08-11-97 Electronic Filings on Internet Domain Names

###
Number: 232
From:      <southbrook-lan@voyager.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/11/97 9:48pm
Subject:   COMMENT ON INTERNET DOMAIN NAMES

First, minimize government mucking about - that which they do best, 
mucking up the works, that is.

Second, minimize the cacademics' participation - this matter is not
one well suited to ivory tower hypotheses.  We will be living with
the consequences for some time to come.

Third, make them manifestly meaningful, i.e., banking industry=bnk,
publishing of all natures=pub, smut=xxx, etc., with particular 
consideration for transparent clarity English as well as as many
other languages as possible - with an 
eye to (a) same or similar meaning, and (b) avoidance of contradictory
interpretation.  (Remember the Chevy Nova that did not sell well in 
Latin America because Nova comes across as "no go?"

Fourth, deeply involve those (techies and management) that will have 
to explain the system as good and reasonable, and who will have to 
make it work on a daily basis.

James B. Graves
Forbes Computer Co.
Post Office Box 427
Holt, Michigan  48842-0427

###


Number: 233
From:     <FinanciaCo@aol.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/11/97 6:25pm
Subject:  Domain names

A spectre is haunting America! The spectre of Internet Solutions, Inc.
Compounding the reckless registration policies of this outfit, unsupervised
by NSF, and abetted by ISPs that have capitalized on the mutual greed, a
govenment dictated solution to the chaos is needed.

The "first come - first served" exculpatory excuse by Internet Solutions does
not square with the real world of trademark and intellectual property laws
and customs. Do not believe any of Internet Solutions, Inc. policy on dispute
resolutions. It is a smokescreen that rivals Hitler's Goebles.

I am the victim of a thief registering my fanciful, distinctive, unique, and
now famous trademark that has been used in commerce since 1983. They now
mistakenly believe that they have property rights to my trademark by virtual
of their .com system. I have furnished sufficient proof of ownership
including the PTO sending a direct fax copy to their outside counsel. I have
refused sending the original PTO binding and and am perplexed at their latest
demand for a certified copy that is merely the same thing with a ribbon
affixed. 

Their contributory infringement prohibits me from using the intuitive address
for FINANCIA that has worked well on AOL's members page but caused me to have
to use FinanciaCo on the www domain. Later when financia is available I will
have to give them another $100. and perhaps even another $100 to register
Financiainc. Is not this game in need of redress?

Sincerely,
Darrell J. Bird - Financia@aol.com
 

###
Number: 234
From:      Louis Epstein <le@main.put.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/11/97 1:10pm
Subject:   Domain Names...Too Easy to Get!

I note that you are accepting comments on the future administration
of domain name registration on the Internet.

In a nutshell,it is FAR too easy to get a domain name for insufficient
reason.For users to get their own domain names is the Net equivalent of
incorporating cities in their back yards.You do not need and should not
want a domain name unless you are going to support a large number of
users over an exclusive fixed internet link.The proliferation of
www.lookeelookeemamaIgotmyveryowndomain.com sites is bad namespace
usage and harms network performance.

Now there is pressure for more gTLDs,to further aid the unwarranted
prioliferation,which is of course promoted by those standing to make
money in the process.I say no...there should be no gTLDs not with
clear differentiation from all others in their function.

Obviously,administration has to be done in such a way as to prevent
duplication of names,or they become useless.The prevention of
price-gouging should be done by regulation,not by competition.

The registration of domain names may be a growth industry,
but unreasonable growth sprouts weeds and waste.Government
solutions should not be aimed at helping a feeding frenzy,
but at reining it in.

Louis Epstein
Putnam Internet Services


###
Number:   235 


August 15, 1997

Patrice Washington
Office of Public Affairs
National Telecommunications and
Information Administration
Room 4898
14th Street and Constitution Avenue, N.W.
Washington, D.C. 20230

Re: Request for Comments on the Registration
and Administration of Internet Domain Names

Dear Ms. Washington:

This letter is in response to the Department of Commerce's Request for Comments on the Registration and Administration of Internet Domain Names, which appeared in the July 2, 1997 edition of the Federal Register.

A. Appropriate Principles

The domain name registration system is not best left to the private sector. The assignment of a domain name carries no inherently valuable commercial content any more so than does the assignment of a telephone number, a post office box, or a postal address. Private sector competition in the domain name registration "business" would only serve to further confuse the already complicated domain name system. Administration of the domain name registration system by an international regulatory body would be more efficient, fairer and make more sense.

B. General/Organizational Framework Issues

1. The principle disadvantage of the current domain name registration system is that it, unlike the trademark registration system, does not permit two entities in non-competing businesses to use the same name, so long as there is no likelihood of confusion. Thus, for example, a company which legitimately uses the name "ABC" to sell furniture, could not register the domain name "ABC.com" if it had already been registered by ABC News.

3. Because of the international nature of the Internet, domain name registration systems should be administered by an international organization, in a manner similar to the operation of the ISO. The makeup of such an international entity should include representatives from both the public and private sectors in various countries in which the Internet is being used.

4. Currently, the disputes over domain names are caused by the fact that many Internet users expect to find a particular company's site simply by entering that company's name with the ".com" top level domain name extension. However, once an Internet site is known to a user, that user no longer has a need to remember the domain name, because the user can simply "bookmark" the site in his or her web browser. In addition, as the Internet comes into wider use, it will become increasingly difficult for companies to use domain names that are easily recognizable or memorable. Therefore, Internet search engines and indices will become more important and more prevalent in the way users of the Internet locate sites of interest. Therefore, I would suggest that a more sensible way of allocating domain names would be to entirely eliminate the domain name system, and replace it with the numerical system used for IP addresses. In fact, the current use of host domain names is simply a surrogate for the IP numbers, to which the domain names map. By using the essentially random IP numbers, instead of domain names, many of the disputes over domain name registrations would disappear. In this manner, domain names would be no more distinctive then telephone numbers.

8. The transition to the new "numbers only" system should be accomplished in a phased but rapid manner. The Internet is always fast-changing, and the change in the domain name system, though radical, would quickly be absorbed and adopted by users. Thus, the new "numbers only" system could probably be transitioned into use over a period of only a few months.

C. Creation of New gTLDs

11. New gTLDs should not be created. If new gTLDs are created (such as .inc, .ltd, .firm, .store, or any of the other suggested gTLDs), companies are likely to respond by simply registering the same second level domain name across several top level domain names (i.e., ABC.com, ABC,inc, ABC,firm, etc.) Thus, creation of gTLDs as alternatives to ".com" would only cause companies to register their company's name across several top level domain names.

E. Trademark Issues

24. Conflicts over trademarks in the domain name context can best be prevented by simply eliminating the source of the conflicts by using a "numbers only" domain name system.

Very truly yours,

David Leit

cc: Mike Heltzer
INTA Government Relations Program Coordinator
International Trademark Association
1133 Avenue of the Americas
New York, NY 10036-6710


###
Number: 236
From:     "antoine@eci.com" <Anthony.Tong@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/11/97 3:16pm
Subject:  Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Anthony Tong 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.

-------------------------------
Monday, August 11, 1997 15:05:25 EDT
Anthony Tong



###
Number: 237
From:     "rick@rickster.com" <Rick.Frankel@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/11/97 3:28pm
Subject:  Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Rick Frankel 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.

-------------------------------
Monday, August 11, 1997 15:26:41 EDT
Rick Frankel

###
Number: 238
From:     "zod@walrus.com" <Charles.Hope@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/11/97 6:59pm
Subject:  Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Charles Hope 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.

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Monday, August 11, 1997 18:57:59 EDT
Charles Hope


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