08-16-97 Electronic Filings on Internet Domain Names

###
Number: 295
From:      David Diano <dave@diano.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 12:39am
Subject:   Comments:Trademark and TLD

To the weary people reading all of these suggestions:

 I believe that part of the Trademark issue can be handled by a Top
Level Domain dedicated to that purpose.
  I propose a  .TM  (or  .TMK ) top level domain. This domain would be
restricted to only those companies with registered trademarks. The
"first-use" rule would still apply to .com, but the new .TM would be
controlled by legal registration of trademarks. (At least it would be no
worst than the problems that already exist in trademark law.)

  In general, the top level domains should be broadened and should
reflect the current model used by the USENET newsgroups. The .COM name
is so overloaded that it no longer carries any useful information as a
category.
  I basically agree with the following recommended tld's:

   .web    for entities emphasizing activities related to the World Wide
Web
   .arts   for entities emphasizing cultural and entertainment
activities
           (although, should be .ART)
   .rec    for entities emphasizing recreation/entertainment activities
   .info   for entities providing information services

 I suggest adding the following:
   .law           for legal services
   .med           for medical (hospitals, doctors, drug companies, etc)
   .mag           for current print magazines
   .xxx or .sex   for sexually oriented material
   .kid or .k12   for child oriented material
   .per           for personal domains
   .cty           for local City governments
   .env           for environmental and conservational efforts (a global
problem)
   .tm  or .tmk   for registered trademarks   

  I hope my comments have been helpful and will contribute to a general
consensus.

  Sincerely,
  David Diano

###
Number: 296
From:      "Dan S. Tong" <drdancm@concentric.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 2:01am
Subject:   Comments

It's quite clear to me, but apparently not clear to some of the authors
of the publicly listed comments, that the domain naming/administration
task is very complicated and requires a lot of background knowledge.

Since I am by no means even adequately knowledgable on this subject I
will confine my comments to general suggestions.


1. Whatever solutions are proposed and seriously considered they must
allow for the nearly unlimited expansion of domain names (3-5x the
population of our planet projected for the next 50-100 years, may be
adequate).

2. It would also be extremely useful at the same time to create a
universal unique ID/E-MAIL address system so that mailing addresses
would become portable for life and not be hostage to one's current ISP.


3. Domain names should be affordable (less costly than they are now)
and  should be inexpensive to maintain (a small fraction of the initial
registration fee).

4. The administration should be efficient and cost effective-either
private (non-profit) or government run -but TOTALLY APOLITICAL. I am not
sure which would work best. I think the current administration has
worked reasonably well (except for recent big errors) and the overly
hight cost of registration and maintenance.

Sincerely,

Dan S. Tong, Ph.D.
Computer Consultant

###
Number: 297
From:      "Thomas Thompson" <tomrt@muscanet.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 10:47am
Subject:   Domains

 Dear Sirs,

I believe that no private company should control the distribution of
domains.  If the internet is going to be a true information media, no
private interprise should control the distribution.  Right now the price
to obtain a domain is price inhibiting to some individuals.

Thomas Thompson

tomrt@mucscanet.com


###
Number: 298
From:      "rev@starnetinc.com" <Ron.Vikara@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/11/97 8:31pm
Subject:   Comments on Domain Names

My idea is to give all adult sites a .xxx so all filters

will work right. I think this must be the only way we the

people can let our kids and teens use the web.

A law should be writen to enforce it so no links can be

to any adult site that is not one itself. A good ext. can

be .ADT or .21 or some form. We can't stop the sex but we

can keep it hidden away. No jail time but to be kicked off

the net is a good way. and to setup a page to report crime

on the net. It a new world and the goverment has got to do

its part in it. Already child porn and drugs are being sold

over the net, whats next?

I have lots of ideas and I wish I had some say in what

would be the new police dept. (World-U.S. Net Police)

I would police the net.

Thanks for reading,

    Ron Vikara

-------------------------------
Monday, August 11, 1997 20:29:51 EDT
Ron Vikara

Lets just say:

DuPage Co.

Illinois.



