08-09-97 Electronic Filings on Internet Domain Names

###
Number: 216
From:      Milton Mueller <milton@usthk.ust.hk>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/9/97 11:56pm
Subject:   Comments -- Internet Domain Names Notice

The attached document is a Word 6.0 file containing 
my comments for "Registration and Administration of 
Internet Domain Names" (Docket 970613137-7137-01)

Please acknowledge receipt.

Milton Mueller

--



Before the

U.S. DEPARTMENT OF COMMERCE,

National Telecommunications and Information Administration

Washington, DC 20230


In the Matter of                     )
                                     )
REGISTRATION AND ADMINISTRATION      )    Docket No. 970613137-7137-01
OF INTERNET DOMAIN NAMES             )
                                     )


Comments of Dr. Milton L. Mueller

Milton L. Mueller
Syracuse University
School of Information Studies
Syracuse NY 13244


Associate Professor
18 August, 1997

TABLE OF CONTENTS

* Summary 2

* A. Appropriate Principles 3

* B. General/Organizational Framework Issues 4

* C. Creation of New gTLDs 6

* D. Policies for Registries 7

* E. Trademark Issues 8

SUMMARY

1. NTIA is to be commended for initiating this Request for Comments. There is growing confusion and conflict over Internet administration. Key resources and agencies are stranded in a legal vacuum. Because of its historical responsibility for the funding and organizational framework of the Internet, U.S. Government action of this sort is overdue.

2. This comment supports privatization and additional competition in the top-level domain namespace. It recommends adding freedom of expression to the list of appropriate principles used to evaluate proposals. The comment calls for the definition of procedures that would allow new TLDs to be created in response to entrepreneurial activity and market demand. It strongly opposes the proposal to phase out gTLDs in favor of compulsory national TLDs. It also refutes the equation of domain names with trademarks or brands, and rejects attempts to forge inappropriate links between domain name registration and trademark protection.

Before the

U.S. DEPARTMENT OF COMMERCE,

National Telecommunications and Information Administration

Washington, DC 20230

In the Matter of                     )
                                     )
REGISTRATION AND ADMINISTRATION      )    Docket No. 970613137-7137-01
OF INTERNET DOMAIN NAMES             )
                                     )




Comments of Milton L. Mueller.

1. Dr. Milton L. Mueller respectfully submits comments in this proceeding. Dr. Mueller is Associate Professor and Director, Graduate Program in Telecommunications and Network Management, School of Information Studies, Syracuse University. He is the author of numerous scholarly works on telecommunications policy and regulation, including issues related to Internet economics and administration. He has also served as consultant to governments and businesses in the United States and Hong Kong on regulatory policy issues in telecommunication.

2. The views expressed here are those of an individual faculty member and do not necessarily represent the views of Syracuse University or its School of Information Studies.

A. Appropriate Principles

b. The private sector, with input from governments, should
develop stable, consensus-based self-governing mechanisms for
domain name registration and management that adequately defines
responsibilities and maintains accountability.

3. This statement reveals a degree of confusion about the existing situation and the proper role of government. The current crisis in domain naming is a product of a legal and administrative vacuum for which the US government is directly responsible. The domain name problem is about ownership and allocation of valuable resources; specifically, root name servers and top level domain names. No existing entity has direct, unambiguous property rights over these resources.

4. In particular, the commercialization of the Internet has stranded the Internet Assigned Numbers Authority (IANA) in an ambiguous position. IANA does not have a clear legal right to manage the root as a private, commercial entity. Nor has the root been declared a public resource to be managed by government(s). Nor has IANA been given any legal or procedural mechanism for distributing relevant property rights to competing firms in the private sector. This legal vacuum does not encourage "self-governance;" it only perpetuates confusion and invites the Internet equivalent of land grabs and squatting. As for "consensus," it is evident from the growing number of lawsuits, the angry rhetoric on listservs, and the growing schism between the key institutions of Internet administration that no consensus exists.

5. In this context, loose references to "self-governance" and "private sector initiative" are not helpful. They only obscure the legitimate and unavoidable role governments must play in the definition, enforcement, and adjudication of property rights. Without clearly defined property rights, there is no "private sector." Without stable rules governing the nature and use of resources, there can be no "self-governance."

