From: Jay Fenello <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/23/98 3:41pm
Subject: Iperdome's Response to the Green Paper

Before the
National Telecommunications and Information Administration
Washington, DC 20230

In the Matter of )

Notice of Proposed Rulemaking

Comments of Jay Fenello, Iperdome, Inc.

Jay Fenello,

Iperdome, Inc.
1150 Lake Hearn Dr., Suite 200
Atlanta, GA 30342
+1 404-250-3242

23 March 1998

Jay Fenello respectfully submits comments in this proceeding
published at 63 F.R. 8825 (No. 34, Feb. 20, 1998).

Jay Fenello is the President of Iperdome, Inc., a new company
offering Personal Domain Name services under the .per(sm)
name and Top Level Domain. He has been active in the DNS
debate since Iperdome formed in January 1997. He was . . .
- one of the founders of the eDNS movement.
- one of the first to ask for the U.S.
Government to review the activities of the IAHC.
- the only small company representative to attend
the White House's IATF meeting on June 9th.
- one of the invited speakers at the Domain Name
Conference sponsored by the ITAA, CDT, and ISA.
- one of the first to frame this debate as
one of control, not domain names.

>I. Introduction

Although many do not yet realize the importance of these deliberations, the
Internet is about to undergo a birthing process. When it is complete, we
will have established some ground rules for the newest human frontier.

Those who have ventured forth into the ether have found a new world -- one
of ideas, freedom, and commerce. In fact, there is little that we do today
that we won't someday do on the Internet. Things as common as working,
shopping, attending school, visiting friends and relatives, even traveling
will be available in our emerging cyber world.

What these deliberations are about is how we will get along in this cyber
world, who is in charge, and who gets to decide those questions that can
only have a single answer on the Internet.

Domain Names just happen to be one of those things. To retain a single,
unified root, there must be a single decision making body. The MOUvement
and the US Government both have very different solutions to this question.

The MOU puts a very small group of stakeholders in charge of these
decisions. It features closed meetings and discussions, no due process,
has little if any representation, and is set up as a Swiss based cartel to
avoid anti-trust considerations. It creates a highly controlled,
bureaucratically administered name space, instead of a free market approach
that has fueled much of the Internet's world wide growth.

In addition, the IAHC process broke long standing Internet traditions when
it discarded draft postel, and it ignored existing working code. It also
included organizations like the ITU that were previously known to be
hostile to the private networks that make up the Internet.

Finally, the MOU goes to great lengths to define the name space as a public
trust. This insidious designation has far reaching consequences that are
not obvious to the casual observer. Primarily, this designation invites
governmental intervention from the likes of the ITU. It is important to
note that, by definition, the name space is NOT a public trust. Please see
the analysis as prepared by Open-RSC for more information on this topic:

In closing, we appreciate the efforts of the U.S. Government in the
preparation of the Green Paper and this proceeding. Iperdome agrees with
most of the content of the Green Paper, and respectfully offers the
following suggestions for its improvement:

>IV. The Future Role of the U.S. Government in the DNS
> This discussion draft, shaped by the public input described above,
>provides notice and seeks public comment on a proposal to improve the
>technical management of Internet names and addresses. It does not
>propose a monolithic structure for Internet governance. We doubt that
>the Internet should be governed by one plan or one body or even by a
>series of plans and bodies. Rather, we seek to create mechanisms to
>solve a few, primarily technical (albeit critical) questions about
>administration of Internet names and numbers.

While it would be extremely unpopular for the scope of this paper to
propose a monolithic structure for Internet governance, Internet governance
MUST be addressed here and now.

As we have always suggested, the DNS situation must be resolved quickly but
Internet governance must be allowed to evolve over time. That evolution
must be structured through this process.

For now is when the last vestiges of an authority on the Internet are to be
exercised in the formation of an independent organization. Once complete,
that transfer will be almost impossible to undue, given the international
nature of the Internet and the lack of any jurisdictional precedents.

>V. Principles for a New System

In addition to the principles stated, we strongly support efforts that
limit oversight and regulation to the absolute minimum required to retain
stability in a fair and robust system.

>VI. The Proposal

>A. The Coordinated Functions

> The U.S. government would gradually transfer existing IANA
>functions, the root system and the appropriate databases to this new
>not-for-profit corporation. This transition would commence as soon as
>possible, with operational responsibility moved to the new entity by
>September 30, 1998. The U.S. government would participate in policy
>oversight to assure stability until the new corporation is established
>and stable, phasing out as soon as possible and in no event later than
>September 30, 2000. The U.S. Department of Commerce will coordinate the
>U.S. government policy role. In proposing these dates, we are trying to
>balance concerns about a premature U.S. government exit that turns the
>domain name system over to a new and untested entity against the
>concern that the U.S. government will never relinquish its current
>management role.

The devolution of the current NSI monopoly, addressing the grievances that
have occurred over the last couple of years, and the corresponding
expansion to the name space should all proceed with all due speed. To do
otherwise allows the currently unfair position of NSI and other chosen
registry operators an unfair windfall at the expense of the Internet
community and the free market entrepreneurs who have been diligently trying
to enter this industry.

That's not to say the new gTLDs must be entered into the root tomorrow,
only that a definitive policy must be announced that will enable all
participants to plan for that eventuality.

The establishment of "the new corporation" should be thoroughly discussed,
and after consensus is reached with International and domestic stakeholder
communities, should be established in as secure and protected manner as
possible. This implies a congressional charter.

> The board of directors for the new corporation should be balanced
>to equitably represent the interests of IP number registries, domain
>name registries, domain name registrars, the technical community, and
>Internet users (commercial, not-for-profit, and individuals). Officials
>of governments or intergovernmental organizations should not serve on
>the board of the new corporation. Seats on the initial board might be
>allocated as follows:

The ISOC and its affiliated I* organizations are directly responsible for
many of the fissures that now exist in the Internet community. They no
longer live up to their self proclaimed definition:

"The Internet Society is the international organization
for global cooperation and coordination for the Internet
and its internetworking technologies and applications."

Rather than cooperate and coordinate, they continue to split the Internet
community in a fatalistic attempt to implement their power grabbing scheme
at all costs.

For these reasons, the U.S. Government must be very careful in composing
this new board. We suggest that the ISOC and its affiliated organizations
be censured from involvement in the initial composition of this board.

We would prefer to see the ISP/C or some other newly constituted
organization used to provide this initial representation.

> Two members designated by the Internet Architecture Board
>(IAB), an international membership board that represents the technical
>community of the Internet.

The IAB is closely affiliated with the Internet Society. Given the recent
actions of the ISOC, under their current leadership, any organizations
affiliated with or appointed by the ISOC should be considered suspect.
Iperdome suggests that other Internet and Industry organizations like the
ISP/C, NANOG or the IETF are better organizations for the stated purpose.

For more information about the IAB and its history, please see:

> 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.

Again, the ISOC should be disqualified from inclusion in this
representation. Some organizations to consider include CIX, ISP/C, DNRC,
ISA, ITAA and the CDT.

>B. The Competitive Functions

> Some have made a strong case for establishing a market-driven
>registry system. Competition among registries would allow registrants
>to choose among TLDs rather than face a single option. Competing TLDs
>would seek to heighten their efficiency, lower their prices, and
>provide additional value-added services. Investments in registries
>could be recouped through branding and marketing. The efficiency,
>convenience, and service levels associated with the assignment of names
>could ultimately differ from one TLD registry to another. Without these
>types of market pressures, they argue, registries will have very little
>incentive to innovate.

We strongly agree with this position.

> 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.

These are valid concerns that can be solved without resorting to a single
monopoly registry, nor resorting to exclusively non-profit registries.

Iperdome, for example, has implemented Renewal Price Guarantees.
Basically, we promise to never charge existing clients more for their
renewal fee than the Suggested Retail Price at the time of their original
name reservation (adjusted for inflation).

Other groups, like Open-RSC have proposed solutions like a Domain Name
Holders Bill of Rights (Appendix 4), and a Registry Code of Ethics
(Appendix 5).

We believe that these issues can and should be addressed using industry
standards and competitive market forces.

>C. The Creation of New gTLDs

> Internet stakeholders disagree about who should decide when a new
>top-level domain can be added and how that decision should be made.
>Some believe that anyone should be allowed to create a top-level domain
>registry. They argue that the market will decide which will succeed and
>which will not. Others believe that such a system would be too chaotic
>and would dramatically increase customer confusion. They argue that it
>would be far more complex technically, because the root server system
>would have to point to a large number of top-level domains that were
>changing with great frequency. They also point out that it would be
>much more difficult for trademark holders to protect their trademarks
>if they had to police a large number of top-level domains.

The market will adapt to any fair policies that are implemented on a
non-discriminatory basis. Specifically, new gTLD creation should be
available to all companies large and small, without regard to country of

> We believe that during the transition to private management of the
>DNS, the addition of up to five new registries would be consistent with
>these goals. At the outset, we propose that each new registry be
>limited to a single top-level domain. During this period, the new
>corporation should evaluate the effects that the addition of new gTLDs
>have on the operation of the Internet, on users, and on trademark
>holders. After this transition, the new corporation will be in a better
>position to decide whether or when the introduction of additional gTLDs
>is desirable.

While we understand the rationale for a limit of five new gTLDs, we don't
necessarily feel that is enough. Rather, we prefer a process as outlined
in Open-RSC ( that's
referred to as a gating function.

Here, a new gTLD will be added every month. Based on the impact of these
additions, this process can be slowed, stopped, or if no problems are
encountered, increased.

