08-08-97 Electronic Filings on Internet Domain Names

###
Number: 167
From:     Adam Prall <adam@hawaiian.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 1:08am
Subject:  Top-Level Domains

To Whom It May Concern;

Currently there are many plans put forth by various commercial ventures
who want to control the new top-level domain "system" of naming that is
currently used on the Internet, all of which make the average person pay
them a fee for "registration" and "maintenance". What "maintenance fee"
are they charing for? A database is simply a file that contains
information, just like a physical card catalog that is still used in
many libraries today. It does not require "maintenance", and
"registration" is simply the insertion of a new "card" into the "card
catalog", or simple data-entry. There are many companies which would
like to charge us, the public, fees for one minute of typing on a
computer, and additional, higher fees for them not to delete us from
their databases. Currently, the InterNIC has this position. As a web
publisher, my company has registered several domain names with a
registration company, let's say about 15 names in the last 2 years. So
with our business alone, this registration company has made about
US$1500 for about 15 minutes worth of typing. Fortunately, when I was
born, name registration was still free, so that my mom didn't have to
pay $100 to name me. I think it is very rude for us to have to pay a
company to gain the right to have a name on the Internet. Under whatever
plan is finally arranged by our government, I don't think people will be
willing to pay for something which should remain free.

Adam Prall

###
Number: 168
From:      "John Schaub" <john@printcolor.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 11:46am
Subject:   Domain Names

Barbara Wellbery
Chief Counsel
U.S. Department of Commerce
National Telecommunications and Information Administration

Dear Ms. Wellbery:

Our domain name is vital to our business. We have advertised it and invested
a great deal of time and money in getting it out to our customer base.
Please do not allow anything to happen that would make us loose our domain
name or make it too expensive to maintain it.

We are a small business. My biggest fear is that a larger business would
"buy" the rights to our name and take it over along with our customer base.
Please protect America's small business by protecting our ability to
maintain our domain names at a reasonable cost.

Thank you for your concern.

Sincerely,
John Schaub

Sir Speedy Printing
2640 Financial Ct., Suite B
San Diego, CA 92117
619/581.1884
john@printcolor.com

###
Number: 169
From:      "Harlan Pittelkau" <harlanp@dis.wa.gov>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 2:39pm
Subject:   Domain Names

Site identification and subject content are often at odds with what we want
to see.  At the very least, Domain Names need to properly describe the
site.  

Harlan Pittelkau
Washington State Year 2000 Program Office
harlanp@dis.wa.gov



###
Number: 170
From:      howard <hleshner@map.com>
To:        NTIADC40.SMTP40("dns@ntia.doc.gov.")
Date:      8/8/97 1:11pm
Subject:   Government DNS Policy

To Whom it concerns,

I believe that government regulation specific to the internet in any
respect is wrong.

This should not be and can not be the model of a sucessful information
infrastructure.

The issue of DNS TLD regulation by the government would be a mistaken
endevor.

The only government laws that should have any effect on the DNS issue
are the current antitrust laws NOT specific to the internet and other
current laws prohibiting restraint of trade and commercial monopolies.

I believe The paradigm implemented by name.spaceTM is the most
pro-competitive, democratic and open system proposed so far with
respect to opening up the administration and operation of the
Domain-Name-System ("DNS"). The structure advocated by name.space
removes the artificial barriers to entry that exist today as a result of the
monopolistic control over the domain name registration market exerted by
Network Solutions,Inc. The name.space paradigm incorporates a fair,
competitive structure which encourages investment and innovation by
companies wishing to compete in the provision of this service which is
essential to the operation and continued growth of the Internet. 

Howard Leshner



###


Number: 171
From:      "Doug Lakin" <Doug@TeleCommerce.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 5:58pm
Subject:   Response to RFC on Internet Domain Names

Please accept my comments on your subject RFC.

I have attached my response in two formats. The first attachment is a
Word/95 document (rfc-resp.doc), and the second is in HTML format
(rfc-resp.htm) to facilitate display on the web.

Please feel free to contact me if you would like further explanation.

Respectfully submitted,

Doug Lakin
TeleCommerce, Inc.