6. As an alternative formulation of principle (b.) I respectfully propose the following: The U.S. government must play an active role in moving the core resources of the Internet out of the US-based public sector and into a competitive, private sector-driven, global institutional framework. Only government can establish the legal and institutional basis for private sector competition and ongoing self-governance. Because of its historical responsibility for the central authorities of Internet administration, the US government must take the lead in this process.

Other principles

7. A new principle should be added to this list. Domain names must be recognized as a form of expression or communication. Domain names convey ideas and transmit organizational identities. They can be put to creative uses. They are often selected to attract attention, and in some cases form phrases. Domain names can make references to people, institutions, and events. In formulating public policy, therefore, considerations of freedom of expression and of the proper level of restraint upon personal and public communication must be taken into account. Many governments around the world are hostile to freedom of expression. I urge the US government to uphold the principles embodied in its own Bill of Rights and clearly recognize the principle that freedom of expression is implicated in its treatment of domain naming.

B. General/Organizational Framework Issues

4. Are there decision-making processes that can serve as models
for deciding on domain name registration systems (e.g., network
numbering plan, standard-setting processes, spectrum allocation)?

8. One significant model is the system of company symbols adopted by the stock exchanges in the United States. The analogy is relevant because:

a) Names have some semantic relationship to the actual company name;

b) There are competing, privately-run exchanges, but all exchanges manage to make their naming conventions consistent and avoid collisions;

c) Most importantly, the exchanges do not simply hand out symbol strings at random or passively upon application, but actively manage their namespace. For example, NYSE reportedly is reserving the symbol "M" for Microsoft in an attempt to lure it from NASDAQ. This kind of active management of the resource in an environment that combines competition with cooperation is applicable to DNS.

4. (continued) What is the proper role of national or international
governmental/non-governmental organizations, if any,
in national and international domain name registration systems?

9. In establishing rules for privatization of the global namespace, the US government needs to find an appropriate forum in which to coordinate its efforts with other governments. The World Trade Organization is the most appropriate international organization for this purpose. The WTO is free of the sectoral vested interests that characterize, for example, the International Telecommunication Union (ITU) or the World Intellectual Property Organization (WIPO). As a vehicle for commerce and communication, the future of the Internet is vital to the growth of free trade in services and is also likely to have an impact on trade in commodities. Internet-related services themselves form a growing part of world trade. It is best, therefore, for international coordination around the domain name issue to be approached as an instance of trade in services, and the international framework established through WTO agreements.

5. Should generic top level domains (gTLDs), (e.g., .com), be
retired from circulation? Should geographic or country codes
(e.g., .US) be required? If so, what should happen to the .com
registry? Are gTLD management issues separable from questions
about International Standards Organization (ISO) country code
domains?

10. Generic TLDs should not be retired from circulation, and ISO-3166 codes should not be compulsory. Such a course of action would be the most disastrous mistake that could come out of this proceeding.

11. A regime of compulsory national TLDs is unfriendly to users. The primary purpose of domain names is to make addresses easier to use than numbers. ISO-3166 codes are only marginally better than numbers. The codes themselves are often counter-intuitive and confusing. For example, ".au" could be Austria or Australia; ".il" could be Iceland, Ireland, or Israel.

12. Another aspect of user-unfriendliness is the additional hierarchical levels that a country-code system imposes on users. National TLDs usually have a second-level hierarchy with additional "generic" categories inside them. (If country codes were compulsory then all of them would need generic second, and possibly even third, -level hierarchies.) Under a national TLD regime, expansion of the namespace can only occur by adding additional levels. The economic premium placed on existing gTLDs, especially ".com", by multinational companies is largely attributable to the shorter, more easily remembered name. A very large number of users have demonstrated a clear preference for shorter domain names.

13. Elimination of gTLDs eliminates all innovation in naming conventions. It fixes the total number of TLDs and imposes a single top-level categorization scheme upon the entire Internet, regardless of user demand. Ideas such as the ".nom" or ".per" space for personal names, or the ".num" space for telephone numbers, could not be implemented on a global basis.