###
Number: 299
From:      "J Johnson" <jjohnson@inneroffice.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 8:32am
Subject:   domain names

After spending the better part of a month trying to come up with a new name
for my web site design business, only to find, each time, that the desired
domain name was already taken, it becomes obvious to me that assigning
addresses in the customary fashion simply won't work.  I think that
addresses in the cyberworld should be handled the same way they are in the
tactile world - alpha-numeric designations given out systematically. 
Search engines and "yellow pages" would then assist the traveler in
reaching their designation.  We don't need any more reasons to feed
lawyers.  This should not be an issue left to litigation.  

The concepts of trademark infringement and plagiarism need to be examined
more closely.  As the population of the world increases, ideas, especially
original ones, become harder and harder to generate.  We still have only 26
letters in our alphabet.  The combination makes a finite number of
acceptable words.  As populations soar every one of those words gets used
more and more often.  The only real hope for originality is to make up new
words that then become indicative of a product or service.  Kleenex is the
best example I can think of - and that, boys and girls, ain't easy.  Our
standards of originality must go up and we must begin to rely on the old
adage, "it's not what you have but how you use it" that becomes the
deciding factor.  I occasionally supply answers for an advice column in
this area's primary newspaper.  My answers are carefully researched and
even more carefully worded.  On more than one occasion, I've later found
that entire phrases match, almost word for word, comments made on the topic
by others.  This was not plagiarism on either my part or theirs.  It simply
demonstrates that there are a finite number of combinations of words to
describe a particular idea.  If many people describe the same concept
changes are very good that the answers will be similar.  People don't read
anyway - "gotta have pictures" - and they are a whole lot easier to
regulate since Mr. Kodak has provided us with an endless supply.

Joy M. Johnson
jjohnson@inneroffice.com
jjohnosn@gamma4.com


###
Number: 300
From:      "Henry Teutsch" <hbteutsch@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 11:52pm
Subject:   Proposed Domain Names

Hello I would like to add my comments to the public record regarding the 
proposed domain names. 

First I feel that these other organizations, other than the one which is 
currently in charge of registering domain names, are criticizing the current 
system because they are locked out of any profit involved with controlling and 
registering domains. Also I believe these seven new domain names are an 
attempt to by pass the current parties involved who seemingly have control 
over domains and there registration. There would almost certainly be an 
attempt to reregister such high profile names of the most popular name brands 
by parties hoping to draw attention to their site or sell these names to the 
perspective companies or it would force some companies to register there 
current domains seven times over incurring seven times the current cost. This 
could make a nominal fee available only to those with deeper pockets. If there 
is any regulation where current domains such as coke or Pepsi could not be 
registered by other parties under the proposed domain system then there is no 
point in adding more domain name suffixes. If I own a domain under .com, that 
may or may not be trademarked, could someone else register it under .web? If 
not then the new proposal would not free up names like the backers claim just 
add to the confusion. Domain names should be similar to a broadcast license. 
Once used its unavailable to anyone else. There are millions of names still 
available. The proposal is designed to make other people and companies money 
and to give them part control over a system which is now generally free of 
restraints and not controlled by any company. If the registration process were 
run by American Online, Microsoft, or IBM it would be extremely difficult for 
small companies to acquire names or buy into the Internet for commerce. While 
these companies to my knowledge have been quite concerning these issues. The 
smaller groups and organizations pushing these changes are hoping that they 
will be catapulted into the realms of these big three corporations.
Finally the registration process in my opinion is not flawed. The nominal fee 
is easily justified. But if critics prevail why not let the FCC register names 
or create a semi-private company similar to the US postoffice which just 
registers names and manages the main DNS database. I think there is 
approximately 2 million domains registered. At $100 dollars per year per 
domain name it is clear why people wish to add more possible names. The 
registration business could be a billion dollar industry where it shouldn't 
cost more than a postage stamp.

###
Number: 301
From:      Daniel Dawes <ddawes@gj.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 8:20pm
Subject:   Comments on Domain Name Registration-OCMUG

Attached are the responses of the Orange County Multimedia
Users Group, a group of 3000 multimedia professionals in
Orange County, So.Calif.


