From: "Thomas J. Feery" <supplysider@email.msn.com>
To: NTIADC40.NTIAHQ40(dns),NTIADC40.SMTP40("wrash@mind...
Date: 2/12/98 12:51am
Subject: Govt. regs

Ira,
Why don't you mind your business? We don't need you or any other punks
setting up internet regulations. Think back to the health care fiasco.Which
reminds me, aren't you still in trouble for that.

Take care and give my regards to the task force,
Tom Feery
supplysider@msn.com

###

From: Hadeed <hadeed@batelco.com.bh>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/12/98 1:57am

###

From: Steve Urben <urben@ibm.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/12/98 4:10am
Subject: fed gov is overreaching

they say the WWW was born when a government LAN got way outta hand, and
somehow, the Dept of Comm (usdc) thereby has some authority over its
future development.

well, i must disagree most strongly with this recent attempt (in re:
dns) by the us.gov to establish rules, set standards, or otherwise try
to influence the www. why? because:

1) political boundaries and governments are not relevant to the web.
net standards and agreements must exist, of course, and are likewise
generally independent of geographic or political limits. usdc has no
legitimate or useful role to play.

2) another misguided overreaching by the us.gov, MY us.gov. my view:
this is NOT the proper role of fed.gov. reminds me of an uninvited
guest trying to take center stage and m.c. the show!

3) the web is no longer a child of the u.s. gov - it has grown up, left
home, and went world-wide years ago. it's not just pertaining to a few
gov labs.

4) this is embarrassing, but not surprising, i guess. us.doj v
microsoft arguments recently proved to the world that doj is a newbie to
the web, so by extension, gov clearly has no portfolio to lead anything
in the tech area.

save yourselves a lot of problems and just forget this idea. private
enterprise will sort everything out just fine, thank you.

steve urben, nashville, tn

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From: Dan Cohen <dancohen@best.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/12/98 4:08am
Subject: Submission on a specific topic

I would like to submit a document written by my organization proposing
the next generation of top-level domain structures. Since the document
does not deal with management of the DNS or the coporate structure of
the newly privatized naming authority, I did not want to publish it via
electronic filing at dns@ntia.doc.gov with the other papers.

For an preview of the paper's content, refer to
http://www.clearthink.com/library/internet_letter.html

I think that the proposal we have compiled would be useful and helpful.
Please let me know if there is room for such a submission.

Thank you in advance,

Dan Cohen
President
Clear Thinking Technology, Inc.
Tel. +1 (415) 392-2884
Fax. +1 (415) 392-4341
dancohen@clearthink.com
http://www.clearthink.com

###

From: Roberto Gaetano <Roberto.Gaetano@etsi.fr>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 2/12/98 5:01am
Subject: Comments on the US Dept. of Commerce Green Paper on Internet Name s

Please find below the comments from ETSI (European Telecommunication
Standards Institute) to the Green Paper.
These comments have been endorsed by the ETSI Board, and are the
official position of the company on the subject.

Roberto Gaetano
IT Projects Coordinator
--------------------------

General Comment
ETSI has read with interest the US Department of Commerce Green Paper "A
proposal to improve technical management of Internet names and
addresses", posted at
http://www.ntia.doc.gov/ntiahome/domainname/dnsdrft.htm .
As a general observation, it may be noted that the draft does not take
into account the reality of the gTLD-MoU, and the creation of CORE, with
the result of relaunching issues satisfactorily addressed by CORE.
In many instances, the CORE / gTLD-MoU solution is more appropriate than
the solution envisaged in the Green Paper, and therefore we ask the
Department of Commerce to endorse the former, in the drafting of the
final document.

Shared Registry versus multiple independent Registries
Consensus exists on the need to create new generic Top Level Domains
(gTLDs), to extend the current Internet Domain Space.
The Green Paper proposes competition at the Registry level, as well as
at the Registrar level, with the assignment of each new gTLD to one and
only one Registry. The requirements for a Registry, listed in Appendix
1, do not include "not-for-profit" status.
The gTLD-MoU proposes one not-for-profit Registry to run all new gTLDs
on a cost-recovery basis, supporting multiple Registrars.
While competition at the Registrar level is useful, because it provides
end users choice in supplier for the same goods, the advantages afforded
by competition at the Registry level are not convincing.
On the contrary, multiple Registries have several drawbacks, such as:
* Different Registries may well have different policies, data format,
protocols and database interfaces, which will increase the costs of
implementation to Registrars and ultimately the end user. Furthermore,
global operations on trademark management (like search, verification of
infringement, clearing) will become more complicated, if not impossible.
* A commercial Registry, not bound by cost-recovery charging policy, can
raise the price for renewal of the Domain Name registration. In this
case, the customers have either to pay higher fees, or change Top Level
Domain name, losing all the investment they have done in advertising and
establishing the brand name.
* Competition policy to oversee the "fairness" of the Registries to all
Registrars will be needed to guarantee that NSI-Registry will not favour
WorldNIC versus some CORE Registrar (or vice-versa).

