From: "Michael 'traP' Bourdaa" <bourdaa@chem.ucla.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 4:38am
Subject: gTLD's and other alphabet soup.

The need for change in the current monopoly is apparent, however, I feel
that the need for a large number of gTLDs to be added may not be so acute.

I think it makes far more sence to subdivide .com by industry. For
example, WXYZ radio might become wxyz.am.com (or wxyz.fm.com, or if it has
a 'nickname', goldenoldies.fm.com, or whatever.)

Similarly, web sites like amazon.com might become amazon.buy.com,
indicating their primary purpose as online sales. Ford might become
ford.auto.com. IBM might be ibm.comp.com

Since this isn't feasable, for an overnight transition to these names (and
someone probably owns the short names like comp.com anyway), we use
something like biz, or inc. Leave .com as the "big business" type
addresses, with smaller, or more regional, sites taking less expensive,
hierarchal names.

I do believe, however, that adding a .sex, and requiring that any web
site, or other activity related to any pornographic activities on the
internet use .sex and ONLY .sex, will make it much easier for parents to
lock this out. Adults should, of course, be free to choose to view these
things or not. A severe penalty should be imposed on any violations of
this policy, and it should apply to all "spam" as well - the fines
collected could fund a lot of the reforms being done to the internet
hierarchy.

Anything else to be added could be done with the national domains (i.e.
.us, .ca, .mx). Specifically dealing with .us, I suggest that a set of
second-level domains, for parity with the global ones, be created, and
that these .us sites be the "lower" level, cost wise. The existing gov and
mil should be moved completely, while a new, and seperate, .com, .org, and
.net, should be added to the .us namespace.

In increasing order of "desirability", and increasing order of cost,
fully qualified domain names might then look like this:

trap.comp.com.us
trap.comp.biz
trap.com

The subdomains of .biz should be between 2 and 5 letters, and be easy to
remember. Also, the special name www. preceeding each hierarchy should
give a list of all the sites within that namespace, and short
descriptions. (i.e. www.comp.com.us would be an index of comp.com.us)

Lastly, a strong voice for internet users is needed in the administration
of this system. It might be advisable to eventually make internet
jurisdiction affiliated with, but not directly answerable to, the UN.

###

From: MARUYAMA Naomasa <maruyama@nic.ad.jp>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 7:52am
Subject: FYI Japanese Translation of the discussion paper

FYI

Probably you would like to see comments from Japan, so we have
translated the discussion draft into Japanese and put it into

ftp://ftp.nic.ad.jp/jpnic/domain/green-paper.txt

----
N. Maruyama (Vice President of JPNIC)
maruyama@nic.ad.jp

CC: NTIADC40.SMTP40("board@nic.ad.jp","committee@nic.a...

###

From: Andrew Lutts <andy@salemctr.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 8:43am
Subject: Comments on DNS Proposal

Dear Ira Magaziner,

I would suggest that whatever you decide to do, that you do it now. Further
delays will only slow the growth of the internet. You might not get it
perfect the first time around, but just do it.

I suggest that you add at least 5 - 10 new top level domain names. They are
sorely needed. Certainly you should add the .web domain from Image Online
Design, and you should add .per domain also for families and personal
domains. Other domains like .corp, .shop, .arts, .rec and others should be
considered too, with the best ones being added.

I do not feel that the copyright issue that large companies raise has
merit. It is not fair for large companies to have unfair advantage over
smaller companies that are trying to grow. Certainly if a copyright
infringement exists, we already have ways in place to address this and seek
a resolution.

As our government representative, we rely on you to help create a fair
level playing field for all those involved. This can only mean that you add
several new top level domain names to help enable all businesses,
organizations, groups, and private individuals utilize the internet in the
best possible way.

Thank you for your consideration,

Andrew Lutts, President
Salem Center for Computing
Salem Massachusetts

###

From: "Mark Mettler" <mmettler@earthlink.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 8:54am
Subject: Discussion Draft

Attention: Ira Magaziner

The draft is well prepared, but lacks the obvious. While the US government drags out the process, adds unnecessary burdens and further turns the Internet into a bureaucratic terror, other countries are taking a cue from our lack of resolve and are developing their own standards and networks. So, Domain Registration will become more of a nightmare. If the US is to lead the technological revolution of the Twenty-First Century it needs to dump the politicians and use the advise of the Internet community. We already see a splintering of the net due to the inability of the US to take any action. These new domain naming conventions are needed NOW! Not in two months or two years, but more like yesterday. While Justice is attacking Bill Gates and Microsoft, the government is assigning a pure NET monopoly to Network Solutions, Inc. to provide directory services. So Bill Gates is the monster and the Government never ever creates monopolies? Give us all a break and get on with it. Big Brother seems to be a big baby, unable to make any decision and live with it.

