From: gnana <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/14/98 2:09am
Subject: internet registration

I have an advise for all the people who believe that an intrenational
body based in Switzerland such as CORE will be impartial and fair. Look
at the International Olympic Committe. His Excellency Samaranth hand
picks each member and controls it with iron fist. Do we need His
Excellency Postel and an elite group of regisrars supervising and
controlling the growth of Internet. Internet is still a child and U.S.
Govt. is it's parent. It will be the abdigation of the parental
responsibility to let it go suddenly. Cautious and gradual release into
the hands of a nonprofit international body based in the U.S. is the way
to go. Dev A. Gnanadev. MD.


From: MWHITNEY1 <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/14/98 10:43am
Subject: Technical Management of Internet Names and Addresses

Please consider the thousands of individuals who do not have vast finiancial
resources and who have registered domain names in the future regarding the
cost of renewing a domain name registration. $50 a year is already quite a
bit of money to invest in sites that were not intended to make money. The
cost of domain name renewal should only cover the cost of maintaining the
registration system hopefully managed by a international not-for-profit

Mark Whitney


From: Clmoore7 <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/14/98 7:11pm
Subject: Hands off the internet...

It's quite simple...there are so few venues of true freedom left! To start
regulating the last bastion of freedom I believe will destroy any passion this
country may still have for its' supposed "freedom".

Little by little, the government eats away at us until we are no longer the
America that I grew up in.

CL Moore 7


From: "David J. Anderson" <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/14/98 10:31pm
Subject: Technical Management of Internet Names and Addresses

Dear DoC,

Your paper stinks and is nothing more than a continuation of NSI\'s
monopoly. Sure, they won the bid from the NSF and were lucky by being
\'in the right place at the right time\' but that doesn\'t mean the
DoC has to stick its "Department of Commerce Approved Monopoly" stamp
on it. I thought government was generally against monopolies because
they keep prices high and usually give the end user crummy customer
service. Am I missing something?

How can you attempt to give NSI full power over the almighty .COM
(plus .net/.org) by being the sole company which gets to be a registry
and a registrar? Is that the DoC\'s way of providing a fair and level
playing ground for .COMpetition? Think again please.

NSI has done a poor job managing .COM and in no future scenario should
be allowed to have any special rights over this all important gTLD.
Give .COM to the people with no NSI strings attached and watch it
become a healthy and happy TLD. If you let NSI be the exclusive
registry of .COM/NET/ORG and also a registrar you are giving it an
unfair advantage over any future registrars. What is going to keep
NSI from building in significant additional costs for .com to
\'outside\' registrars which they themselves will not have to pay?
Have you thought of this problem?

As someone who has experience with helping the Network Information
Center (NIC) of a small Asian country automate their technical
functions, I can tell you that NSI has been milking the Internet for
millions more than it should be \'entitled\' to. It is not difficult
to automate what NSI does in terms of registering domain names under
.com/net/org. The NIC which I helped with has a cost of around US$4
per domain. Stake holders like Jay Fenelo (who is jumping up and down
screaming for competition with his .per domain) are right in the sense
that more choice can and should be available. Give these guys the
chance to compete with NSI on an equal footing and you\'ll see


Get your free address at


From: Champion67 <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/14/98 10:41pm
Subject: Proposed Regulations


I am alarmed that the Department of Commerce has published proposed
regulations of the internet. I have read the proposed regulations in their
entirety and do not agree with them for the reasons outlined below.
Furthermore, I am opposed to any regulation of the internet by the department
of commerce. As you know, and as many others have pointed out, the internet
and, indeed, the computer industry and the entire "information revolution"
have been astonishingly successful primarily due to a relative absence of
government regulation.

Any regulations by the U.S. Department of Commerce, no matter how well
intentioned, set a precedent for further attempts at regulation not only by
the U.S. government in the future, but by other governments all over the
world. This would be a disasterous development for the internet. I know that
your regulations are intended to be "temporary" and to minimize government
involvement. Nonetheless, it is inappropriate for the U.S. government, or any
government, to attempt to regulate the internet, especially in the sort of
detailed intrusive manner as the proposed regulations would.