OCMUG Response to Domain Name Questions

Comments of Orange County Multimedia Users Group
August 12, 1997

A.  Appropriate Principles

Responses to Questions a-f

a.         appropriate - yes
           complete - no.  This principle provides no guidance to
conflict resolution or avoidance.  Conflicts over domain
names should be removed from the system and placed into
mandatory alternative dispute resolution (ADR) by statute.
 De novo trial in a court of competent jurisdiction may be
made available after ADR or preferably an opposition
procedure similar to that used before the Trademark Trial
and Appeals Board, TTAB, but using private judges instead.
 During resolution both parties should operate under
appropriate suspense names.  For example, if there were a
conflict on the name ibm.com, the two contending parties
during pendency of ADR would be assigned temp1ibm.com to
the senior party and the temp2ibm.com for the junior
party.
           
b.         appropriate - yes
           complete - no.  While the private sector is more
likely to more efficiently administer name registration,
responsibility and accountability of registrants can only
be guided by statute and private agency regulation
empowered by law.  Only the force of law has the power to
regulate name usage between registrant users of names on
the internet and nonregistrant users of names.

c.         appropriate - yes
           complete - no.  The principle provides for no
direction for global evolution over time.  National
organizations should join in an international congress to
deal with world level issues only, leaving national issues
to the national organization and providing for
proportional representation based on a periodic census of
the number of domain registrants.

d.         appropriate - yes
           complete - no.  The principle provides for no clue to
what would be *fair* or how fairness can be determined in
any given instance.

e.         appropriate - yes
           complete - no.  The principle provides for no clue to
what would be *fair* or how fairness can be determined in
any given instance.

f.         appropriate - yes
           complete - yes.


B. General/Organizational Framework Issues

Questions 1 - 4 and 6 - 8 are answered.

1.         advantages: low price, quickness, public searchability
           disadvantages: inability to meaningfully deal with
name conflicts or to provide a name structure where name
conflicts can be avoided.

2.         The current domain name system can be improved by: 
a.  Removing name conflict from the net when it occurs by
issuing temporary suspense names and putting the disputing
parties into mandatory alternative dispute resolution.
b.  The name structure can be improved by providing hidden
levels in the secondary name rather than splintering
primary domain names.  For example, an address
columbia.com would return to the browser a selection tree
of Columbia(broadcasting).com; columbia(river
rafting).com; columbia(records).com; columbia(coffee).com;
etc.  This would allow the many legitimate columbias which
operate without conflict in the market, but which come
into conflict on the net to distinguish themselves on the
net by the same means that they use in the market and
still all be accessible as columbia.com.  Conflicts in
hidden names, presented only in a selection tree on
addressing, could be arbitrated in a written arbitration
similar to written trademark prosecution in the Trademark
Office, but before the registering body or ADR authority.

3.         Private corporations operating under renewable
government contract works very well.

4.         Domain name registration could follow the model of
film/television title registration as administered by the
Motion Picture Association of America for net registrants
having no prior commercial use of the name.  This
contemplates reserve positions and use obligations.  As to
name conflict resolution between registrants basing a
claim on prior use, the procedures of the Trademark Trial
and Appeals Board, U.S. Trademark Office, in opposition
proceedings offer an attractive alternative to court
litigation.

5.         Top level generic domain names have no particular
utility unless part of the internationally agreed natural
language scaleable naming system.

6.         No comment

7.         Natural language hierarchy systems should be used
which are proven as inherently scaleable naming systems. 
For example, when a new company incorporates it can be
found by conventional addressed mail using its company
name, at a street, city, country location.  A simple four
level tree structure can quickly lead to an addressed
location e.g. United States, to Washington DC, to 14th and
Constitution, to NTIA.  Entry at any level of the tree
known to the user can display the next level down or up to
allow user selection based on other known or guessed level
names.  

8.         Transitions should occur in the same manner as
transitions in area telephone codes are handled.

9.         No comment.
C. Creation of New gTLDs

Questions 10 - 13 are answered.

10.        No.

11.        Yes, if part of a natural language scaleable naming
system.

12.        No.

13.        Yes, depending on the natural language scaleable
naming system employed.

14.        No comment.
D. Policies for Registries

Questions 15 - 19 are answered.

15.        These issues are irrelevant in a natural language
scaleable naming system.  No one level of the name has any
unique role in the scaleable naming system as compared to
other levels.

16.        Registrars should have the same requirements as postal
address naming authorities.

17.        Not necessarily as long as there is adherence to a
single natural language scaleable naming system.

18.        Not necessarily as long as there is adherence to a
single natural language scaleable naming system.

19.        These issues are irrelevant in a natural language
scaleable naming system.

20.        No comment.

E.  Trademark Issues

Questions 21 - 27 are answered.

