### Number: 85 From: Jason Brown email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 1:03am Subject: New internet domain names I personally like the idea of new domains on the internet, especially .store and .web. I also think there should be a board or some such group (internationally) to assign and maintain domain names, outside of a company, because the internet is too big to be controlled by a company... ### Number: 86 From: Alan Bleiweiss firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 1:30am Subject: Request For Comments - Domain Process As an Internet Development Manager since 1994, I can simply state my comments in one paragraph. It is imperitive that the domain registration process be freed of its current stranglehold by one organization. In order for the Internet to flourish and grow, as it should, this process must be democratic and fairly distributed amoungst many companies. The present system is archaic, dictatorial, and destined to cause severe havoc as the masses continue to move to this new medium. -- Alan Bleiweiss Project Manager Web Implementation NetHaven - The Internet Division of Computer Associates International Chairperson, Long Island Webmasters Guild ### Number: 87 From: Michael Gersten email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 2:27am Subject: DNS system comments I want to support the EDNS style system, and the existing EDNS servers. What are the benefits of the EDNS system? Simple. Anyone can start up a top level domain, by simply having a few basic, essential requirements taken care of. There is no need to be a big pocket, major cash player to play; it is very concevable that five or six different non-profit, hobbyist groups can get together and set up their own top level domains, at no cost to the users. Compare this to Alternic's system, where you have to spend $1000 (I belive) to register a top level domain. Or, compare this to the (now defunct) Postel Draft from IANA/ISC, where there was a 2% fee of any money collected from the registries, to support IANA (which now seems to be getting out of the business, although I may be mistaken here). Are there drawbacks to the EDNS system? Yes. First, you have a first come, first served system, with non-shared top level domains. Is this a problem? First come, first served, is (essentially) how the current system of domain registration is _SUPPOSED_ to work. In reality, the people currently running the .com domain (which is what most people consider to be the domain name system) will arbitrarily yank a name if they think that someone else might have a trademark status that would result in their (the registry) being sued in court; this policy has, in fact, resulted in suits from people who have lost a domain name. Is there a problem to first come, first served on the top level? No more than on the second level. Just as someone registered television.com, (and someone else then registered tv.com), just as two different acme corporations have to get different names (only one acme.com), just as I have seen the name "Common Sense Computing" taken in two different counties as a name for a computer consultant (two different people), any sort of "one name per world" will have overlap. This is not a serious objection. Is there a problem to non-shared registries? Not really. A shared registry ultimately is silly. Computers do not look up your name by the registry, they look it up by the zone file. If two different registries are serving the same zone file, they have to share the data, and there is *NO* difference as far as any user can see in the service performed, the only difference is the price to register. This is not enough of a reason to force a lot of changes on the system. A bigger question, and one of far more importance, is who is to own the existing registries. Right now, existing top level domain names have been given to people who have, or are, abusing it. Examples? The .us domain, which is geographical by state. One state was given to an ISP in that state; the cities in that state then organized, and wanted to each be listed (sorry, I don't remember the name of the state) at the third level. Because of the large number of cities in this state, the ISP refused, and would only allow a small number at the third level (below which it would delegate out to others at that level). That may be appropriate for county level division, but that's not how the .us domain works, normally. Consider that we do not say "los-angeles.la-country.ca.us", we say "la.ca.us". Worse? One country is "lucky" enough to have the top level domain of ".tv". This is a little, poor country, offshore. This domain name is suddenly the most valuable asset it can have. Except that there is a private company, an ISP that was given control of that name. I really think that fixing the existing bad delegations of names, away from ISP's, and towards the people who will actually USE the names, and who the names represent, is more important, in the long run, than worrying about expanding the top. And I think that a "no big pockets needed, simple and basic system" is the best way to go; this is the EDNS system (www.edns.com). Note that I'm not saying that I think that the people in charge of EDNS currently are the best qualified to run the top. At some point, some one person or group has to be responsible for saying what is and is not in the top. EDNS has some seemingly straightforward restrictions -- a top level name may be rejected for unspecified reasons (example: had the CDA been upheld, the name ".sex" would not have been allowed), or for perceived copyright reasons (example: someone registering ".ibm" or ".toyota" without