membership association (to be created)

representing domain
name registries and registrars.

4.-<seven> sixteen members designated by a membership association (to be
created) representing
Internet users, <*internationally.*> At least one of those board seats
could be designated for an individual or entity engaged in non-commercial,
not-for-profit use of the Internet, <*seven representing each of the
continental regions' interests, and seven representative experts focused on
the potential effects of the board's actions on individual end users
(linguist, visual perception expert, human factors, organizational
behavior, economics, politics, sociology). The remaining seat could be
filled by a lawyer representing the interests of all and interpreting the
law.*>

5.-the CEO of the new corporation would serve on the board of directors.

<*The focus on human user representation which will act as a de facto
super-majority for protecting the rights and freedoms of individuals*> <or
even consensus requirements may be useful> to protect against capture by a
self-interested faction. The new corporation's charter should provide a
mechanism whereby it governing body will evolve to reflect changes in the
constituency of Internet stakeholders. The new corporation should establish
an open process for the presentation of petitions to expand board
representation.

Continued on Part II

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:43pm
Subject: #5 Two Methods for Selecting TLDs: The Elitist Method and the Populist Method

February 3, 1998

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

In re: A PROPOSAL TO IMPROVE TECHNICAL MANAGEMENT OF INTERNET NAMES AND
ADDRESSES DISCUSSION DRAFT 1/30/98

#5 Two Methods for Selecting TLDs: The Elitist Method and the Populist Method

There are two ways of expanding TLDs, and they represent polar
opposite philosophies. One way is the "controlled TLD method", which is
another name for a DARPA/IANA-legacy "command and control" method. This
subtly institutionalizes a fear of unleashed competitive changes by
assuming that innovations can be controlled in a competitive environment.
It maintains the power of the monopolistic forces (first to be given the
golden goose), while using delaying tactics and "well-reasoned evolution"
to continue to institutionalize "scarcity". This method is the only one
way has been mentioned by anyone, so far and we can call it the Olympic
Elite Method which has a rigid structure for qualifying to compete. It is
organized by geo-political nation-states and is a feeder network of track
clubs, AAU sponsorships, colleges, and qualifications. Only by going
through the proper channels can one apply for the privilege of competing.
It is an elitist method with a large barrier to entry.

The second method is a method which will gather much more consumer
information, while respecting the innovativeness and entrepreneurial spirit
which might bubble-up from the creative minds of individual human activity
seeking a return on creative investment. This method can be called The New
York Marathon Method. It allows anyone to line up, professionals, amateurs,
young and old, and they all have a chance to win. One's chances to win
will depend upon one's training, tenacity, stamina, and the amount of time,
effort, and money invested to get to the race. It is a populist method,
with a low barrier to entry. As many TLDs as can be created and supported
should be allowed to be included in the Root Servers. (However, limited
SLD registrations would be agreed upon by all participating TLD Registries
and Registrars because the Streets and Roads can only hold so many people
running at the same time.)

For example, if registries were allowed to sell registrations for
1000 TLDs (think of the Internet=Universal Set like an expandable Roget's
Thesaurus) supported by registries and registrars worldwide, all of which
were included in the Root Servers of IANA, then a limited TEST determining
the demand (limited to 2000 SLDs), would create choices for 2 million new
addresses. The sign-up pattern would demonstrate demand, which would show
which Roadrunners have invested and prepared for running the Marathon, and
would also send them a clear signal about whether their continued
investment in being in the registry business is worthwhile.

Another way of visualizing the two methods, Elitist and Populist,
is to imagine a TV satellite system capable of delivering 1000 channels.
Seven have been broadcast for 15 years (.COM Channel, .NET Channel, .ORG
Channel, etc.) and commercialization of 5 more is being proposed. Only
companies with the ability to outbid or "buy their way in" are actually
able to hurdle the barriers to entry. That's the Elitist method. Tracking
consumer behavior in an environment of scarcity provides little
information.

