From: Bob Allisat <>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/4/98 9:57am
Subject: Internet: The Founding Convention

Internet: The Founding Convention

We are facing the very real prospect of the
Internet being disassembled by every nation on
Earth intervening on behalf of their own
interests. The US and EU are but the first
combatants in what is shaping up to be a global
conflict. A conflict that can only end with
dissolution of what, up to this point, has been a
unified medium.

There has been considerable mismanagement or
rather non-management of the Internet on all sides
but primarily under the jurisdiction of the United
States. Extremely complex diplomatic and
administrative tasks have been illegitimately
suborned by technicians who mistakenly identify
occupying a power vacuum for fulfilling a
legitimate governance role. While most of the
blame can be placed on the unexpected and
explosive development the Internet has experienced
all national governments (including the US) have
been tardy in addressing the issues that now seem
to plague us all. It is very clear that
representatives of real live governments must
intervene at this point in time to provide
sanctioned guidance to a highly important medium
which is spiralling very much out of control.

The real dilemma is how the many World nations
will be able to simultaneously fulfil their
national agendas and yet keep their interferences
to a minimum on the Internet, a medium that
thrives on freedom. A real, critical dilemma we
must successfully address. If one hundred and
ninety nations each toll in with their own
Internet governance structures the phenomenon will
die overnight. We face the overwhelming need for
an International treaty or agreement process to
set fundamental, technical and administrative
guidelines within which the Internet can function
across all borders.

How will we get to the point where all nations,
each with their own strengths and weaknesses can
find consensus? A very tough question indeed.
Though we are dealing with a radically new medium
it seems we must refer to Historic precedents in
dealing with Internet Governance. Another sticky
question is *which* historic precedent! My bias is
towards the "founding convention" model. This
involves the successive gathering of diverse
participants with the express goal of finding the
answer. The people involved are given a task,
resources and a time frame to accomplish the task.
And we hope and pray it works.

The course of action I advocate is a rotating
series of "founding conventions" that move around
the world. There is a steering committee appointed
by governments of a non-partisan or rather
multi-partisan nature. Their role is to facilitate
the outpouring of consensus and to forge that
consensus where things get difficult and bog down.

Necessarily the nations of the world would have to
ratify any accomplishments of this founding
convention a difficult proposition in itself. As
an incentive we could choose to make ratification
of the conventions findings a prerequisite to
complete connectivity to the global network.
Nations would have an positive goal in
participating ... they would only be able to join
on the Internet at a reduced or limited level
should they choose not to support the global
process. Acceptance and involvement in an yet
unformed Internet regulatory body (I call it the
Internet Commission) would be the prerequisite to
full Internet access.

This Internet Commission itself would form, in
effect, an Internet government sanctioned by all
others. The over-riding majority of positions in
this voting body must belong to "netizens" at
large representing the interests of national
blocks (North America, Europe, China, Asia, etc).
This group would be enhanced by non-voting or
minority advisory technical or corporate support
staff and function in an open, fully public
manner. It is time we step up the democratisation
of the medium and legitimise rational,
representative governance to what has been a sadly
neglected but massively important communications
network. No more old timer inside deals and
all-mighty technocrats!

Through a series of founding conventions the
nature of Internet Governance and regulation is
evolved. All nations are presented a treaty which
upon signing give those entities full access to
the Internet. We install a public democratic,
representational Internet governance body and drag
this medium (kicking and screaming if necessary)
into the 21st century shorn of its dictatorial and
authoritarian past. Let us all press our efforts
to this noble and difficult cause. I put myself at
the disposal of those who wish to advance the
ideas I have set forward here and in other

TeleVirtually Yours,

Bob Allisat



From: "Andrea Naldi" <>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/4/98 7:22am

I have made a little cost analysis on a registry, which has to run with a
business model based on USG Green Paper.

Well, suppose that the fixed costs are those suggested in the GREEN PAPER, it
has to have
two lines, operate in a security framework, with 24/7 help desk and so on;
assuming that it will register 50.000 ( not a particularly successful registry,
but one with a broad base anyway) the fee for covering these cost will be 43$/
registration. Just for the cost of the registry !

If registries like NSI work on a 50% model ( I think ) then the cost for
registering a domain name will be 86$ per year for a registar, then the registar
must add something, we easily go to more than 150$ per year.

