### Number: 61 From: wallace koehler email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/6/97 6:08am Subject: Request for TLD Comments Attached in Word 6 are comments on your request for gTLD comments I appreciate the opportunity wallace koehler (firstname.lastname@example.org) --Response to Department of Commerce Request for Comments on Internet Domain Names
Wallace Koehler (email@example.com)
A. Responses to General/Organization Framework Issues:
A. Comment: There has been much interest expressed about and interest in
modifications to the
domain naming structure, particularly to the gTLD .com domain. This concern resulted in a set of
recommendations by the International Ad Hoc Committee (IAHC) of the Internet Society (ISOC)
as well as a continuing commentary and criticism of the process and its recommendations. For
example, the IAHC maintained a listserv (archived at the ISOC site (www.isoc.org)) and the issue
was the subject of some debate at the INET'97 Meeting (ISOC Annual Meeting) in Kuala Lumpur
in June 1997.
A.1. Argument Foci. The argument as presently constituted revolves around two
issues: (1) domain naming space has become congested, and (2) domain names may represent a
threat to the trademarks of established corporations. Arguments and proposed solutions include
recognition that the current gTLD structure is inadequate to manage the naming requirements of
commercial entities worldwide and that trademark issues are important. The IAHC solution,
meritorious as it is, fails in one key aspect. It seeks to impose a solution maintained and
administered by what is essentially a technical non-governmental organization on a regime that is
inherently legal, political, and economic in nature. NGOs, particularly technical NGOs lack the
expertise, authority, experience, and jurisdiction to regulate in that environment. The IAHC also
was very limited in its scope and membership, and did not address (nor did it seek to address)
wider domain naming issues beyond expansion of the com domain, trademarks, and related
In addition to the IAHC recommendations, others have suggested (1) creation of a flat TLD
structure, allowing registrants to choose individual TLDs without regard to "controlled
or "indexing"; (2) elimination of the TLD topography by either eliminating alphanumerics and
reverting to IP numbers only or by generating random TLDs; and (3) migration from the
functional TLDs (gTLDs -- com, net, org -- and the edu, gov, mil TLDs) to an exclusive adoption
of the geographic (ISO 3166) two-letter codes now employed largely but not exclusively (.us)
outside the United States.
Option 2 would eliminate trademark issues but would prove unwieldy and unpopular. Neither
option 1 nor option 3 would address trademark questions.
A. 2. Other Stakeholders. This debate tends now to be dominated by three
Commercial interests seeking to protect oftentimes legitimate and sometimes questionable
trademark rights, the technical Internet community, and the root domain registrars -- both the
established and the hopeful. There are other constituencies and stakeholders with significant
interests in the outcome of the TLD naming debate. These include governments (that the
Department of Commerce has requested comments on this issue speaks for itself), the information
science and library community, and the non-commercial and quasi-commercial domain and virtual
domain name owners, as well as others.
Unfortunately, these other stakeholders have tended to be ignored. I am one of those other
"stakeholders" in that I find that the TLD and second-level domain (2LD) tags of URLs can be
used as an important non-keyword Internet search methodology. In that light, neither the
geographic TLDs as well as both the functional TLD status quo as well as the IAHC proposal do
not threaten the methodology. Flat TLDs would destroy the utility of the method while IP
would render it perhaps hopelessly complex.
It is undesirable to destroy any search methodology that helps organize and regularize the
Searching on "URL fragments" is one such approach, and is supported by several major search
engines. If anything, "controlled vocabularies" and "indexing" (both timetested and honored
vehicles for information management and retrieval) should be expanded in the Internet context. It
could be expanded by more universal use of standardized 2LD and 3LD tags now employed by
some but by no means all geographic TLDs. Examples include gob.mx (government servers in
Mexico), co.jp (commercial servers in Japan) and ac.uk (academic servers in the United
Other variants include [state postal code].us, fi.cr (financial entities in Costa Rica), and tm.fr
(trademarks in France). A somewhat universal application of standard 2LD tags together with
existing TLD tags could improve "quasi-set" creation and, as a result, search precision.
A.3. Responses to: Issues 1, 2, 3, 5, 8, 9, 10, 11, 13, 14, and F "Trademark Issues"
1. Advantages/Disadvantages of Status Quo. The status quo does not address trademark
issues, it cannot regulate either trademark rights nor the distribution of domain names in general,
and the size of the com TLD is unwieldy. On the other hand, the functional and geographic
system provide some classification and categorization structure.
2. Improvements. Expand as necessary TLD tags, but restrict that expansion to
manageable limits. Expand the use of 2LD and perhaps 3LD standard naming conventions.