14. Most importantly, a regime of compulsory ISO-3166 codes threatens to give national authorities the same bottleneck control over the Internet that they have traditionally enjoyed over post, telephone, telegraph and broadcasting systems. That is, domain name policies and conventions would be set by national governments or national registration monopolies. Naming conventions could be subordinated to the desire of national governments and/or network administrators to control and monitor the activities of Internet users. One virtue of gTLDs is that they create a global competition for names and registrations. It is ironic that a form of "Internet nationalism" would be proposed now, when telecommunications and broadcasting industries are slowly extricating themselves from the constraints and inefficiencies of a regime organized around national monopolies and national boundaries. Forcing Internet TLDs into a hierarchical framework organized around nation-states invites the politicization of Internet governance. It is also totally out of synch with the global, borderless nature of Internet communication, and the regional and local boundaries of language and culture.

15. A high level of coercion would be required to implement Internet nationalism. Tens of thousands of gTLD domains would have to be migrated into national TLDs. Many registrations under national TLDs would also have to change. There are at least 50 country-code registries that now accept registrations from hosts not resident in that country. This practice would have to be ended and policed.

C. Creation of New gTLDs

10. Are there technical, practical, and/or policy considerations
that constrain the total number of different gTLDs that can be
created?

16. Technically, there seems to be no significant disagreement with the proposition that there could be 500-600 TLDs (i.e., 250-350 more than currently exist). After that, expert opinion varies, but it is not uncommon to hear technically supportable claims that the system could sustain up to 10,000 new TLDs.

17. By way of background it is worth noting that in February 1996 IANA's Jon Postel, someone who could reasonably be considered an authority on the operational aspects of the Internet, proposed adding 300 new TLDs over a period of five years, with 150 new TLDs added in the first year.

18. Trademark protection is sometimes cited as a reason against creating new TLDs. In fact, additional TLDs help to decouple domain names from brands and trademarks and thus improve this alleged problem. This argument is developed in greater detail in the section on trademark protection.

19. User "confusion" is also cited as another reason to restrain or limit the number of TLDs. This argument assumes that domain names need to be part of a controlled, exhaustive classification scheme. In fact, there is no empirical evidence that users benefit substantially from a controlled classification scheme in the top level. All that matters is whether the TLD is easy to remember and gives users some semantic clues as to the nature of the address (e.g., ".biz," ".sex").

20. The most important practical considerations are not technical but economic and administrative. Specifically, the procedure for distributing the right to create and administer new TLDs must be carefully defined. If this process is open and continuous, as it should be, poorly defined procedures in the early stages of implementation may result in "land grabs" that could create injustices and threaten the connectivity or operational integrity of the network.

11. Should additional gTLDs be created?

21. Yes. More precisely, a procedure that allows new TLDs to be added continuously in response to consumer demand, entrepreneurial effort, and market evolution should be defined. More TLDs should be created because:

a) it reduces conflicts over desirable or popular names or expressions

b) it increases competition for registry services

c) it reduces the incentives for name speculation

d) it provides an additional channel for entrepreneurial innovation in value-added registration services and naming structures

e) it will eventually provide a mechanism for domain names based on non-Roman alphabets

13. Are gTLD management issues separable from questions about ISO
country code domains?

22. The real issue is the creation of new TLDs, not new "g"TLDs. Until and unless there is a consistently enforced policy that every name must end in a national TLD, there is no important distinction between "generic" TLDs and national TLDs. At the present time users still have the choice of registering in a "g"TLD or in alternative national TLDs. As long as this is true, national TLDs are nothing more than badly truncated, semantically unattractive generic TLDs.

D. Policies for Registries

15. Should a gTLD registrar have exclusive control over a
particular gTLD? Are there any technical limitations on using shared registries for some or all gTLDs? Can exclusive and
non-exclusive gTLDs coexist?

