Electronic Filings on Internet Domain Names


###
Number: 1
From:      Brian Kitchen mr_b@cyberdude.com
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/1/97 1:06am
Subject:   internet domain registration

In my Humble opinion, we( internet users) as a group must somehow solve
this dilemma. I would like to see ALL x-rated stuff in it's own domain,
thank you very much. The internet does now and should reflect real
society. We know where the "red light districts" are and we can choose
to go or not. Thanks to the first amendment, we are free to speak our
minds. But lets do something about the domains and access. Would it not
seem easy to somehow classify areas without restricting free speech. As
the internet grows, more domains are needed so why not have .xxx ? There
has to be a way to control this. I don't mind xxx when I WANT xxx. I
really mind searching on hotbot for free and getting a xxx reference in
the 31st position. This is bullshit. Regulation of one sort is
inevitable. Let's hope for the sake of us all that for the first time in
history we the people...on a global scale...can regulate ourselves
without a governing body screwing it up. Some independent organization
should be set-up, voted on over the internet, (digital certificates)to
deal with domains and new domains. This will be a very powerful
organization and I.M.H.O. the best way to protect the public would be a
democratic body based on the American Bill of Rights, accountable to
internet users and the general public.
Thanks for the soapbox  Brian Kitchen a.k.a. mr_b@cyberdude
-- 
mr_b's CyberWorld
http://www.telusplanet.net/public/mr_b
http://www.adgrafix.com/info/bkitchen/
http://www.beevy.com/card_search/usa?89-1314

###
Number: 2
From:     christopher post cp15@cornell.edu
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 1:07am
Subject:  Internet Domains

Hi!,

I am resonding to the request for comment on the internet naming
debate.  I feel that the adhoc committee has done an excellent job of
designing a system to increase the number of top level domains
available.  Although the new naming system was not developed by a
government entity, it was developed with the future of the internet in
mind.

Sincerely,

Christopher Post
Graduate Student, Cornell Unversity, 503 Bradfield Hall, Ithaca NY 14853
cp15@cornell.edu

###
Number: 3
From:     Victor Gavin Victor.Gavin@unilever.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 8:12am
Subject:  My suggestions for resolving the DNS issues.

Hi.

Comment #1
-------------

I believe that there should be no special Top Level Domains (as there
are at the moment e.g. .com or .uk) handled by a special agency.

Instead, I suggest is that anybody should be able to register a Top
Level Domain and that the registration process should be handled
similarly to patents.

The registration would be handled by an international committee with
national sub-committes who would vet applications before authorising
their creation. There should be a legal obligation on registree's to
research ownership of a name before it can be used.

Once registered, the owner would/should not be held liable for trademark
infringements within the domain. What I mean by that is that sub-domains
should be able to incorporate trademarks (accidental or deliberately)
without fear of legal proceedings. The rationale behind this is that a
domain name is to all intents and purpose an address, and corporations
can't sue for damages just because their trademark is used in a street
address in another country - e.g. 128 McDonalds Drive, Kirkintillock,
Scotland.

            vic

###
Number:  4
From:     STriker RedWolf/Kelly Price kprice@physics.umd.edu>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:07am
Subject:  Input on new domain names

At this time, the use of domain names is proliferating wildly, becoming
a kaos into itself.  I propose the logical organization of those domain
names.

To illustrate my point, I will theoretically "create" a few names in
this mail alone:

strlabs.com  - a standard company
amazonpark.org - for Amazon International Park (saving the Amazon.  "We
     breath for the world")
amongus.com  - ISP
umd.edu      - yes, University of Maryland, College Park.

Now for the organization of .edu, .org, .com, .net, et al.

.edu will always be for educational associations.  (umd.edu stays)

.net will be reserved to, and should be exlusive for, ISPs.  No ISP
should have a .com unless it provides another function (strlabs.com
would still be stlabs.com, as it's a standard company, but amongus.com
would have to be named amongus.net)

.org will be for non-profit organizations.  amazonpark.org stays the
same.  Companies would be moved out.  In the event that this continues
to be "a mess," the below organization may be enacted (so amazonpark.org
would become amazon.park.org)

.com will be reorganized:

  News organizations would be moved from .com to .news.com.   Therefore,
  abcnews.com and msnbc.com would become abcnews.news.com (or maybe
  abc.news.com) while msnbc.com would be stuck with msnbc.news.com.  
  C|Net's news.com would have to be renamed cnet.news.com.

  Television stations, networks, and shows would be moved to .tv.com.
  Therefore, cbs.com and local wjz.com would be moved to cbs.tv.com and
  wjz.tv.com (or wjz.md.tv.com, since it is local).

  Movies should be moved to .movies.com in similar fashion. 
batman.com   would be batman.movies.com.

  Similar organizations can be made, like that of the popular web page
  index "Yahoo".

Therefore...

strlabs.com may become strlabs.sci.com, depending on it's goals.
amazonpark.org may stay the same or use amazon.park.org
amongus.com would be forced to become amongus.net
umd.edu will always be umd.edu

Hopefully, some logical, sensible reorganization of names would only be
required for to fix, or delay, this problem.

-- 
p   |\      _,,,---,,_      Kelly "STriker" Price -Spiritual Polymorph
u   /,`.-'`'    -.  ;-;;,_  http://www.furnation.com/striker
r  |,4-  ) )-,_..;\ (  `'-' Not offical word of AITS/UMCP.  Junk Mail
r '---''(_/--'  `-'\_)  fL  fined.  Never wake sleeping physics majors.

###
Number: 5
From:     Edwin Hayward info@igoldrush.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:08am
Subject:  Response to Request for Comments on new gTLDs

Sirs,

Please find attached my response to your RFC on the proposal to extend
the current gTLD administration system. The response is in Word 97
format.

Edwin Hayward

Response to Request for Comments on the
Registration and Administration of Internet Domain
Names

Basis for response: Owner and operator of Internet
Gold-Rush [www.igoldrush.com], the Internetfs #1
collection of domain name news and information.

Author: Edwin Hayward

Date: July 1st, 1997

A. Appropriate Principles

The Government seeks comment on the principles by
which it should evaluate proposals for the
registration and administration of Internet domain
names. Are the following principles appropriate?
Are they complete? If not, how should they be
revised? How might such principles best be
fostered?

a. Competition in and expansion of the domain name
registration system should be encouraged.
Conflicting domains, systems, and registries
should not be permitted to jeopardize the
interoperation of the Internet, however. The
addressing scheme should not prevent any user from
connecting to any other site.

It is important to define what exactly the term
gcompetitionh refers to in this context.
gCompetitionh could be considered as market forces
that combine to bring about conditions in which
the cost of administering domain names decreases.
gCompetitionh could also be considered in terms of
groups and individuals competing for a limited
number of domain names.

It is essential that the proposal that is adopted
is accepted by 100% of the Internet community
worldwide. In essence, the .com, .net and .org
domains are excellent examples of such acceptance.

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

The problem here is that different elements of the
private sector have conflicting interests. For
instance, companies that have invested heavily in
their domain name [such as Mecklermediafs recent
purchase of internet.com for a sum reported to be
in excess of $100,000] and companies that have
invested a lot of time and money in promoting
their domain name [such as the major search
engines and companies such as Microsoft and
Netscape] have no interest in expanding the domain
name system, as this would dilute the value and
perception of their domain names.

Similarly, companies that make a living from
domain names, such as domain name registries
[several hundred companies], vanity mail services
and domain name brokers have no interest in
changing the existing status quo.

Individuals and organizations who have invested in
domain names, either for current use or future
deployment, will not wish the existing domain name
system to be expanded.

For all the above reasons, reaching a full
consensus may prove impossible.

c. These self-governance mechanisms should
recognize the inherently global nature of the
Internet and be able to evolve as necessary over
time

Correct. I am concerned about the repeated mention
of the role of the US Government in this process
of revising the domain name system. The US
represents an ever-shrinking portion of the global
Internet, and any agreement reached in defiance of
the will of the international community will be
bitterly opposed at best and unenforcible at
worst.

d. The overall framework for accommodating
competition should be open, robust, efficient, and
fair

These four conditions are irreconcilable. Any
truly fair proposal that takes full account of the
intellectual rights of trademark holders will not
be efficient. Any proposal that does not take full
account of such rights will not be fair. This
should be redrafted to reflect a best case balance
between the four conditions outlined above.

e. The overall policy framework as well as name
allocation and management mechanisms should
promote prompt, fair, and efficient resolution of
conflicts, including conflicts over proprietary
rights.

Yes. Such conflicts must be resolved on a global,
rather than national scale.

f. A framework should be adopted as quickly as
prudent consideration of these issues permits.

There is no hurry to modify the current system.
Domain names are only running out because of a
combination of two things: market forces in the
secondary market for domain names, and a failure
of the imagination on the part of companies and
individuals involved. As I recently explained to
Inter@ctive Week, there are an astonishing number
of domain names still available in the .net and
.org hierarchies. The rules surrounding these
domains have recently been relaxed and effectively
anyone can register domain names under .org and
.net.

A further tightening of the rules surrounding
speculative domain name purchases, together with a
more robust system for looking up domain names
will prove perfectly adequate to meet the current
demand for domain names.


B. General/Organizational Framework Issues

1. What are the advantages and disadvantages of
current domain name registration systems?

The advantage of the current system of domain name
registration is that it is relatively inexpensive
and open to anyone at an individual or corporate
level.

The disadvantage of the current system of domain
name registration is that it is shrouded in too
much mystique for the average Internet user to
fully understand the process behind such a
registration. This enables unscrupulous companies
to charge usurious fees [$250 to $1000+] for very
limited services provided when registering domain
names on behalf of clients.