I think that a registry can't survive with only one gTLD, it has to serve more
TLD or be a really successful one.

This means that under the Green Paper the cost of the registration will
dramatically rise or that we will have fewer gTLD
For example .NET and .ORG which have about 30.000 domains / year will never
start !

Andrea Naldi


From: z80 <>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/4/98 7:20pm
Subject: dns comment


(The New Paradigm for the Old DNS)

I DO NOT support the MoU.
I Brady Mattson [](Bessemer, MI)
do hereby support the design of the expanded
toplevel Internet namespace which is currently
operated by pgMedia,
Inc.'s name.spaceTM service, located on the internet
at (or

The paradigm implemented by name.spaceTM is the most
democratic and open system proposed so far with
respect to opening up
the administration and operation of the
Domain-Name-System ("DNS").
The structure advocated by name.spaceTM removes the
artificial barriers to
entry that exist today as a result of the
monopolistic control over the
domain name registration market exerted by Network
Solutions, Inc.
("NSI"). The name.spaceTM paradigm incorporates a
fair, competitive
structure which encourages investment and innovation
by companies
wishing to compete in the provision of this service
which is essential to the
operation and continued growth of the Internet.

pgMedia, Inc. has created, through substantial
private investment in
research and development, its name.spaceTM registry
administered by
thirteen toplevel root-directory servers located in
five countries. The
name.spaceTM registry uses innovative and creative
techniques which bring
the old DNS out of the Cold War and into The 90'S.

The name.spaceTM system decentralizes the
administration of DNS and
enables open competition in the Public Domain
Toplevel Namespace
without regulation by any governments or
quasi-governmental authority,
nor does it require the enactment of new laws or

Description of the name.spaceTM service:

On the name.spaceTM system, name registrations are
taken by registrars
who administer client accounts under the given
toplevel name categories
(publicly shared toplevel namespace). All registrars
must register their
digital ID with a trusted third party/parties which
authenticates and
authorizes them to function as registries. The
application process is
administered by an independent company, similar to
the process used by
banks when authorizing merchant credit-card
accounts, and the operation
of secure servers used in commercial transactions on
the Internet today.

Registries update the database on demand based on
the availability of a
given name address using the IDSD system
(IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by
pgMedia which is
available, without limitation or charge. (A detailed
description of the IDSD
protocol can be found at IDSD makes it
technically feasible for ALL registries to share the
toplevel namespace
equally, eliminating any technical justification for
"exclusive" control over
any given toplevel name by a single registry, such
as NSI currently enjoys
with ".com".

Registration is accomplished instantaneously through
an interactive,
form-based interface on the World Wide Web with
online payment
options via a secure server. During the registration
process, a registrant
establishes an account, a contact "handle" and, of
course its "name". The
registrant has the option to choose whether or not
its personal contact
information will be publicly listed. All other
account information, of course,
remains confidential. The registrant may then
establish a Portable Address
Record, over which it has full administrative access
on the
nameservers. This service allows a registrant to
change service providers
and easily take its "name" to a new host without
delay or complications.
Upon completion of the registration process by the
registrant, the
name.spaceTM system immediately processes the
information and creates
the second level entry into the toplevel database,
which is then distributed
to all other root-servers via the IDSD protocol. The
registration process
and the creation of Portable Address Records are
instantaneous, and
function on the Internet within minutes, not days or
weeks as in the current

Issues and Answers

Under the name.spaceTM paradigm, the toplevel
namespace functions as a
Global Directory Service and would be managed within
the competitive
marketplace in the general interest of the Internet
public through the various
independent registrars. Each generic TLD ("gTLD") is
administered by all
registrars who wish to offer services thereunder
with no exclusive claim of
ownership of any toplevel name by any individual,
corporation or
government, subject to existing intellectual
property law.

These gTLDs may be added or removed based on public
demand. Also,
gTLDs may include languages other than English,
limited only to the US
ASCII character set, the English alphabet plus 10
digits and the hyphen for
a total of 37 characters.