###
Number: 172
From:     "foodie@chef.net" <Alif.Terranson@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 12:34am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Alif Terranson do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 00:32:52 EDT
Alif Terranson

Box 775544
St. Louis, MO 63177





###
Number: 173
From:      "jghicks@wordswork.com" <Jennifer.Hicks@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 1:22am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jennifer Hicks do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 01:21:30 EDT
Jennifer Hicks

Boston, MA





###
Number: 174
From:      "registration@g3.org" <George.Morris@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:50am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I George Morris do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 00:48:16 EDT
George Morris


###
Number: 175
From:      "gimmi@inx.net" <Susanne.Schropp@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:59am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Susanne Schropp do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:58:13 EDT
Susanne Schropp






###
Number: 176
From:      "david@speco.com" <David.Schutt@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:32am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I David Schutt do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 09:30:29 EDT
David Schutt

Speco, Inc.
3946 Willow
Schiller Park, IL
60176





###
Number: 177
From:      "tsmith@collegeboard.org" <Tamara.Smith@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:23am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Tamara Smith do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 09:21:25 EDT
Tamara Smith

###
Number: 178
From:      "jlevine@li.net" <Jason.Levine@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:02am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jason Levine do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 09:01:19 EDT
Jason Levine






###
Number: 179
From:      "Rick@Bueker.com" <Rick.Bueker@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 8:57am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Rick Bueker do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 08:55:59 EDT
Rick Bueker






###
Number: 180
From:      "kpx@panix.com" <kevin.prichard@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 8:54am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I kevin prichard do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 08:53:12 EDT
kevin prichard






###
Number: 181
From:      "boww@eden.rutgers.edu" <David.Bowser@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 8:48am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I David Bowser do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 08:46:48 EDT
David Bowser






###
Number: 182
From:      "Roel@lx.student.wau.nl" <Roel.Janken@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 8:34am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Roel Janken do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 08:32:27 EDT
Roel Janken

http://dondersteeg.free.zone





###
Number: 183
From:      "ddprod@walrus.com" <Danny.Dries@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 8:18am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Danny Dries do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 08:16:52 EDT
Danny Dries






###
Number: 184
From:      "husham@bigfoot.com" <husham.memar@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 7:56am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I  husham memar do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 07:54:35 EDT
 husham memar








###
Number: 185
From:      "sandra.fauconnier@rug.ac.be" <Sandra.Fauconnier@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 7:54am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Sandra Fauconnier do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 07:53:20 EDT
Sandra Fauconnier






###


Number: 186
From:      "Webmaster@Uniad.com" <Osvaldo.Medina@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 7:32am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Osvaldo Medina do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 07:30:51 EDT
Osvaldo Medina

San Juan, Puerto Rico





###
Number: 187
From:      "hrainer@tks.fh-sbg.ac.at" <Hansjoerg.Rainer@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 7:04am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Hansjoerg Rainer do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 07:02:07 EDT
Hansjoerg Rainer


###
Number: 188
From:      "Paolo@khm.de" <Paolo.Atzori@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 6:42am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Paolo Atzori do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 06:40:44 EDT
Paolo Atzori

Luetticher Strasse 34    D-50674   Cologne





###
Number: 189
From:      "fil@bok.net" <RIVIERE.PHILIPPE@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 6:18am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I RIVIERE PHILIPPE do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 06:16:32 EDT
RIVIERE PHILIPPE






###
Number: 190
From:      "mvario@escape.com" <Michael.Vario@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 6:03am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Michael Vario do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 06:02:15 EDT
Michael Vario






###
Number: 191
From:      "chisler@usa.net" <David.Chisler@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 5:49am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I David Chisler do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 05:48:10 EDT
David Chisler






###
Number: 192
From:      "michelc@quebectel.com" <Michel.Canuel@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 5:40am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Michel Canuel do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 05:38:27 EDT
Michel Canuel






###
Number: 193
From:      "felicity12@earthlink.net" <Ed.Nguyen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 5:22am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Ed Nguyen do hereby support the design of the expanded toplevel Internet
namespace which is currently operated by pgMedia, Inc.'s name.space(tm)
service, located on the internet at http://namespace.pgmedia.net (or
http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 05:20:58 EDT
Ed Nguyen






###
Number: 194
From:      "mdana@hevanet.com" <Michael.Dana@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 3:41am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Michael Dana do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 03:39:18 EDT
Michael Dana

2980 NE Division st.
Space: 45
Gresham, OR; 97030-6039





###
Number: 195
From:      "arjenjkl@noord.bart.nl" <Arjen.J.Kloppenburg@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 3:29am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Arjen J. Kloppenburg do hereby support the design of the expanded
toplevel Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 03:28:07 EDT
Arjen J. Kloppenburg