On the other hand, if the satellite system were to carry 1000
channels and allow for a limited sign-up period, in order to gauge demand,
as a means of demonstrating to potential investors and entrepreneurs that a
market exists, then several things are accomplished. Stability of the
system is maintained, while the TLDs database is expanded (using the
Elitist approach the database is not expanded.) Barriers to entry are
reduced and diversity of participation is encouraged. Free market
principles of market competition are fostered. Return on investment
potential is provided at an early point in the process, providing important
information to registries.

The Internet, is a populist tool, with low barriers to enter for
all users. Therefore, I would like to propose that the Populist Method be
chosen as opposed to the Elitist Method.

Qualifications of the Commentator:

Founding member, attendee, and signer eDNS Charter Meeting, March
4, 1997, Atlanta, Georgia. Operator of Internet .A*-.Z* Name Registry, a
Pleasanton, California domain-name registry for .a-z* , a global Top Level
Domain (TLD), and single-digit domain-names (.A* thru .Z*),
(www.a-z-registry.com) as well as Dot Registry, Inc., a Root Server
Confederation (RSC) serving competitive TLDs including .A-.Z TLDs, non-stop
since March/April 1997, until Alternic founder's problems with the U.S.
government began.

Prior to that, Principal Investigator of a Network Architecture
project grant funded in 1994 by the Department of Defense' Advanced
Research Projects Agency, (DARPA), faciliated by Smart Valley, a network of
Joint Venture Silicon Valley, San Jose, California, sponsor of CommerceNet,
the DARPA-funded project for stimulating commercialization of the Internet
(referenced below).

Began tracking commercialization of DNS when IANA (Jon Postel's)
draft plans were released October, 1996. Submitted Draft-IAHC-SJPAGE-001
in January 1997 in response to IANA's request for comments. When IANA
created the IAHC process, an apparent international monopoly supported by
the ITU, he recognized in February 1997 that eDNS represented the only true
inclusive system for adding TLDs to the DNS root in existence. So, he
attended its first and only meeting of eDNS in Atlanta, Georgia. At this
meeting, he was instrumental in eliminating the pre-meeting 3-13 character
limitation for eDNS-compliant TLDs, as well as unlocking the potential
value of the single-digit level (previously unused) as a meaningful
sequence of SLD/TLD combinations. He submitted to NTIA's August 18, 1997
request for comments a BRIEF entitled: DNS, Language, and the Constitution.

His specific focus has been on network architecture and design of
useful telecommunications data networks, with an emphasis on the role of
adaptive learning by human (biological) network architectures and the
resulting impacts on the future of telecommunications and economics, the
subject of electronic commerce.

He possesses Bachelor of Science degrees in Combined Sciences
(physical, biological, and social sciences), and Physiological Optics and
Optometry (the study of how human beings' brains process light energy), and
a Masters degree in Business Administration. He was a Distinguished
Military Graduate and George C. Marshall (citizen/soldier) Award Winner
prior to serving as a Commissioned Officer in the Regular Army of the
United States.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved. Excerpted from
a forthcoming book, entitled "How the World of DNS Works."

###

From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/3/98 10:44pm
Subject: Part 2. Comprehensive Commentary of Stephen J. Page (rep. Internet .A-.Z* Name Registry)

Part 2.

X. RE: The Competitive Functions

"There appears to be strong consensus that, at least at this time, domain
name registration - the
registrar function - should be competitive. There is disagreement, however,
over the wisdom of
promoting competition at the registry level."

COMMENT #10:
Before tackling the definitions of the operating entities
(registrar and registry), it is important to define competition, since
clearly the absence of a common meaning prevents there from being a
"consensus", therefore leading to a disagreement. Once one defines
competition, one can apply it at the "Set" level (using Geometry) to the
Internet (or Internet=Universal Set).