>D. The Trademark Dilemma

Historically speaking, Iperdome has not taken much of a position with
regard to the Trademark Dilemma. This is primarily due to the nature of
our TLD, which by definition, is "personal" in nature.

It is our belief, however, that the Trademark issue is the fundamental
roadblock standing in the way of new gTLDs. For this reason, we
respectfully submit the following analysis and proposal:

According to the USPTO, A TRADEMARK is either a word, phrase, symbol or
design, or combination of words, phrases, symbols or designs, which
identifies and distinguishes the source of the goods or services of one
party from those of others.

While there is a clear need to provide similar protection for the sources
of goods and services visible on the Internet, the fundamental problem is
that Domain Names are not Trademarks, and Trademarks are not Domain Names.

Trying to map literally millions of Trademarks, in hundreds of
jurisdictions, across multiple classes of goods and service into a single,
global name space is simply not possible. Any attempts to do so results in
an unnatural expansion of trademark law outside it's current scope, and
inhibits innovative growth in favor of commercial protectionism.

Current proposals to deal with this situation have many problems.
First, they allow any Trademark owner in any jurisdiction to contest any
Domain Name after it has already been issued. Complex arbitration and
appeal procedures have been proposed to deal with this approach.
Unfortunately, the aggregate overhead associated with this approach is
huge, since every single registration is subject to claims of infringement,
arbitration, appeal and further law suits.

Second, they don't recognize the inherent differences between Trademarks

and Domain Names, nor the physically impossible task of mapping existing
Trademarks onto the global name space.

For example, there are many Trademarks like "Prince" that are protected in
multiple jurisdictions under multiple classes of products or services.
Trying to map these Trademarks onto the name space results in multiple
conflicting parties that have a legitimate claim to use that mark in the
global arena.

The domain name system should not allow one of these multiple, legitimate
users of a mark to circumvent "First Come, First Serve" rules by preventing
others from using that mark in a global domain name. On the other hand,
there are certain marks that should never be used by others in a domain
name (i.e. IBM).

The questions is, where do you draw the line?

To provide a mechanism to restrict uses that are clearly not allowable
while permitting those that are, Iperdome suggests an alternate form of
protection for the small number of companies that are truly entitled to
global protection of their name and their mark:
"According to research widely attributed to D&B, less
than 50 companies do business in more than 50 countries,
and less than 200 companies do business in more than 30

Iperdome believes that it makes more sense to deal with this problem from
the perspective of the 200 or so companies likely to be most affected from
domain name infringement.

To solve this quagmire for marks that already have globally recognized
significance, Iperdome proposes the following:
The establishment of a private certification of world
wide Trademark status known as a "Domain Mark"(sm) and
represented by a stylized, lowercase (dm)(sm) surrounded
by a circle. It will be awarded in a process similar to
that used by Underwriters Laboratory (UL) to certify
electrical appliance.
This mark will be awarded to companies that meet certain global recognition
standards that Internet stakeholders or the new non-profit corporation
shall set.

For example, one such standard could be that any company that can show that
they have existing Trademark protection in more than 50% of the global
Internet community shall receive this designation.

To prevent Trademark infringement, all new gTLD "Registries" would agree to
check a publicly available database for these global Domain Marks(dm)(sm)
before issuing a new registration.

Concurrent with this submittal, Iperdome has started this "for-profit"
Domain Marking Service. (

For a fee of $4,995 per year, Iperdome will independently verify all claims
to foreign and domestic Trademarks through the independent law firm of
Hassett, Cohen, Beitchman & Goldstein, with all verification costs to be
billed separately. (

Iperdome will then publish these independently confirmed results in a
shared database in a standard format so that every "Registry" world-wide
can do a free Domain Mark(dm)(sm) search before issuing a new domain name.
Clients who meet the requirements for a Domain Mark(dm)(sm) as established
above will be designated as such, and any attempts to register that mark
will be refused.

Some will argue that it is inappropriate for a private company to profit
from this service.

We would argue that, especially on the Internet, Intellectual Property is
the most valuable commodity. Those who solve difficult problems through
creativity, risk taking, exposing themselves to ridicule, etc. deserve to
be rewarded for their efforts.

Should we lose this argument, however, Iperdome will be happy to spin off
this service to an independent organization (profit, non-profit, or
otherwise) to serve the greater good of the Internet community.

>VII. The Transition

> 5. The new corporation must establish processes for determining
>whether an organization meets the transition period criteria for
>prospective registries and registrars.

The USG must also address the pending grievances of those who have been
harmed under the apparently illegal and anti-competitive activities of the
IANA and other government authorized entities as part of this transition plan.

>A. The NSI Agreement

NSI has received many benefits through its contract with the USG. Since
NSI has fulfilled the terms of their contract in a responsible manner,
neither they nor their shareholders should be penalized.

At the same time, they should not receive special consideration either. If
it is decided that new gTLDs will be added to the root, one per "Registry",
then NSI should be held to this same standard. Consequently, in this
event, they should be required to divest two of their three gTLDs.

>B. Competitive Registries, Registrars, and the Addition of New gTLDs

> Over the past few years, several groups have expressed a desire to
>enter the registry or registrar business. Ideally, the U.S. government
>would stay its hand, deferring the creation of a specific plan to
>introduce competition into the domain name system until such time as
>the new corporation has been organized and given an opportunity to
>study the questions that such proposals raise. Should the transition
>plan outlined below, or some other proposal, fail to achieve
>substantial consensus, that course may well need to be taken.

Many companies have tried to enter this new industry, and many companies
have been wronged in their quest. Some have paid $10,000 to a group who
has failed to follow through on their promises. Others have invested
significant time and money, only to find their options limited because of
unfair trade practices and collusion.

Ultimately, it is the U.S. Government that is directly, although not
deliberately, responsible for this very contentious situation that now
exists in the Domain Name Expansion debate.

The U.S. Government is directly responsible because certain government
contractors were operating without proper supervision, and engaged in
certain anti-competitive and potentially treasonous activities. This was
recently highlighted when one contractor re-directed more than half of the
world's root servers to an alternate source.

The U.S. Government is not deliberately responsible because many of the
actions of these contractors were cloaked in technical details, and easily
hidden. Complicating matters even further were the number of funding
sources and points of supervision. Finally, decisions made to accommodate
moderate growth were inadequate in the bright light of the exponential
growth the Internet has experienced.

So while we understand that the U.S. government would prefer to stay its
hand, we would argue that the U.S. Government is obligated to address the
grievances of the various groups as part of the solution, and as part of
the transition plan.

>Registries and New gTLDs
> This proposal calls for the creation of up to five new registries,
>each of which would be initially permitted to operate one new gTLD. As
>discussed above, that number is large enough to provide valuable
>information about the effects of adding new gTLDs and introducing
>competition at the registry level, but not so large as to threaten the
>stability of the Internet during this transition period. In order to
>designate the new registries and gTLDs, IANA must establish equitable,
>objective criteria and processes for selecting among a large number of
>individuals and entities that want to provide registry services.
>Unsuccessful applicants will be disappointed.

Iperdome also supports a go slow approach with regard to actually adding
new gTLDs to the root. Rather than an arbitrary limit of five, however, we
suggest that other factors determine the exact number.

As mentioned above, we feel that the USG has an obligation to address the
current grievances of those who have been harmed by the actions and
inaction's of certain US Government contractors before the new non-profit
corporation takes over.

Current estimates indicate approximately 15 companies have actively
participated in approximately 200 free market TLDs (Appendix 3). Actively
participated, in this case, includes TLDs that have been defined, publicly
announced, with at least a SOA record in the alternate root zones.

This criteria can be further defined to include tests for actual
operational intent and execution. Even today, many on this list are not
properly configured, are not accepting registrations, have little or no
data in their TLD zone, have no lookup capabilities, and have not been in
continuous operation. Using these more stringent tests, there would only
be around five companies representing about 25 gTLDs.

And, as a totally self-serving exercise, only Iperdome meets all of these
requirements and offers our clients immediate visibility in the Legacy Root
Zone (under the .nu and .to TLDs).

We should also include and CORE. While they may or may not meet
the criteria outlined above, they also have pending claims for certain TLDs.

By way of compromise, Iperdome suggests that each of these organizations
get to choose one gTLD to develop. The rest will become available to other
entities on the net. This implies that NSI will divest itself of two
existing gTLDs.

Depending on the actual criteria used, that would mean at most 20 new
gTLDs. It would also eliminate many lawsuits and years of additional
delays and fighting.

To summarize, Iperdome suggests:
- Increase the number of transitional gTLDs from 5 to
at most 20 to accommodate a brokered solution for
existing claimants to new gTLDs.
- Use a gating function to add one new gTLD per month, and
adjust this rate depending on experience.
- Use the new Domain Mark (dm) procedure to protect
multinationals from Trademark infringement in cyberspace.

>E. The Process

There is a certain order to pending events that will make this transition
process work more smoothly.

1. A decision must be made as to which registries have a legitimate claim
to a new gTLD, as well as their relative position in the queue.

2. The technical, financial, and managerial requirements for a Registry
must be finalized.

3. The gating function should be implemented based on the order in which
the legitimate claimants (as defined in #1) prove their compliance with the
final Registry requirements (as defined in #2).

Finally, claimants should be allowed to trade their position in the queue.

For example, even though Iperdome has signed agreements to upgrade our
technical capabilities to meet the proposed terms of the Green Paper, and
could do so in short order, we would prefer to gain entry in three to six
months. This would give us time to plan for a coordinated launch with
media and our industry partners.

