From: gnana <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 12:22am
Subject: comments on internet registration domains

The internet was born in this country. It grew with the help of our tax
payers money. There is no doubt in my mind that that freeing the system
from the current monopoly by Network Solutions Inc. will accelerate the
grouth. But the plan put forth by the " Internet Council Of Registrars"
appears to be very dangerous to the future growth in commerce to the
U.S. companies. So please proceed cautiously. I like your deligent
approach compared to the radical approach advocated by Dr.Postel and
friends. Dev. A. Gnanadev. MD


From: digital division <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 10:37am
Subject: DNS suggestions

Dear Dept. of Commerce,

I am responding with a follow-up letter about our suggestions and comments
regarding the DNS system and the future of the Internet. The email is an
extension and review our meeting on Friday, March 6th at 1:30 with Chad
Folkening of Hunter Investments and Ira Magaziner and staff. Hunter
Investments suggests the following;

1. Form an independent Non-biase committee to receive, review and appoint
nominations for board members of the new corporation.

2. Develop a policy and exit strategy in case the new gtlds, the
non-profit corporation or the system fails or needs adjusting.

3. Allow more end-user input into IANA requirements and procedures for
testing, reviewing and auditing registry and registry applicants.

4. With of a two-tiered system (registry and registrar), cost for a domain
name should have a minimum and maximum pricing option.

5. Form a new body of law for trademarks to ensure all countries and
domains have same uniform parameters when a domain is in dispute.

6. Develop policy for making sure Ip numbers/ root servers/ domain names
interface uniformly.

We believe the most important concern is the stability and synergy of the
Internet. This includes how the market reacts and accepts the new tlds,
root servers, Ip addresses, the non-profit corporation and new problems and
conficts that arise will be solved. This process should not be rushed.
THe world is just beginning to revolve around the Internet and rushing the
process, before careful, complete input and evaluation, could severally
damage the global economy and its impact and influence on society.

Thank you for your time.

Chad Folkening- Hunter Investments,
A member of the DNSGroup
88 rogers rd
Carmel, In 46032


From: Randy Marshall <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 11:24am
Subject: Green Paper

In addition to the 7 gTLD extensions of .firm, .shop, .web, etc., you
should have also considered adding .mov for movies so that a movie will
not necessarily take up a domain name that would in other instances be
useful to a company. The reason I suggest this is that movies are very
often a short lived entity and frequently are only present on the web as
a domain name for a year or so.

Just a suggestion-
Randy Marshall
Metropolitan Video


From: <>
To: Karen Rose
Date: 3/10/98 11:49am
Subject: Iperdome Announces Registrar



Iperdome Changes Policies, Announces First "Registrar" for the ".per" Domain

Atlanta -- March 10, 1998. Iperdome, Inc. (, the company offering Personal Domain Name services under the .per(sm) name and Top Level Domain (TLD), today announced a restructuring to comply with the U.S. Government's Green Paper process. Iperdome also announced that it had established its first Registry/Registrar relationship with (

Earlier this year, the U.S. Government announced their long awaited plan for expanding the Domain Name System. While nothing in the domain name expansion debate is certain, the so called Green Paper appears to support existing TLDs like .per(sm). Iperdome now believes that Personal Domain Names are likely to eventually gain entry into the default root servers.

To prepare for that outcome, and to comply with the requirements of the Green Paper process, Iperdome has reorganized its business into Registry and Registrar functions. In addition, it has focused its core business on the Registry business, and made registration services for the .per(sm) name and TLD available at wholesale pricing to authorized resellers (Registrars). Other changes include the implementation of a Personal Privacy Policy, as well as Renewal Price Guarantees.

"In making these changes, we have prepared for the new competitive environment as described by the Green Paper process" said Jay Fenello, President of Iperdome. "We have also addressed issues raised by MoU supporters, issues like Personal Privacy and Renewal Price Guarantees. With today's announcement, we are positioned to offer Personal Domain Name services regardless of the outcome of the DNS debate."