Trademark and Intellectual Property
Consensus exists on the need for urgent improvement to eliminate, or
dramatically reduce, cybersquatting, i.e. the improper use of domain
names. Also, the current trademark litigation procedures are felt to be
too long and complex.
The Green Paper tries to address this issue in the chapter "The
Trademark Dilemma", but is unable to define a consistent proposal. The
consequence of favouring local laws applicable in the elected
jurisdiction where the Registry or Database resides over international
law will add confusion, and indeed is inconsistent with the global
nature of the Internet.
The gTLD-MoU proposes mediation and arbitration by WIPO, the world
recognized UN Organization responsible for international Intellectual
Property protection and management. WIPO has thoroughly investigated the
correlation between Internet Domain Names and trademark litigation, and
has defined a framework and process for litigation resolution. Their
model for trademark litigation and arbitration (ACP) is, so far, the
only one that is acceptable to the international community, and,
moreover, not only fulfils the requirements spelled out in Appendix 2 of
the Green Paper, but goes well beyond that in the refinement of the
process.
CORE Members have signed a MoU that engages Registry and Registrars to
use this model for disputes, and to accept WIPO's authority. WIPO has
access to the CORE Database for the necessary operations aimed at detect
and resolve disputes.

Ethics
The Green Paper does not mention any basic ethical rules to be observed
by Registries and/or Registrars. The general approach is not to define
rules, and allow the market forces to function unencumbered.
The gTLD-MoU establishes definite rules of ethical behaviour. Moreover,
CORE Members have signed a MoU that engages Registry and Registrars to
this specific ethical behaviour. Rules and sanctions are provided in
CORE Articles of Association (AoA).
ETSI feels that there is an inconsistency in the Green Paper, that on
one hand claims to be willing to phase out monopoly in an orderly
fashion, but on the other hand it proposes an undisciplined solution,
ignoring the progress made so far by the Internet community.

Timeframe
There is global consensus inside and increasingly outside the Internet
community about the urgency of a new solution for Domain Names
management.
The Green Paper sets September 30, 1998 as the deadline for a new system
to be operational. Even though a transition phase is envisaged, it is
likely that the existing monopoly situation will continue to the end of
1998.
Under the gTLD-MoU, CORE is ready to start on March 2, 1998. The only
milestone that remains is the introduction of the new 7 gTLDs, as
defined in the gTLD-MoU, in the Domain Name Root Servers.
CORE satisfies the majority of the requirements listed in Appendix 1 of
the Green Paper. The renewal of the Internet could start with limited
operations by CORE on at least one of the new gTLDs. This decision could
be very beneficial to the whole process, at it should allow to test the
new system, and provide the US Government with very useful indication on
how the transition may work. All of this at virtually no risk.

Bottom-Up Process
Consensus exists on the importance of the adoption of a "bottom-up"
rather than a "top-down" decision process for the assessment of the new
Domain Name policy.
The Green Paper states, under the header "Principles for a new System",
the need to retain "the bottom-up governance that has characterized
development of the Internet to date".
The gTLD-MoU is the result of an internal process of the Internet
community which has grown geographically and across different parts of
the business sector engaged in this activity.
Agreement in principle therefore exists on this point. The best way to
put this approach into practice, is to allow self-governance continue. A
consultation has taken place, the results are known, the industry has
invested resources in the implementation of the chosen solution, and at
this point in time further pressure from the US Government will be
perceived as an intrusion in the bottom-up process. Furthermore, his
intrusion is incompatible with the claims of phasing out US Government
dominance in the Internet.

International Scope
The Internet is increasingly perceived as an international community.
Statements like "the Internet does not belong to a country, but to the
whole world" are gaining validity through participation and usage.
The Green Paper clearly states the need for a solution consistent with
the international vocation and scope of the Internet, and for a process
that should include the "larger voice in Internet coordination" claimed
by entities outside the US. In contrast the practical proposals make
reference to US laws and require the new IANA to be incorporated in the
US, indicating disregard for overseas partners. No mention is made for
any requirement of presence at the international level for Registrars or
Registries, nor to the possible geographical distribution.
The process that led to the creation of the gTLD-MoU was international,
and further discussion in the gTLD-MoU forum is world-wide. Moreover,
CORE is really international in scope. The CORE seat is in Europe, the
Chairman comes from the US, the Vice-Chairman from Australia. Its
Members reside in all five continents (37%US, 45% Europe, 14% Asia
Pacific, 5% Rest of the World), bringing the Registrars closer to the
end users, but granting at the same time global coordination and common
business practice and ethics world-wide.