2. How might current domain name systems be
improved?

The process of domain name registration should be
fully documented in less technical terms. The
central domain name registry should provide name
server services for all domain names it issues.
This removes the onus on domain name registries
and web hosting companies to provide DNS services,
and protects the rights of the domain name holder
[There have been numerous cases of DNS abuse;
either the company providing the DNS services has
refused to change the IP address that a domain
name points to, or it has pointed the domain name
at its own site]

Ideally, the central registry or registries should
provide the following minimum services:-

A) Simple form-based registration process
B) DNS services for the domain name included in
the maintenance price for the name
C) A mechanism for automating or partially
automating the process of submitting intellectual
property information in support of a domain name
claim

The way to solve the shortage of domain names is
very simple. Implementation of the following
procedures will free up needed domain names and
ensure that an adequate supply will be available
for the future:-

A) Increase the fee for retaining domain names
from $50 to $100 per year, effective from the
renewal date for current domain names. This serves
to discourage speculators.
B) Implement a system in which money is demanded
up front, rather than the current system in which
a grace period of up to 90 days makes it easy for
speculation to take place. This has a number of
advantages: a guaranteed cash-flow in exchange for
the provision of domain names; reduced
administration costs [no longer any requirement to
send out reminders for individuals and
organizations that have failed to meet the
deadline for invoice payment]; reduction in domain
name speculation [speculation is less attractive
when the money must be paid up front]
C) Rolling renewal system in which a reminder is
sent 8 weeks before the current term of domain
name ownership expires. If payment has not been
received by the expiry date [a second reminder is
issued at 4 weeks] then the domain name
immediately defaults and is put back into the pool
of available names.
D) A more comprehensive method of dealing with
domain name disputes, and one which does not
penalize the owner of the name from the start, but
only removes the right to the given name at the
end of the process.
E) A clearer explanation of where funds raised by
the domain name process will be distributed and
used. Mechanisms to ensure that this money is
actually used in practice for the stated purpose
[more public accountability]
F) Open up the .org and .net domain names fully,
so that they have the same status as .com
G) In conjunction with F), give control of .org
and .net to two separate organizations, forming a
triumvirate of registrars with the organization
chosen to continue the administration of the .com
domain name.

The above 7 steps will be adequate to solve the
problem of the shortage of domain names. They will
also be less costly and less difficult to
administer than any proposal that involves
expanding the number of top level domains.

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

Quite frankly, that is the most preposterous
suggestion I have read for a very long time. There
are over 1,000,000 .com domain names in
circulation, most of them paid for. This means
that there are as many as 1,000,000 potential
lawsuits over the loss of .com names. In addition,
.com has become firmly ingrained in the publicfs
consciousness as the gconventionalh form of an
Internet site address. Domain names appear as part
of site addresses in a wide range of situations,
from advertisements in trade magazines to
indications at the foot of posters and even in
television advertisements.

.us is a good idea. The US is one of the few
countries that does not fully regulate its domain
name system.

The .com registry can remain in its present form,
a completely global registry not subject to
localized rules and regulations. The .net and .org
domains should be further promoted and opened up,
potentially nearly tripling the number of domain
names available.

In addition, a process should be instigated to
regulate the .us domain, or a new alternative to
the .us domain, along the lines of the .uk domain
in the UK. There, the central registry demands
various forms of proof that the registrar is a
genuine company, including the companyfs
deposition at Companies House in London. A similar
system for the .us top domain would ensure that
its use be limited to companies. This will easily
solve much of the congestion around existing
domain names, which are mainly being bought up by
speculators and investors.

6. Are there any technological solutions to
current domain name registration issues? Are there
any issues concerning the relationship of
registrars and gTLDs with root servers?

Yes. They should be one and the same. The
registrars should be sub-contracted by the
organization running the root servers. Only one
set of root servers should be sanctioned at the
international level, and the money to pay for the
upkeep of these root servers should come from part
of the funds collected to pay for the domain
names.

This prevents the ludicrous farce that has been
perpetrated recently around the attempts of the
eDNS coalition and AlterNIC to form their own
alternate domain name system. AlterNIC pulled its
support for eDNS, and its name servers, meaning
that the eDNS domain names were effectively
rendered worthless. No company or organization
should be allowed to exert that kind of control
over another.

8. How should the transition to any new systems be
accomplished?

In two stages. First, disseminate clear, simple
details about the new system after it has been
finalized. Ensure that members of the Internet
public have a chance to consider and understand
the implications of the new system before it is
put into practice. Second, refuse all applications
for new domain names until a random interval of
several days or weeks has elapsed. This eliminates
much of the stress that would be put on the new
system by domain registration companies queuing up
gpre-registrationsh ready to fire at the central
registryfs computers as soon as the new domain
names become available. Also, implement a system
to restrict the number of domain name purchases
through any one organization to a low number, say
100 a week, for an initial gteethingh period of a
few weeks or months to effectively curb any
potential for a wave of speculation in the new
domain names.


C. Creation of New gTLDs

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

Yes. The intellectual property disputes
surrounding a case such as parallel registration
of gibm.comh and gibm.neth by two different
organizations pale into insignificance next to the
problems that might arise if a single company can
purchase a g.ibmh address. Thus, any proposals
that effectively allow an unlimited number of top
domains, such as PGPMediafs name.space plan,
should be blocked immediately.

There is also the problem of perception. Domain
names are only useful as long as they are
memorable. They serve as mnemonics in place of IP
addresses. If the domain naming system is unduly
complicated to the point of having several dozen
possible top domains, it will be extremely
difficult for individuals to easily remember
internet addresses. Some people already get
confused between XYZ.com and XYZ.org; the
situation becomes unimaginably worse if they also
have to choose between XYZ.ABC, XYZ.CDE, XYZ.EFG
etc.

11. Should additional gTLDs be created?

No. There is absolutely no need for any new gTLDs.
All that needs to happen is a gradual but firm
tightening of the rules surrounding the existing
gTLDs, coupled with a better exploitation of a
country domain for the US.

D. Policies for Registries

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

Yes, but the costs and profit level should be
regulated by an international body. A good example
of such a system in the offline world is the
running of the UK National Lottery. The lottery is
run by a private organization, Camelot, but with
government-specified levels of profit.

By exercising this type of partial control over
the domain name registrar, any possible abuse of
the monopoly over a given gTLD can be avoided.

16. Should there be threshold requirements for
domain name registrars, and what responsibilities
should such registrars have? Who will determine
these and how?

Yes. They should have sizeable assets and the
technical know-how to guarantee that they can
maintain their systems in full working order at
all times. They should be responsible for
providing DNS services for domain names under
their control. They should be able to INSTANTLY
issue domain names [even though the update could
be reflected periodically in the central DNS
databases, such as once a day as per the current
InterNIC system]

17. Are there technical limitations on the
possible number of domain name registrars?

Yes. The InterNIC database is already extremely
slow due to the number of queries being sent to
it. If registrars need to query the databases held
by all other registrars, or alternatively need to
all share a centralized domain name registry
database, the system will slow to a crawl. One
domain name, one registrar, one database.

18. Are there technical, business and/or policy
issues about the name space raised by increasing
the number of domain name registrars?

Yes. Increasing the number of registrars increases
the possibility of conflicts between different
groups seeking to register a single domain name.

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

Yes. 1. All rights should always be exclusive.

20. Are there any other issues that should be
addressed in this area?

No.

E. Trademark Issues

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

All trademarks should be given weighting when
considering domain name disputes, IRRESPECTIVE of
the country of origin of the domain name. This is
vitally important: US trademarks should not be
given any kind of precedence over trademarks
issued by other countries.

22. Should some process of preliminary review of
an application for registration of a domain name
be required, before allocation, to determine if it
conflicts with a trademark, a trade name, a
geographic indication, etc.? If so, what standards
should be used? Who should conduct the preliminary
review? If a conflict is found, what should be
done, e.g., domain name applicant and/or trademark
owner notified of the conflict? Automatic referral
to dispute settlement?

Yes, for the new .us or similar country domain
that I outlined earlier. In this case, the
trademark should be a US trademark only. An
independent body should be set up to monitor such
disputes. A cost could be levied on the disputee
and on the disputer; the successful party in the
dispute would have the cost refunded, and the
losing partyfs cost would pay for the review
process.

NO ACTION should be taken until the process has
completed and a decision is reached. The current
system that DNS services are suspended to the
domain name holder UNTIL a settlement is reached
is completely unacceptable, and is not conducive
to promoting the use of the Internet as a tool for
global business.

.com, .org and .net names should be allocated on a
first come, first served basis. Any resultant
disputes should be handled by a similar,
independent body. Because of their global nature,
any pre-review process would be unsuitable for
such domain names.

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

An international organization should be formed
with the specific aim of resolving such disputes.
A framework of rules should be laid down to make
all but the most complicated of cases a mere
formality.

24. How can conflicts over trademarks best be
prevented? What information resources (e.g.
databases of registered domain names, registered
trademarks, trade names) could help reduce
potential conflicts? If there should be a
database(s), who should create the database(s)?
How should such a database(s) be used?

Trademark databases already exist. Patent
databases can also be considered when resolving
such disputes. An organization could be set up to
integrate these databases in some form, possibly
via a unified query mechanism to provide a front-
end interface to these various databases.

25. Should domain name applicants be required to
demonstrate that they have a basis for requesting
a particular domain name? If so, what information
should be supplied? Who should evaluate the
information? On the basis of what criteria?

Yes, for the new .us domain name reserved for
companies. Proof of company ownership should be
required. Small businesses and self-employed
people, and individual domain name applicants
should content themselves with other domain names
such as .com, .net and .org.

If this new top domain becomes widely used as THE
domain for US companies, then problems such as
conflicts between IBM.com and IBM.org [for
example] will be of much lesser significance.

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

Every time you add a gTLD, you add another
potential battleground for companies to fight over
the rights to a domain name, and another potential
domain name that can be hijacked away from its
rightful owner.

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

No. First come first served is the fairest system
if both claims are valid.

One additional partial solution would be to have a
standardized glinking systemh that sites would be
required to display on their top page to dispel
confusion. So for example, IBM.com would be
required to display the information: gIf you are
looking for International Bowling Members, please
go to IBM.net. If you are looking for Interior
Bazaar Malls, please go to IBM.org.h at the foot
of its main page [standardized font size and a
high-contrast colour]

In the above example, the site belonging to
IBM.net would have to display the following: gIf
you are looking for International Business
Machines, please go to IBM.com. If you are looking
for Interior Bazaar Malls, please go to IBM.org.h

Finally, in the same example, the site belonging
to IBM.org would have to display: gIf you are
looking for International Business Machines,
please go to IBM.com. If you are looking for
International Bowling Members, please go to
IBM.net.h

28. Are there any other issues that should be
addressed in this area?

No.