21.        Domain names can function as service marks, trade
names and trademarks as well as simply a domain name
without other commercial significance.  The manner and
what it is used for on the net determines this function. 
Customers ask for services, products and companies by
name, whether on a label or in a domain address.  When
used as a protectable mark, then the rights of the mark as
provided by law must be enforceable.

22.        Screening of domain names by an authority will
unacceptably slow the process and create unnecessary
beaurocracy and costs similar to current trademark
registration, where costs are several hundreds of dollars
and delays of 12 months typical.  Free registration of
nonidentical names with quick and low cost opposition
resolution in cases of conflict is preferred as a
self-screening system.

23.        Internet trademark conflicts should be submitted to
mandatory mediation or arbitration with recourse to an
trademark opposition style trial on written records before
private judges, whose judgments are entered as judgments
of courts of competent jurisdiction over the parties as
determined by current federal practice (Title 28).

24.        Domain name and trademark databases currently exist,
are affordable, are easily accessed and are available to
those who seek to avoid conflict.  Trademark attorneys
capable of assisting users in making private judgments of
availability are available everywhere.

25.        No.  The registrar should not be burdened or tasked
with making entitlement judgments of any kind.

26.        No effect as long as a single natural language
scaleable naming system is used.  Trademarks, service
marks, and trade names can be used as the lowest level of
the scaleable naming system.  Higher level names can
distinguish similar lowest level names on the internet in
the same way that other market factors currently
distinguish the lowest level names in the market.  For
example, the likelihood of confusion between tradenames,
trademarks and service marks are currently adjudicated
based on the standard of the law as set forth in In re E.
I. DU PONT DE NEMOURS & CO., 177 USPQ 563 (CCPA 1973)
where the factors are listed as:(1) The similarity or
dissimilarity of the marks in their entireties as to
appearance, sound, connotation and commercial impression.
(2) The similarity or dissimilarity and nature of the
goods or services as described in an application or
registration or in connection with which a prior mark is
in use. (3) The similarity or dissimilarity of
established, likely-to-continue trade channels. (4) The
conditions under which and buyers to whom sales are made,
i.e. "impulse" vs. careful, sophisticated purchasing. (5)
The fame of the prior mark (sales, advertising, length of
use). (6) The number and nature of similar marks in use on
similar goods. (7) The nature and extent of any actual
confusion. (8) The length of time during and conditions
under which there has been concurrent use without evidence
of actual confusion. (9) The variety of goods on which a
mark is or is not used (house mark, "family" mark, product
mark). (10) The market interface between applicant and the
owner of a prior mark: (a) a mere "consent" to register or
use. (b) agreement provisions designed to preclude
confusion, i.e. limitations on continued use of the marks
by each party. (c) assignment of mark, application,
registration and good will of the related business. (d)
laches and estoppel attributable to owner of prior mark
and indicative of lack of confusion. (11) The extent to
which applicant has a right to exclude others from use of
its mark on its goods. (12) The extent of potential
confusion, i.e., whether de minimis or substantial. (13)
Any other established fact probative of the effect of use.


Therefore, a natural language scaleable naming system
would have level names such as (1) The name which gives
the commercial impression, i.e.  Cola;(2) The nature of
the business, goods or services associated with the name,
i.e. manufacture and distribution of beverages; (3) The
established, likely-to-continue trade channels, i.e.
wholesale and retail consumer trade; (4) The variety of
goods on which a mark is or is not used (house mark,
"family" mark, product mark), i.e. a listing of Cola
branded products and services.  The browser would simply
ask for *Cola* (dot nothing).  The browser would get back
a listing of all names including *Cola* at level 1 and a
tree or table showing levels 2 - 4.  Existing search
engines such as used by Thomson & Thomson and others can
make immediate spelling and natural form variations from
the root search word.  
The correct Cola would be the one that met the correct
criteria.  Other Colas would be distinguished by the
relevant market factors as they are in the market place. 
Yahoo currently returns 243 sites for *cola* with much
less specificity.  The current domain naming structure
does not provide an unique dictionary selection according
to meaning, but promotes a nonunique random word
association.  Those desiring to directly address a site
could simply use the address, Coca
cola.beverage.consumer.house mark, or King
Cola.beverage.consumer.trademark.  If there were only one
Coca Cola site, then only the unique portion of the name
would be needed in the address.  (Yahoo returns 86 sites
for Coca Cola).  The specific names used would be chosen
by the domain owners and only compared by the registrars
to a single database for identical conflict at all levels.
 Domain owners wishing to be found will chose optimal
names for themselves.  The computer works equally as well
with fixed ISO standards as with user selected codes.  If
desired two or more levels for geographic location could
be added, e.g. Coca cola.beverage.consumer.house mark.
AltlantaGeorgia.U.S.  
Coca Cola could establish a level 1 monopoly for *Coca
Cola* if it could establish its fame regardless of: (1)
the nature of the business, goods or services associated
with the name; (2) the established, likely-to-continue
trade channels; and (3) the variety of goods on which the
name is or is not used.  This is more than famous mark
owners can now achieve with the present naming structure,
since many others return a hit on *Coca Cola* than the
Real Thing, Coke.  Browsers thus could search on domain
name only using the natural language naming system and/or
search headers for subject relation as they presently do. 