Other registries, like IO Design, might opt to be first in line. Once the
three decisions above are made, however, the market can easily resolve the
order of new TLD entries.

>Appendix 1--Recommended Registry and Registrar Requirements

>Registry Requirements

While desirable, these requirements represent a step beyond where any
Registry is today. Only a handful are even close, NSI being one of them.

The vast majority of TLDs, especially among ccTLDs, have substantially
lower standards. That's not to say the higher standards are not desirable,
only that they are overkill for most TLDs.

Iperdome suggests a sliding requirement scale that becomes stricter as the
number of SLDs in a zone increase. The same standards should apply to
ccTLDs as to gTLDs, based upon SLDs per zone.

Given free market competition, infrastructure will likely be enhanced as
needed to respond to unique factors and to position one gTLD over another.

For example, commercial transactions may eventually require some type of
"Secure DNS" to facilitate commerce. If .biz were to implement this value
added service, they might have a competitive advantage in the commercial

At the same time, it might not make sense for other TLDs like .per(sm) to
incur the bandwidth overhead to provide "Secure DNS" to individual
Netizens. The market is the best decision maker in this regard.

>Registrar Requirements

Technical requirements for Registrars are probably too strict, fiduciary
responsibilities are probably not strict enough.

>Appendix 2--Minimum Dispute Resolution and Other Procedures Related to

As outlined above, Iperdome supports a prevention strategy rather than a
reactive strategy. Not only will this be far less expensive, but it will
enable better privacy rights for registration information.

One of the big issues that apply especially to Personal Domain Names is one
of privacy. Iperdome currently has a policy to release personal
information on an as-needed basis only. We consider making detailed
ownership information publicly available on private Netizens as an
unnecessary infringement on their privacy.

Appendix 3 -- A Concise List of New TLDs That Appear Real.

as prepared by Richard Sexton for Open-RSC:

TLD Steward Operational
=== ======= ===========


800 VRx, Bannockburn, Ont, CA. Jul 96
888 VRx, Bannockburn, Ont, CA. Jul 96
FAQ VRx, Bannockburn, Ont, CA. Jul 96
DDS VRx, Bannockburn, Ont, CA. Jul 96
ZOO VRx, Bannockburn, Ont, CA. Jul 96
LLB VRx, Bannockburn, Ont, CA. Jul 97
PRICES VRX, Bannockburn, Ont, CA. Jul 97
GALLERY VRx, Bannockburn, Ont, CA. Jul 97
NIC VRx, Bannockburn, Ont, CA. (Jan 96)
SQL VRx, Bannockburn, Ont, CA. Feb 98
LIST VRx, Bannockburn, Ont, CA. Feb 98
GMBH VRx, Bannockburn, Ont, CA. (Jul 96)

ENT ITC Canada, Toronto, Ont, Ca. Aug 96
SEX ITC Canada, Toronto, Ont, Ca. Jun 96

SKY ATC Canada, Toronto, Ont, Ca. Aug 96
ART ATC Canada, Toronto, Ont, Ca. Aug 96
ARTS ATC Canada, Toronto, Ont, Ca. Aug 96
BANK ATC Canada, Toronto, Ont, Ca. Jan 97
DIR ATC Canada, Toronto, Ont, Ca. Jan 97
FILM ATC Canada, Toronto, Ont, Ca. Jan 97
FUND ATC Canada, Toronto, Ont, Ca. Jan 97
HELP ATC Canada, Toronto, Ont, Ca. Jan 97
RADIO ATC Canada, Toronto, Ont, Ca. Jan 97
VIDEO ATC Canada, Toronto, Ont, Ca. Jan 97
HOTEL ATC Canada, Toronto, Ont, Ca. Jan 97
MUSIC ATC Canada, Toronto, Ont, Ca. Jan 97
ISP ATC Canada, Toronto, Ont, Ca. Jan 97
ZINE ATC Canada, Toronto, Ont, Ca. Jan 97
MED ATC Canada, Toronto, Ont, Ca. Jan 97
XXX ATC Canada, Toronto, Ont, Ca. Jan 97

EUR Netnames, Lodon, UK May 96

WEB IO Design, San Luis Obispo, Ca, US Jul 96

BIZ Macro Computer Solutuions, Chicago, Il, US Dec 95
NPO Macro Computer Solutuions, Chicago, Il, US Dec 95
K12 Macro Computer Solutuions, Chicago, Il, US Dec 95
CORP Macro Computer Solutuions, Chicago, Il, US Dec 95

ANIME Software Customization Aug 97
SOFT Software Customization Aug 97

USVI de Blanc, St. Thomas, USVI Aug 96
TOUR de Blanc, St. Thomas, USVI Aug 96
ZONE de Blanc, St. Thomas, USVI Aug 96

MALL UNIR, Napierville, IL, US Mar96

HIGGS Higgs America, Wash DC, US Jun 96
NEWS Higgs America, Wash DC, US Jun 96
COUPONS Higgs America, Wash DC, US Jun 96
REBATES Higgs America, Wash DC, US Jun 96

FREE Nair, Selangor, Myandar May 96

FAM Lanminds, Berkeley, CA, US Aug 96

PER Iperdome, Atlanta, Ga, US Jan 97
LIVE Iperdome, Atlanta, Ga, US Mar 97
CHIRO Iperdome, Atlanta, Ga, US Mar 97

I Page Optometry, Pleasenton, Ca, US Mar 97
A Page Optometry, Pleasenton, Ca, US Mar 97

GAY Cognoscenti, Chicago, Il, US Mar 97

VID ???? Apr 97

Appendix 4 -- Domain Name Holders Bill of Rights


A domain name holder has the right to reasonable service.

A domain name holder has the right to use their domain for any
legal purpose consistent with the published policies of the
registry involved.

A registry shall not act to in any way interpret the potential
legality of any use of a domain. Only a court of appropriate
jurisdiction and venue can make such a determination and it is
an inalienable right of a domain name holder to operate under
the expectation that the registry will not intervene unless so
ordered by the courts.

A Registry will publish their TLD fee raising schedule.

A Registry will publish their invoice terms and their removal
schedule for non-payment of invoices.

A Registry is not obliged to make a domain operational prior
to payment, but such service can be made available.

A domain holder gains the perpetual right to maintain
ownership of a 2nd level domain in exchange for timely payment
of posted yearly rates.

A domain name holder has the right to expect the the
Association of Internet Registries shall endeavor to keep all
TLDs active, even in the event of business failure of a
registry. This endeavor shall be on a 'best effort' basis and
does not include long-term operation of a TLD that proves to
be un-viable.

Appendix 5 -- Registry Code of Ethics


I will not gouge domain name holders.

I will make domain registrations available as cheaply as

I will ensure continuous and robust operation of DNS services

I will run a TLD according to it's charter.

I will not make arbitrary and capricious changes to policy or
operations. If there is a problem that requires such changes,
the Internet community will be made aware of the problem and
possible solutions will be discussed in an open manner.

I will abide by local laws and be responsive to the internet

I will process domain registrations, modifications and
deletions in an expeditious and secure manner and will do my
best to ensure only a domain name holder can modify or delete
a domain.

CC: NTIADC40.NTIAHQ40(krose)


From: Tony Rutkowski <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/23/98 3:41pm
Subject: Comments in Docket No. 980212036-8036-01

Karen Rose
National Telecommunications and Information Administration
Washington, DC 20230

Dear Ms. Rose,

Please find below my comments in the above captioned proceeding.
They are also attached as a Micosoft Word document.

Anthony M. Rutkowski


Before the
National Telecommunications and Information Administration
Washington, DC 20230

In the Matter of )

Notice of Proposed Rulemaking

Comments of Anthony M. Rutkowski


Anthony M. Rutkowski
NGI Associates
13102 Weather Vane Way
Herndon VA 20171


23 Mar 1998


In general, the U.S. government in this matter is taking precisely the right
course. It has instituted a lawful process domestically, sent the right
messages internationally, and constructed an enduring, stable, open,
industry-driven model and specifics for effecting these Internet-related
administrative responsibilities.

To the extent modifications are needed, it involves effecting a more diverse
representative structure - especially involving Internet Service Providers
and users - as well as avoiding the inclusion as of right by secondary

The proceeding and the associated "outreach" activities of U.S. government
officials are responsible and commendable actions in the face of predatory,
disinformative, and frequently abusive behavior on the part of parties that
attempt to assert themselves as representing the "Internet community," as
well as international organizations who seek inappropriately to assert their
jurisdiction and involvement in the management of the millions of private
networks, computer hosts and applications that share their resources through
the Internet protocols.

The steady reasoned course outlined in the NPRM will serve the Internet's
development and growth - indeed the world - for decades to come.

-------------------------------- break --------------------------------

Before the
National Telecommunications and Information Administration
Washington, DC 20230

In the Matter of )

Notice of Proposed Rulemaking

Comments of Anthony M. Rutkowski

1. Anthony M. Rutkowski respectfully submits comments in this proceeding
published at 63 Fed.Reg. 8825 (No. 34, Feb. 20, 1998). His expertise is well
known to the agency - as an engineer-lawyer with more than 30 years
experience and leadership in industry, government, and academic
institutions, as well as author of scores of articles and numerous books.
He is currently the principle in the consulting firm of NGI Associates with
several Internet-related company clients - none of whom are directly
affected by the outcome of this proceeding - and director of the Center for
Next Generation Internet. He is also on the boards of Internet-related
organizations and publications, but not speaking on their behalf. Full
details are available at <>.