23. Shared registries may reduce users' risk of losing any sunk costs they invest in a particular domain name. In a competitive marketplace, this may make shared TLD registries an attractive option to users. However, there is no reason why all TLD registries should be required to be shared. There are no technical or administrative barriers to the co-existence of shared and exclusive TLD registrars. Hence, the choice of a shared or exclusive TLD registrar can be left to end users.

19. Should there be a limit on the number of different gTLDs a
given registrar can administer? Does this depend on whether the
registrar has exclusive or non-exclusive rights to the gTLD?

24. In the initial distribution phase of TLD rights there must be fairly stringent limits imposed on the number TLDs given to each registrar, otherwise applicants will have an irrational incentive to claim as much of the top-level namespace as possible regardless of their real capability to administer it, in order to pre-empt competitors and/or profit from a secondary market.

E. Trademark Issues

21. What trademark rights (e.g., registered trademarks, common
law trademarks, geographic indications, etc.), if any, should be
protected on the Internet vis-à-vis domain names?

25. A great deal of nonsense has been written about this issue. There is a pervasive fallacy that domain names are the same thing as brands or trademarks and that textual identity of a domain name and a trademark is equivalent to a violation of intellectual property. The issues surrounding trademark rights will never be resolved justly until these fallacies are disposed of.

26. The "trademark-like" status of second-level domain names has been greatly exaggerated by the artificial restriction on the supply of gTLDs devoted to business. As long as ".com" was the only game in town, naive Internet users could assume that typing in "www.<companyname>.com" was a reasonable way to find the web site of a particular company. Browser software reinforced this assumption by automatically filling in ".com" when users typed in an unadorned company name. In this environment, it was rational (if not ethical) for name speculators to take advantage of the huge gap between the low cost of registrations and the high potential economic value of famous company name registrations under ".com". Given the monopolistic status of ".com" it was also rational (if not legally correct) for the affected companies to see such speculative registrations of their name by third parties as a dilution of their brand identity or trademark.

27. Expansion of the TLD space is the only permanent solution to this problem. As alternatives to ".com" proliferate, the putative equation of domain names, brand names, and trademarks is progressively weakened. As TLD space expands, it becomes increasingly unlikely that the mere presence of a "famous name" in the second or third level of a domain name will attract attention or dilute the value of a brand.

28. The domain name/trademark debate seems to have lost sight of some fundamental facts about the Internet. There are millions of web sites out there. The number is doubling every six months. Users do not flock to a particular web site merely because of the character string in a domain name. Site content must be promoted and updated, and the site address advertised, cross-linked and bookmarked to attract significant, recurring attention. Owners of internationally famous names and brands have the resources to promote their own Internet sites and to forge a strong link between their Internet domains and their own unique brands and trademarks. Similarity of domain names per se does not constitute dilution or passing off unless the offending domain name holder also engages in systematic efforts to exploit the famous name and confuse users.

29. The only legitimate link between trademark/IPR protection and Internet domain names and sites occurs when domain names contribute to the defrauding of customers or users. That is, if a company other than Microsoft acquires a domain name with "Microsoft" in it and organizes its information, products or services in ways that deceive users into believing that they are interacting with the "real" Microsoft, then and only then does a legally actionable trademark problem exist.

30. Trademark protection must be balanced with the principle (proposed above in paragraph 9) that domain names are a form of expression. It is legitimate for companies, organizations, and individuals to use domain names to refer to other companies, organizations, events, or individuals, as long as no attempt at deception or "passing off" is involved. For example, a group of disgruntled Microsoft customers has a perfectly legitimate claim to register the domain "microsoft.org" and set up a web site at "wehate.microsoft.org." In this case the domain name can be construed as a reference to the Microsoft Corporation, in the same way that one would use the term "Microsoft" in writing or talking about that company. Just as Microsoft's ownership of its trademark does not give it a right to prevent people from using its name in all documents or speech, so domain names per se must not be equated with brands or trademarks.

22. Should some process of preliminary review of an application
for registration of a domain name be required, before allocation,
to determine if it conflicts with a trademark, a trade name, a
geographic indication, etc.?