Since DNS is a core element of the design of the Internet (a part
of Internet=Universal Set's structure), if competition is going to be
applied to the Internet=Universal Set, it will be applied like the forces
of physics are applied throughout the Universe...across all distances,
applied to all things which exist within the Set. If one does not wish to
apply competition, then the word competition should not be used. A better
word to use would be regulation. (In the case of regulation, the highest
level of regulation would be total controlled economic activity or
monopoly, and the lowest level of regulation would be an absence of state
control or free market economy.)

Competition can be viewed hierarchically, with pure competition at
the Top Level, and absolute regulation at the Bottom Level, with varying
degrees of competition in between. Traditionally, the historical
Internet=Universal Set was a completely regulated space, functioning at the
Lowest Level of competitive freedom (command and control through DARPA
contracts). However, in 1993 when DARPA funded commercialization of the
Internet=Universal Set, it was clearly intending to function as a
stimulator of free market competition, by funding private companies and
entrepreneurial activities to transfer technological asset to the private
sector (under the Technology Reinvestment Project or TRP).

The fundamental conflict between the DARPA-controlled contractual
historical past and the DARPA-funded 1993-forward TRP-stimulated "future"
(a Commercial Internet stimulated by a $6 million investment in
CommerceNet), has created the meta-level "disagreement" between the two
parties and their differing world views. On one extreme, tied contractually
to the past to IANA's legacy, and on the other extreme believing in the
inevitable reality that true competition exists within and between
worldwide economies and aggregations of human energy, which cannot be
controlled without damaging effects, because one cannot control or bottle
up human energy.

"Some have made a strong case for establishing a market-driven registry
system. Competition among registries would allow registrants to choose
among TLDs rather than face a single option.
Competing TLDs would seek to heighten their efficiency, lower their prices,
and provide additional
value-added services. Investments in registries could be recouped through
branding and marketing.
The efficiency, convenience, and service levels associated with the
assignment of names could
ultimately differ from one TLD registry to another. Without these types of
market pressures, they
argue, registries will have very little incentive to innovate. "

Comment #11: Modern economic understanding recognizes that all
investments, or equipment, or time, or intellectual energy transformed into
intellectual property, has costs. Without the incentives of a return on
one's investment of money or time required to invest in new things, there
is no incentive to innovate.

"Others feel strongly, however, that if multiple registries are to exist,
they should be undertaken on a not-for-profit basis. They argue that lack
of portability among registries (that is, the fact that users cannot change
registries without adjusting at least part of their domain name string)
could create lock-in problems and harm consumers. For example, a registry
could induce users to register in a top-level domain by charging very low
prices initially and then raise prices dramatically, knowing that name
holders will be reluctant to risk established business by moving to a
different top-level domain."

Comment #12: Not-for-profit (no return for risk taking, therefore no
risk-taking), activities can be undertaken by public networks which
function within the Internet=Universal Set (which is comprised of both
public and private networks.) However, in recognizing the diversity of the
Internet (public and private), mandating not-for-profit status penalizes
the investments made by those who are interested in increasing the value of
the DNS to individuals, while earning a return on their investment.

Regarding "lock-in" problems, the only reason that any consumer
would ever be "locked-in" to any addressing system would be due to the lack
of alternatives available under a historically-shackled IANA which is still
functioning in the Command and Control mode. The absence of a mechanism
for scaling the number of TLDs from small to large is what creates the
temporary scarcity which provides monopolists any argument at all about
"harming consumers". With increasing numbers of TLDs (choices), prices
will remain "at the market" level, because charging exhorbitant fees will
be penalized as customers migrate to other "directories" (TLDs).

"We concede that switching costs and lock-in could produce the scenario
described above. On the
other hand, we believe that market mechanisms may well discourage this type
of behavior. On
balance, we believe that consumers will benefit from competition among
market oriented registries,
and we thus support limited experimentation with competing registries
during the transition to
private sector administration of the domain name system."

Comment #13: Exactly.