2. At the outset, the subject matter of this NPRM deserves focus for what it
is, and is not. The Internet by definition and in practice consists of
millions of networks, computer hosts, and applications overwhelmingly in
private hands that have autonomously provided for some degree of
interconnection and sharing of those resources. It is this self-organizing
agglomeration that we all casually refer to as the Internet.

3. There is a significant collective, general public interest in assuring
the continued operation and development of the Internet and its
applications. There is also a legacy role of the U.S. government that has
been well portrayed in the NPRM, and an array of intellectual property and
other legal issues. However, the identifiers associated with the Internet's
operation are not limited like radio spectrum, nor are they used for the
operation of public telecommunication networks. They are simply created,
administered, and published for those operating and using the Internet.

4. Internet identifiers are therefore not "public" resources nor should they
be part of a "public trust" model. Our systems of law domestically and
internationally ascribe special meaning and effect to those terms that bring
them under governmental and intergovernmental jurisdiction and made an
inextricable part of many normative provisions. This is wholly inapposite
here. Some parties - particularly intergovernmental ones - have sought to
ascribe public resource and trust status to these identifiers. As the
agency well knows, such a result has significant, far reaching, and
uncontrollable effects that it has wisely eschewed. If it is necessary to
create any kind of model, it should be a shared private trust. Explicit
treatment of this matter in the subsequent Report and Order in the
proceeding, and in diverse intergovernmental and bilateral forums will be
necessary to effectively implement these policies internationally.

I. The Proposal

A. The Coordinated Functions


5. The creation of a new private-sector, industry-oriented corporation as
proposed in the NPRM is precisely on target. The existing Internet Assigned
Numbers Authority (IANA) arrangements in which a DOD research contractor and
staff were tasked with these responsibilities has long been divorced from
the reality of a huge commercial Internet infrastructure and marketplace.

6. The existing institutional arrangements and processes have been closed,
with no due process or records, with significant conflicts of interest in
evidence - yet remaining to be legally protected and funded by the U.S.
government. This has unfortunately also contributed to an extensive period
in which contract personnel, various non-profit organizations, and the
intergovernmental organizations have sought to lay claim to these
responsibilities and craft their own self-serving


7. The staff and staff arrangements for the new corporation should be free
from conflicts of interest that might give even the appearance of
impropriety. The IANA function is presently provided for the U.S.
Government under a significant sole-source contract to the University of
California Information Sciences Institute; and the employees involved have
direct, significant, and long-standing relationships with various of the
parties whose interests are very much involved in decision making matters
before the new corporation. Such a requirement is not only good policy for
an industry organization, it will be a material requisite in minimizing
subsequent litigation.

8. Although these ISI employees must necessarily be involved in any
transition to new arrangements, the actual secretariat of the new
corporation should either be outsourced by open, competitive bidding, or
staff hired as part of open hiring process. Any newly employed contractor
or staff should be not be affiliated in any way with present or future
organizations whose interests are affected by matters before the new

9. Serious consideration should be given to creation of the new IANA
organization as a congressionally chartered corporation. Doing so could
provide additional stature and avoid any problems associated with the
authority of the Dept. of Commerce in directing the creation of a
corporation. Such action would need to be carefully described to make it
plain that such incorporation is simply a ministerial act necessary under
any jurisdiction, that the resulting corporation is a private international
organization, and is not intended to serve any special U.S interests.

10. Further to the issue of operating as a private international
organization, the established corporation in its charter should specify a
requirement that the number of directors from any one country cannot exceed
fifth percent. In addition, the organization should register with the Union
of International Associations, effect relationships with other international
organizations, maintain multilingual capabilities, and distribute the
physical location of secretariat components. It should maintain especially
strong, continuing communications with the national TLD registries world as
well as the Internet operational organizations.

11. The NPRM appropriately notes the extraordinary and growing diversity of
the "Internet community" so as to make the term essentially meaningless.
Almost every organization that exists can probably find some argument why it
should be represented in this IANA corporation. In addition, there is the
problem of dealing with fronts. For example, the Internet Architecture
Board (IAB) is by no means "representative" of any Internet technical
community. It is nothing more than an advisory committee of the small,
highly-conflicted party in this proceeding - the Internet Society - which
wholly maintains and controls the IAB to further the interests of the
Society and its Board members in this matter.

12. On the other hand, there are Internet stakeholders who are to a
significant degree affected by the NPRM and the ensuing activities of the
Corporation. In pursuit of a objectives of the NPRM, if not legal
sufficiency, the composition of the Board should be framed entirely in terms
of stakeholder groups rather than organizational representatives.

13. The individual Board members should serve as individuals chosen by
stakeholder groups, not as representatives of organizations per se. The
NPRM attempts to identify some of those groups, specifically 1) the existing
IP number registries, 2) the IAB, 3) a name registry association, 4)
Internet users including non-commercial, not-for-profit use of the Internet,
individual end users, commercial users, including trademark holders.

14. However, there are some glaring errors and omissions here. As noted
above, the IAB exists simply as an Internet Society advisory committee. The
existing IP number registries are administrative entities which are not
themselves stakeholders. Conversely, the most directly relevant
stakeholders are missing entirely, namely the several thousand Internet
Service Providers. They are a large, diverse, and rapidly growing community
that have little involvement or representation in older established Internet
groups. Reference, for example, the attendees at any recent ISP Conference

15. If the Board of the new corporation is to be truly representative of
stakeholders - and thus minimize its risk of litigation - it will need to
more effectively balanced. Annex 1 identifies these stakeholders, and is
offered as a means of achieving better identification of groups and a
balance in the composition of the board.

16. The NPRM objective of subjecting the new body to antitrust liability is
commendable and a very important precedent in establishing a general model
for future Internet-related industry activities.

B. The Competitive Functions


17. The NPRM's proffered Registry-Registar model that allows for diverse
imlementations is an approach that is both pragmatic and should balance the
needs for both stability and greater competition at several levels.

18. The NPRM fails, however, to apply the model broadly enough. It should
apply to all top level domains, not just the ones the so-called generic
ones. Not only is there no reason not to apply the model to all TLDs, but
failure to do so is patently discriminatory.

19. These policies established both through this proceeding, as well as the
subsequent activities of the Corporation apply to the many private networks,
host computers, and applications interoperating openly via the Internet
Protocol - falling largely outside the normal jurisdiction or exercise of
authority by national authorities. As noted above, these are private, not
public, identifiers used in conjunction with private systems. In addition,
these national TLDs can be readily conveyed by lease to anyone to be used
for other purposes - as has already occurred in the case of the .IO domain.
A private IANA corporation should not be exhibiting discriminatory treatment
among any TLD groups.

C. The Creation of New gTLDs


20. The expansion of gTLDs at a deliberate and controlled pace is
appropriate to allow for evaluation of the impact of the new gTLDs and
well-reasoned evolution of the domain space. Although many parties have
asserted there is a significant demand, it many in fact be minimal.
Continuing experience suggests that the preponderance of U.S. domestic users
prefer to find variants in the .COM or .ORG domains much more preferable
than any other domains. Thus the real demand may in fact be far smaller
than some have suggested.

21. On the other hand, given the self-organizing properties of the Internet,
it seems unfeasible to control in any kind of absolute way, the emergence
and use of new name systems. Parties of record such as Image OnLine,
Iperdome, AlterNIC, AURSC have long maintained operational systems. Others
such as InternetOne have leased national TLDs to provide new services.
Still others such as CORE and pgMedia seek also to initiate services. All
of these parties can provide useful, diverse testbeds, that hopefully can be
managed and studied by the new Corporation - relying also on interested
groups of experts such as the ORSC and any new bodies that will evolve.

22. Additionally, as the standards for new applications and systems begin to
be used - such as the object models of the Open Management Group (OMG), or
mobile autonomous agents of the Foundation for Intelligent Physical Agents
(FIPA) - entirely new kinds of DNS approaches and ontologies will be
necessary. Proceeding with flexibility and rapid adaptability cannot be
underscored enough.

D. The Trademark Dilemma


23. Domain names are used primarily for corporate identification and
branding in the United States. As the NPRM notes, remarkably few disputes
have arisen, and these have overwhelmingly been solved among the parties,
with litigation being very rarely necessary. Any new requirements or
process relating to trademark disputes should be minimalist, and not
encumber in any way the normal rapid issuance of domain names. Requiring
registries to resolve disputes seems inherently ill-suited to their
orientation and skill sets.

24. Because the vast preponderance of existing and future generic top level
domain use is in the U.S. - and is likely to remain so - the construction of
arrangements so as to maximize any resulting litigation in the U.S., seems
highly desirable. The remarks of some commenting parties - particularly
outside the U.S. - on this matter are especially disingenuous. In fact, the
so-called generic TLDs have long been regarded as de facto U.S. domains, and
eschewed in preference to national domains on a large scale throughout the

25. To call for complex and unnecessary global processes outside the U.S. to
deal with what has primarily been a problem among U.S. parties, is little
more than a calculated attempt to impede the rapid pace of Internet use and
assimilation in the U.S. The general principles on these matters set forth
in the NPRM - including the minimal procedures in Appendix 2 and the
proposed study - are the right steps, and any new encumbrances should be
weighed carefully.

E. The Intellectual Infrastructure Fund


26. The recent abolishment of the fund and the collection of monies by the
National Science Foundation has made this subject moot.

II. The Transition

A. The NSI Agreement


27. The proposed transition arrangements with respect to NSI under the NSF
cooperative are equitable and serve the interests of all parties concerned.