actually representing the company in question). Although these seem like reasonable policies, there's a lot of actual cases and details to be worked out. The actual policies used in practice may not be so good, and may require the people who determine "what's in the top" to be changed. Finally, there's a bigger problem: The top level is global, not US. I personally don't think that the U.N. is the right group to control this, nor would I trust any multinational corporation. If I had to name an individual that I thought could do it properly, I'd name Jon Postel of IANA/ISC, but even he will die eventually. I have no clue as to how to determine any sort of long term solution to this problem. -- Michael Gersten firstname.lastname@example.org http://www.stb.info.com/~michael NeXT Registered Developer (NeRD) # 3860 Without Prejudice, UCC 1-207 ** HIRE ME: http://www.stb.info.com/~michael/work/ ### Number: 88 From: wallace koehler email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 6:07am Subject: gTLDs NOTE: I sent this in Word 6. I went to check the quality of transmission at your site and was unable to open it. Here it is enclosed in email. Response to Department of Commerce Request for Comments on Internet Domain Names Wallace Koehler (firstname.lastname@example.org) 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 related 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 matters. 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 vocabulary* 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 groups: 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 numbers would render it perhaps hopelessly complex. It is undesirable to destroy any search methodology that helps organize and regularize the Internet. 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 Kingdom). 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 naming 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 -- (corporate_icon).tm.TLD would be restricted and protected. Non-.tm 2LD might not carry the same level of trademark protection. 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 as 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 yet 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. B. Background 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: 89 From: Andrew Hofer email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 8:19am Subject: Comments on Domain Name Administration I manage multiple domains for clients of my company, NST Systems, Inc. of Stamford, CT. The paramount concern that I would have regarding a change in administration of Domain names on the Internet is to make certain that a SINGLE entity is responsible for registering and resolving names at the top levels. Please don't perpetrate another disaster on the American public in the name of "antitrust" by breaking up a single, well-coordinated company into dozens of competing, disorganized entities all vying for our attention and screwing up our records. When the US Government broke up the phone system, AT&T advertised only for "corporate image" and otherwise ran a good system where the most important feature was that you never had to think about their service... you just took it for granted. Now the phone system has been a complete mess for years, with hundreds of thousands of our dollars wasted on advertising to get our business, dozens of little phone companies constantly trying to switch our service and convince us that what we want is "choice." The public doesn't want "choice" in what are perceived as utility services -- they just want SERVICE! The public doesn't care whether the service is competitive -- the price we pay for competition is greater than what we pay a monopoly! Just look into regulating these monopolies properly to keep them reasonably fair, and otherwise don't bother them. If competition is so great, why don't we allow alternative federal governments and let each member of the public choose a governmental "service provider" according to which government has the best rates and sales pitch? How effective would THAT be as a way to run the country? Andy Hofer NST Systems, Inc. ### Number:90 From: "techmage" firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 8:47am Subject: NSI Network Solutions Inc, as it currently operates is a monopoly in its most clasical form. Its rates are way outside what its service entales. $100 per domain, per year is ridiculos, when you consider what is costs them to perform this service. email@example.com The Dark Tower can be found at: http://www.geocities.com/SiliconValley/Lakes/2669/ ### Number:91 From: firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 9:32am Subject: DNS I would prefer that the commerce department maintain the spirit of the Framework for Global Electronic Commerce. Though the CD has been tasked by the president in a backdoor maneuver to evaluate the DNS issue, let the the non-government, non-profit organizations continue to oversee these functions (in the spirit of the Internet not being burdened by government regulations). The Internet is one area which I would prefer not to see "the law" forced upon Internet users for the sole reason that certain individuals feel "law" should be in place. If the government starts regulating the DNS issue, then it's foot is in the door -- a fox in sheeps clothing. Don't evaluate; don't recommend. William D. Hetzel 1029 Blvd East, #5 Weehawken, NJ 07087 ### Number:92 From: Chrissy email@example.com To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 11:09am Subject: InterNIC I work for an Internet Service Provider and am in charge of domain name registration for our customers