XI. The Creation of New gTLDs

"Internet stakeholders disagree about who should decide when a new
top-level domain can be added and how that decision should be made. Some
believe that anyone should be allowed to create a top-level domain
registry. They argue that the market will decide which will succeed and
which will not. Others believe that such a system would be too chaotic and
would dramatically increase customer confusion. They argue that it would be
far more complex technically, because the root server system would have to
point to a large number of top-level domains that were changing with great
frequency. They also point out that it would be much more difficult for
trademark holders to protect their trademarks if they had to police a large
number of top-level domains."

Comment #14. The Internet=Universal Set, as a network of public and
private networks, cannot be both competitive and innovative as well as
being controlled at the same time. TLDs are nothing more than indexes of
locational aids (symbols, characters, abbreviations, syllables, and words),
thought of as Streets and Roads whose meaning helps users self-organize so
that they can better communicate with others as either customers or
suppliers. Some streets will have lots of merchants, because they were the
first street in the new territory (.COM Street), while others may be more
specialized (.STORE Street). The success or failure of the streets to
attract tenants will be due a combination of market factors...supply of
alternatives, demand for the activity, the marketing and distribution of
the "offer", the offering price itself.

For anyone to be bold enough to speak for the millions of Internet
users and say that "such a system would be too chaotic and would
dramatically increase customer confusion", is like saying that "there are
too many streets in a particular city or geographic territory". The answer
to that is a better system for organizing the Streets, not limiting the
number of Streets.

If technical complexity were bought as a reason for never flying,
the Wright Brothers would never have done anything, and modern jets would
never have evolved, and we would have never reached to the moon.

In an ever-growing domain-specific DNS system rich with TLDs, a
trademark system with geographic relevance becomes historical abberation,
and obsolete. It is a meta-problem which places geographical control
(governmental protection of trademarks) in direct opposition to the needs
and interests of users to communicate more directly and easily with others.
That problem will not be solved. Geographical control (traditional
governing) is undermined by a geographically-independent communications
medium (Internet). Only a recognition by traditional governing bodies to
cooperate at the Internet=Universal Set level will work, a
Internet=Universal Set Trademark Agreement will be able to achieve a
compromise. Otherwise, litigation will continue.

In the future, the value of trademarks will rest more with the
central mark itself, and less with the combination-marks which are being
created. McDonalds.corp may be a strong trademark by the owners of the
famous brand, but as other TLDs are added which allow more detail,
specificity, and granularity, like .accounting or .law, or .per, then there
is no need for McDonalds to protect its trademark in every category or
domain. McDonalds.law, mcdonalds.accounting, and mcdonalds.per are
irrelevant to them.

"All these arguments have merit, but they all depend on facts that only
further experience will reveal. At least in the short run, a prudent
concern for the stability of the system requires that expansion gTLDs
proceed at a deliberate and controlled pace to allow for evaluation of the
impact of the new gTLDs and well-reasoned evolution of the domain space.
The number of new top-level domains should be large enough to create
competition among registries and to enable the new corporation to evaluate
the functioning, in the new environment, of the root server system and the
software systems that enable shared registration. At the same time, it
should not be so large as to destabilize the Internet."

Comment #15: There are two ways of expanding TLDs, and they represent
polar opposite philosophies. One way is the "controlled TLD method", which
is another name for a DARPA/IANA-legacy "command and control" method. This
subtly institutionalizes a fear of unleashed competitive changes by
assuming that innovations can be controlled in a competitive environment.
It maintains the power of the monopolistic forces (first to be given the
golden goose), while using delaying tactics and "well-reasoned evolution"
to continue to institutionalize "scarcity". This method is the only one
way has been mentioned by anyone, so far and we can call it the Olympic
Elite Method which has a rigid structure for qualifying to compete. It is
organized by geo-political nation-states and is a feeder network of track
clubs, AAU sponsorships, colleges, and qualifications. Only by going
through the proper channels can one apply for the privilege of competing.
It is an elitist method with a large barrier to entry.

