From: Collignon Francois-luc <collignon@netbay.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/25/98 5:49am
Subject: Green Paper is a $ ?

Monsieur Magaziner,

Si je vous écris dans ma langue maternelle c'est pour vous montrer que
le Net n'intéresse pas seulement Shakespeare mais aussi Molière, Dante
ou Goethe. Vous pouvez penser que le phénomène du Net est un produit de
communication destinée aux seules ménagères de l'Arkansas mais j'ai
connu votre merveilleux pays que j'aime avec de meilleures
considérations pour vos amis d'outre atlantique.
Le papier vert non seulement ne prend pas en compte le travail de tous à
travers le monde mais il me semble très dangereux pour l'avenir et la
stabilité du système.
Que veut dire une réforme vers de multiples registries incohérents sinon
diviser pour mieux régner ?
Les choses le plus simples sont les moins compliquées, si vous souhaitez
être en accord avec les fondements de la libre concurrence il me semble
que les registrars doivent avoir affaire, chacun, aux mêmes conditions
de travail. Comment argumenter du fait que des registries peuvent
s'entendre pour une meilleure stabilité du système ?
Quant à NSI, il me semble que j'ai versé grâce à eux 30% de taxes soit
environ 120$ représentant ma faible contribution à l'effort de votre
administration. Cela me donne le droit de vous demandez ce que vous en
avez fait. Mais je ne suis pas pingre et dans le passé vos parents ont
donné, eux, bien plus que 120$ aux miens, mais n'oubliez pas M.
Magaziner c'était pour vaincre l'obscurantisme et favoriser les idées de
liberté et d'échange à travers le monde. De cela nous ne vous dirons
jamais assez notre considération. A nous maintenant d'être à vos cotés
pour que vous ne l'oubliez pas.

Francois.

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From: Advanced Digital Research <jon@adr.weare.nh.us>
To: Advanced Digital Research <adr@weare.nh.us>
Date: 2/24/98 11:08pm
Subject: NTIA Internet Domain Proposal

I've have read the "Improvement of Technical Management
of Internet Names and Addresses" document and would like
to make a few comments based upon two concerns an
observation.

Section VI, A, 4, Paragraph 6:
In addition to the comment "fair, open and pro-competitive,
protecting against capture by a narrow group of stakeholders."
I believe the document should also include language that
ensures "accessibility" to small companies and individuals.
Currently, any individual who has the technical ability to
correctly fill out a Domain Name registration or change to
a Domain Name record, can do so. I believe this MUST be
maintained within the new private structure to help
ensure that registration pricing remains a minimal cost.

The document makes the following point of illustration:
"Companies that design Web sites for customers might, for
example, provide registration as an adjunct to other services.
Other companies may perform this function as a stand-
alone business."

I would like to avoid the situation where registration or
changing of domain name information must be done only
through a "partner" of the TLD registrar. The Appendix 1
specification for registrars does not adequately protect
consumers and competition if it does not allow registration
at the individual level. Please add language to this effect.

Section VI, B, Paragraph 6:
I don't believe the document nor its authors have given the
"lack of portability" concern the merit that it is due. In fact,
the document provides no evidence other than a belief in
"market competition" to assert that registration pricing will
remain reasonable. But what market competition? There
is only one .com TLD, one .net TLD. These are well
established and there is little reason to assume that any
current business or entity utilizing these domains are
likely to change. More importantly, it seems likely that
the new registry of the .com or .net TLD will realize this
as well.

While a new TLD such as .vend or .store may attract new
business, the odds of current businesses moving from
existing name space is remote. The document offers no
guidelines to prevent price gouging for established domains
and this could be a serious problem. The Internet business
community is very well established at this point and I don't
believe new TLD name space will be received with much
enthusiasm from the end users viewpoint.

Even amongst registrars, the potential for abuse is much
greater than the document would have readers believe.
The document provides no data in regards to the number
of registrars that will be available per TLD. If there is only
one registrar as with NSI today, or even only a handful
under the new proposal, where is the competition??
Competitive pricing is acheived by the availability of MANY
entities to provide the same service.