Iperdome's first "registrar" is Founded in 1996, has grown to become one of the leaders in worldwide domain name registration services. This leadership is what attracted such companies as Ford, Baxter Healthcare, Chrysler, United Airlines, Iomega and thousands of small businesses and private individuals to use

"We see Iperdome and Personal Domain Names as leading the domain name expansion debate. To my knowledge, they are the only new TLD that offers their clients immediate world-wide visibility under other country code TLDs. They are actually giving three domains for the price of one!" said Chris Bura, President and CEO of "Their new policies are very good for the industry, and I'm pleased that has been selected to be the first Registrar to enter this exciting new arena."

Under the restructuring, Iperdome now offers Traditional DNS Services under three domain names for $34.95 per year. For an additional $15 per year, will provide registration, virtual hosting, personal homepage, and email forwarding services.

For more information, please contact:

Jay Fenello, President,
Iperdome, Inc
Chris Bura, President & CEO,


From: Bruce Cannon <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 12:50pm
Subject: Comment re: Technical Management of Internet Names and Addresses

Thank you for the opportunity to read you proposal and comment.

"A private coordinating process is likely to be more
flexible than government and to move rapidly enough to meet the
changing needs of the Internet and of Internet users. The private
process should, as far as possible, reflect the bottom-up governance
that has characterized development of the Internet to date."

I strongly disagree. If I had to select one of the strogest defining
characteristics of the internet, it would be its not-for-profit nature.
Without digressing into a debate about big government, let me simply
point out that commercial interests are not free of regulation. The
regulation which they impress upon a system is simply the profit motive
rather than the public good. A not for profit entity is the ONLY way to
insure the will of the public is served.

"Seven members designated by a membership association (to be
created) representing Internet users. 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, and one for individual
end users. The remaining seats could be filled by commercial users,
including trademark holders."

Why is the board designed to empower commercial users? The influx of
commercial users into the internet was an organic process; it doesn't
reflect devine providence.

"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."

This is absolutely what will happen.

"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."

When has this EVER been the case???


From: Chris Perleberg <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 4:19pm
Subject: Comments on Domain Name Document....


The problem with the document is the assumption that "competition"
will keep prices for domain names reasonable. Unfortunately, there
is nothing to stop annual fees (for existing domain names) from
rising to outrageous levels. Who can "" or ""
complain to if the controlling entity decides to raise the fees
to ridiculous levels? There is no "competition" that Ford and
AT&T can go to, if they want to keep the same domain name.

Because of this problem, I think two other possibilities should
be seriously examined:

1) An International Organization could provide domain name
service, at a reasonable cost, similar to an automobile
"license plate" registration. US$50/year is fine. Having
the Organization controlled by a board of technical people
would allow "innovation" to occur.

But the second possibility is a better solution yet:

2) Create a truly competitive environment: One way of doing
this is to allow the owner of a domain name to control the
destiny of the domain name. That is, the owner decides in
which registry (of the many competing registries) he would
would like to keep his domain name information. This would
keep costs low and would create competition that would
improve quality and reliability.
There are technical issues that would need to be resolved,
but this possibility creates the competition that the authors
of the Domain Name document are seeking.

By the way, I don't think the US Government should be afraid of
using legal action to regain control of the .com, .net, and .org
databases from Network Solutions. A little action now to rectify
the situation could save the world from having to deal with a
poor domain name system for the next few centuries. I'm also not
sure what the rush is to get the US Government out of the picture.
Better to take the needed time to design a reliable
well-constructed domain name system that has true competition, or
that has guarantees built-in with respect to pricing and service

Sincerely Yours,

Chris Perleberg


From: "Friedrich Kisters" <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 8:44pm
Subject: Comments on GREEN PAPER

Dear reader

Among others, I have read through Capital Networks' (CORE Registrar) response to the Green Paper, written by:
Ed Sweeney <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/9/98 2:35am

Allow me to say a few words on that.

Again: I doupt that there will be a strong competition among the registers of the CORE. If you take a look at how you can pre-register with them already now, you won't be able to find big differences concerning the pricing. After all, they all are "under the same roof", aren't they?

Trademarks: If there are trademark-conflicts on a country tld-level the problem seems to me much smaller, as most internet users will not try e.g. pepsi. ... with all country-tlds until they find something about pepsi or someone else using this name for its own purposes. And even if this would be the case, the number of users doing so, would probably be limited to the country they are living in.