The second method is a method which will gather much more consumer
information, while respecting the innovativeness and entrepreneurial spirit
which might bubble-up from the creative minds of individual human activity
seeking a return on creative investment. This method can be called The New
York Marathon Method. It allows anyone to line up, professionals, amateurs,
young and old, and they all have a chance to win. One's chances to win
will depend upon one's training, tenacity, stamina, and the amount of time,
effort, and money invested to get to the race. It is a populist method,
with a low barrier to entry. As many TLDs as can be created and supported
should be allowed to be included in the Root Servers. (However, limited
SLD registrations would be agreed upon by all participating TLD Registries
and Registrars because the Streets and Roads can only hold so many people
running at the same time.)

For example, if registries were allowed to sell registrations for
1000 TLDs (think of the Internet=Universal Set like an expandable Roget's
Thesaurus) supported by registries and registrars worldwide, all of which
were included in the Root Servers of IANA, then a limited TEST determining
the demand (limited to 2000 SLDs), would create choices for 2 million new
addresses. The sign-up pattern would demonstrate demand, which would show
which Roadrunners have invested and prepared for running the Marathon, and
would also send them a clear signal about whether their continued
investment in being in the registry business is worthwhile.

Another way of visualizing the two methods, Elitist and Populist,
is to imagine a TV satellite system capable of delivering 1000 channels.
Seven have been broadcast for 15 years (.COM Channel, .NET Channel, .ORG
Channel, etc.) and commercialization of 5 more is being proposed. Only
companies with the ability to outbid or "buy their way in" are actually
able to hurdle the barriers to entry. That's the Elitist method. Tracking
consumer behavior in an environment of scarcity provides little
information.

On the other hand, if the satellite system were to carry 1000
channels and allow for a limited sign-up period, in order to gauge demand,
as a means of demonstrating to potential investors and entrepreneurs that a
market exists, then several things are accomplished. Stability of the
system is maintained, while the TLDs database is expanded (using the
Elitist approach the database is not expanded.) Barriers to entry are
reduced and diversity of participation is encouraged. Free market
principles of market competition are fostered. Return on investment
potential is provided at an early point in the process, providing important
information to registries.

The Internet, is a populist tool, with low barriers to enter for
all users. Therefore, I would like to propose that the Populist Method be
chosen as opposed to the Elitist Method.

"We believe that during the transition to private management of the DNS,
the addition of up to five
new registries would be consistent with these goals. At the outset, we
propose that each new
registry be limited to a single top-level domain. During this period, the
new corporation should
evaluate the effects that the addition of new gTLDs have on the operation
of the Internet, on users,
and on trademark holders. After this transition, the new corporation will
be in a better position to
decide whether or when the introduction of additional gTLDs is desirable."

Comment #16. Defining a limit of 5 new TLDs is clearly an elitist approach
to an issue which is a issue which affects Internet user preference,
choice, and diversity. Regulating limits is like allocating scarcity bread
during a famine. Those lucky few who know somebody or can pay for a seat
at the TLD Superbowl will be the lucky five, unless there is a more lawful
and methodical system for choosing. True evaluation of the effects of new
gTLDs on the operation of the Internet, on users, and trademark holders can
only be made using a Populist Method.

"Individual companies and consortia alike may seek to operate specific
generic top-level domains.
Competition will take place on two levels. First, there will be competition
among different generic
top-level domains. Second, registrars will compete to register clients into
these generic top-level
domains. By contrast, existing national registries will continue to
administer country-code top-level
domains if these national government seek to assert those rights. Changes
in the registration process for these domains are up to the registries
administering them and their respective national
governments."

Comment #17. Competition for 5 spots is far too few TLDs to obtain any
relevant consumer information. Alternate TLDs with no support from IANA's
root servers have had somewhere between 0.5% and 1% of the DNS traffic,
which shows that there is demand for alternatives. Choosing a small subset
(5) of what already existed (and maybe not even choosing some of them that
already existed) as an offering of 'competition' is going to damage the
entrepreneurial activity of many who have actually been doing business in
the TLD registry industry.