There is currently no usable domain name directory or
dictionary.  Anyone can list themselves under any name
regardless of any unique identity, whether it be fictional
or actual.  This would not be a tolerable practice in a
telephone directory (everyone lists themselves as
BillClinton1.com through BillClinton250,000,000.com as
opposed to BillClinton.president.UScitizen.human) and it
is not a tolerable practice in domain name listings.


27.        Yes.  The same or similar trademarks may not create a
likelihood of confusion and hence an infringement based on
other commercial factors as provided by law.  The same
factors can be used to establish a single natural language
scaleable naming system, which realistically reflects how
consumers distinguish the marks in the market.

28.        No comment.


###
Number: 302
From:      "mikel@codamc.com" <Mike.Lile@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 1:30am
Subject:   Comments on Domain Names

In addition to my comment made through the pgMedia site, I would add

the following:



As an Internet Administrator for the last two years, I have

always been skeptical of the centralized, government controlled

nature of DNS on the Internet.  I would very much like to see

this system moved in to the private sector (perhaps with

minimal subsidies) and decentralized.



Thank you for your time and attention.

-------------------------------
Saturday, August 16, 1997 01:29:18 EDT
Mike Lile

4956 Gem Dr

High Ridge, MO  63049



###
Number: 303
From:      Roger Jones <activeink@home.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 3:41am
Subject:   junk email

Sirs:
There is little problem with socalled junk email or spam, since I can
delete it at a stroke.

What you ought to stop is sending of junk mail to US residents' physical
mail boxes by the US postal system. It has more than once caused me to
lose important mail amongst pages of useless offensive advertisements,
it destroys trees, and it annoys the heck out of me.

If you allow the US government connive in filling people's mailboxes
with this offensive junk 6 days a week you must by the same token allow
sending of unsolicited email.

Personally, I block, with ease, all unsolicted email except maybe once
or two every two weeks, when I allow myself receive a few merely to
learn what's new and hot and what's not.

Anyone who complains about receiving junk mail is an idiot. It isn't
difficult to prevent receipt. The fact is that many people are putting
enormous misdirected energy into attacking this perfectly normal
American business practice. The anti-brigade display unhealthy
fanaticism. Not to mention ignorance and lack of logic.

Yours truly

Roger Jones
author

###
Number: 304
From:      NatCom <natcom@dnet.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 8:56pm
Subject:   US Dept. of Commerce: Domain Names

Dear Sirs/Madams:

     There is no need to add additonal Domain Names to the internet. This will
just add to the confusion and make things even harder to find.

     What is being overlooked is the already available use of the "." (the
DOT). By using dots (.s), you can have a number of DNs just as it is now
set up. For example, if I wanted a DN that somehow reflected Western North
Carolina, most names with WNC,westernnorthcarolina, etc are taken!  BUT-
when you start using dots (.s), this is a different story. You can now have
www.homes.wnc.com or www.realestate.wnc.net etc. An almost unlimited number
of DNs can be created using this system.

     This eliminates the need for all the other ludicrus DN extensions that add
to the problem, rather than make it better.

     Also, there should not be a single entity that gives out DNs for profit.
If there is, is should be an agency of the US Federal Government, and any
excess monies should be use for the NSF.