Mark Mettler
PGP Public Key available @
http://wwwkeys.pgp.net:11371/pks/lookup?op=get&search=0xD4AA3DB3
or VeriSign Digital Certificate @
http://www.verisign.com/securemail/welcome.html

###

From: "Paul Richard Fowlie" <fowlie@walt-disney.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 2:27pm
Subject: your proposal

Ira Magaziner:

Let the Internet be open to competition and democracy. The U.S. cannot control an international medium of communication. Let the new domain names take effect now.

Let .firm, .shop, .rec, .nom, .info, .arts, and .web become active through the gtld mou.

Thank you for making the right decision,

Paul R. Fowlie
AutoCAD Technician

###

From: "Samuel Warner" <samwarner@deal-maker.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 2:58pm
Subject: SAY NO TO THE GREEN PAPER

The U.S. Commerce Department has a lot of nerve assuming it can run the world's domain name system. The last time I checked, there are a few more people using the Internet than just Americans. While much of our sales business centers in the U.S., we are considering expanding to Europe. What are we supposed to tell European clients who are Internet users themselves? There is so much confusion as to what is happening with the new domain names. My clients are interested in the .firm and .shop domain names

. They are not satisfied with the InterNIC monopoly, and believe service could be much better if the new domains were introduced, thus creating competition. Let InterNIC have their .com; the new names are a long time coming. You know as well as I do that U.S. business will suffer if the green paper is successfully adopted.

Sincerely,

Samuel Warner
Sales & Marketing Executive

###

From: <lesage@altern.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 5:37pm
Subject: Papier Vert

N\'oubliez pas que Internet n\'est pas le propriete des Americaines.
Les autres pays du monde doit prendre la responsibilite
pour le system des domaines et doit supporter un Internet
internationale. La technologie est pour tous;
pas pour un monopolie de Network Solutions ou cinq monopolies..

N\'oubliez pas les autres qui utilise l\'Internet.

Veronique LeSage
vendeur des ordinateurs

###

From: "Ronald L. Yin" <ryin@limbach.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 5:35pm
Subject: Response to Proposal Dated January 30, 1998

March 2, 1998

Via Electronic Mail dns@ntia.doc.gov

United States Department of Commerce
NTIA/OIA
14th & Constitution Avenue, N.W.
Washington D.C. 20230

Re: Draft Proposal Dated January 30, 1998 to Improve
Technical Management of Internet Names and Addresses

Dear Sir or Madam:

I write in response to the draft proposal dated January 30,
1998 with regard to the U.S. Government's efforts to improve
technical management of Internet names and addresses and to
express my opposition thereto. I believe that the proposal
is seriously flawed and should be totally reconsidered. By
way of background, I am a practicing attorney who has
practiced over 20+ years in the field of intellectual
property dealing with high tech issues including trademark
and copyright. The views expressed herein are personal and
are not those of the firm or its clients.

I. THE PROPOSED DRAFT WILL NOT INCREASE THE NUMBER OF
GENERIC TOP LEVEL DOMAINS (GTLDS).

One of the purposes of the proposed draft is to increase the
number of gTLDs in an effort to mitigate conflicts between
trademark owners and others who seek to register domain
names that are *identical*. The proposal is to increase the
number of gTLDs from .COM (in the commercial sector) to five
(5) new gTLDs. Examples of the new gTLDs, widely reported
in the press, include .SHOP, .FIRM, etc. Thus, according to
the rational of the proposal, the creation of additional
gTLDs will enable company A desiring to register XYZ as a
domain name to register it as XYZ.COM whereas company B
desiring the same domain name can register it as, e.g.
XYZ.SHOP. I believe this assumption is flawed.