The proposed "non-profit corporation" which would have regulatory authority
over the internet sounds like a private, as opposed to a government, solution.
However, similar regulatory schemes in the investment industry, such as "self-
regulatory organizations" like the National Association of Securities Dealers
(NASD) have imposed endless, stiffling and constantly changing regulations.
As the president of an NASD member firm, I am all too familiar with what
"self-regulation" means in practice. The proposed regulations sound like they
would impose similar "self-regulation" upon the internet with disasterous

The proposed "new corporation" would have the authority to license new Top
Level Domains and registries and registrars for domains. The new corporation,
would also control the "A" root directory. By virtue of those powers, the new
corporation would easily have the kind of powers currently exercised in the
investment industry by the NASD. The NASD also gives out licenses, just as
the proposed "new corporation" would license registries and registrars. The
"new corporation" is said to represent the internet "stakeholders" (a vague,
ill-defined term) by virtue of having a board of directors made up of people
from various interest groups. This is also true of the NASD board and has in
no way hindered the NASD from imposing mountains of crushing regulations on
its victims who in theory are only "self-regulated". The cost of complying
with NASD regulations is thousands of dollars per year for the smallest firms
it regulates and millions of dollars per year for large companies. In total,
it is costing countless billions every year in fees and compliance costs.
More importantly, the atmosphere in the investment business is one where
innovation is fraught with nightmarish "compliance issues" where everyone is
constantly afraid of running afoul of the rules and no one can possibly know
what all the rules are. This will happen to the internet if the proposed
regulations are adopted.

The following are specific criticisms of the proposed regulations:

(1) The regulations would require that anyone seeking to have a domain name,
or perhaps even an internet account would have to provide their name, address
and other information, plus have an ongoing liability to remember to provide
continuous updates of new addresses, phone numbers, etc. If this system were
implemented, I would expect that the first time it is discovered that someone
provided a ficticious name or failed to update their phone number, that new
regulations would be proposed requiring that people provide identification or
even fingerprints in order to be able to open an internet account and that
there would be substantial penalties for providing false information. Based
on my knowledge of the evolution, growth and enforcement of similar
regulations (such as those imposed by the NASD, which really does require
fingerprints from everyone even remotely connected with its licensees) I would
not be surprised to see people fined, expelled from the internet or even put
in jail a few years from now for the "offense" of forgetting to file a change
of address with the proper internet regulators. (or licensed domain name
registrars, to use terminology closer to yours). This has been the result of
a very similar scheme for "self-regulation" of the investment industry by the
NASD. This sort of regulation of the internet is not necessary, not
appropriate, and exceeds the constitutional authority of the United States
federal government. It may also exceed the geographic limits of U.S.
jurisdiction with respect to foreign countries.

(2) The proposed requirement that all domain name registrants enter into a
legally binding agreement to accept the jurisdiction of particular courts for
trademark or other disputes is an outrage, particularly the Department of
Commerce's suggestion that such jurisdiction would be a United States
jurisdiction or even the jurisdiction where the "A" root server is located.
Although I do live in the United States, millions of internet users do not and
this effort to bring every internet user in the entire world under the
jurisdiction of the United States' courts will be considered an absurd
suggestion by non-U.S. users of the internet. The effort to subject
foreigners to U.S. legal jurisdiction merely for registering an internet
domain name may even evoke diplomatic protests from foreign governments
including countries closely allied with the U.S. Looking at just a few of the
responses to this regulation from non-U.S. companies and users it is clear
that I about the views of foreign internet users. The idea of requiring
everyone to agree to just one jurisdiction (where the "A" root server) is
located, would be potentially inconvenient and inappropriate even for U.S.
residents who live in other parts of the country from the jurisdiction where
the "A" root server is located (currently near Washington D.C.) Notably, this
is similar to requirements imposd by NASD "self-regulation" where applicants
are not only required to agree to accept the jurisdiction of every state in
the country, but must even agree to give government officials power of
attorney for certain legal proceedings. It is routine for those under NASD
"self-regulation" to have to fly across the country to attend alternative
dispute resolution hearings even for charges which are transparently without
merit, are subsequently dismissed, and could have been dealt with in court by
mailing a preliminary motion for dismissal of the case. (There has never been
a complaint against me or my firm, but that is rare)

(3) The proposed regulations incluede a requirement that the private, Internet
Assigned Numbers Authority, (IANA) should be in some manner induced or coerced
into giving up its functions to the U.S. government. This is supposedly to
facilitate the transfer of those functions to a corporation created by the
U.S. government, the "new corporation" mentioned in the regulations. This is
an intrusive effort to increase the role of the U.S. government. Even if the
"new corporation" should end up being independent of government control, the
IANA has been carrying out these functions for many years. IANA's leader, Jon
Postel, helped design the Internet Protocols and the domain name system and
probably knows more about the subject than anyone on Earth. There is no
authority I am aware of for the government taking it away from them nor any
reason to believe that there is anyone better suited for the task than IANA.
If for some reason, IANA needs to be modified or replaced, IANA itself or the
internet community generally, through organizations such as the International
Ad Hoc Committee (IAHC) are well equipped to deal with the problem. It is my
understanding that the issuance by the U.S. Department of Commerce of proposed
of regulations has actually interferred with IAHC's efforts.