and have had nothing but trouble with InterNIC's billing department. I have had instances where InterNIC has deposited our check and it has posted at our bank and then 3 days later, they have put the domain that was paid for on hold for non-payment. The people that answer the phone are completely incompetent and all give diferent answers to the same question. I have then later talked with their supervisors about it and they are just as incompetent and act like they do not care. Supposedly in April they overhauled their billing system but nothing has changed. I am so glad that they will not be handling domain name registration after March of 1998. My suggestion for the future of domain name registration is to learn from all of InterNIC's mistakes, especially their billing mistakes. Thank you. Christinia McGuire NKN ### Number: 93 From: cardclb firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 2:01pm Subject: Sincere suggestion for domain names. Domain names should be set up like the phone book. For ex.: www.government should take us to a very patriotic and official page with links to all gov't related sites (i.e. www.government/congress). And: www.church should take us to a page with every type of church. Then www.church/catholic should explain the catholic faith and have links. And: www.computer should be related to the industry with appropiate links. Finally: www.personal would lead to www.personal.johnsmith I would leave off that "www.", too, if it were me. Thank you for your time, if you bothered to read this far. -Chad ### Number: 94 From: Arlie Davis email@example.com> To: "'firstname.lastname@example.org'"
Date: 7/8/97 3:23pm Subject: Comments on the InterNIC I helped to found a small, successful Internet service provider. Interaction with the InterNIC was a crucial part of the job. So I am in a good position to comment on the quality of the InterNIC's service and their policies. First of all, the quality of the service at the InterNIC has gotten much worse since they started charging for domain names. The service is, at best, inconsistent. Sometimes requests sent to the InterNIC would be processed within a week; very often, requests would take more than a month or would simply be lost. The InterNIC argued that charging a (very high) fee for its services would guarantee fast, professional service. It has completely failed to deliver on its promise. As a partner in a small Internet provider, our ability to serve our customers (who needed domains registered) was severely hampered by the inefficiencies and high cost of dealing with the InterNIC. Second, the quality of the policies of the InterNIC are not satisfactory. There needs to be a system of arbitration for domain names. The responsibility for choosing who gets to register a domain name needs to be separated from the companies that provide the root-level name service. The idea of a single, private company like Network Solutions having absolute control over the namespace of the Internet is abhorrent; imagine if a single company governed what other companies were allowed to name themselves, or goverened how street addresses were assigned in new cities. This needs to be done by an external body which does not have a financial interest in the outcome of the decisions. The InterNIC has no pressure at all on it to increase the efficiency and decrease the cost of its services. It is impossible for a competing company to provide the same services. The best solution would be to separate the responsibilities of the InterNIC into two types of organizations. The first would necessarily be a single organization, possibly an agency of the US federal government or an international body. This organization would govern the namespace of the Internet, and would arbitrate disputes over domain names. The second type of organization would simply provide the actual network services required to provide the Domain Name System; it would not make any policy decisions. Many different companies could act in this role; the competition among them would necessarily allow for a cheaper, more robust, and less easily-monopolized Internet. Thank you for your time. -- Arlie Davis ### Number: 95 From: calvin email@example.com> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 4:02pm Subject: government operation of domain name system I personally don't see why the government couldn't continue to run the domain name operations. To feasibly run the system the government could just turn part of the operations over to the patent office and when they issue a company a patent on their trademark why not at the same time issue the company a patent for a domain name with the same as that of the trademark? The other alternative is to set up a computer program that would automatically generate a domain name based on the patent number given to the company for their trade mark. The latter of the two solutions I suggest would eliminate squabbling over who gets what domain name. To pay for the government operation would also be quite easy. All the government would have to do is to add a small tax of say $.05 to $.10 cents per month onto all personal ISP accounts and $.15 to $.20 cents per month onto all business ISP accounts. ### Number: 96 From: Glen McCourtie firstname.lastname@example.org> To: NTIADC40.NTIAHQ40(dns) Date: 7/8/97 7:08pm Subject: Internet Domain Names I believe the government needs to stay out of the Internet. The government has already, with little success, tried to "help" the Internet. But, it has caused more harm to the the Internet than any "good intentions" it has tried to act upon. Glen McCourtie 238 Ballard Jackson, MI 49201 ### 07-08-97