This is of course completely different with the new gTLDs as they stand for a world-wide-reference.

Where would you try to find informations on e.g. "adidas"? At "", at "", or at "". Of course you'd first try "" and then "", but - unless you are living in Germany - certainly not "".

Therefore the responsability concerning new gTLDs is much higher than concerning country-tlds.

The mistakes which have already been committed shouldn't just be repeated, because of the strong economical interest of the CORE and others.

Concerning trademark-problems in any TLD I think we'd better stop using just the "punishment-method". If someone was clever enough to register e.g. when this important-company wasn't interested or didn't yet care about the internet - so what? Why sould this person be punished? Is it clever to punish clever people?

I don't think so. In my eyes it would be much better just to set limits. The "clever person" should be forced to hand over his important-company-domain-name to the important company, if that company in exchange is ready to pay e.g. 5'000 $ for it. This amount corresponds to a short advertising on tv and is unlikely to cause financial problems to the "important-company" (if it's interested in getting that domain-name).

On the other hand the "clever-person" wouldn't just be punished and - who knows - maybe she or he will build up a new, small company with that money. This would be a profit for the economy as such, wouldn't it?

Of course, some lawyers may not agree with me ... but their costs in any trade-mark dipute may be considerably higher than a general-5'000$-solution, as I'd like to suggest.

About the CORE:

The major problem about the CORE, as I have tried to show in my comment of 3/8/98, is not economical, but political. If the U.S. Government leaves the internet, it will be a step into the wrong direction. A better step would be to motivate the U.S. Government to ask other countries to join them in their responsability concerning the internet and to slowely develope something like the "United-Internet-Nations" (e.g. UNI) or build up a "Congress of Nations of the Internet", maybe called CONI.

In the internet, we will soon be faced with problems that need politcal solutions on a global, world-wide level. We ought to be prepared and not just glance on a possible short-time profit.

By the way, I wonder how the CORE knows that a majority of internet-users shares its opinion?! How do you know the opinion of people who just whatch, but don't like to talk too much? Don't you think that the real majority of internet users is in fact a "silent"-majority? Do they all share the COREs dogmatic opinion? I'm not so convinced as the CORE itself seems to be.

Maybe I'd have a better feeling towards the CORE, if they didn't demonstrate such an exaggerated self-consciousness and pretended responsibility for the whole internet. (Please excuse the strong expressions, but this is what I feel)

Of course the Green Paper cannot consider all opinions, but at least it is not just guided by one single opinion.

Please do not hesitate to comment on my thoughts. It is now an important, if not historical, moment in the development of the internet.

I am eager to learn about what you think, be it negative or positive and I am convinced the U.S. Government will apreciate your opinion, too.

Thank you for reading this comment. (You can find previous comments of mine at the following Dates: 2/14/98, 3/6/98, 3/8/98.)

Best regards

Friedrich Kisters

P.S.: I think the comment of Jim Fleming <> of 3/6/98 2:04pm as well as Paul Happ's comment (Date: 3/9/98 4:24pm) <> to be interesting.


From: <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/10/98 11:15pm
Subject: Please correct your Green Paper

-How can your government release a new policy on internet without
considering that INTERNET is mainly an abbreviation of two words
-You can't decide for the world (1 country, 1 registrar and 1 language)
-Leave this to an international non-profit organization like CORE
(gTLD-MoU). They understand the situation because they are closer to the
internet community (23 countries, 88 registrars and 12 languages)
-Why are you suing Microsoft when on the other hand you support
NSI monopoly and want to create 5 others with your GP, this makes no
- We are living a page of history on the Internet, let's ALL start on the
right foot by giving every member of the Internet, that is, the whole
equal representation and competition.
-The USGOV should sign and support the gTLD-MoU,
just go to:

Thanks for your time

Albert Y. Boud


From: the continuum <>
To: "''" <>
Date: 3/10/98 8:31pm
Subject: discussino draft

The American government should stick it's nose elsewhere and stay OUT of the internet, period. The track record of congress is dismal and inevitably anything they touch is fouled. STEER CLEAR OF THE INTERNET AND LEAVE IT WELL ENOUGH ALONE.