<snip>

"Market driven systems result in innovation and greater consumer choice and
satisfaction in the long run. We expect that in the future, directory
services of various sorts will make it easy for users to find the sites
they seek regardless of the number of top-level domains. Attempts to impose
too much central order risk stifling a medium like the Internet that is
decentralized by nature and thrives on freedom and innovation."

Comment #18. For market driven systems to result in maximum innovation,
therefore maximum acceleration toward a more valuable Internet to
individual users, barriers to entry should be lower, and more diversity
should be encouraged. A large number of level domains will make it easier
for individuals to pursue "interactive self-service", which should be a
goal of anyone interested in seeing "ecommerce" thrive. Electronic
commerce has not taken off because individuals are not able to
self-navigate to specific domains where they might seek and find products
or services.

XII. The Trademark Dilemma

<snip>

XII. THE TRANSITION

A number of steps must be taken to create the system envisioned in this paper.

Comment # 19. A Mission Statement should be adopted (see sample.)

1. The new not-for-profit organization must be established and its
board chosen.

2.The membership associations representing 1) registries and
registrars, and 2) Internet
users, must be formed.

Comment #20. Organizations have already been formed, eDNS, uDNS, dotDNS,
a-zDNS, Alternic, CORE. Is there any mechanism for recognizing their
fundamental role in shaping the commercialization process underway over the
past year?

3. An agreement must be reached between the U.S. government and the
current IANA on
the transfer of IANA functions to the new organization.

Comment #21. The higher level Principles which will guide the organization
should be crafted before the Agreements and transfers occur.

4. NSI and the U.S. government must reach agreement on the terms and
conditions of
NSI's evolution into one competitor among many in the registrar and
registry marketplaces.
A level playing field for competition must be established.

Comment #22. NSI's value as a business is a direct result of
institutionalized scarcity created by a legacy Command and Control system
applied by IANA under contract with DARPA. NSI's interest will naturally
be to slow down dilution of its franchise by the addition of new TLDs. The
limit of 5 TLDs appears to be designed to appease NSI.

5. The new corporation must establish processes for determining
whether an organization
meets the transition period criteria for prospective registries and
registrars.

Comment #23. The barriers to entry should be lowered, and the historical
role of the small indepedent registries who have done lawful business in
the U.S. over the past year should not be ignored. DARPA funded
CommerceNet in 1994 for commercializing the Internet. That very clear
mandate to commercialize the Internet, funded under the $500 million
Technology Reinvestment Project (TRP) was focused on stimulating maturing
R&D projects which could lead to valuable innovations. One such resulting
innovation was the recognition that a domain-specific addressing method
could be of value to consumers than the present system. Internet .A-.Z
Name Registry <www.A-Z-registry>, and others have been incorporated and
doing business by outsourcing infrastructure over the past year.
Investments have been made.

<snip>

The NSI Agreement

<snip>

Competitive Registries, Registrars, and the Addition of New gTLDs

<snip>

Registries and new gTLDs

"This proposal calls for the creation of up to five new registries, each of
which would be initially
permitted to operate one new gTLD. As discussed above, that number is large
enough to provide
valuable information about the effects of adding new gTLDs and introducing
competition at the
registry level, but not so large as to threaten the stability of the
Internet during this transition period. In order to designate the new
registries and gTLDs, IANA must establish equitable, objective criteria and
processes for selecting among a large number of individuals and entities
that want to provide registry services. Unsuccessful applicants will be
disappointed."

Comment #24. The Populist Method of having more TLDs up front will provide
more information than the method outlined above. If the Elitist Method is
maintained, then increasing the number of TLDs to enable active registries
who have made investments and have been doing business to participate,
should be the minimum number of TLDs allowed.