B. Competitive Registries, Registrars, and the Addition of New gTLDs
(ref. App 1)


28. The proposals to introduce additional competition during the transition
period are measured and appropriate. However they should also be applied
to national registries for the reasons outlined in para. 19, above. Pioneer
preferences seem appropriate.

C. The Root Server System


29. The root server system operation is properly a matter for the U.S.
government, its management contractors including ISI and NSI, existing root
server operators, and major Internet Service Providers. This should be
coordinated by all these parties cooperating together to assure a robust,
secure, and performant system. It should not involve outside interests such
as technical society advisory committees - which is wholly inappropriate.

D. The .us Domain


30. The assignment of the .US domain by the government's IANA function
contractor - ISI - to itself to undertake other government specialty
contracts was an inappropriate and ill-advised action at best. It has long
been recognized that transferral of this function to an appropriate industry
body - either for-profit or non-profit - under appropriate safeguards would
be highly useful to an enormous number of U.S. users. As the NPRM notes,
however, the current administrative arrangements are far too cumbersome.
The matter deserves urgent attention, and could be easily effected during
the transition period.

31. There is no reason whatsoever to move .GOV and .MIL users under a .US
domain. This is a wholly unnecessary and costly undertaking. Those two
domains can simply be recognized and administered as de facto U.S. domains
as has long been the case.

E. The Process


32. The U.S. government and the associated officials and staff have played a
highly positive and beneficial role with respect to these important Internet
administrative functions. The articulated principles serve the interest of
the public, industry, and the world. This is a unique time of transition
when important models are being set for years to come.

33. The administration of Internet-related identifiers is potentially
subject to significant anticompetitive abuse, as well as arbitrary behavior
and personal favoritism. It inherently arises no matter how well
intentioned the responsible staff or responsible officials. In addition,
with respect some of these identifiers such as domain names, there may be
important issues associated with freedom of expression. Making this
activity subject to antitrust, First Amendment, and tort law of the Unites
States provides an ideal check on wrongful behavior by those undertaking
this activity. It is also patently where the most intense usage is
occurring, and the support is likely to be efficient and the costs
comparatively low. If significant demand for these services arises in
different global regions, it is very easy to distribute them as has already
been done for IP addresses.

------------------------------------- break

Annex 1


O Providers

Root Admin Services
Existing (1)
New entrants (TBD)
Root Server Services
Existing (13)
New entrants (TBD)
TLD Services
Existing gTLD (4)
Existing nTLD (~200)
New entrants (TBD)
Sub-TLD Services (~70,000)
Registration intermediaries (?)
BIND server software (~10)
Registration software (?)

O Users and Uses

Internet Service Providers
Web site builders
Trademark owners
End user
Business identity
Professional identity
Individual identity
Branding & marketing
Free expression
Object owners
mobile agents


O Other Industry
O Service providers
O Software vendors
O Hardware vendors
O Telecom providers

O Public
O Ordinary people
(50 million +)


From: "Janine Coulthard" <>
To: Return requested <>
Date: 3/23/98 3:41pm
Subject: Technical Management of Internet Domain Names

I attach the comments of the British Post Office on the US Government Green Paper on the Technical Management of the Internet Domain Name System. The format of the attachment is Microsoft Word, Version 6.

CC: "Tony Humphries" Return requested <Tony.Humphries...



23 March 1998


The British Post Office welcomes the opportunity to comment on the proposals of the US Government to improve the technical management of the Internet Domain Name System. In general, the British Post Office considers that the US Government has reached a sensible compromise in the face of the many diverse views on what should best be done in this fast moving and complex area. The British Post Office has a few specific comments which are set out below.

New gTLDs

We welcome the proposal that a study be undertaken of the effect of new gTLDs and related dispute resolution procedures on trade mark and intellectual property right holders. However, we are not clear what force the recommendations of such a study might have.

We note the comment that trade mark disputes arise very rarely on the Internet. However, we feel that this may be attributed, at least in part, to that fact that the large majority of trade mark owners simply do not carry out checks for third party use of their trade marks on the Internet (whether as part of a domain name or otherwise) and so are unaware that their trade marks are being used to confuse their customers and/or take unfair advantage of or damage their reputation. Often, the first time the trade mark owner becomes aware of such activity is when it comes to register a domain name and finds that someone else has registered it already. The resulting problems have been well aired in the English courts, with conflicting decisions on whether or not mere domain name registration may of itself constitute trade mark infringement.

The introduction of new gTLDs may reduce the attractiveness of the .com gTLD and thus disputes over the right to register names in that domain. Conversely, the increased number of gTLDs will make policing the Internet for potential infringements even harder work. The proposed requirement that an applicant certify its intention to use the domain name may effectively prohibit protective registrations, depending on what the sanction for misrepresentation is. We therefore feel that an easy to use facility for searching across all the domain name databases should be introduced to alleviate this problem. If this database were to include a few more details on the domain name owner e.g. type of business, main brands etc., then this database might be used by Internet users to find addresses of websites for which they were looking. The user would thus not have to rely on more circuitous routes (e.g. pot luck - by tapping in the company name followed by .com) which carry the risk of confusion. As a result, the form of the domain name should diminish in significance, with the domain name reverting to its essential function as an address, rather than as a tool to indicate the data that may be found at the Internet Protocol address corresponding to that domain name. Any additional value as a descriptor could be likened to that of a personalised phone number or address, or at its lowest level, a vanity number plate - of value to the owner but not essential.

Dispute Resolution Procedure

We welcome the proposal that an on-line dispute resolution process be introduced. However, rather than having separate dispute resolution procedures being run by each different registry, we would prefer to see a centralised dispute resolution function. Without this, we feel that there is great scope for conflicting decisions being reached by the different registries. For example, the certification statement by an applicant that it "knows of no entity with superior rights in the domain name" [our emphasis] is open to various interpretations: does McDonalds, the international fast food restaurant chain, have superior rights to the domain name when compared with a Mr McDonald, who has run a fish & chip restaurant for the last 20 years in, say, Edinburgh?

We also feel that the right of suspension of a domain name should be exercised with great care, and should only be exercised once the objector to the application has produced a minimum amount of evidence in support of its objections. Without this evidential requirement, the system would be open to abuse by, for example, entities seeking to disrupt the Internet activities of their competitors.

The New Corporation

The British Post Office is anxious that the composition of the board of the new corporation reflect the international nature of the Internet. It also recommends that, at least initially, there be a representative on the board with a specific interest in intellectual property issues affecting the Internet (such as the use of domain names to infringe trade mark rights), and suggests that a representative from the World Intellectual Property Organisation (WIPO) would be appropriate.


From: John Frangie <>
To: "''" <>
Date: 3/23/98 3:54pm
Subject: Comments on the Green Paper from Image Online Design, Inc.

These comments are submitted in unformatted text, as well as an attachment in Microsoft Word format. Please use the attachment if possible, the text is being sent as a backup.

Image Online Design, Inc.

Comments on the Proposal to Improve Technical Management of Internet Names and Addresses (discussion draft, 1/30/98)

Submitted by Image Online Design, Inc.

1241 Johnson Avenue, Suite 201

San Luis Obispo, CA 93405

+1 805 543 4716 Voice

+1 805 543 4735 Fax (Company Site) (.WEB Domain Registry)


Initial Comments – The Need for Change

To say that there is widespread dissatisfaction about the absence of competition in domain name registration is to point clearly at the problem. While there are those who would also say that the existing registry/registrar has in the past mishandled the job, that is not the point (whether true or not). Indeed, introducing competition to the field is the solution for both problems.

The basic points of the proposal are not to be disputed, as the proposal outlines a system with which Image Online Design can immediately agree and endorse. As anticipated, however, there are a number of points that Image Online Design feels should be clarified, refined, or modified. To be absolutely clear, the proposal, in its current form, appears sound, workable, and fair, and has the support of Image Online Design, Inc.

Introduction and History

Image Online Design, Inc., a California corporation, has been operating the .WEB Domain Registry since August of 1996. In July of 1996, at a meeting at the IANA offices in Marina Del Rey, California, a representative of Image Online Design was given permission by a representative of IANA to begin operation of the .WEB Domain Registry for the purposes of operational testing, pending inclusion in the root servers under the plan being refined at the time. This plan, commonly called the "Postel Draft" was subsequently discarded when a committee, the Internet Ad-Hoc Committee (IAHC) took control of decisions on domain registration. Image Online Design participated in the IAHC’s procedure, anticipating a resolution similar to the Postel Draft, and, at the least, honoring of IANA’s commitments made in July. When it became apparent that the IAHC had no intention of either, Image Online Design opposed the IAHC’s final recommendations. These recommendations were created by the Council of Registrars (CORE), an organization claiming complete control over the Internet Domain Name System. Image Online Design has opposed this action to the present.

Image Online Design feels that the proposal set forth in the Green Paper is the logical outcome of the conflicts in this area, and provides a fair and workable resolution for all parties currently or to become involved.


The Future Role of the U.S. Government in the DNS

The proposal notes, "We doubt that the Internet should be governed by one plan or one body or even by a series of plans and bodies." Image Online Design agrees. From direct experience, we have found that a single plan and body tends to become inclusive, and tends to enact policy that cannot be debated or easily changed. An open system, with many bodies working in cooperation and fair competition will find many plans, all working in parallel, creating choice and promoting innovation and interoperation.

The proposal says, "The introduction of a new system should not disrupt current operations, or create competing root systems." Having been involved in an experiment to create a competing root system to test its viability, Image Online Design must agree with this point. While competing root systems might succeed, there would be a lack of coordination in the naming. Inevitably, competing root systems would conflict on names, and confusion would be the least of the problems.