###
Number: 196
From:      "daveb@interlog.com" <David.Berman@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 3:23am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I David Berman do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 03:23:12 EDT
David Berman






###
Number: 197
From:      "gargoyle@echonyc.com" <Steve.Jones@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 2:53am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Steve Jones do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 02:52:09 EDT
Steve Jones

New York City

###
Number: 198
From:      "dschuerewegen@europarl.eu.int" <Dany.Schuerewegen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 3:42pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Dany Schuerewegen do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 15:40:05 EDT
Dany Schuerewegen

Coord. Informatique DGI
European Parliament
Batiment Schumann 3/36
Plateau du Kirchberg
L-2929 Luxembourg
Luxembourg





###
Number: 199
From:      dannero@worldnet.att.net <Melvin O@zero.tolerance.org,
Danner@zero.tolerance.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 2:52pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Melvin O, Danner do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 14:45:21 EDT
Melvin O, Danner

22998 E. Crenshaw St.
Tampa, Florida 33610





###
Number: 200
From:      "leander@dds.nl" <Leander.Janssen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 2:07pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Leander Janssen do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 14:06:19 EDT
Leander Janssen








###
Number: 201
From:      "serpent@v-wave.com" <Sary.Mao@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 1:59pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Sary Mao do hereby support the design of the expanded toplevel Internet
namespace which is currently operated by pgMedia, Inc.'s name.space(tm)
service, located on the internet at http://namespace.pgmedia.net (or
http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 13:57:53 EDT
Sary Mao






###
Number: 202
From:      "john@fenixsf.com" <John.Blower@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:19pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I John Blower do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:18:05 EDT
John Blower

41 Murdock St
Brighton, MA 02135
US





###
Number: 203
From:      "imda@imda.com" <Judy.Leshner@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:18pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Judy Leshner do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:16:31 EDT
Judy Leshner

617B College Hwy. Southwick MA 01077





###
Number: 204
From:      "hleshner@map.com" <Howard.Leshner@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:15pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Howard Leshner do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:12:20 EDT
Howard Leshner

PO Box 974 Southwick MA 01077





###
Number: 205
From:      "106576.113@compuserve.com" <Ralph.Beloch@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:12pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Ralph Beloch do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:10:27 EDT
Ralph Beloch






###
Number: 206
From:      "mystic.one@mci2000.com" <Daniel.Prather@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:05pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Daniel Prather do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:03:27 EDT
Daniel Prather

3521 Florida Avenue
Panama City, Florida
32405-3324






###
Number: 207
From:      "adeen@parsons.edu" <Anthony.Deen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 11:22am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Anthony Deen do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 11:20:52 EDT
Anthony Deen

500 West End Avenue
New York, NY 10024





###
Number: 208
From:      "john@theonly.com" <John.Catlin@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:34am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I John Catlin do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:32:33 EDT
John Catlin

3 Shore Dr.
Shutesbury, MA 01072





###
Number: 209
From:      "feldmann@metronet.de" <Martin.Feldmann@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:08am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Martin Feldmann do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:06:45 EDT
Martin Feldmann






###
Number: 210
From:      "jbdomic1@msn.com" <Jorge.B.Domic@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:02am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jorge B.Domic do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:00:45 EDT
Jorge B.Domic






###
Number: 211
From:      "jwkckid1@ix.netcom.com" <Jeffrey.A.WIlliams@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:57am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jeffrey A. WIlliams do hereby support the design of the expanded
toplevel Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 09:55:46 EDT
Jeffrey A. WIlliams

1333 west Cambel rd.  #176
Richardson, Texas, 75080


###
Number: 212
From:     "bwarden@rmci.net" <Brett.Warden@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 7:34pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Brett Warden do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 19:32:52 EDT
Brett Warden



###
Number: 213
From:      "123@pobox.com" <Mark.Whitby@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:17pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Mark Whitby do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 21:15:48 EDT
Mark Whitby

###
Number: 214
From:     "hawkmoon@mindspring.com" <Greg.Shields@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 10:44pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Greg Shields do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 22:42:43 EDT
Greg Shields

###
Number: 215
From:     "jrscott@hotmail.com" <John.R.Scott@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 6:36pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I John R. Scott do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 18:34:46 EDT
John R. Scott