(4) The regulation proposes that the "A" root server operated by Network
Solutions, Inc. would be given up on instructions by the U.S. government.
This is to allow it to be given to a new non-profit corporation, though the
wording of the proposed regulation makes possible the seizure of the "A" root
server directly by the U.S. government. Network Solutions, Inc. is a
government created monopoly. Although the expiration of Network Solutions'
contract with the U.S. government is to be welcomed, this should not be an
excuse for the U.S. government to regulate the internet. As Jon Postel at
IANA demonstrated shortly after the U.S. Dept. of Commerce released its
proposed regulations, the internet can disconnect Network Solutions' "A" root
server at any time that the internet users agree on an alternative. It is not
necessary that the U.S. government take a role in breaking the monopoly held
by Network Solutions, Inc. in domain name registration. All that is necessary
is that the U.S. government stop supporting the Network Solutions' monopoly.
The proposed regulations would continue to grant Network Solutions' a favored
position by permitting Network Solutions to administer a registry with three
Top Level Domains (TLDs), specifically, .com, .org and .net, while all other
registries would be limited to just one, and only a few (5) favored companies
who complied with the regulations listed in the Appendices 1 & 2 would be
permitted to operate TLD registries at all.

(5) The proposal that registries be required to indemnify the proposed "new
corporation" for legal costs in connection with litigation is another example
of unnecessary and excessive regulation which puts those subject to the
regulations at a distinct disadvantage. This requirement is particularly
reminiscent of the type of unfair, excessive and burdensome regulations
imposed by the NASD which, like the proposed "new corporation" is a private
corporation, not controlled by the government, with a board elected by those
regulated by it. The similarities are striking.

(6) The special rules for expedited procedures for handling trademark
disputes, particularly within the first 30 days after registration are
reminiscent of the 20 day waiting periods for securities registration and
other seemingly simple regulations which plague the investment business and in
practice have been turned into enormous obstacles costing years and hundreds
of thousands of dollars to comply with. Licensing, waiting periods,
"alternative dispute resolution" and the other key elements of these proposed
regulations are direct parallels to the "self-regulation" imposed on the
investment industry. The Department of Commerce claims that this does not
constitute government regulation, but is instead, self-regulation by the
internet. The maze of rules, inspections, forms, electronic reporting,
licensing, fingerprinting of applicants, and even the requirements for
applicants to agree in advance to legal provisions making it easier for them
to be served with legal notices, to be hauled into non-judicial "alternative
dispute resolution" hearings imposed by the NASD are a testiment to what
"self-regulation" actually means. The only reason it seems that Trademark
holders would benefit from special protection in the internet is because the
court system in the United States is so woefully inaccessible, slow, expensive
and, in many cases, unfair. Trademark holders need a court system that
provides swift justice, not a maze of rules and regulations imposed on the

(7) Those people who only read the first few pages of the proposed regulations
heard absolutely no proposed rules, but lots of rhetoric on how the U.S.
government does not want to regulate the internet and will not regulate the
internet. Most of the actual proposed rules are actually relegated to the
Appendices. This has the effect, intentional or not, of grossly misleading
the readers who did not have the patience to wade through not only the entire
document, but the appendices as well. In fact, these proposed regulations are
interfering with the private International Ad Hoc Commitee's efforts,
establish a precedent for U.S. regulation of the internet down to its smallest
details, and outline a plan for "self-regulation" which sounds great, but is,
in fact a means for hyperregulation such as has been endured by the U.S.
investment industry at the hands of the NASD and other "self-regulatory"
organizations similar to the one proposed for the internet.

In summary, the proposed regulations should be rejected in their entirety, the
U.S. Department of Commerce should propose no rules whatsoever. The U.S.
Department of Commerce should allow the contract with Network Solutions, Inc.
to expire without trying to step in and set up a successor system. The
internet users can handle this without government interference. The U.S.
government should generally refrain from imposing any regulations on the
internet. The other governments of the world should refrain from imposing any
regulations on the internet and should repeal the ones they have already
attempted to impose. The United Nations should not, as some have proposed,
play any role in the management of the internet.

I would make these same recommendations even if there were broad support for
the proposed regulations. On the contrary, the general response from internet
users seems to be overwhelmingly against any government regulation of the
internet. For this reason more than any other, governments of the world
should respect the clearly expressed opinions of the internet "community" and
leave us alone.


Charles J. Champion, Jr.
Sunshine Securities Corporation
Member firm NASD, SIPC