The proposal points out that "market mechanisms that support competition and consumer choice should drive the technical management of the Internet because they will promote innovation, preserve diversity, and enhance user choice and satisfaction." Image Online Design feels that this is the key to a stable and fair system, agreeing that competition at the registry as well as the registrar level will ensure that these benefits are realized at all levels.

Comments on Coordinated Functions

Image Online Design agrees that "coordination of the root server network is necessary if the whole system is to work smoothly." Even with previous plans, there has been no comment on the coordination of the root servers. Regardless of the physical operation of the root servers, a single body, properly empowered, should be responsible for coordination.


The Creation of the "New Corporation"

The creation of a non-profit corporation to oversee policy and operations is an excellent resolution to the current problems. Unlike other proposed solutions, the fact that this new corporation will not be directly responsible for the operation of any registries or registrars adds a level of insulation against possible conflicts of interest.

The funding of the corporation by domain name registries and regional IP registries is both appropriate and fair, provided it is done in a fair manner, collecting no more money than is reasonably expected to be necessary for operations. It is to note that the original Postal Draft called for a 2% fee to be paid by registries for the operation of the overseeing body. Many felt that this amount was more than could be accounted for in the operating budget. Setting the appropriate structure for funding will require striking a very difficult balance.

The outline for membership on the board of the corporation appears sound, although the fact that there are 7 members from a single membership organization, and 7 members from all other organizations combined suggests the possibility for deadlocks. Image Online Design suggests the addition of one more member, either from one of the existing groups, or perhaps from the IETF directly.

The Role of IANA in the Interim

A major concern is the role of IANA in the interim. CORE has stated that IANA is in a position to continue to function while the new corporation is established. It is clear, however, that while the new corporation will incorporate the functions of IANA, and should benefit from the experience and expertise of IANA, that IANA is clearly biased at this time. Jon Postel, after having his draft recreated by the IAHC, has maintained that he is involved with CORE, and intends to enact their policy. To give IANA the power to make policy decisions in the interim would be questionable, at best. It is the opinion of Image Online Design that the U.S. Department of Commerce should continue to have policy authority until the new corporation is created.

Comments on the Competitive Functions

The first sentence of the proposal states, "The system for registering second-level domain names and the management of the TLD registries should become competitive and market-driven" Image Online Design could not agree more. Furthermore, this is the very heart of the issue.

The distinction between a "registry" and a "registrar" has been proposed in the recent past, and has never been contested. While Image Online Design went operational in a way that would suggest being both a registry and a registrar, the separation of functionality that this distinction would imply is both acceptable and logical. In the specific case of Image Online Design, registrar functions would be terminated in favor of being a registry.


Comments on the call for more International participation and CORE

It is to be noted that some individuals and groups have criticized the proposal as being too "US-centric" and not "International enough" in scope. These groups then make the claim that the CORE proposal would resolve this problem. Therein lies what Image Online Design believes to be the true motivation behind such criticism. All comments that Image Online Design has seen to date both criticize the U.S. proposal while claiming that the CORE proposal is better as a result of its international nature. While it is true that CORE has members in many countries, it is by no means an "Internationally approved proposal." Indeed, the CORE proposal, if implemented, would grant complete control over the Domain Name System to CORE, which appears to be the intent of such comments.

It has been noted that a major criticism of the proposal is that it does not take CORE’s proposal into account. This criticism does not, in our opinion, carry much weight. The proposal does not name any single proposal by name, but it is widely known that it incorporates pieces of many prior attempts, including the original IANA proposal, eDNS proposal, the comments of many individuals and companies, and finally, the CORE proposal. Indeed, the concept of registry vs. registrar was originally proposed by CORE, and is now a major part of the Green Paper. If the proposal were to mention CORE by name, it would, to be unbiased, have to name all competing proposals. In the case of Image Online Design, we are quite pleased that parts of our position were incorporated into the Green Paper, and have no need to see our company mentioned by name.

In addition to such comments, a large number of electronic replies to the Green Paper have been seen on the NTIA web site claiming to be in favor of the CORE proposal. While numerous, these comments appear to be submitted by individuals and organizations with questionable motives. A CORE member went so far as to implore all of their "pre-registrant" customers (those people who paid money for the possibility of having their chosen name in one of CORE’s 7 selected TLDs) to send in comments. It is to note, however, that most of these comments implied that CORE’s plan had been previously approved and that only now was the U.S. Government attempting to stop it. This is, as you know, untrue. Additionally, many comments claimed that CORE had been "doing a good job until now" and should be "allowed to continue." Both of these claims are also untrue. CORE has not, nor have they ever been in any position of authority over the Domain Name System, so doing any kind of job until now is impossible. As to being allowed to continue, Image Online Design has never opposed CORE’s entry into the DNS. The opposition has simply been to CORE’s position of being the final authority over the DNS, and CORE’s appropriation of the .WEB TLD, after Image Online Design had been developing and operating the TLD for over a year, internationally, before CORE was even formed.


For-profit vs. Non-profit registries

The point of for-profit vs. non-profit registries has been brought up consistently by CORE. CORE's position is that all registries should be non-profit. This comes as no surprise, as their business model, when they assumed that they would be in control, called for a non-profit registry to service a large number of for-profit registrars. Obviously, nobody is opposing for-profit registrars.

But let's take a closer look at the idea of a non-profit registry. In the CORE model, the non-profit registry is funded by the membership fees of the CORE members ($10,000 to start and, reportedly, $2000 a month). This is more than enough to fund the creation of a non-profit registry, and under the CORE plan, participation was mandatory: you could not be a registrar unless you helped fund the registry.

In the real world, however, there is no CORE-like plan to require the non-profit registry to be funded by membership fees. Anyone is free to be a registrar and will have equal access to the registry. While a registry might try to charge a significant "membership fee" to fund its creation (in a consistent manner to all registrars), the simple fact that there is more than one registry will dissuade many (if not all) registrars from paying extra.

This is in the case where there is a mix of for-profit and non-profit registries. What about if they are all mandated non-profit? The answer is simple: there will be no registries at all. Why create a non-profit registry, invest the money and time for its creation, and not realize any benefit (other than, of course, altruistic) for its operation? Everyone will be a registrar and wait for the non-profit registries that never arrive. The only possible exception would be NSI, which has a mandated split ahead of them. We would have competition in com/net/org, but no new TLDs. While some trademark groups might like this, it is obviously not the solution that everyone is moving towards.

In short, a non-profit registry is a viable option if it is the only option, and the registry is the exclusive source of domains. With the Green Paper opening both registry and registrar functions to competition, a non-profit registry is clearly not a workable option.

Addressing Proposed Problems with For-Profit Registries

The major concern surrounding a for-profit registry seems to be the possibility that a registry may charge initially low fees, and then raise the fees in the future. This is a serious problem, acknowledging that investment in a name is commonplace. Without pointing out in detail that even a non-profit registry could do this by simply increasing the operating cost, this problem is completely removed if the registry takes one of two possible actions. The first is offering extended terms of registration at a pre-determined price. A registry could offer domains for terms of 2 or more years at an agreed-upon price structure, contractually bound. Alternatively, a registry could make it binding policy, contractually binding that prices will not be increased more than a certain amount over time. A percentage over the cost-of-living index has been suggested. Regardless, it has been shown that any company, even ones with "captive customers", is quickly out of business once prices rise drastically.

On the Creation of Additional TLDs

There are arguments from both sides on this very important point. One side would have no new TLDs created and the other would have an unlimited number created, relying on market forces to keep the confusion at bay. Image Online Design finds that a middle-ground is the best course of action, creating not a limited number of TLDs, but rather governing the rate at which new TLDs are created. This has the advantage of creating an initially small number of TLDs and allowing observation of their operation while not placing an arbitrary limit to the number of TLDs created.

Indeed, placing an arbitrary limit will cause problems in that the limit may be less than the number of companies or organizations that are both qualified and prepared to operate a registry. By setting a rate of insertion instead of an arbitrary limit, all qualified companies and organizations will be assured of inclusion unless there are serious technical problems.

This brings up the question of order: in what order are companies and organizations inserted into the roots? Image Online Design’s proposal is thus:

The queue for inclusion will then be based upon all companies that meet the criteria and the order in which they were operational. Inclusion will begin at the top of the queue, with the first company or organization being evaluated for compliance. If a company or organization meets the criteria, it is inserted into the roots. In addition to the evaluation of the criteria, the entity validating an application will also check the validity of the date of first operation. The registry applicant should cover the cost involved in this application process.

By using an impartial third party to verify and validate all claims of operational dates, IANA (or the entity responsible for interim management) will avoid being placed in a position of liability for the determination, and avoid charges of acting in an arbitrary or inequitable manner.

It is possible that the first few companies or organizations in the list may be inserted immediately, and that this number would be arbitrary. After this initial insertion, however, a schedule for subsequent inclusion would be followed. Initially, one new TLD every 30 days would allow for slow growth, while denying entry to no company or organization.


The proposal asks for comments on limiting the pool of applicants. Image Online Design believes that by ordering the initial applicants by date of first operation, no limiting is then needed.

Finally, with regards to the selection of names, Image Online Design feels that this should be left to the registries, as market forces will dictate the selection. A registry may select to run a generic name, or may select a specific name for specific purposes. Provided registries comply with all other requirements, name selection is irrelevant. Additionally, the ordering of the pool of applicants by date of first operation will eliminate any conflict in name selection. If a list of names is required, one has only to look at the names that existing prospective registries have selected. This list is the best example of the market-driven selection process.