At the outset, it should be noted that for most of the
*large* clients that I represent, it is their intention not
to have
*fragmentation* in the domain names on the Internet. As a
result, those with large resources and famous marks would
register the mark in each and every one of the gTLDs that
becomes available. This would only increase the costs to
these clients and would not create additional domain names
by which others can register identical names.

At the same time, for a small client who does not have the
resources and who can afford to only register the domain
name under only one or a few of the generic top level domain
names, this proposal puts the small client at a
disadvantage. For example, a small client who can afford to
register only the domain name XYZ.COM, and who cannot afford
to register XYZ in each and every one of the newly proposed
gTLDs, would be forced to share the same name with another
who would register as XYZ.FIRM. This would fragment the
market and create confusion in the minds of the consuming
public. When the public seeks a URL address the public must
remember whether it is XYZ.SHOP, .COM, or .FIRM. In fact,
the White House and this administration is keenly aware of
the problem of fragmentation of the domain name
marketplace. WHITEHOUSE.GOV is the address for the
President and Mrs. Clinton. At the same time,
WHITEHOUSE.COM is a pornographic site. The public has
already been confused by the reference to WHITEHOUSE without
knowing whether it is .GOV or .COM. This administration is
aware of the use by WHITEHOUSE.COM for pornography and has
protested such use.

Therefore, the creation of additional gTLDs would not create
additional top level domain names for those clients who can
afford it and would actually place the small client at a
disadvantage who must share the fragmentation of the domain
names, including sharing them with *unsavory* information
providers. Since the benefit of increasing the number of
gTLDs is minimal and the detriment to the consuming public
as well as to the small business is tremendous, I urge the
reconsideration of this aspect of the proposal.

II. REGISTRATION OF DOMAIN NAMES AND MAINTENCE THEREOF
SHOULD BE A REGULATED INDUSTRY

Registration of domain names should be regulated as a
monopolistic industry.

One of the purported reasons given for the proposal with
regard to increasing the number gTLDs is to assign the
registration (and the collection of fees for the
registration) for each of the newly proposed gTLD to a
different entity. In this manner, according to the
proposal, market competition forces would drive the price of
registration and maintenance of the domain names to a *more
reasonable* level.

As discussed previously, the expansion of the domain names
to increase the number of gTLDs is not in the consuming
public*s interest. The fragmentation of the gTLDs would
create more market confusion. I respectfully submit that
the problem of NSI or any other entity having a monopolistic
position in the registration of the domain names and the
maintenance thereof can be cured by recognizing that the
registration process and the maintenance of the domain name
is a regulated industry and the government has a role in
regulating it. Just as the government regulates tariffs for
local telephone access or local utility access, where there
is only one provider, the access of a business to a domain
name registration should be recognized as one which is
monopolistic in nature and thus should be subject to
regulation by the government. This is one role that the
government has and it is indeed proper that the federal
government should take the role in regulating the domain
name registration and maintenance.

Finally, while I applaud the creation of a non-profit
organization in which the role of the government is
decreased and the function of the policy making and the
coordination development of other technical parameters
associated with the Internet can be transferred to the
non-profit corporation, this non-profit corporation should
provide the role of overseeing the Internet, i.e. regulating
and setting the fee for domain name registration and
maintenance.

III. RESOLUTION OF DOMAIN NAME DISPUTES

Unfortunately, the draft proposal did not address the issue
of resolution of domain name disputes. This is undoubtedly
one of the thorniest issues concerning the stability of the
Internet for commerce. The report states that NSI has
registered millions of domain names and only a fraction of
which has been challenged by a trademark owner. However,
due to an absence of predictability caused by non-existent
policies, this poses a major impediment to the viability of
the Internet as a vehicle for commerce.

At the outset, it should be recognized that trademarks are
territorial. In contrast, the Internet is global in nature
especially with gTLDs. Further, the registrant for the
domain name, such as NSI, does not have the capability of
adjudicating domain name disputes, intertwined with
trademark issues. With these facts serving as the
background, I suggest that any domain name dispute
resolution policy should take into the following
considerations:

1. The registrant for the domain names, such NSI, should
have no legal liability and should not be in a position to
adjudicate or resolve these types of disputes.