The .us Domain
A final comment on a point addressed in the Green Paper, but not in the
scope of the gTLD-MoU: the assessment and enhancement of the .us Domain.
The Green Paper expresses the need for better management of the .us
domain, and the possible migration of .gov and .mil under this TLD. This
is a point on which there is general consensus. However, this is an
all-US subject, where the US Government is and should remain solely
responsible and therefore it is inappropriate for outsiders to comment.

###

From: "Dan Hughes" <dhughes@ford.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/12/98 6:22am
Subject: Domain Name Proposal

I'd like to register my comments on our government's proposal to privatize
the Domain Name process.

As the Web is a global entity, granted most users are probably in the
states, it seems to me that the US Government has no business trying to do
anything associated with it, except maybe being partners with other
governments in providing input to international responsible organizations .
If these organizations do not exist then the US Government should work with
other interested parties to organize them. However, at no time should ANY
government be part of the resultant organization.

As the Web is in it's infancy, there will be issues of concern that will
effect US citizens as well as it's users throughout the rest of the world.
We should start now formulating a policy to lead by example, in that we
cooperate will these International Organizations rather than try and usurp
their authority.

Maybe the place where these organizations should reside is the UN. (It is a
globally excepted organization) However, I can see that with the current
state of affairs at the UN, that probably is not the best place to
coordinate anything. Maybe, for now, we let these organizations stand alone
as they "Pop-Up". Sometime in the future they will probably gel into an
central administration on their own.

Granted the world seems to think of the US as the last of the Super Powers,
but I don't believe we should begin to exercise that power in governmental
and regulatory areas. I seems to me to be a lot presumptuous of us to
decide that ONLY we know what's best for the rest of the world. That we
alone should set-up any governing body trying to set standards and
regulate(?) any global entity.

With specific reference to domain-naming process, I believe that since there
is already an international organization trying to address the many issues
associated with this process, that we get out of the loop and provide
whatever input we can to this organization. Our government SHOULD NOT
presume to set-up ANOTHER organization, in the US, with a charter as limited
as the one Mr. Magaziner's office has proposed. I do agree, obviously, that
the US Government should get out of the direct process and hand it off to a
private group. I just don't think that this group should; 1) necessarily be
located in this country, 2) be set-up with the restrictions that Mr.
Magazines office has proposed, and 3) be outside of existing organizations
already formed for this purpose.

Granted there are probably good reasons for Mr. Magaziner to suggest forming
a new organization. However, in the long run, I believe the global
community would be better served if we took off our blinders and tried to
listen to the rest of the world.

Dan Hughes, :-D

###

From: "Riffle, Stuart" <SRiffle@tibent.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 2/12/98 11:06am
Subject: Domain name changes (my 2 cents)

Telephone numbers are needlessly hard to remember and often far too
long. Unfortunately, a string of digits was the limit of technology when
they came into use, and that "standard" is still with us today.

The current scheme of internet addressing is equally arbitrary, and
evolved from programming convenience. It is, however, still young enough
to be killed without major repercussions. Most internet-aware software
would have to be updated to support a new format, but much of it is
regularly re-engineered for major operating system releases anyway.
Adding more area codes and prefixes allows for more phone numbers, but
doesn't make the archaic system any easier to use. Adding more top level
domain names allows for more site addresses, but
this.is.not.a.good.idea.either.gov.

I don't claim to know what the best way is. I *do* know that tacking
more limbs on the current system, while very easy, is not productive in
the long term. Domain names breed confusion: the same name might (and
often does) refer to a different site in each domain. If people have to
look through directories and use search engines just to find the site
they want, which is the way I have to find phone numbers, then what are
we spending all this money for? Might as well go back to digits, and not
tease people with the notion that site names can actually mean
something.

Wouldn't it be nice to just type "national weather service", and be
connected to the correct place? Let's not drive the current system into
the ground before we build one that makes sense.

Thank you for your time,
Stuart Riffle.

CC: "'wrash@cmp.com'" <wrash@cmp.com>

###

From: Paul Preston <ppreston@imsglobal.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/12/98 7:56pm
Subject: I Support CORE

To Whom It May Concern:

With the following I would like to express my support for the swift
implementation of the CORE system. I support:
-Internet Domain Name deregulation,
-Free Internet enterprise, and
-Internet self regulation
as stated in the plan submitted to the Administration by Jon Postel (head of
the Internet Assigned Numbers Authority)

For over three years now I have contributed to making the Internet the best
source for educational material for college students, instructors and
professionals.

I would like to continue contributing to the world community and provide
information services without the burden of government regulation but with
the flexibility and benefits of the CORE proposal.

As such, I have personally invested time and money toward the support of
CORE.

Finally, I believe that the CORE model is in congruence with the rights and
freedoms of all citizens and commercial entities around the globe.

I hope that the CORE model implementation will proceed swiftly and that this
administration will take credit for it.

Sincerely,

Paul Preston

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