The Issue of Trademarks

Trademarks, and trademark enforcement is a major issue in the creation of new TLDs. Image Online Design’s position has been the same for the past three years: It is an exercise in arrogance to believe that we can solve a problem that is more than 100 years old, just because it is manifesting itself in a new area.

With that in mind, the proposal for more robust searching mechanisms, acknowledgement of registrants of possible prior use, and statement from registrants agreeing that they know of no prior or superior claim are steps in the right direction, and are quite acceptable.

The question of jurisdiction may be answered by mandating that all conflicts take place wherever the registrar is located. This will allow registrants to select a registrar that meets their level-of-comfort for jurisdiction. This, while beneficial for the registrant, might then have the opposite effect for any trademark holder. Again, this is an old and difficult question, with no clear answers.

Comments on the Transition

Image Online Design has no comments at this time about the ramp-down of NSI, as this is an action between the U.S. Government and NSI, and Image Online Design does not feel itself to be a party to this action, other than to appreciatively note that NSI has already publicly approved of this proposal.

Comments on the transition specific to the interim creation of new TLDs and new registries have been described above.

Comments on Appendix 1

First of all, and without reservation, the need for objective criteria in qualifying registries is absolute. With that said, Image Online Design approves of the criteria in this appendix, and wishes to state for the record that Image Online Design meets, and in most cases exceeds these criteria. Many of the criteria lack specific quantifiable amounts, however, and will need such. Examples include the level of scalability, the actual number of zone file servers (Image Online Design suggest no less than three), etc.


From: <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/23/98 3:32pm
Subject: Technical Management of the Name Space

Dear US Government,

Maybe Americans are dumb enough to believe your bs about creating true competition for the GTLD domain name space but Canadians and Europeans alike are not so easily fooled.

The Canadian name space has been managed for ten years (far longer than Network Solutions control of .COM) by a committee of Canadian stakeholders and it is an open registry that works well, and at no fee to the end user! Did you consult with them about their experience running the .CA domain (or others) so that you could make an informed draft proposal? Did you know that the name speculation which plagues .COM has not happened in .CA? I think not.

Your proposal needs to be ripped to shreds and you need to start over. Begin with contacting those registries *overseas* which have a decade or more of running a fair registry service like Canada, Australia, and Japan. They have been through the problems you have are attempting to tackle and can help you reform .COM to a fair and competitive GTLD.

I hope very much that the Department of Commerce completely breaks the stranglehold on .COM which Network Solutions so greedily enjoys (see their SEC filing). Don't make the mistake of keeping these nincompoops solely in charge of .COM in the future. They should not be allowed to be the only company which is both a registry and a registrar. The internet community will not forgive the US government a second time if you continue to give Network Solutions an unfair advantage in GTLDS.

Peter Hansen


From: "Richard J. Sexton" <>
To: NTIADC40.SMTP40("")
Date: 3/23/98 7:11pm
Subject: Comments of Richard Sexton

Before the
National Telecommunications and Information Administration
Washington, DC 20230

In the Matter of )
Improvement of Technical Management ) Docket No.
of Internet Names and Addresses )

Comments of Richard J. Sexton

Richard J. Sexton

Richard J. Sexton
Maitland House
Ontario, CANADA


18 Aug 1997

------------------------------ break ------------------------------

Comments of Richard J. Sexton

Richard J. Sexton respectfully submits comments in this proceeding.
Richard Sexton is the sole owner of VRx Network Services, Inc.
and one of the founders of the Open Root Server Confederation
and is actively involved in top level domain name
issues. Richard Sexton has been seeking a resolution to the
problem of Network Solutions unilateral policy decisions since
inception, favoring an internet community based solution. He has
and spoken a great deal on this subject in Ottawa,
Washington DC and Wall Street, to educate users, industry and
government to the issues today concerning the Internet Domain
name system.

------------------------------ break ------------------------------

1) The Green Paper proposes a plan of action and is an attempt
to mediate the mess that is todays Internet names and numbers.
The numbers and protocol codification issues are sound as is.
The DNS problem has a rather obvious solution: rather to
do *something*, do *nothing* more than tell the TLD
stakeholders to go away and come back when they have negotiated
among themselves. Failing that strategy, we press on, regardless
with the rest of our comments.

2) Creation of an institutionalized IANA is a sound plan. I have
grave concerns about automatic inclusion of current
people. If they're so capable, why do we have this mess?

3) Criteria for additions of new TLD's are discussed. 5 is
too few of an initial number, and what is important is not the
number but the rate of insertion of new TLD's into the root.

4) Concerns about the stability of the Internet re new domains are
unwarrented. In the last year many new country code TLDs have been
added and not only did few poeple notice, but stability of the
internet was never in question. With country code TLDs seldom
used in the ITU inspired X.400 model they were originally created
number due to consumer demand, the distinction of a national
TLD (nTLD) and international TLD (iTLD) is tenuous at best.
RFC 1592 specifies these acronyms and gTLD is a marketing
device use by the various IAHC committees and not used here.

5) It wold be unwise to restrict the growth of the Internet
because of trademark issues.

6) Cyberspace itself, or the physical location of the registry
should be the jurisdiction.

7) Concerning the Intellectual Infrastructure Fund. If it
is not going to be used for it's original and intended
purpose (to maintain the purity of the IETF *process*)
then it should be refunded. Canada has paid in roughly
$2M and it would be unethical to use this for solely
for American interests.

8) The GP proposes .edu me run as a non profit. Why
not .org, too? Who will do this?

9) Registries should be allowed to bundle services with names
but it should be possible to buy unbundled domain names.

10) WHOIS is the standard domain name search and lookup
mechanism and does not appear to be any need to go beyond

11) The ITU's involvlment in any way is inappropriate.

12) Is there a need for registrars?
------------------------------ break ------------------------------


It would require the wisdom of Solomon to arbitrate this
mess and short of everybody getting the TLDs they want
to run, there will be unhappy campers who have worked very
hard and invested significant amounts of time and energy
in this so far and have been disappointed with IANA's
actions to date - for example, giving Chris Ambler of
IOdesign approval to go ahead with a .WEB TLD registry then
signing off on the horribly flawed IAHC plan; also publishing
a list of TLD applications received by IANA then never
doing anything with it.

In three years of watching this debate I have seen cooperation
from all involved stakeholders and true give and take. The
two notable exceptions are CORE and Both think
they have some special a priori right; CORE because they
feel they are "authorized by IANA" and because
of their anti-trust suit which they believe will get them automatic
inclusion into the roots.

Until they come to the understanding that the Internet works
by cooperation and consensus, not some God or court given special
authority that gives an advantage to a certain group there
will be no consensus. So, the easiest thing for the US
government to do is tell all potential TLD registry
operators to go away and come back when there are no
major disputes. There may be minor disputes, but the
difference between minor and major disputes is easily

In short a zero sum game where I win because you lose
has never and will never work, especially in a medium
such as the Internet where new technology and decentralization
of authority are the mainstay.

This is what the FCC did with the HDTV crowd, and when told
to go away and agree, they did.

At the end of the day, poeple don't care if CORE or my uncle Joe
run a registry. All that matters is price and service, and
given some reasonable self-regulation that builds customer
confidence and prevents gouging - as is the current philosophy -
then there can be many registries.

The GP is quite correct in stating there are good cases to
be made for profit driven and non-profit registries and
while I would personally run the TLDs I want to run as a non
profit just to shut people up, I firmly believe all we can do
is try it both ways and see what happens. We just won't know
until we do. The Internet has a peculiar way of routing
around damage and I cannot imagine a case where something
so awful happens that it cannot be repaired for a TLD
does not belong to anybody, it merely has a temporary steward
and the customers of that TLD may at any time overthrow
that steward if that entity should prove to be objectionable.

------------------------------ break ------------------------------
2. COMPOSITION OF THE IANA: The next generation (IANAng)

This is fundamentally a sound plan, but what makes me very
nervous is the idea that IAB, APNIC, RIPE, etc. seem to have an
automatic play in. Since these are more or less subordinate
to IANA currently, and since they have done nothing to
improve the current DNS mess I cannot find any justification
for their automatic inclusion. I would ask countries
and the various internet communities (ie,mailing lists and
noticeable DNS phenomena) to nominate people to this board
then let these communities develop a short list that least
people object to.

------------------------------ break ------------------------------

5 is too few. This would give trademark holder the false impression
they can merely grab their name in all new TLDs (although one has
wonder have they done this already for all 240+ country code TLDs?
and they have exclusive worldwide use of a certain character
string which obviously does not scale in other countries
and languages.

20 or 30 TLDs would be an improvement, but more important is
the *rate of insertion* of names into the legacy root zone
with names being added in a round robin fashion. This is the
only way to kill of the notion of "other root servers" for if the
legacy root servers are not comprehensive, they may well be
by a more comprehensive root zone or, poeple may primary
the root zone for themselves which is quietly gaining acceptance.
We don't actually *need* root servers. All they do is provide
information as to where the TLD servers are, and if one is
to replace the standard UNIX root.cache file with a the 100K
file that shows the addresses of all known valid TLD servers
the roots can be safely ignored. Here is the one we use:

The Green Paper suggests that is a registry is "approved" or
"selected" then they may pick a TLD. This is a very bad idea
as nobody I know wants to run A tld, they want to run the
TLD they have a vision and a mandate for. If the purpose of this
proceeding is to minimize lawsuit, this issue needs to be addressed
as there is actual stated intent, prior use and in a few cases
trademarks of TLDs. This needs to be revisited.