--
Edwin Hayward, Tokyo, Japan info@igoldrush.com
Internet Gold-Rush [ http://www.igoldrush.com ]
The premier source of free domain name news and info
*** LIST A DOMAIN NAME FOR SALE FREE / BROWSE NAMES ***
###
Number: 6 
From:     Christopher Quinn 
To:  "Paula Bruening, NTIA" 
Date:     7/1/97 11:20am
Subject:  gTLD:  UTI - no!  NSF - yes!

          I utterly mistrust and object to Secretary General Pekka 
Tarjanne's and the International Telecommunication Union's (UTI's) 
attempt to hijack the Internet. 
          The proposed plan to transfer control of the Internet from the 
U.S. government to an intergovernmental organization in Switzerland is 
not in the best interests of Americans (like me) or the Internet. 
          The ITU,  the United Nations agency responsible for 
coordinating telecommunications policies of governments, not the U.S. 
government's National Science Foundation  (NSF), would become the 
worldwide central depository for new Internet domain names, and the World 
Intellectual Property Organization (WIPO) would administer the 
arbitration and appeals mechanisms. Utter folly! Americans paid for and 
developed the Internet; and only Americans, due to our Constitution, our 
economic and military strength, are in a position to safeguard the 
privacy of American citizens and free flow of information and commerce on 
the Internet.  Not some selfordained United Nations bureacracy and a 
fragile balkanized coalition of vested international interests. 
          You don't see Apple, IBM, Microsoft and Netscape Communications 
rushing to endorse the Geneva plan; and even if those major players got 
stupid, an increasing number of smaller organizations are actively 
campaigning against the proposals, afraid that the UTI takeover could 
lead to the splintering of the Internet into rival domain-name groupings. 
The proposal has, in fact, already provoked legal action from Internet 
services companies in the United States. These companies are justifiably 
angry at what they see as the hijacking of the Internet by an unelected 
international body; Richard Beaird, the U.S. government representative, 
would thus be best advised to make sure the absurd proposal is vetoed.
          A protest meeting on the domain-name issue organized by the 
Association for Interactive Media will take place in  Washington, D.C. on 
July 9; so the American protest against the Geneva plan should be in full 
roar by August.
          Having Vint Cerf, known as the "father of the Internet", MCI 
and 80 other organizations with less than sterling motives endorsing such 
a anti-American plot will not sway the majority of Americans, once they 
find out what is really being proposed. Not so much the idea of adding 
seven new generic top-level domains to the five established domains, 
which include .com, .edu and. gov, or even the complex registration, 
payment and appeal process, but the idea of the world dictating what 
Americans can and cannot do with an American technology and architecture 
is galling. 
          Pekka Tarjanne's defense of rushing this through, by saying his 
organization had to act quickly so as not to miss the opportunity to 
reform the Internet, is specious at best. The UTI is secretly salivating 
over future tariffs (taxes) on American Internet commerce and being able 
to acquire covert data on American interests. 
          Americans will no longer stand for our own government 
overtaxing us and methodically diminishing our freedoms; so we sure as 
heck aren't going to take it from beyond our borders. I know I won't! 
Tarjanne and Cerf can stuff it; and so can any American administration 
that plays into their hands.
          
Christopher Quinn

###
Number: 7
From:     Tommy Lakofski 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 12:35pm
Subject:  Possible solutions to gTLD clutter.

Sir,

The document at http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm
raises many valid questions. I'm not in a position to comment on most of
them, but it would seem that a fairly obvious solution to the overwhelming
growth of gTLD domains would be to restrict the allocation of such domains
to one per company, organization, body, or individual. This, I believe,
was the original intent of the hierarchical nature of DNS zones -- any
organization could subdivide its namespace as it saw fit in a hierarchical
manner. This indeed is the manner in which most reputable companies on the
Internet manage their DNS -- cf. Digital, IBM, Apple, Microsoft et al. In
my (humble) experience, it is only those less 'worthwhile' companies which
undertake domain registration en masse, for the purposes of speculation,
vanity DNS naming, etc. I believe that these activities must be the chief
factor in the cluttering of the generic namespace, and its eventual
non-operability -- and it would sem that these activities would be the
easiest to eliminate, via a change in the registration process for generic
domains which would require proof of identity -- corporate or individual.

I'd also like to throw in a brief word on the retirement of the gTLDs: 
This would seem to be perfectly justified, and by reducing the 'glamor' of
the gTLDs, would eliminate the registration of gTLDs by organizations
outside the US, further reducing pressure on the namespace. As the
Internet seems to be becoming a more global than exclusively US-centric
domain, the incorporation of the gTLDs into the .us namespace seems
entirely appropriate. It would also make room for the possibility of
global gTLDs for multinational organizations (although this is provided
for currently by .int).

In any reorganization of the DNS, there should be competition between the
registries of names (and with IPv6, numbers) on the Internet, as well as
the continuing minimal interference of governmental organizations, which
will never be able to keep pace with the dynamic evolution of this global
network.


I hope these comments prove useful. Thank you for your time.

Thomas Lakofski.

###

Number: 8
From:     
To:  NTIADC40.NTIAHQ40(dns)
Date:     6/30/97 8:28pm
Subject:  New domain naming system

My main concern on domain naming is that the owners of domain names be
required to submit real contact information, that the registries be
required to verify the contact information and that there be substantial
penalties for providing incorrect or nonfunctional contacts, e.g.,
telephones that are never answered, E-mail routed to /dev/null. 

The reason for this is that currently the major spam domain have bogus
contact information in order to avoid having to listen to complaints. 

 Shmuel (Seymour J.) Metz
 shmuel@os2bbs.com

###
Number: 9
From:     Daniel Prather <10ebm3s3ipcm@mci2000.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     6/30/97 8:44pm
Subject:  Internet Domain Registry Structure

     
     Hello.  My name is Daniel Prather, and I'd like to share a few of my 
ideas on the future Internet Domain Registry Structure and workings.  
I have tried to structure this in a sense that I feel will best 
benefit you, the reviewer, and answer any questions that you may 
have.  Also, if something in this document is not thoroughly 
explained, and you'd like a more detailed explanation, feel free to 
e-mail me at the address at the end of this letter below.  Thanks!

     Daniel Prather
     Panama City, Florida
     (850)784-1253
     mystic.one@mci2000.com

     
The following section of this message contains a file attachment
prepared for transmission using the Internet MIME message format.
If you are using Pegasus Mail, or any another MIME-compliant system,
you should be able to save it or view it from within your mailer.
If you cannot, please ask your system administrator for assistance.

   ---- File information -----------
     File:  internet.txt
     Date:  1 Jul 1997, 0:43
     Size:  4716 bytes.
     Type:  Text

-- Internet Domain Registry Infrastructure and Workings ---
                      

Introduction:
     
     First hand, I would like to say that this request is not organized in
the way that comments were expected.  Mainly, I feel that the preconceived
format is not adequate to describe the ideas and thoughts which I will
soon depict in this document.  I have organized it in a way that I feel
will make it easy to read, and easy to understand.  If you have any
questions, please refer to the e-mail address towards the end of this
document. 

Overview:

     Due to the sudden growth of the Internet, many of the previously
conceived systems which control Internet traffic have become greatly
overworked.  Not to mention, many things have become disorganized,
creating a very difficult to navigate network.  The text that follows are
my ideas on it's solution.  In writing this, I have primarily addressed
the main problem of domain registration.  I shall begin by giving a
somewhat general overview of what I think may solve several problems in
the current system, and further along, I shall go into more specific
detail. 

New Internet Domain Infrastructure:

     First of all, the domain registration should be administrated by one
organization.  It would be preferably a federally funded operation, which
is also supported by the fees of domain registration.  This organization
would also be the home of the few domain nameservers.  New protcols would
need to be enacted to allow for the use of 128-bit IP addresses as well. 
These few nameservers would be the only ones operational.  I say this
because most of the Internet clutter is created by the popular "static IP"
which usually includes a domain such as "username.domain.ext" ... although
this 3 field URL is not particularly disorganized, sometimes they grow to
take up 5 or 6 fields.  This is completely ridiculous, and wasteful.  In
keeping with a few nameservers, running on high-speed connections
(multiple OC-3s or OC-12s) we could provide domain lookups for the world's
Internet community, and manage it easily. 

     The servers would be linked so that if one goes offline, another may
take on its load, as well as its own.  This would created a continious
domain service.  It would be advisable, though, that a few of these
nameservers be located in different locations as to minimize the chance of
a failure.  Caching servers may be setup as they are now, but may only be
modified by the main servers.  This would allow them to still recieve
queries, and still direct users to desired sites, but not allow useless
data to be entered by a user. 

     When a company or individual registers a domain name, there should be
a set cost.  This cost would include a block of rougly 5 IPs, instead of
the blocks of 256 given now.  Extra IPs may be purchased at a set cost,
and all DNS entries and "static IP" domains would need to be approved by
the new registry.  To be approved, they would have to submit a form
detailing the intended use of the domain, as well as information regarding
the user.  This would minimize the amount of "nonsense" domains currently
residing on the network nameservers.  Only domain administrators (working
for the new domain organization) will be able to make changes to the
registry. 

     Domains would need to have longer extensions.  .com, .edu. .gov, etc,
usually are sufficient, but with more and more sites appearing with
different social orientations, these extensions will eventually become
unusable.  In place, I'd suggest something a little more descriptive and
restricted, .com domains would only be given to commercial sites, and they
would have to show proof of their business stance.  .edu isn't sufficient
for all of the educational resources available.  Possibly creating a
.highschool, .college, .university, etc would be more sufficient. 
Government organizations could be categorized in a similar way. 
.localgov, .federalgov, etc. 

     Locations need not be required in domain names.  These tend to be
pointless, in my opinion.  But geographic information SHOULD be stored, so
that if a query is performed (by dnslookup or finger) on a site,
geographic information can be obtained, as well as other information
submitted to the primary registry. 