2. There may very well be disputes of domain names but for
which there is no trademark dispute. An example of this
would be an owner of a trademark XYZ solely doing business
in Germany, and registering for the domain name XYZ.COM and
a U.S. company solely doing business in U.S. also attempting
to register the identical domain name. In this case, due to
the nature of the gTLD, with both seeking the registration
of the identical domain name, there would be a domain name
dispute. However, there is no trademark dispute, because
each operates in a different territory. In addition, each
would have a legitimate right to have registrations on the
Internet and it would be inherently unfair to permit one
entity to have a superior right based solely upon it being
the first to apply for domain name registration.

One possible resolution is to require that all applicants
for domain names agree that in the event another seeks the
registration of the identical domain name that a web page be
created in which both names appear with links to their
respective sites. The cost of this *yellow page-like
directory* would be borne equally by all those who are
listed under the same domain name. From that page, links
would be made to the U.S. company listed on the directory
and to the German company also listed on that same
directory. An example of this can be found at
http://www.scrabble.com. The creation of these directories
may develop faster than the creation of a worldwide yellow
page directory.

Of course, the same mechanism, i.e. the creation of a
*yellow page-like directory* can be used, where there is a
trademark dispute in fact, with the directory maintained,
until the appropriate legal authority has adjudicated the
dispute.

In any event, it is important that the government in this
instance provide the leadership by proposing a domain name
dispute resolution mechanism.

Very truly yours,

Ronald L. Yin

###

From: "Mr. Burke" <mrburke@mail.bc.rogers.wave.ca>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 10:13pm

The time has come for regulating the growth of the Internet. The
exponential growth of both the size of the Internet and the number of users
has now surpassed all predictions. No longer a communications tool
for academics and military personnel, the Internet has reached a stage
where self-administration is no longer feasible. The time is now for the
government to take an active role to ensure the stability and the future
of this invaluable tool that is bringing education, commerce and
entertainment into the 21st century.
There are, however, some caveats regarding government intervention.
Specifically in the areas of competition of registries and registrars, and
the resolution of trademark disputes.

The government is correct in its decision to relinquish its role in
governing of the Internet and the distribution of Domain Names. Yet the
method is flawed. Switching from a system whereby a single company
(Network Solutions) enjoys a monopoly over the registration of all TLDís to
one in which several companies have individual monopolies over individual
TLDís creates a situation whereby there is only slightly more competition.
For instance, if I am a retailer wishing to register my operation for the
purpose of on-line commerce, the domain name mystore.shop does not compete
directly with the domain name
mystore.arts. There must be competition between registrars for each of the
TLDís and the only apparent solution is to give all registrars access to
the newly available TLDís from a single, shared registry.
Emergent Corporation is currently developing such a solution, called the
Shared Registry System in response to this need. It is not apparent why the
US government opposes this system.

In regards to trademark disputes, there MUST exist a single set of rules
and a single judiciary governing all TLDs. The only alternative to this
would be a disjoint group of beauracratic systems making domain name
registration with several TLDs a virtual nightmare for companies and
organizations. For example, if I want to register myco.com, myco.firm,
myco.shop and myco.web but a ìcyber-squatterî beat me to it, I would have
to challenge each TLD name separately, to four different governing bodies
operating under four different sets of rules. Again, there is already an
internationally accepted framework, the gTLD-MOU, to serve this purpose.
This should be the basis for dispute resolution.

Let us regulate the growth and development of the Internet, that is,
monitor its expansion, but move ahead. Regulating growth is not the same as
slowing it down.

Sincerely,

Eric B. Burke

---
Stolen pleasures are sweetest.

###

From: "dave texidor" <superordinary@hotmail.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 12:36am
Subject: leave the Internet alone!

enough said!
dave texidor
u.s. citizen

______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com

###

From: "Jimmie Haines" <Jimmie_Haines@nsist.unomaha.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/3/98 4:26pm
Subject: Blue Ribbon Panel Member Recommendation

The University of Nebraska is currently deploying a paradigm shift in computing
and engineering educational programs. These new programs include creating a new
college of Information Science & Technology and a new Instititue of Information
Science, Technology & Engineering representing integration of engineering and
information disciplines. In addition, a new facility is under construction
(approximately 25 % complete) to house the new college IS&T college, now in
temporary quarters, and the new institute of IST&E.
I recommend that the Dean of the new College of IS&T, Dr. Michael Mulder be
added to your "blue ribbon" panel.

CC: NTIADC40.SMTP40("mmulder@unomaha.edu")

###