"We have examined a number of options for recognizing the development work
already underway in the private sector. For example, some argue for the
provision of a "pioneer preference" or other
grandfathering mechanism to limit the pool of would-be registrants to those
who, in response to
previous IANA requests, have already invested in developing registry
businesses. While this has
significant appeal and we do not rule it out, it is not an easy matter to
determine who should be in
that pool. IANA would be exposed to considerable liability for such
determinations, and required to defend against charges that it acted in an
arbitrary or inequitable manner. We welcome suggestions as to whether the
pool of applicants should be limited, and if so, on what basis.

Comment #25. As one who has invested in the development of this industry,
the basis should be based upon actual demonstrated 1) investment to
actually perform business (incorpration, dba, etc.) 2) investment in
infrastructure (as demonstrated by receipts, etc.), 3) investment in
web-page development, 4) investment in outsourcing technically to companies
which can handle the technical requirements, 5) investment to protect one's
TLDs (if proprietary), 6) investment in sales 7) actually attendance and
participation in the formulation of the competitive registry industry, 8)
development of educational and/or training material to promote the registry
in intrastate, interstate, and international commerce.

"We propose, that during the transition, the first five entities (whether
from a limited or unlimited
pool) to meet the technical, managerial, and site requirements described in
Appendix 1 will be
allowed to establish a domain name registry. The IANA will engage neutral
accounting and
technical consultancy firms to evaluate a proposed registry under these
criteria and certify an
applicant as qualified. These registries may either select, in order of
their qualification, from a list of available gTLDs or propose another gTLD
to IANA. (We welcome suggestions on the gTLDs that should be immediately
available and would propose a list based on that input, as well as any
market data currently available that indicates consumer interest in
particular gTLDs.) "

Comment #26. Outsourcing should be recognized as a means of qualifying.
Some technical firms may be qualified to maintain a network infrastructure
but not be qualified for sales or marketing. Other firms may be better at
sales or marketing, but cannot maintain a network infrastructure. No
registry or registrar should be required to do it all themselves as a
prerequisite.

<snip>

Registrars

Any entity will be permitted to provide registrar services as long as it
meets the basic technical,
managerial, and site requirements as described in Appendix 1 of this paper.
Registrars will be
allowed to register clients into any top-level domain for which the client
satisfies the eligibility rules, if any.

Comment #27. Same as 26.

The Root Server System

<snip>

The .us Domain

<snip>

Clearly, there is much opportunity for enhancing the .us domain space, and
the .us domain could be expanded in many ways without displacing the
current geopolitical structure. Over the next few
months, the U.S. government will work with the private sector and state and
local governments to
determine how best to make the .us domain more attractive to commercial
users. It may also be
appropriate to move the gTLDs traditionally reserved for U.S. government
use (i.e. .gov and .mil), into a reformulated .us ccTLD.

Comment #28. Who is the point of contact for working to reformulate or
increase the value of the ccTLD system? How can they be contacted?

The U.S. government will further explore and seek public input on these
issues through a separate
Request for Comment on the evolution of the .us name space. However, we
welcome any
preliminary comments at this time.

Comment #29. A commercialization strategy needs to be developed and
implemented, which will take time and investment, just as gTLD registries
have invested in commercialization.

The Process

<Snip>

"Our goal is to seek as strong a consensus as possible so that a new, open,
and accountable system
can emerge that is legitimate in the eyes of all Internet stakeholders. It
is in this spirit that we present this paper for discussion."

Comment #30.
While this paper is a very welcome addition to the process of
creating a more useful DNS system for individual users, it comes at a very
late date for those of us who have understood how DARPA has traditionally
stimulated commercialization of defense-funded technology like
DARPANET/NSFNET/INTERNET.