------------------------------ break ------------------------------
4. Concerns about the stability of the Internet when adding new

I cannot imagine what these concerns might be. True, at an
10,000 TLDs with very few SLD registrations, the cache coherency
of the DNS breaks down and the root servers melt, but at 5000
this is debatable and at 2000 nobody believes it's a problem. The
number of TLD wanting to go live today is well under 1000 if
you include the (in my opinion) specious 450+ massively
colliding domains, and under 100 if you do not.

The last year or two have seen a plethora of new TLDs added
in the form of "country code" domains from small countries that
offer their TLDs as a clever alternative to .com and few people
noticed and Internet stability was never in question. I
frequently see lame delegations for .es (Spain) and .ch
in the name server logs and the world does not come to an end. This
is why multiple secondary name servers are important.

RFC 1591 specifies first-come-first-served and there is no
other fairer way and no reason to believe this does not
scale to the top level domains.
------------------------------ break ------------------------------

With regard to trademarks, the trademark community has certain
right in law, currently, and the creation of a new media does
not in any way change their rights although it does create
new and faster way to infringe trademarks and resolve
disputes. Since there is no uniform or global trademark
law and since the number of trademark infringements is
such a truly minute fraction of all domain registrations
it wold be unwise to restrict the growth of the Internet
because of this issue.
------------------------------ break ------------------------------


There is no good answer to the question as to where
the jurisdiction of disputes should be settled. If
we are to believe a recent Georgetown school of law article,
cyberspace itself should be a discrete jurisdiction. Failing
that, the location of the registry is probably the next
best thing as this is the fount.

------------------------------ break ------------------------------


When Don Mitchell of the NSF created this fund it was specifically
created to maintain the "purity" (ie, non-proprietary nature)
of the IETF process. As a citizen of a country that has
collectively contributed $2M to this fund, I would be horrified
if it were used for any other purpose.

------------------------------ break ------------------------------
8) .EDU and .ORG

The GP proposes .edu me run as a non profit. Why
not .org, too? Who will do this?

This is an interesting notion and speaks to the fundamental
nature of domain names in that they encompass all uses of the
net, commercial and non-commercial. It doesn't bother me that
Microsoft or IBM have to pay $100 for a .com name, but I've
seen many many small non-profit .org holders endure hardship
to pay $100 ($140 CDN) to pay for the domain. I suggest making
.org non-profit as well.

------------------------------ break ------------------------------


I have no problem with registries optionally bundling value
added services with domain names, but it seems silly to pay
for them if they are not needed. Bundling should be optional
and never mandatory.

------------------------------ break ------------------------------


The suggestion for a completely searchable database
is interesting, but I'd stick that one in the "tomorrow file".
whois is perfectly capable (either as a standalone Unix
client program or with a web interface) of serving these needs.

I've modified whois to use an outboard file, as was suggested
on so that it "knows" where
all the contemporary TLD whois servers are. There are 7 whois
domain servers in the world, only 5 are in the legacy roots.

You can find the software at:

------------------------------ break ------------------------------

The old style of telephony, which the ITU symbolizes, could not
without tight central control and management, to get protocols,
voltages, timings, signalling, and all of those things working
correctly. The Internet uses a different kind of technological
which doesn't require tight administrative control.

------------------------------ break ------------------------------

It seems to me there are several "classes" of registrars:

1) Person that buys domains from anywhere and everywhere. The
barrier to entry to this is very low. A single web page and half
a clue will suffice. No special arrangements need be made,
and this is, in a sense what we all do with NSI right now.

"Authorized registrar"
2) Person that buys domains from a registry, as one of
a group of select people that are the only ones that can.
If Nominet didn't sell to the public this would be an
example. This is like 1) but the public can't buy from the
registry directly.

"Registered Domain Agent"
3) Person that buys domains from a registry, but they have
direct access to the registry database. CORE is somewhat like
this. This is like 2) but rather than submitting a request
to the registry, they do the work themselves.

Now, in the strictest technical sense, and if the system
isn't designed to require them (as CORE is) then there
is no need for registrars. There is a strong *desire*
to have them that will never go away, and this is good,
but lets face it, the net grew and developed without them
and at such time as a registry is sufficiently advanced
with polylingual capabilities and stunning front line
support, this *desire* may go away.

Now, if there were a 4th class, like 3 but the general
public could "roll their own", the need for registrars
is again diminished, and if we get to a point where
any domain can be purchased from a single web site
in this manner, the need/desire would go away even

But I doubt it will go away entirely. Some poeple
who can, do not, change their own oil.

So, the need for registrars is policy driven or
market driven, but there is no technical need
for them. This was the point of that thought
in the document Given that registrar means anything
from a guy with one web page that forward a template
to a publicly accessible registry all the way to
somebody that can fiddle with a registry database,
the term is vague

------------------------------ break ------------------------------


From: Jay Fenello <>
To: NTIADC40.NTIAHQ40(dns)
Date: 3/23/98 4:17pm
Subject: ORSC's Response to the Green Paper

Before the
National Telecommunications and Information Administration
Washington, DC 20230

In the Matter of )

Notice of Proposed Rulemaking

Comments of Open-RSC

23 March 1998


We, as the founding participants of the ORSC are a group of people with
varied backgrounds and interests which we have collectively found to have a
single common focus on helping to resolve the difficult problems of
developing an open cooperative governing process for the Internet, and
specifically for an OPEN ROOT SERVICE CONFEDERATION. We find that we have
a common belief in the power of self organization as it applies to Internet
Governance, and we are openly working toward helping that self organizing
process along.

We have individually contributed to the development of the recent US
Government Green Paper, through individual public comments to the 1997 NTIA
Notice of Inquiry, through additional individual public comments, and
individual responses to specific questions when requested.
We find that the Green Paper embodies many of the principles of fairness of
competition and governance that we advocate, and we are now working to
support and further refine the governing concepts and the operational plans
put forward in the Green Paper.

Please consider the contents of the collective works of the Open-RSC
participants at as our formal comments to this

CC: NTIADC40.NTIAHQ40(krose),NTIADC40.SMTP40("domain-p...


From: "Rich Robins, ESQ." <>
To: "NTIA" <>
Date: 3/23/98 2:04pm
Subject: Rotten-to-the-CORE windfall profits for new GTLD registrars

On this, the final day to submit feedback to the CORE plan for new
internet domains, it is worth mentioning that creating the 5 or 10 new
GTLD's will not only stifle various countries' own internics' abilities to
sell their domestic domains in the future, it will also create a source of
windfall profits (at cyberspace's expense) for the new international
registrars. Already several CORE-endorsed registrars are abusing their
CORE-vested authority by selling lots in their respective lottery pecking
orders for exaggerated fees. While these interested CORE registrars claim
there's a legitimate "need" for the new GTLD's, one cannot help but wonder
who is being served, other than the registrars that sell Yahoo (etcetera)
additional (and unnecessary) domains like or or . For those who are really
concerned about maintaining trademark integrity, the new GTLD creation
seems like the opening of a Pandora's box of problems from which companies
will need to protect themselves at great cost, resulting in higher prices
for all.
The currently-used system serves people quite well, and any real need to
change it is hard to grasp. Even Continental Airlines acquired and it's working quite well. What's wrong
with that perfectly memorable address? If Continental wanted to
over-protect its international trademark interests, nothing stops it from
acquiring the domain from Turkmenistan via or some other provider. The ".tm" part quite closely
resembles the internationally-acceptable suffix for "trademark". This
added precaution would not be necessary, though; it's just an interesting
example of how we can make do with the current system a lot more easily and
innovatively than anarchist$ at CORE would try and have us believe.
With the proposed CORE system, various countries' NIC's like
Turkmenistan's will probably have to close their doors in the absence of
unanticipated government funding. A similar scenario applies to Mexico,
which has hardly even sold 5,000 internet domains during its
various years of existence, despite 's efficiency and
honesty. According to the CORE's rushed "plan" Latin America is excluded
from the present list of registrars despite its being the world's
economically fastest-growing region. If the Europeans and other CORE
advocates claim that they are really THAT concerned about the international
promotion of cyber-space, I can't help but ask the Europeans if they're
willing to begin subsidizing the truly international domestic domain
administrators throughout the world that will be so adversely affected by
implementation of their pet CORE program....
While the Europeans attempt to counter that the USA (which invented and
financed the internet, incidentally) has no moral authority to become the
international authority regarding new GTLD development during the next
decade, a counter-point that is easy to raise is that ONLY the USA has
enacted a Foreign Corrupt Practices Act preventing its country's
entrepreneurs from paying bribes to foreign governments, not to mention
from deducting them from their domestic taxes! The USA's moral highground
was established through the enactment of this Foreign Corrupt Practices Act
decades ago and all other countries throughout the world continue to pay
mere lip service to their supposed plans to enact, and enforce, similar
domestic restraints. As the Europeans, etcetera preach the value of human
rights and government fairness while simultaneously continuing to engage in
virtually unquestioned and unrestricted trade with repressive regimes like
China's, I still fail to see the inappropriateness of letting the USA
continue to supervise the fair-administration of its internet invention for
international cyber-space's well-being. The alternative appears to be
rotten-to-the-CORE, quite frankly.

Rich Robins, ESQ.
Mexico City, Mexico
Texas Bar license #00789589

Jefferson Technologies, S.A. de C.V.
Londres 167, Suite 1-476; Mexico, D.F. 06600 / /

CC: NTIADC40.SMTP40("","orobles@nic...