31. No. This question assumes that the mere textual identity between a domain name and a trade name creates a legal or economic conflict. That assumption is totally invalid for the reasons explained in paragraphs 28-32 above. More generally, re-organizing the whole world's domain name registration system in order to give major multinational trademark holders veto power over all name allocations represents an unwarranted expansion of the power of trademark and a grotesquely disproportionate response to a fairly minor problem. Furthermore, such an approach would exacerbate rather than resolve trademark conflicts. Current domain name categories bear no relationship to the jurisdictional, industrial, and geographic boundaries of trademark protection. Those who conduct such a preliminary review thus have no solid legal basis for resolving conflicting claims.

23. Aside from a preliminary review process, how should trademark
rights be protected on the Internet vis-à-vis domain names? What
entity(ies), if any, should resolve disputes? Are national courts
the only appropriate forum for such disputes? Specifically, is there a role
for national/international governmental/nongovernmental organizations?

32. When real trademark violations occur on and through the Internet, they can be handled in the same way as international intellectual property violations are handled now. There is nothing unique about Internet domain names in this regard. There is simply no evidence for the presumption that mere textual identity or similarity between a domain name and a brand name somehow gives intellectual property violators sweeping powers to reap illicit gains at the expense of IPR holders. Real trademark violations involve sustained sequences of actions designed to pass off or defraud. The adoption of a domain name, by itself, cannot accomplish this.

25. Should domain name applicants be required to demonstrate that

they have a basis for requesting a particular domain name? If so,

what information should be supplied? Who should evaluate the

information? On the basis of what criteria?

33. This is a helpful question, but needs to be reframed. The answers to these questions can only come from the policies name registries adopt to prevent name speculation and to control the secondary market for names. Name speculation is a form of arbitrage. The speculators attempt to exploit the gap between the price of registering a name and the higher value of that name to some other potential user. Name speculation thus provides a clear signal that the primary distributor of name registrations is not exploiting the full economic value of its name resources.

34. The best long-term solution to this problem is privatization of name registration and expansion of TLD space. It is in the rational self-interest of commercial registries to manage name resources actively rather than passively. Just as airlines or movie theater owners do not allow aggregators and wholesalers to buy up all available seats and resell them to end users, so it seems unlikely that private, profit-motivated name registries would allow speculators, rather than themselves, to exploit the full economic value of their namespaces. As the namespace becomes privatized and commercialized, it seems likely that more active monitoring of who is applying for names and why would take place. Administrative policies such as this are much preferable to intellectual property law as a solution to problems of name speculation.

26. How would the number of different gTLDs and the number of
registrars affect the number and cost of resolving trademark
disputes?

35. As noted above, additional TLDs reduce legitimate conflicts over name allocations. If there are fifty additional generic TLDs devoted to businesses, then United Airlines, United Van Lines, and the United Hardware Store of Wahoo, Nebraska can all find unique, second-level domain names based on the string "united". What additional TLDs do not do is make it possible for one of those three companies to stake a global claim to all possible uses of the string "united" in the second level of the hierarchy. In fact, no one should be able to do that--unless, of course, they are willing to pay the full market price for the name resources they exclude others from using.

36. Apologists for multinational trademark holders have attempted to argue that additional TLDs "worsen" the "trademark problem" by making it more difficult for them to reserve or register a famous name in all possible TLDs. This argument is fallacious. There are about 250 TLDs in the world now. In response to the demand for name protection, intermediary companies such as NetNames have already established "international Internet name registry" services that offer multinational firms registrations of their desired names in the world's top commercial domains. In other words, global name protection is readily available for companies that are willing to pay for it. When these companies lobby for elaborate bureaucratic mechanisms to vet domain names, and/or for artificial restrictions on the supply of TLD namespace, they are simply asking the world's governments and Internet users to subsidize their own private commercial objectives. This is unfair and unnecessary.

37. Creating additional TLDs will probably make global name reservation/protection services more expensive (although competition and improving market organization may have countervailing effects). But for well-intentioned companies, it should also reveal the futility and irrationality of the notion that they need to control all possible uses of particular character strings in all domains.

27. Where there are valid, but conflicting trademark rights for a
single domain name, are there any technological solutions?