In October of 1996, IANA (Mr. Jon Postel) had mailed a document to
me which outlined the principles for the transition of the DNS to a
competitive system. IANA as a contractor to DARPA, the research and
development arm of the U.S. Department of Defense. IANA was operating
under the authority of the U.S. Government to sponsor a system for creating
competition, which led to the (unaccountable) IAHC process
(POC/CORE/PAB...) which had implemented the process leading to a
non-competitive, non-U.S. controlled, TLD-delegation cartel. The enhanced
Domain Name System (eDNS) was formed as a free market response to the
IANA-driven, IAHC process.

eDNS' First Meeting in Atlanta. The attendees included Karl
Denninger (MCSnet, .BIZ, .NPO, .K12...), Eugene Kashpureff (Alternic, many
TLDs), Jay Fenello (Iperdome, .PER), myself (representing Internet .A-.Z*
Name Registry, .A-Z*, .A*, .B*, .C*...) as well as others. The lone
conference call attendee was Chris Ambler of Image Online Design (.WEB).
This meeting was the actual first step in the self-organization of a truly
competitive DNS system envisioned by anyone who recognized that increasing
choices would be beneficial to Internet users. The substance of the
meeting was focused on implementing an operating process. It should be
formally recognized for this significance as it is the historical precedent
of eDNS 'process' that the DNS Plan Discussion Document of 1/30/98
reflects:

1) the first formally recognized benefits of separating of the Root
Service (absent the proposed non-profit cooperative), from the Registry
Service (initially called Registration Authorities), from the Registrar
Service (called 'Registries' using eDNS terminology). Each of these
functions had previously been integral to Network Solutions' performance
under its contractual agreement (monopoly) with the NSF.

2)defining the technical limitations of the future of competitive
Registry Industry (prior to the meeting the eDNS Charter limited any TLD to
between 3-13 digits), which are recognized as being one digit (.x) to an
upward limit of 24 digits (.xxxx...) because at the meeting the issue was
raised about the single-digit level and the sequence of language elements
(alphabetical characters a-z) which had never before been used as TLDs. It
was recognized by all of the engineers present, and confirmed later in the
week by the technical experts, that no such technical limitations existed
with the DNS.

3)actual business transactions were made by entrepreneurs who had
taken the U.S. Government-sponsored IANA's (funded by DARPA) stated
intentions at face value...to create competition. Having been a Principal
Investigator for a DARPA-funded Network Architecture Project, submitted in
1993 and funded in 1994, sponsorsed by Smart Valley, the technology
division of Joint Venture Silicon Valley, I had witnessed how DARPA
functioned as an organization dedicated to helping transfer
Government-funded technologies to the private sector. A more competitive
DNS, like a more competitive telecommunications system (legislated by
Congress in its Telecommuncations Act of 1996) would help accelerate
electronic commerce into existence.

At the time of our award, JVSV had also sponsored CommerceNet (also
awarded a DARPA grant for commercializating of the Internet) which had been
funded $6 million to build commercialization momentum. That process
directly led to the creation of Netscape, Yahoo, and other companies, and
created the new Internet Industry. After witnessing the workings of DARPA
and its effect on the process of commercialing new industries, it was very
clear to me that with the backing of DARPA, IANA's process was clearly
going to be another piece of the puzzle called the Commercial Internet,
where "ecommerce", the flow of monetary value in exchange for goods and
services over electronic networks, would be enabled by a commercial DNS,
creating a new Registry Industry.

5)Recent meeting in New York by a number of eDNS attendees and subsequent
Press Release showed how closely the DNS Plan of the NTIA was being shaped
by the eDNS process. However, if the U.S. government-sponsored NTIA, a
department of the Dept. of Commerce, is to facilitate the process of stably
implementing a more competitive Registry Industry, it should not violate
the principles of the organization which controls IANA (DARPA) nor the
principles which have been historically used by DARPA to stimulate
commercialization.

The principles which are tried and true are 1)uniqueness and
simplicity of design, 2)development of prototypes, 3) recognize
demonstrated investment toward commercialization, which means that risks
have been taken (a higher probability of commercial success when risks have
been taken) 4) a focus on the creation of long term value 5) a focus on
maximum consumer accceptance.

(c) Copyright, 1998. Stephen J. Page. All Rights Reserved.

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