The document is severely flawed in regards to registration
pricing by relying on .com competing against .store and I
don't believe such competition will ever exist. There's a
difference between creating a .store TLD to rationalize
that competition exists, and having realistic expectations
that hundreds of thousands of current users are going to
change their name space to effect that competition.

The document MUST reevaluate the issue of competitive
pricing and the potential effects of registries creating a
lack of portability environment.

Section VI, E:
The following statement is deceptive, in that NSI also
charges $50/year for all subsequent years as well.
Readers of the document who are not familiar with the
registration process or the fees involved should
understand that the fees are (were) perpetual and not
only charged for the first two years.

"In 1995, NSF authorized NSI to assess new domain
name registrants a $50 fee per year for the first two
years."

Sincerely
Jonathan Wallace
ADVANCED DIGITAL RESEARCH
Weare, NH

###

From: James Risner <risner@stdio.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/25/98 11:25am
Subject: DNS

I operate an ISP in Lexington, Kentucky.
I have been administrating TCP/IP and Internet domains and ip addresses
since 1991.

I have a few comments.

First, I believe that there should not be any more TLDs, because it is
already difficult to secure
and keep safe your trademarks and name associations. We obtained both
the .com and .net version
of our name. Had there been a .firm, .isp, .comp, .fun, and so on, we
would also have to obtain these
so that other organizations do not use our name and potentially confuse
user trying to locate us.
This results in NO new options, since everyone will obtain all the new
".whatever" domains to secure
their position. All this really does is increase profits for the
companies dealing with these new top levels.
It does not create competition for the top levels. Maybe have several
second level pool companies.
Companies that maintain a secondary copy of your records, and you apply
with them to create your
"company.com" name. They have contracts with the ".com" authority and
delegate and/or maintain
secondary information from your servers about "company.com" for you.
Maybe having only a few of
these such companies and each obtain the same cut rate from ".com" say
like single digit $8 per year.
They in turn mark these prices up and sell to the public. Each of these
companies would maintain
a root server for free which would be operated by one separate
non-profit company to handle the organization of the delegations to the
15 or so "second level" root servers. Restated:
one company, called RootData, maintaining the root data files and the
delegation to one of the 15
ompanies for each "company.com" name to say company number 4. Company 4
would run their
server secondary to a server at "company.com" and offer the data to the
world from the ROOT
server (this improves performance). Company 4 would operate out of
their profit root server D (4)
as in D.root-servers.net. RootData would charge Company 4 $8 for each
domain Company 4 has
listed with RootData's information. Company 4 would operate capable
root servers with all
of RootData's data for free. Company 4 would operate on the same server
all their domains they
are servicing and charge the end user of the domain $50 a year, for a
profit of $42 a year.
RootData only operates a Single server on the Internet and it is not
used for serving anyone
except for the root-server.net servers. No end users would contact
RootData's server for information.
Whois information would operate on each root reseller (Company 4) and
only maintain the detailed
information of each companies clients. If the lookup is for a client of
Company 3, Company 4's server
would either a) lookup it up from Company 3's servers and return it, or
b) report that Company 3's
servers need to be contacted for this information.

How do you handle trademark disputes?
Make all purchasers sign that they own the right to use the name.
Only under court order does Company 4 change information for a
"company.com" link.
Company 4 (or any other including RootData) can not be in a lawsuit over
a domain name.
Let the legal court system handle name problems the same way they do
with company names
in the phone book or billboards.

James Risner
OpenWorld
Lexington, KY

###

From: John Burke <john@burkeis.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 2/24/98 9:32pm
Subject: domainname

Am hearing that data bases are already being established to purchase domain names under the new structures - with some for profit companies. Is this true - and if so how can such a system be viewed as fair. To my way of thinking its imperative that people have fair and equal access to domain name registration. No one should be able to register a domain name before a predetermined time - when registartion opens to the world. Also limits should be placed upon the # of names a company can purchase in a single instant.

John Burke

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