     Essentially this is most of my suggestions.  If you have any
questions, please e-mail me or call me at 1-850-784-1253.  This new
organization should be called something such as "Worldwide Domain
Services" (www.worldwide-domain-services.system) ... the .system extension
referring to a critical component of the Internet.  Please send me your
comments on the above documents.  Thank you. 

     written by Daniel Prather
     e-mail: mystic.one@mci2000.com

###
Number: 10
From:     
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 1:47pm
Subject:  Trademarks

Network Solutions apparently with the blessing of the NSF has an absolutely
reckless policy as it pertains to registration of trademarked names by third-
party registrants. Their "dispute policy" is so irresponsible that it appears
to
encourage lawsuits for the enrichment of their attorneys.
I have a valid subsisting, unique and famous federal trademark that has been 
used in commerce since 1983. Now, because of Network Solutions policy I will 
have to spend a $150.00 filing fee, spend a day writing the complaint, and
wait
two years for a federal court to order the transfer of the .com registration
back to
the trademark owner. 
The system is in need of change. 
Sincerely,  Darrell J. Bird, 3070 Southdale #D, Dayton, OH  45409
Financia@aol.com

###
Number: 11
From:     Lori Henk 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 4:16pm
Subject:  Creation of New gTLDs #11

11. Should additional gTLDs be created?

  Definitely. The following ideas were proposed at an international level
more than a month ago regarding new gTLDs and the U.S. should remain
consistant with that proposal where possible. There is only one gTLD
proposed that I question and that is .store for retail sites. A more
appropriate gTLD, keeping with 3-4 letters would be .shop.

  The following gTLDs were proposed:
  .firm  - business
  .store - retail  (alternative .shop)
  .web   - web related services
  .rec   - recreation
  .info  - resource/information
  .nom   - personal sites
  .arts  - art related sites

thank you for your time,
Lori Henk
Web Designer
lori@acton.com
###
Number: 12
From:     Nickolai Zeldovich 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 5:09pm
Subject:  Comments on Policies for Registries

See the attached file.
--
Policies for Registries

Domain name registries should not charge excessive amounts of money from
individuals and/or companies and/or organizations registering domain
names, except for what's absolutely needed for the operation of the
servers. Obviously the current $50/year fee generates much more money for
InterNIC than they need for normal operation of the nameservers and other
registrations.

--
+--------------------------+----------------------+--------------------------+
| Nickolai Zeldovich       | ZEPANET              | UCF Math Department      |
| http://www.kolya.ml.org/ | http://www.zepa.net/ | http://www.math.ucf.edu/ |
| nickolai@kolya.ml.org    | nickolai@zepa.net    | nickolai@math.ucf.edu    |
+--------------------------+----------------------+--------------------------+

###
Number: 13
From:     Jim Cerny 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 5:22pm
Subject:  comment on adding DNS top-level domains.

Dear NTIA:

In following the attempts by Internet groups to expand the
number of top-level domains in the last six months, I
think the following clearly emerges regardless of who runs
the registries and regardless of just how many new domains
are added and what they are called:

     Legal counsel for companies will regard it as
     their duty to recommend, for any corporate
     names that have trademark or copyright status,
     the registration of these names in EACH new
     domain.

That will, of course, tend to undo many of the benefits of
expanding the namespace.  The solution, at least from the
point of U.S. law, would seem to be national legislation
that prohibited that kind of multiple registration.  I have
no idea if it is possible to argue for this from some 
parallel situation that has already been legislated.  Some
would suggest a pricing mechanism as an alternative to
legislation, with sharply escalated fees for extra 
registrations.  If it were just a matter of charging $100
(say) for the first registration and $10,000 (say) for each
additional one, that would be hard to administer with
competing registries and would discriminate strongly against
small companies (for a large corporation the $10K would be
a trivial cost of business).

  Jim Cerny
    Web manager, University of New Hampshire
     jim.cerny@unh.edu
###
Number: 14
From:     Dennis Fazio 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 7:26pm
Subject:  On the Registration and Administration of Internet Domain Names 

Comments in response attached as ASCII text.

My full contact info:

Dennis Fazio
Executive Director
Minnesota Regional Network
2829 University Ave SE
Minneapolis, MN 55414

dfazio@mr.net
(612) 362-5850
--

Dennis Fazio
Minnesota Regional Network -- Gabnet: (612) 362-5850

Comments in response to a Request for Comments on the Registration and
Administration of Internet Domain Names, Docket No. 970613137-7137-01. 

Section A. Appropriate Principles 

I agree with all six principles

Section B. General/Organizational Framework Issues 

Questions 1-9: The current domain name system has been overrun by the
growth of the Internet; it no longer scales with the need. Generic Top
Level Domains should be retired and the use of the US Domain, as currently
defined in RFC 1480, should be mandated for the United States in its
place. Detailed explanation and justification follows: 

 I believe any scheme predicated on an extension of the current,
essentially flat naming system is doomed to failure. The recent proposal
by the International Ad Hoc Committee (IAHC) to add a limited number of
new Top Level Domains does not seem to be a scaleable solution and will
not likely ameliorate the major issues of trademark infringement. 

It seems the key problems are: 
a. Demand by several parties for the same name 
b. Use of the domain name system as a directory service 
c. Technical and operational management of the growing Domain Name System 

Most all of the rest of the issues and problems are a result of these three.

It would be easiest of these had apparent technical solutions.
Unfortunately, they all don't. The second problem could be solved with a
mix of policy (adhere to a standard) and technical (implement a separate,
easy-to-use directory service). The third is partly policy (agree on some
practices; again, standards) and implement them (mostly
technical/operational.)

It's that first one that is the real source of all the ruckus. One path to
a possibly easier solution would be to look at the world we had
pre-Internet and see how we dealt with those issues of similar naming and
trademarks. 

We deal with them now by allowing the use of the same name as long as they
are in different areas of activity or in different states. This leads us
to a solution that doesn't perturb the current setup all that much:
mandate the use of the US domain. 

First, it's heirarchical and does not suffer the scaling problem of the
current proposals, even as they are themselves increased with more
top-level domains. There are 50 states and thousands of localities in
which to fit your organization's name. 

Second, it allows for either a single registration authority or the
logical division to any number of registration authorities, each of
different size and scope of operation according to their capabilities. 

Third, it permits multiple organizations to have the same name.
Acme.Minneapolis.MN.US and Acme.Los-Angeles.CA.US can both exist and keep
their names if they are in different business lines. In those cases where
the same name is to be used in the same community, categorical names could
be slipped in: Acme.Paints.Minneapolis.MN.US,
Acme.Towing.Minneapolis.MN.US. 

Fourth, it provides some semblence of a limited directory service. Right
now, if we know the name of a prominent company and add .com, we can go to
its web server. However, that only works for one company with that name.
With an heirarchical US domain, we only need know the company name and
where it is to find their web site. Note that we will still have need of a
good directory service to really make the system work, but it's always
nice to have some shortcuts. 

Fifth, and most important, it helps leverage the existing practice we now
use to keep trademarks manageable because it provides a system very much
like the real world we now are familiar with. It's not a perfect match,
and some new policies, procedures and perhaps new law will have to be
created to make it really work well, but nowhere near the mess and
seemingly insurmountable task we now see before us with the current
system. 

There have been many objections to the use of the US domain, some
specious, the rest, nonconsequential. 

1. The names are too damn long:  This is just a fact of life when so many
are now involved. You need more characters to differentiate organizations
when you get into the thousands and millions. The best solution is to use
already familiar names that are easy to remember. There are plenty of
features in email (aliases) and web programs (bookmarks) that make it
unnecessary to type in the actual name very often. Most email is a
response to another email; the address is never entered in those cases,
but automatically entered by the email client. We deal with long names in
our lives all the time anyway. Many of us use long street addresses or
long town names that we have to write time after time on our applications,
documents, forms, etc. or US Mail letters. We deal with it. This objection
is specious. 

2. People and organizations move and would have to change their domain
names:  What happens when a person or organization moves now? First you
have to get a new telephone number (though this necessity may change in
the future). You perhaps need a new driver's license as an individual. You
need to print tons of new stationary. You need to send out large
quantities of "change of address" postcards. On the Internet, it's a 5
minute job to send "change of address" messages to all your correspondents
(all of whom are conveniently cataloged with nice short aliases in your
mail client) and mailing lists. I hardly think that sending out some email
change notices adds all that much to the overhead necessary when you move
your household or your business. What if you graduate and get a job?  What
if you get a new job? Your email address will change. It happens all the
time to lots of us now anyway. 

Life means change. We change schools, homes, workplaces, favorite foods,
spouses, family size. A major portion of the population still changes
their names at some time in their lives. Businesses move, change products,
change their corporate names. What can be so difficult about changing an
email address or corporate domain name once in a while. Change is good for
us. We should all seek any opportunity to change something about ourselves
often. This objection is also specious. 

3. In Cyberspace, names shouldn't be tied to physical location:  Most of
those arguing for the abstraction of a "Cyberspace" as a new "lifespace"
seem to be denying or attempting to put aside the real world. I think it
is more important for us to encompass the real world in this new virtual
world. 

Seeing that someone is associated with a particular university or
corporation, or is located in a particular place humanizes the message or
the information. All I have in front of me is a screen full of words or
images. The organizational or geographic mapping in their return address
or the web site gives a small amount of identity to the person who wrote
those words or placed those pictures. The tendency to respond rudely and
viciously is amplified when there is no real person looking you in the
eye. We've all seen evidence of that on the Internet. If there was no
shred of identity association at all, the messenger becomes even more
abstract and dehumanized. Discourse can degenerate quickly when all you
debate with are disembodied words. 

Cyberspace is floating too freely as it is. It needs some anchors in
something now existing so that newcomers feel welcome and not just lost in
a strange new world with absolutely no familiar touchstones. 