Consider the use of .tm (trademark) to indicate a "protected" domain --
would be restricted and protected. Non-.tm 2LD might not carry the same level of trademark
3. Administration of domain name systems. Technical NGOs are inadequate to the task.
Perhaps the system could be managed by an arm of the ITU, advised by a board consisting of the
interested stakeholders and constituencies. That board could be nominated by important NGOs,
other IGOs, commercial entities and trade associations, governments, universities, governments,
the intellectual property bar, etc.
5. Retire gTLDs. I see no compelling reason to do so. Some see gTLDs as indicating
implicitly an American registry, others have accepted it as more universal. The geographic TLDs
are sometimes interpreted, particularly in commercial circles, as more parochial or regional in
character. As a consequence, non-US commercial entities sometimes adopt functional rather than
geographic registrars. That may lead to minor confusion. However, many corporations have a
global character and the functional TLDs may reflect that.
8. Transition to New System. Slowly, if at all.
9. Other issues. Use of 2LD and 3LD standard tags.
10. Technical, practical, policy restraints on new gTLDs. From a practical/policy
perspective, gTLD proliferation can lead to confusion and perhaps a breakdown in its usefulness
an information organizing medium.
11. Create new gTLDs? Yes, or move to a 2LD system. But limit the number of gTLDs.
13. Separability of gTLD from ISO 3166 TLDs. Certainly there are jurisdictional and
syntax differences between geographic and functional TLDs. gTLDs, other functional TLDs, and
geographic TLDs are administered by different root registrars. That is manageable. However, all
registrars need, no, must follow protocols and standards which facilitate Internet communication.
14. Other issues. Please consider the adoption of 2LD and 3LD standards as well as a
reasonably rational approach to the allocation of TLDs by group and classification.
F, Trademarks. The trademark issue will dominate the TLD debate since interests are so
vested and extensive. All sides in the debate make valid points. While trademark law is extensively
developed, its application tends to be more national than international in scope. There does not
exist an adequate body of international jurisprudence to mitigate the challenges resulting from the
Internet, a largely unregulated and truly international medium. Reliance on national regimes will
likely prove inadequate. Moreover, efforts by technical NGOs to regulate this issue will not only
fail, but will probably significantly reduce the perceived competence of such NGOs in their
established areas of expertise and proficiency.
I am a student in the MSLS program at the University of Tennessee writing a thesis on the longevity and constancy of Web pages and Web sites. I hold a PhD in government from Cornell (1977). I am author/co-author of a number of papers on Internet searching, cataloging, and related issues. Most recently I presented at the Internet Society Meeting (June 1997) on search methodologies. I have also been employed by an information broker/consultant as a senior researcher to a US government agency to develop methodologies for WWW cataloging (for a list, my c.v. can be found at http://www.public.usit.net/willing)
### Number: 62 From: Surffing The Net firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/6/97 11:44pm Subject: Domain names Yes you should control names, but for adult or porn sites it should NOT HAVE A: .com, .gov, .org or any ext. like what we use. Its early in the game of the internet and NOW YOU can do something. Make a new ext. for all the "Adult" sites so our filters can avoid them. Our teens using computers at schools and other public places can't get "adult" sites. Don't take away freedom of the net. We can't look over what our teens are seeing on the net, but we can do something about access to the sites. Filters work but what if some teens want to learn about safe sex. The filters we now have will not let the word "sex" go. Here, I have a new ext. for all the "adult" sites: .adt or .21 Please look into this. Thanks for reading this. :) Ron Vikara email@example.com Villa Park Il. ### Number: 63 From: "David A. Matson" firstname.lastname@example.org> To: "'email@example.com'" firstname.lastname@example.org> Date: 7/6/97 8:08pm Subject: domain names The best thing to do about domain names is just let go of them. Let competing technologies try to figure out what should be done and create a De Facto standard. Why? 1. It won't cost the government any money. 2. It has worked for everything else on the Internet. 3. The best, or one of the best technologies will become the standard. 4. When privatized, almost everything becomes better. I hope this helps. David Matson Dmatson@bigfoot.com ### Number: 64 From: Paul Nixon email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/6/97 4:30pm Subject: Re: Commerce Department Domain Name Proceeding >"The Internet has thrived in an environment of communal discussion and >consensual decision making, largely free from government regulation," said >Commerce Secretary William Daley. "Many believe that its extraordinary >growth and success stem, at least in part, from its decentralized structure >and bottom-up self-regulatory governance. The Clinton Administration >strongly believes that our challenge is to resolve these issues within that >unique structure and governance." The above is exactly why the Clinton administration, the Commerce Dept, and the Federal Government as a whole should stay the heck out of any effort to resolve this issue. Let is resolve itself: it will, likely better without bureaucratic involvement. ### Number: 65 From: Bonita Walker firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/6/97 1:53pm Subject: Domain Names I am not sure about alot of this but I was thinking about the porno on line problem and wondered it it would be feasible to end all the names with .sex. That way browsers could have options not to let them in and if they put it out with another ending they would be fined or something. Just a thought. 07-08-97