All leading authorities are in agreement that there
is no limit to the number
of possible toplevel names, as there is no limit to
the number of root
directories under the UNIX file system. As NSI

"DNS is highly scaleable. There is no technical
limit to the number of new
top-level names that could be introduced. The
original designer of DNS,
Paul Mockapetris, has verified the scalability of


Thus, any claim that expanding the toplevel
namespace is technically not
feasible is simply unfounded. The proponents of such
claims seem to be
guided by a desire to limit the potential market so
as to create an artificial
scarcity which translate into higher prices and

The use of arbitrarily defined and limited
categories such as ".com" has
forced many registrants to engage in verbal
gymnastics, and to rely on
unwieldy content-based search engines - this would
be obviated by the full
implementation of the name.spaceTM paradigm. Thus,
for example,
Acme.computers and could both have a
presence on the
Internet without having to artificially pervert
their names. The "byte-counter
mentality," which has plagued us with the dreaded
"Millennium Bug," was
responsible for the initial constraints on the
toplevel domain name
nomenclature. The name.spaceTM system simply
recognizes that such
limitations have long since been eliminated and are
wholly artificial.

With respect to intellectual property issues, no
regulatory framework can
assure the complete protection of holders of such
rights against
infringement by unauthorized parties. However, the
potential for such
infringement, which exists in all published media,
should not be used as a
basis to limit the free speech rights of the vast
majority of law abiding users
of the Internet, while protecting artificial
monopolies. Furthermore, it is
wholly inappropriate to empower any registrar to
adjudicate the rights of
holders of intellectual property, for that role must
ultimatly reside with the

Fees for registration services should be dictated by
the market. Waiver of
fees and discounts should be considered for
qualifying educational and
non-profit organizations, as well as a selection of
totally free categories
(such as the Free.Zone provided currently by

In conclusion, name.spaceTM has developed and
implemented a new
paradigm for the Global Directory Services on the
Internet by bringing the
function of the old DNS, a legacy of the Cold War,
into sync with the
current dynamic of the public, global, civilian and
commercial Internet.

The name.spaceTM system is a reality today. The
name.spaceTM automated
registry has been fully functional for nearly one
year now and has proven its
reliability and desirability as evidenced by the
thousands of users who have
been using the name.spaceTM servers to resolve their
DNS and those who
have registered their names in name.spaceTM .

I fully endorse and support the endeavors of
pgMedia, Inc. and the
name.spaceTM system and highly recommend that the
U.S. Department of
Commerce recommend and concur in its full
implementation on the


From: Internet Gateway <>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/4/98 7:49pm
Subject: Discussion Draft on Domain Names

attn: Ira Magaziner
re: Commerce Department Discussion Draft on Domain Names

As chief executive of one of the largest Internet
Service Providers in the western United States and
Canada, I would like to add our comments to the
US Commerce Department's recently released "Green Paper"
concerning the the re-structuring of the Intenet's
Domain Name System.

The Discussion Draft outlines a basic guideline
for re-organizing the Internet Domain Name System
and for introducing competition in the domain
registration service. However the Discussion
Draft falls far short of providing a definitive
transition plan and does not present a solution
that is in the best interests of consumers and
the Internet as a whole.

The most important problems with the Draft are:

-monopolistic practices will remain among registries
since each registry will retain the 'sole rights'
to a particular TLD. For example, Internic will
still retain its much criticized monopoly over
.com, .org, and .net domains. As another example,
if a large corporation has invested heavily in
the promotion of its own domain name, what
recourse does it have when it is faced with
'poor service' from a TLD registry? Likewise,
what is to prevent a registry from raising annual
renewal rates to exorbitant amounts once it has
amassed a sizable client base? This is analogous
to phone companies charging higher premiums each year
for customers to retain their existing phone numbers.

-there is no clear process to approve registries. Given
that there are only 5 TLD registries, will there be
a democratic, competitive process to approve each
registry? Furthermore, this leads one to ask why
only five TLDs will be introduced. Jon Postel, head
of the Internet Assigned Numbers Authority, had recently
proposed as many as 150 new TLDs which is in the best
interests of consumers and the Internet as a whole.

-there are no guidelines established for dispute
resolution. This opens the door for trademark
abuse among registrars and registries as well.
Trademark disputes have already been a significant
problem with Internic, and will increase dramatically
without an international trademark authority such as WIPO.
Since the Draft proposes five TLD registries, this
problem will automatically be compounded five-fold.

Thank-you in advance for addressing these concerns.
While I do not expect a formal response from the
Commerce Department, I hope that you will consider
the above problems with the Discussion Draft seriously.


Paul C.H. Lum
General Manager/Chief Executive
Internet Gateway Corporation