If we want this new and growing facility to be used by the greater
population, then we have to make it accessible, we have to build it having
an association with the familiar REAL WORLD that we all live in. We are
all real people in real physical places. With few exceptions, almost all
of our sense of community comes from our geography: school, church,
neighborhood, social organizations, civic organizations, government
participation, etc. It is what helps make us human and social beings. We
don't need the concept of an abstract "cyberspace" to bring new people
together on the Internet. The concept of a diverse set of people
geographically dispersed over great distances, yet brought together by
electronic communications can be a powerful draw. A
locality/geographical-based naming system helps us to build that concept.
This objection is inconsequential. 

Let us think about what we are trying to accomplish and the best way to
encourage that. The best new things are those that have some sort of
usefulness or tie that people can tie to something already familiar to
them. It is what helps new things grow and flourish most rapidly. 

In summary, we can probably futily attempt to pull and stretch and warp a
current system that was never intended to scale to this size and scope, or
give up and adapt something entirely different, very familiar, and staring
us in the face all along. 

Section C, D, E:  I have no supplementary comments on these sections
beyond what has been already covered above. 

--
Dennis Fazio, Minnesota Regional Network   --|||--   Gabnet: (612) 362-5850

###
Number:15
From:      Ringmaster 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/1/97 7:46pm
Subject:   About InterNIC...

Well I just have a little comment, the system InterNIC is using right
now is way to stoneage. For ex. if you wanna update your profiles it
takes days to get it done and e-mails has to be sent back and forward to
the hostmaster (or whatever), wouldn't it be easyer if they just could
get a real system up and running where you can update your info on-line,
internet is commercial and not only the "old" computer nerds are using
it anymore...

My two cents...(or is it one cent?)


[minimjuk] Ringmaster
 - http://www.geocities.com/~gcring/
 - minimjuk@geocities.com

###
Number: 16
From:     Charles 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:15pm
Subject:  REGISTRATION OF INTERNET DOMAIN NAMES

To whom it may concern,
     I am inclined to aggree with the executive summary on almost all
aspects of included content. I am strongly in favor of the internet
being regulated by the public sector, leaving legal enforcement matters
to the government agencies. As far as domain names are concerned they
should open more domains for the use of public as well as business
concerns, cost of which should be absorbed by the users. Business should
pay their part as well as the private sector. As a private user of the
internet I have found it increasingly difficult to log on to my service
due to the rising amount of usage, as well as the many larger servers
being brought down due to the massive hits to their systems. These facts
alone are proof something need be done and very soon. I can see a major
failure happening within the next few years due to the steady rise in
traffic and stress on an already taxed system. Regards Charles Leffler 

-- 
For quik contact= Mailto:leffler@okeechobee.com
Home Page= http://www.okeechobee.com/~leffler/index.html
Truckers Page=
http://www.okeechobee.com/~leffler/index.html/bookmark3.htm


CC:        NTIADC40.SMTP40("jerry@southeast.net")

###
Number: 17
From:     Jesse Kornblum 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 11:40pm
Subject:  Comments on DNS issues


B. 

1. Problems with current DNS system: 

   Under the current system, if a person registers for a DNS entry, but
later another company that holds a trademark to that name (e.g.
www.superbowl.com) wants that domain name, the first person is stripped,
without compensation, of the name. I believe that trademark holders should
be able to purchase the domain names of trademarks they hold, but at a
fair market value. (Perhaps the cost of the registration fee for as long
as the person held the name...)

5. The existing gTLDs should not be retired, but new ones should be
created. It might be a good idea to have a .us domain, and then the US
could administrate everything in that domain, but who would decide other
country codes? And how would those debates be decided? I like the idea of
InterNIC, a semi-autonomous organization that runs the whole deal. Like
the UN, only for the Internet. (Please note that the Internet should NOT
be under control of the UN.) :)

7. Well, I'm going to get a little technical here. Remember that DNS names
(e.g. www.whitehouse.gov) are only nicknames for the *real* addresses,
which are IP addresses that look like this: 18.233.0.21, etc. It may very
well be necessary to expand IP addresses to five blocks. (Each block can
range from 0-255) Having existing systems work with these new systems
would require updating the Internet, a daunting task, but nonetheless
necessary...

C. New gTLDs

1. Yeah. Nothing should be banned. If you want a site
www.profanity.#!@#??, then you should be able to get it.

2. YES! The current system is too restrictive. For example, .isp for
service providers, .store for well, stores, .adult, for sites with adult
content (great for filtering software!) 

Thanks for listening,

Jesse D. Kornblum             |         Even if the voices aren't real,
403 Memorial Drive - DKE      |           they have some good ideas
Cambridge, MA 02139-4397 USA                             
617-494-8250, ext. 114   http://mit.edu/jessek/www/


###
Number: 18
From:      David Shaw dshaw@nin.skiles.gatech.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/2/97 10:02am
Subject:   Internet Domain Naming

I think that the naming system should remain as it is today.  If it it
turned over to an international body it will become increasingly
difficult (if not impossible) and prohibitively expensive to register
domain names.  I have personally set up several domains for clients and
it is not a difficult process.  If we have control over it, we should
maintain that control.

-- 
------------------------------------------------------------------------
David Shaw                           SGI/HP Platform Manager, Erdas Inc.
                                                 "Endian Little Hate We"
------------------------------------------------------------------------
###
Number:19
From:     Stephen Burley stephenb@uunet.pipex.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/2/97 11:50am
Subject:  Request for coments


     The .com as an international domain is a good idea but it does not work
in practice. The biggest problem is that there is no one global legal body to
enforce the trademark law. What maybe a trademark for one product in one
country could be an different product in another. i.e. Durex is a well known
brand of condom in this country but in Australia it is a brand of sticky tape.
     What i would like is to see the .com domain put on hold and as NSI are
losing the registration contract that would be an ideal time to do this. I do
not mean kill it off just allow the domains to continue and eventually fade it
out. If a company wants an international presence then they would register in
each country they want to. Trademark laws within the country could then be
applied and enforced. This would also have the effect of spreading the name
space globally rather than concentrating it in the US. If a international
domain was seen to be essential then this could be done by iana, but only if
the company matched a list of certain criteria which made them truly
international.

These are my own personal thoughts.

###
Number: 20
From:     thoth@purplefrog.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/2/97 12:33pm


http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm


A.e  "conflicts over proprietary rights"

  Some of the domain-name disputes are over a DNS name that corresponds
to a trademark (mcdonalds.com).  Someone convinced me that rather than
extend trademark law into the internet, there should be a separate layer
that maps from a corporate identity into a domain name.


B.1 "What are the advantages and disadvantages of current domain name
registration systems"

  Recent experiences with the Internic has convinced me that they are
having difficulty telling their ass from a hole in the ground.  What I
want from a registrar is competence, economy, and stability.  If a
monopoly registrar can do it, I have no objections.  If we need
competition to accomplish this, then I hope it doesn't cause more
problems than it solves.


C.11 "Should additional gTLDs be created?"

  I seriously doubt it.  If you have .inc and .com name spaces, then the
CocaCola corporation is going to want both coke.inc and coke.com.  I
think this will merely increase citizen confusion and the cost of doing
business.

  My straw man above can be burned if you distance corporate identity
from the domain name space.  Keep reading.


D.16. "Should there be threshold requirements for domain name registrars,
and what responsibilities should such registrars have? Who will determine
these and how?"

  The "failure" of a registrar would be a devastating event.  There
should be requirements in place that make this extremely unlikely (bonds?
gvmt crisis management teams?)


D.19. "Should a gTLD registrar have exclusive control over a particular
gTLD? Are there any technical limitations on using shared registries for
some or all gTLDs? Can exclusive and non-exclusive gTLDs coexist? "

  I deplore name-grabbing for profit.  It is currently an issue under the
.us domain space.  If a registrar has monopoly control over a domain,
then there is no opportunity for a more efficient registrar to compete.


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

  also see A.e

  Absolutely none.  The mapping from a company identity to a domain name
is rarely obvious and different people will try different domain names to
find a certain company.  There should be a separate and widely deployed
mechanism for mapping from corporate/product identity into internet
resources (whether web sites or email addresses).


E.22. "Should some process of preliminary review of an application for
registration of a domain name be required, before allocation, to
determine if it conflicts with a trademark, a trade name, a geographic
indication, etc.? If so, what standards should be used? Who should
conduct the preliminary review? If a conflict is found, what should be
done, e.g., domain name applicant and/or trademark owner notified of the
conflict? Automatic referral to dispute settlement? "

  Waste of time and money to solve an unsolveable problem.


E.24. "How can conflicts over trademarks best be prevented? What
information resources (e.g. databases of registered domain names,
registered trademarks, trade names) could help reduce potential
conflicts? If there should be a database(s), who should create the
database(s)? How should such a database(s) be used? "

  When you incorporate in a state, you should also provide information
about internet resources you provide.  The state should administer the
database.  These registries should be heirarchically grouped under a
national registry, and then the national registries should be grouped
under an international registry.  

  This registry should not be confused with the domain name registry. 
This is a corporate identity registry.


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

  When you invalidate the idea of trademark rights for a domain name, the
issue becomes moot.  


-- 
Bob Forsman                                   thoth@gainesville.fl.us
           http://www.gainesville.fl.us/~thoth/

###

Number: 21
From:      "Shasta Willson" shasta@1soft.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/2/97 12:57pm
Subject:   DNS comments

Please find attached a Word document with the input of Greg Thorne,
president of 1Soft Corp., concerning:


 Billing Code 3510-60 

DEPARTMENT OF COMMERCE 

[Docket No. 970613137-7137-01] 

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

If you have any difficulties, please contact me directly at:
shasta@1soft.com

Shasta Willson
Web Maven 
shasta@1soft.com
541.822.6000 ext.103

1Soft Corp.
www.1soft.com

----------

A. Appropriate Principles 

The Government seeks comment on the principles by which it should evaluate
proposals for the registration and administration of Internet domain names.
Are the following principles appropriate? Are they complete? If not, how
should they be revised? How might such principles best be fostered? 

a. Competition in and expansion of the domain name registration system
should be encouraged. Conflicting domains, systems, and registries should
not be permitted to jeopardize the interoperation of the Internet, however.
The addressing scheme should not prevent any user from connecting to any
other site. 