     The current fees are excessive, in my opinion. $100 up front is high.
Also, all the large corporations that obtained DNs for FREE, should have to
pay the $50 yearly renewal fee, just as I do for my six DNs- and I have a
very small company, which may never actually make a profit after expenses.

     I hope this input will be considered.

Respectfully,

Merlin Gagle
Gagle Communications

Gagle Communications
"Let us be your billboard on the Information Superhighway"
The All Cities Network: http://www.allcities.net
The US Cities Network:  http://uscities.net  http://www.uscities.com
Azine For WebNovices: http://www.webnovice.com  http://webnovice.net


CC:        NTIADC40.SMTP40("Paul.Chavez@MSNBC.COM")

###
Number: 305
From:      Lloyd Manley <defaultuser@domain.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 8:19pm
Subject:   comments on dns

Dear sir/mam,
I am furious about what I am reading in the popular press about the
designs being placed on the dns situation by corporate interests and
copyright fanatics. First of all, IT IS NOT the governments place, or
any other bodies place, to interfere with the development of new
technologies to protect some special interest such as the copyright
supporters and others who have a lot to profit from the internet.

If the internet spells the end of copyright as we know it (which I
believe it will, no matter what anyone does), then it is the
responsibility and headache of those who would profit from copyrights to
find another means by which to generate profit. If this, AT SOME FUTURE
TIME, results in an objectively measurable inhibition of those producing
quality, academic or artistic material for public consumption, THEN, and
only then, should minimal interventions be considered.

With that in mind, I believe that all matters regarding domain
registration and the handling thereof should be mediated by parties who
have NO INTEREST in copyright concerns.

Though you may find this to sound somewhat revolutionary in tone, I
write it because I want to convey what is at stake here if we don't stop
copyright fanaticism. The very power of the internet, the very things we
appreciate about this medium, will be entirely lost if we give in to
copyright concerns and we will be thrown back to '50's in terms of
communications technologies. The possible benefits of the internet are
so enormous (especially to the average and poor individuals that make up
the 'masses' of our societies-the power of information will truly
liberate them) that it would literally be a crime against humanity for
anyone to stand in support of copyright demands.

The honor of a reply would be greatly appreciated.
Sincerely,
Lloyd Manley, dept. of physics and astronomy, University of Georgia



###
Number: 306
From:      "mikel@codamc.com" <Mike.Lile@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 1:25am
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 Mike Lile 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 16, 1997 01:23:42 EDT
Mike Lile

4956 Gem Dr
High Ridge, MO  63049



###
Number: 307
From:      "marxx@ljudmila.org" <Marko.Peljhan@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 3:48am
Subject:   Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Marko Peljhan 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 16, 1997 03:46:45 EDT
Marko Peljhan

Ane Ziherlove 2
1000 LJUBLJANA
SLOVENIA



###
Number: 308
From:      "106401.1503@compuserve.com" <Schels,Michael@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 6:16am
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 Schels, Michael 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 16, 1997 06:15:07 EDT
Schels, Michael

Dr.-Carlo-Schmid-Str. 48
90491 N rnberg
Germany




###
Number: 309
From:      "tristan@www.victor.com.au" <Tristan.Gulyas@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 6:21am
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 Tristan Gulyas 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 16, 1997 06:20:24 EDT
Tristan Gulyas




###
Number: 310
From:      "henkka@l16.fi" <Henrik.Huhtinen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 1:25pm
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 Henrik Huhtinen 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 16, 1997 13:24:09 EDT
Henrik Huhtinen




###
Number: 311
From:      "vgranger@imaginet.fr" <valery.grancher@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 3:41pm
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 valery grancher 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 16, 1997 15:39:31 EDT
valery grancher


53 rue de seine 75006 paris
france



###
Number: 312
From:      "hartnett@btigadoon.com" <Daniel.Hartnett@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 4:33pm
Subject:   Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Daniel Hartnett 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 16, 1997 16:31:52 EDT
Daniel Hartnett

D.E. 303 East 8th Street
NYC, NY 10009




###
Number: 313
From:      "sakurako@sprynet.com" <Noriko.Fukuyama@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/16/97 7:46pm
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 Noriko Fukuyama 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 16, 1997 19:44:33 EDT
Noriko Fukuyama