38. Again, the assumption that mere textual identity between a domain name and a trade name creates a legal or economic "conflict" must be rejected. Valid, conflicting claims for the same second-level domain name will undoubtedly arise. This problem must not be confused with a conflict over "trademark rights." United Airlines, United Van Lines and possibly hundreds of other companies have a perfectly legitimate claim to "united.com." When such conflicts arise, the solutions are semantic and economic. For example:

a) The loser can choose an alternative formulation of its name. (e.g., united-van.com; united-vanlines.com; move-united.com)

b) The person who wants "united.com" the most can bid a higher price for it.

c) The excluded party can move to an alternative TLD (e.g., united.firm, united.biz)


###
Number: 217
From:     "bluefin@thing.net" <Hatsumi.Asaka@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 12:53am
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 Hatsumi Asaka 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.

-------------------------------
Saturday, August 9, 1997 00:51:37 EDT
Hatsumi Asaka



###
Number: 218
From:     "jagware@ibm.net" <Joe.Givens@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 1:20am
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 Joe Givens 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.

-------------------------------
Saturday, August 9, 1997 01:18:49 EDT
Joe Givens

Since this country was founded on competition, why should we be subjected
to the monoploy of the internic??  Name.space fosters competition in this
burgeoning industry, IMHO




###
Number: 219
From:      "MTM@aon.at" <ads.GmbH.-.Peter.Kuhlang@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/9/97 1:57am
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 ads GmbH - Peter Kuhlang 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.

-------------------------------
Saturday, August 9, 1997 01:55:36 EDT
ads GmbH - Peter Kuhlang

MTM@mycity.at
we hace registrated:
MTM.firm
ESC.firm


###
Number: 220
From:     "adler@sachsen.de" <Mathias.Adler@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 3:53am
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 Mathias Adler 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.

-------------------------------
Saturday, August 9, 1997 03:51:54 EDT
Mathias Adler

01157 Dresden
Meissner Landstrasse 127

###
Number: 221
From:     "scharn@il.us.swissbank.com" <N.Scharnagl@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 5:27am
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 N.Scharnagl 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.

-------------------------------
Saturday, August 9, 1997 05:25:49 EDT
N.Scharnagl


###
Number: 222
From:     "mspiteri@maltanet.net" <Marcel.Spiteri@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 8:23am
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 Marcel Spiteri 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.

-------------------------------
Saturday, August 9, 1997 08:22:02 EDT
Marcel Spiteri

"Valley View" flat,
Valley Str.,
Mellieha SPB14,
MALTA.


Free the net!!!


###
Number: 223
From:     "fk@bln.de" <Frank.Kunkel@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 8:30am
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 Frank Kunkel 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.

-------------------------------
Saturday, August 9, 1997 08:29:00 EDT
Frank Kunkel


###
Number: 224
From:     "bonita@4dcomm.com" <Bonita.Walker@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 11:51am
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 Bonita Walker 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.

-------------------------------
Saturday, August 9, 1997 11:50:20 EDT
Bonita Walker


###
Number: 225
From:     "churn88@aol.com" <Janie.Angus@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 4:12pm
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 Janie Angus 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.

-------------------------------
Saturday, August 9, 1997 16:11:15 EDT
Janie Angus


###
Number: 226
From:     "kjr@ap.net" <Kevin.Shepherd@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 7:20pm
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 Shepherd 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.

-------------------------------
Saturday, August 9, 1997 19:16:14 EDT
Kevin Shepherd





###
Number: 227
From:     "ahochber@iname.com" <Alex.M.Hochberger@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 9:34pm
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 Alex M. Hochberger 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.

-------------------------------
Saturday, August 9, 1997 21:33:01 EDT
Alex M. Hochberger

305 NW 111th Ave
Coral Springs, FL 33071


###
Number: 228
From:     "regwhit@yorku.ca" <Reg.Whitaker@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 11:08pm
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 Reg Whitaker 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.

-------------------------------
Saturday, August 9, 1997 23:06:26 EDT
Reg Whitaker

Department of Political Science
York University
Toronto Ont M3J 1P3
CANADA