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

c. These self-governance mechanisms should recognize the inherently global
nature of the Internet and be able to evolve as necessary over time. 

d. The overall framework for accommodating competition should be open,
robust, efficient, and fair. 

e. The overall policy framework as well as name allocation and management
mechanisms should promote prompt, fair, and efficient resolution of
conflicts, including conflicts over proprietary rights. 

f. A framework should be adopted as quickly as prudent consideration of
these issues permits. 

B. General/Organizational Framework Issues 

1.         What are the advantages and disadvantages of current domain name
registration systems? 

I think it works quite well. Since domain names cost $100, it dissuades
persons from hoarding them. I personally am very involved in the InterNet
and have reserved approximately 300 domain names at a cost of $30,000 fee
to Internic. As I set up web sites on each one, there will be additinal
costs, but I hope to do a great deal of business in many different forms on
the internet in the coming decades. I see this as an investment.

2.         How might current domain name systems be improved? 

It's really quite good. You might allow a few other companies to administer
the reservation of names. If the database were open it would be far easier
to search and see what names were available.

I would not increase the number of TLDs. More TLDs would only increase
confusion. It's perfect the way it is. There are plenty of good .COM names.
Witness that a reported 70,000 new domains are being reserved every month.

Websites can easily "piggy-back" off other .com names, e.g.
www.meyers.store.com or www.pacific-retailers.com/meyers.

If there were additional TLDs, where would it end? I think there would be
thousands and it would be very confusing. Suppose Meyer's is a fishing
tackle store, do you go to meyers.rec, meyers.store, meyers.fishing,
meyers.outdoors or meyers.com? If instead there was only .com, you'd know
that part. The rest could be up to Meyers to develop in their catchy
jingle, slogan or whatever. Then you could just type in "myers fishing
tackle". Your browser might even condense the spaces and default to .com

3. By what entity, entities, or types of entities should current domain
name systems be administered? What should the makeup of such an entity be? 

4. Are there decision-making processes that can serve as models for
deciding on domain name registration systems (e.g., network numbering plan,
standard-setting processes, spectrum allocation)? Are there private/public
sector administered models or regimes that can be used for domain name
registration (e.g., network numbering plan, standard setting processes, or
spectrum allocation processes)? What is the proper role of national or
international governmental/non-governmental organizations, if any, in
national and international domain name registration systems? 

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

I think geographically coded TLDs  should be retired. Three letter TLDs
should be used for governments however., e.g. .USA, .FRA, .GER

6. Are there any technological solutions to current domain name
registration issues? Are there any issues concerning the relationship of
registrars and gTLDs with root servers? 

7. How can we ensure the scalability of the domain name system name and
address spaces as well as ensure that root servers continue to interoperate
and coordinate? 

8. How should the transition to any new systems be accomplished? 

9. Are there any other issues that should be addressed in this area? 

C. Creation of New gTLDs 

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

11. Should additional gTLDs be created? 

No, except very sparingly.

12. Are there technical, business, and/or policy issues about guaranteeing
the scalability of the name space associated with increasing the number of
gTLDs? 

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

14. Are there any other issues that should be addressed in this area? 

D. Policies for Registries 

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

16. Should there be threshold requirements for domain name registrars, and
what responsibilities should such registrars have? Who will determine these
and how? 

17. Are there technical limitations on the possible number of domain name
registrars? 

18. Are there technical, business and/or policy issues about the name space
raised by increasing the number of domain name registrars? 

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

20. Are there any other issues that should be addressed in this area? 

E. Trademark Issues 

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

Trademarks and TLDs are different things. This whole concept of a TLD
infringin on a trademark was something that started with big business
(McDonalds, e.g.). There was someone with the last name of McDonald. It
seems to me they had the perfect right to reserve mcdonald.com and set up a
family web site. If McDonalds really wants a web site with their name, they
should pay for it. I'm sure they can negotiate a price to buy it from the
holder. Anyone with a trademark who wants to be on the web, ought to have
reserved their name yesterday, not be whining about it later. First come,
first serve. Let the free market place moderate. Good names should be
traded freely.

A holder of a TLD does not own a trademark and a trademark owner does not
automatically hold rights to a permutation into a TLD. TLD owners are
protected by having reserved their TLD. Trademark holders overlap by
industry. It is not possible to arbitrate. And there's no need. It should
be first come first serve. If I hold a trademark for "apple" records, and
Apple computer has reserved www.apple.com, then I should have to come up
with something different, e.g. www.apple-records.com. If I invent a new
word, e.g. ChiZen, and I reserve a site www.CHIZEN.com then I have been
protected. I may not even need to bother registering a trademark, easing
the burden on the PTO and everyone else worldwide.

22. Should some process of preliminary review of an application for
registration of a domain name be required, before allocation, to determine
if it conflicts with a trademark, a trade name, a geographic indication,
etc.? If so, what standards should be used? Who should conduct the
preliminary review? If a conflict is found, what should be done, e.g.,
domain name applicant and/or trademark owner notified of the conflict?
Automatic referral to dispute settlement? 

No.

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

Domain names may include trademarked words surrounded by other words, e.g.
www.apple.com, www.apple-walnut.com The holder of the trademark "apple" has
the option of buying the domain name, but should not automatically be given
a right to it. Afterall, the word apple is not itself a trademark. Use of
the word only infringes on registered trademarks if it used in a confusing
way, e.g. if the site were to sell "Apple" computers. That would be an
infringement. Selling Washington apples on the site would not be an
infringement.

If I think Photogenics would be a great name for a modeling agency and I
create a website called www.photogenics.com, it wouldn't be fair for
someone in Georgia who owns a 24 hour photo processing store called
Photogenics with a registered trademark to have rights to the site
(www.photogenics.com) if I have already paid for it.

24. How can conflicts over trademarks best be prevented? What information
resources (e.g. databases of registered domain names, registered
trademarks, trade names) could help reduce potential conflicts? If there
should be a database(s), who should create the database(s)? How should such
a database(s) be used? 

There should be no conflicts. Ignore any bogus claims. These are imaginary.
A domain names is not a trademark. It's a domain name.

25. Should domain name applicants be required to demonstrate that they have
a basis for requesting a particular domain name? If so, what information
should be supplied? Who should evaluate the information? On the basis of
what criteria? 

No.

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

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

First come first serve.

28. Are there any other issues that should be addressed in this area? 

____

###
Number: 22
From:     Total Web Solutions support@totalweb.co.uk>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/2/97 2:14pm
Subject:  DOMAIN NAMES

To whom it may concern:-

First of all let me introduce myself.  I am the Sales Director for Total
Web Solutions in the United Kingdom.  I along with my colleagues set up
this organisation two years ago with a reasonable understanding of what the
internet was and how it operated due to our techincal backgrounds (software
engineers).  It has become aparent though that the Internet and its
resourcs are expanding at an ever increasing rate, thus meaning that it is
incredibly difficult to stay on top of the latest fad or technologies with
limited resources.  Customers often ring up and ask for certain tools, or
do you support this or can you do that.  It is very customer driven.  It is
with this in mind that i say why not let the Internet decide, not some
company such as my own or organisation too big to realise what the people
of the planet really want.

What I propose is to have a web site hosted say by Internic which allowed
internet users to register there thoughts on which top level domains should
be introduced and whom shall have authority, giving the user some pointers
of course.  This site shall be the recognised place for registering your
views as an individual.  There are far to many sites relating to this issue
and to be frank its a huge pool of bullshit.

People also need to be made aware of this web site by banner advertising
and newsgroup postings along with anything else that might attract the
users attention.

The internet is for the people and not the pot bellied money lovers who see
it as a license to print money at the tax payers expense.  

So, back to the web site.  The web site might exist for several months but
it will be a central point to register your beliefs.  It should not be a
discussion forum because in my experience these forums end up going no
where fast.  It needs to be a concise and easy to navigate site with not an
information overload but with a taster of what is expected of their response.
The phrase "keep it simple, stupid" springs to mind.  Once several months
worth of information is gathered and collated then and only then can this
problem be resolved once and for all.  Because at this moment in time I get
around 3-5 calls a day asking about these domains and I cannot supply any
of these enquirers with a definitive answer.

Hope you read this, if not I have cleared one thing up for myself and that
is I hate long e-mails.

regards,

Miesha Vukasinovic. 
-----------------------------------------------------------------------

Sales: +44 (0)161 485 5586              Freephone Sales: (UK) 0800 435715
                               Tech Support: +44 (0)161 485 5548
        Total Web Solutions             Fascimile   : +44 (0)161 485 2226
 Providing the UK's best Web space      http://www.totalweb.co.uk
                                        e-mail: enquiry@totalweb.co.uk

###
Number: 23
From:     Robert Friedman friedman@iname.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/2/97 8:15pm
Subject:  Internet Domain Name Allocation...



Dear NTIA--

1)  The current domain name allocation system doesn't work:  

Too many people are holding domain names with the sole intent of selling
"their" domain names.  There needs to be fewer "entry bariers" to getting
names (e.g. lower costs) BUT more stringent requirements for i) maintaining
domain access and ii) maintaining content that pertains to a particular
domain name.  Anything less is insufficient relative to domain registration
costs and the revenues collected by INTERNIC.

2)  .COM, .GOV, .NET, etc. should not be proprietarily owned:

There is no excuse for maintenance and allocation of these domains to be
given to a single company (INTERNIC).  That is what one calls a MONOPOLY,
and the system should be opened to the free market.

3)  the system should be internationally maintained:

We are not living in a vacuum.  The U.S. may have originated the Internet,
but it certainly doesn't OWN the Internet.  It would be an intelligent act
of diplomacy (a la Tax Free Web Commerce as proposed by President Clinton)
to allow an international organization to maintain fairness and assign
domains on the Web.

-- Robert Friedman
   Princeton University '97

______________________________________________________________________
Robert Friedman                                 friedman@postguard.com
Post Communications                                     (415) 551-9994
1550 Bryant Street, Suite 500                      fax: (415) 431-3007
San Francisco, CA  94103


###

Number: 24
From:      "Claudio Allocchio, +39 40 3758523" Claudio.Allocchio@elettra.trieste.it>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 4:05am
Subject:   Re: U.S. COMMERCE DEPT. NOI ON DOMAIN NAME REG. ISSUES


Hallo,

Just a few comments to help you in your survey.

My name is Claudio Allocchio, and I'm the chairman of the Italian Naming
Authority, i.e. the official body who is entitled to establish rules for
domain names definition within the country code "it" (both Internet and
ISO systems).

The problem of setting rules for domain name definition was raised in Italy
since mid 1993, and finally the final set of rules went into operation one
year ago: July 1st 1996. 

Among the fundamental statements in the set of rules, I can summarise the
following:

- a domain name is an identifier to assign a name to a "generic object"
  esisting on the network.

- a domain name has no relationship whatsoever with anything else: trademarks,
  registered names, company names, personal names, ... are indipendent 
  different objects, and correlation with domain names does not exist.

- domain names are only "assigned in use" by the Italian Registration
  Authority (a separate indipendent body) to the entity requesting them:
  domain names remain a property of the Italian Registration Authority.

- an entity requesting a domain name must declare its right to use such a name
  in written. If any dispute arises due to other entities claiming any kind
  of "xxx"rights on the name, the domain name holder and the other entities
  must solve the issue themselves or via a civil court. The Italian Registra-
  tion Authority just accepts the conclusins of the issue and acts consequently.

- an entity can request a single domain name only, within the "it" country code.

- official telecomunication and value added service providers (holding an 
  official license from the Ministry of Telecomminications) can request
  a separate domain name for these specific services offered to their
  customers:

     e-mail mailbox service
     X.400 ADMD service
     X.500 directory service
     on-line services (like America-on-line)
     gopher pages service
     web pages service
     ftp area service

The complete set of rules and procedures are available (in Italian Language)
at: 

     http://www.nis.garr.it/netdoc/ITA-PE/Documenti/regole-naming.txt

As a further comment, the Italian Naming Authority and the Italian Registration
Authority are jointly operating with the other European Top Level Domain
registration authorities about the current issue of the IAHC new top levels.
The official position of the Italian Naming and Registration Authorities is
that the IAHC proposal does not solve any of the issues, and just creates
more confusion and unneeded complexity to domain name structure. The proposed
new "categories" are just new large places where the same confusion existing
now in the ".net" and ".com" domains will spread out. Regulations about
domain names use can be established only at national levels, due to differences
in existing legislation. International domains should be used only for specific
cases of international entities, and anything else should be registered within
the national country code: for USA this is "us". Thus the IAHC proposal
should not be implemented, but effective regulations and international 
agreements should be established.

More over a set of compulsory netiquette rules are effective for all entities
requesting a domain name under "it" country code. I enclose them hereunder.
Whoever violates such rules can be taken to court and prosecuted. As you will
notice, commercial advertisement via e-mail is explicitly forbidden.

If you have further questions, just let us know

Regards
Claudio Allocchio
chairman of the Italian Naming Authority
(and Internet Engineering Task Force - Application Area)

------------------------------------------------------------------------------

                            N E T I Q U E T T E
           Ethics and rules for the correct use of network services


  Within the community of network service users, especially Internet users
  and, in  particular, inside the  "news"  service  Usenet,  a  number  of 
  "traditions"  and "principles of correct behaviour" have been  developed
  with time: all these rules are generally known as "netiquette".  Keeping
  in  mind  that whoever  provides your  network access  (provider, public
  institution  or  agency,  employer,  etc.)  can also  control even  more
  precisely  the  users'  duties,   we  summarise  in  this  document  the 
  fundamental principles of "netiquette",  reminding everybody  that these
  rules are mandatory.

  1 When you join  a new  newsgroup or a  new electronic mail distribution
    list,  read the  messages posted  there for at  least two weeks before
    starting  to  send your  own  around the world:  in this  way you will
    understand the topics of the discussion and the methods to be  used in 
    such an environment.

  2 If you send a message, be brief and concise, both in the subject field
    as  well as in the message itself.  Always use the  "subject" field to
    specify the topic. If using the "signature" file, please keep it short.

  3 Do not post or send messages  to the target newsgroup  or distribution
    list which deviate from the topic in question.

  4 Whenever possible,  avoid  broadcasting  your message  to many mailing
    lists  (or newsgroups)  at a time.  There is usually only one specific
    mailing list representing the correct target of your message and which
    contains all interested users in that particular topic.

  5 If you answer  a message,  quote  only the  relevant sections  of  the
    original message in order to facilitate understanding by users who did
    not read it,  and avoid  systematically  reposting the entire original
    text.

  6 Do not engage in  "opinion wars" on the network through the sending of
    messages and  replies:  if you have  personal discussions,  solve them
    via private electronic mail correspondence with the interested parties.

  7 Never  publish the  content of  electronic mail  messages  without the 
    explicit permission of the author.

  8 Do  not  post stupid  messages or take  sides  to  support  somebody's
    opinion  within  an  ongoing discussion.  Always  read the  Frequently
    Asked Questions (FAQ) relating  to the discussion topic before sending
    new questions.

  9 Never send advertising  or commercial  promotion messages or any other
    unsolicited message  via electronic mail,  unless explicitly requested
    by the recipient.

 10 Be tolerant with users  who makes  syntactical or  grammar errors when
    posting  messages.  Users  posting  messages must in any case  improve
    their  knowledge of  the  language,  in order to  be understood by the
    whole community.

  Furthermore, to the previously mentioned rules we must add the following
  criteria based on common sense logic:

  A The network is used as a  major work tool by many users.  They do not
    have time  to read jokes,  useless or personal messages which are not
    of general interest.

  B Any activity which heavily affects network traffic, such as bulk data
    transfers, reduces the overall network performance. Users should thus
    perform  these  operations outside  peak  network time  (at night for
    example), taking into account the different time zones.

  C On  the  network a  number  of file server  sites exists,  containing
    up-to-date  copies  of relevant  documentation,  software  and  other
    objects made  available via network. Users must  ask in advance which
    is the most convenient  accessible server  node for  their use.  If a
    file is made available on this server, or locally, there is no reason
    to load  it  again via  the network,  wasting network  bandwidth  and
    waiting much longer for the file transfer to be effected.

  D The software made available on  network servers can  be protected  by
    copyrights  and/or  other  restrictions on its use. Users must always
    read carefully any accompanying documentation before using, modifying
    or redistributing this software in any shape or form.

  E Incorrect behaviour of an explicit illegal nature by users, such as:

    - violating the security of network databases and hosts;

    - violating  other  users'  privacy,  reading  or intercepting  their
      electronic mail messages;

    - compromising  the  correct  performance of  the network and of  any 
      equipment  which  constitutes its  service  with programmes (virus,
      trojan horses, etc.) and other hacking tools;

    are  explicit  criminal  violations and,  as such,  are punishable by
    current laws.

  For  more detailed  information on the principles stated above,  please 
  refer  to the document   RFC1855  "Netiquette  Guidelines",   available 
  on-line at the following URL:

            http://www.nis.garr.it/netdoc/rfc/rfc1855.txt



CC:        NTIADC40.SMTP40("ALLOCCHIO@elettra.trieste.it")
###
Number: 25
From:      Martin Volesky M.Volesky@IEMINC.NET>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 9:31am
Subject:   Domain Names

Hello.

     I have read thr story reported by the MSNBC Internet News Service
regarding the RFC regarding domain names. One issue that I feel is quite
inportant when setting up new top-level domain names is the length of these
names. Working as a systems administrator of ran interactive internet media
company IO have written many scripts and utilities that have been built on
the concept that all top-level domain named have three characters. I do not
think that it would be to dificult to maintain this standard with any new
top level domains. I belive this issue has not been sufficiently addresses.

Thank you for your time.

Martin Volesky.

###
Number: 26
From:      Bruce Paul birdcat@admin.con2.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 9:50am
Subject:   In my humble opinion

I know that one voice does not count for much but since you asked...

I think the entire naming and numbering scheme of the internet should be
handled by a world wide organization - a for profit organization - that
should have accountability to the United Nations (they've got to be good
for something).  By making this new company a for profit organization,
they can fund themselves and by making it accountable to the UN, they
would be regulated on their prices (like the old AT&T before Judge
Green).  Since Network Solutions is already in this business, why not
let them continue but under the auspices of the world community's chosen
representatives?

Like I said, you asked.

Bruce Paul
birdcat@con2.com
webmaster@birdcat.com
bruce.paul@bowne.com


CC:        NTIADC40.SMTP40("webmaster@birdcat.com")

###
Number: 27
From:      Tom and Judy Devaney <1345deva@inet.westshore.cc.mi.us>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 2:22pm
Subject:   Domain Names

Hello....


I want to comment on the "Domain Name" issue:


I want to be starting a business out of my home within the next year or
so.  My wife is going to school so putting all of my effort towards it is
impossible at present.


My biggest fear is that big business and the people who are able to able
to do something NOW will have a better chance of getting a domain name
than I will one or two years from now.  Or, that the price
will be out of reach for anyone with a low income.  Or, I
don't know the RIGHT people.   


I want EVERYONE to be able to have an equal chance to get a domain
name for ALL time to come.



Please consider this when you make your decision as it will affect my
children as well.


Thank You...


Tom Devaney

1345deva@inet.westshore.cc.mi.us

###
Number: 28
From:      "Fontenla" 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 9:53pm
Subject:   Domain names, comment

To whom it may concern,

I think it was a very bad policy to give up full control of domain names to
a private company. Ethics considerations that say that the government
investment should not be given up unconditionally to any for profit
company. Much less with such long term contract and without direct
government supervision. The Internet was funded by our tax money, as a
technological and educational enterprise, and nobody likes giving it as a
gift to any company.

Moreover, this company now is blocking and difficulting the normal
functioning of the Internet, and should be stopped now. The administration
of the Internet should be closely supervised by the govrnment, and any
resolution should be contingent of NSF not opposing it. Besides,
international agreements should be put forward, and enforced by some
government institution.

Dr. Juan Fontenla

###
Number: 29
From:      
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 7:19pm
Subject:   Domain Names Comments


I do have a few comments on the Domain Name issue...The Idea that a solo
company should be allowed to monopolize on internet domain names is
ridiculous....one of the greatest things holding up the Internet today is
the organization of domain names.  Domain Names need to be geographic...if
I want to visit the web site of John K Paul in Burlington Vermont, I should
be able to visit him at www.johnkpaul.burlington.vermont.  Private
companies could compete for the business of registering the millions (or
billions) of domain names that would become availible (creating more
competition and driving the price down) and an advertising funded yellow
pages would make it easy for me to determine WHICH John Paul in Burlington
Vermont I was talking to....


Jason M Page
jpage@lucent.com

###
Number: 30
From:      "Bob Jordan" 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 6:22pm
Subject:   Domain names

I think the government should step in and legislate that the polices in
place for the existing domains shall remain unaltered and that companies
have no claims to copyrighted domain names in those existing domains. In my
opinion, it is unfair to establish new standards and rules and make them
retro-active.

In addition, the government should legislate the establishment of new
domains, such as .firm or .inc (whatever) that do provide for copyright
protection.

###
Number: 31
From:      White 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 4:58pm
Subject:   XXX domain


the NTIA's first step - just from a public affairs/pragmatic angle - should
be to create

".XXX"

as top level domain for all US adult sites.  this solution would instantly,
easily, and with few complications clear up the snafus attendent to the
just-killed CDA and the greater issues that surrounded it.  Better still,
it would be a solution internal to the Internet community, rather than some
sort of content regulation.
     The only step left would be to distribute client-side web software
that would not load .xxx domains.

     A mandatory ".XXX" domain would immediatly create a well-cordoned
Internet red light district - a solution that American courts and
communities have long held to be a viable one in the real world.

DRAWBACKS.
     1. A private citizen not in the business of selling adult content
could post adult content to a private site.
     Solution:  There is none.  The first amendment protects such
things.  However, a volunatry internet standard could be pushed by ISPs
(which are "bandwidth providers" of the vast number of personal webpages)
that anyone posting adult stuff should put it within an "xxx" directory on
their private site.  Not everybody would do it, but enough would that,
combined with the .xxx solution, internet adult content would be tough to
come by "by accident."

     2.  Foriegn sites.
     Solution:  With the US's massive percentage of the world's internet
sites, it is reasonable to expect many foriegn based adult sites to come
onboard such a plan, adopting a "xxx" based domain name.
     Those that don't - well, NO American-based solution will change
their minds anyway.

matt white

###
Number: 32  
From:      "Wm. MacDonald" 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 4:17pm
Subject:   Domain Names

Domanin names should continue to be reasonable and free from having
commercial intrests run them.

W. MacDonald

###
Number: 33
From:      "John Alexander" 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/3/97 12:59pm
Subject:   Comments on DNS proposal

Hi:

I believe that the current handling of the InterNIC is sub-standard, and
anything that is done should at least fix current problems, without
creating additional ones.

Network Solutions is incapable of handling the volume they currently
handle, so they do not get involved in any issues.  For example, there is a
domain, "congress.org", that has nothing to do with Congress, and is not a
non-profit organization.  There are also several ".net" domains which have
nothing to do with being Internet Service Providers.

When I brought this to the attention of the InterNIC, they sent back a form
letter asking why I thought that I had the rights to these domain names.  I
don't.  I just don't want to see other companies abusing the current
Internet domain naming system.

If you allow additional companies to create root-level domain names, here
are the things I think are important:

     * Competition will hopefully increase quality while keeping costs in
check.
     * The various root-level domain name providers MUST reference one another,
or each company connected to the Internet will be required to manually
modify their DNS machines to reflect the new root servers.  This would be
impossible for many Internet users.
     * A cross-domain board should be established to regulate names.  The rules
need to be enforced by an independent organization, rather than a company
who has a vested interest in selling domain names for money.

You may wish to work with the various tier-1 Internet Service Providers,
including UUNET, MCI, Sprint, PSINet, Digex, ANS, AGIS, etc.  They may be
able to offer a solution which involve using the ISPs as the root-level
DNS, then having the management of the domains handled by separate
companies.

My 2 cents, for what it's worth (if it's even worth 2 cents ).

/John Alexander
 Consulting Engineer
 IKON Technology Services

###
Number: 34
From:      Chris Ehrhardt 
To:        NTIADC40.NTIAHQ40(dns)
Date:      2/20/96 6:30pm
Subject:   input on domain names...

the system we are using now work. there is no reason to change it. its
bad enough when i get pissed off when i can't find an address because
its .net and i am trying .com ... if its working, why try and change it?

chrisehrhardt
hard2overcome


###
Number: 35
From:      <FoxxMulder@aol.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 5:04pm
Subject:   Domain Name Discussion

It is my opinion that any future domain name registration and database
service should be a non-profit corporation with it's controlling board made
up by appointees of the backbone owners and any online service, ISP, or
internet software developer over a pre-determined size.  There should also be
several seats representing the universities, secondary schools and general
internet using public.  Giving control of such a lucrative business to a
for-profit company will make the system even more political and the end-user
will not be served.

The NSF should take the ball on this to make sure the organization is above
board and fair to everyone involved.  

Jerry Jones
263 Dempsey Way
Orlando, Florida 32835

###
Number: 36
From:      J Richard Daub <oldfolks@mail.oldfolks.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 3:06pm
Subject:   Domain names

>Date: Fri, 04 Jul 1997 10:19:04 -0500
>From: Enter Your Name Here user@nantucket.net>
>MIME-Version: 1.0
>To: dns@ntia.doc.gov
>CC: jrdaub@oldfolks.com
>Subject: Domain names
>X-URL: http://www.ntia.doc.gov/ntiahome/domainname/dn5add.htm
>
>Briefly,
>                      Any change, alteration or abandonment of  a security
>of domain
>names  such as InterNic will render ALL domain names USELESS.
>        Registered domain names are as the trademark or copyright of the
>holder of that particular domain name.
>
>
>J Richard Daub
>
>
>jrdaub@oldfolks.com
>

###
Number: 37
From:      Thomas Cameron <tcameron@three-sixteen.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 2:08pm
Subject:   DNS Naming after InterNIC 

Why not have a random slection between say, the 10 best suited ISP's (in
technical capabilities) of registration duties?  

For instance, every year or two years, an independant council made up of
industry professionals (from perhaps IEEE and maybe educational
facilities, consumer groups, etc.) would evaluate the ISP's that were
interested in the domain registration business.  They would come up with
a list of the top 10 or 20.  Those would go into a lottery style
drawing.

That way, there is no way to cry "favoritism."  No one company gets all
the profits from registration fees.  It would involve changing the
top-level DNS servers once every one or two years, but that is a
relatively straight-forward task.

Just a thought.

Thomas Cameron, CNE, MCP
Three-Sixteen Technical Services, Inc.

512-891-9202

###
Number: 38
From:      Theuer, Scott <scotttheuer@pathway.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 11:40am
Subject:   Domain name system

Please consider these comments when deciding the future of the domain name
system:

1) Regardless of the system in place, it is imperative that hoarding and
hawking domain names  be made illegal. Names already hoarded should be
released at cost back to whatever authority ends up with responsibility for
domain issuance.

2) No additions should be made to the current number of top level domains.
The confusion that will result from multiple companies with the same name
(i.e.: acme.com, acme.web, acme.bus, etc) will effectively render domains
unusable when a user is attempting to find a company online

Thanks you,

Scott Theuer

###
Number: 39
From:      Enter Your Name Here <user@nantucket.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 11:19am
Subject:   Domain names

Briefly,
                Any change, alteration or abandonment of  a security of domain 
names  such as InterNic will render ALL domain names USELESS.
          Registered domain names are as the trademark or copyright of the 
holder of that particular domain name.

JRichard Daub
jrdaub@oldfolks.com


CC:        NTIADC40.SMTP40("jrdaub@oldfolks.com")

###
Number: 40
From:      "Starr L. Pierce" <starr77@primenet.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 11:05am
Subject:   Electronic Filing of Comments on Internet Domain Names

Appropriate Principles, a: I agree.  b: I disagree.  c: Absolutely.  d:
Yes.  e: It should be what it is.  We should not try and control it.
The internet will evolve on it's own. f: A framework 'will' develop on
it's own.

General/Organizational Framework Issues, Point #5: No, I do not think
that .com should be retired.  As for the rest, a little to technical for
me.

Creation of New gTLDs, No comment.

Policies for Registries, #15: Absolutely, a gTLD registrar have
exclusive control over a particular gTLD.

Trademark Issues, Ok, your not going to like this, but trademark names
have no place on the internet.  most ppl will not violate trademark
names.  only a select few.  those that do are usually out for a buck.
that's life.  there can be NO control over trademarks on the internet.
let it be self governing.  thank you.

I know that  I didn't fully answer all of your questions, but I hope
that this reply will assist in some way.  Many of the topics are to
technical for me.  I am just a average 'puter user that's been ion the
internet for a few yr..  I don't have a technical or computer
background.  I hope this helps.

Sincerely,

Starr L. Pierce

###
Number: 41
From:      Jack Scheinuk <scheinuk@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 10:41am
Subject:   Comments re E28

-- 
Jack Scheinuk, P.E.
7927 Maple St., New Orleans LA 70118
Tel: 504-866-1221  -  Fax: 504-866-1258


CC:        NTIADC40.SMTP40("tmc@ix.netcom.com")

Owners of existing second-level names may have substantial investment in
such names. 

Therefore, I recommend that there be a provision for name reservation or
"pre-registration", prior to the time new gTLDs are functional, to allow
second-level name owners the opportunity to register their existing
second-level names under new gTLDs. 

For example, there could be a window of time of 120 days from the time
each new gTLD become functional to allow present name owners to register
existing second-level names under such new gTLD. 

As second-level owners can be considered to have knowledge about this
subject generally, I also propose that it be the responsibility of the
existing name owners to be aware of the time of availability of each new
gTLD and, if desired, to register within the reserved period. 

###
Number:42
From:      Jill Ferguson <jillferg@home.cynet.net>
To:        "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date:      7/4/97 10:08am
Subject:   domain names

There is definitely a need for more domain suffixes, as that would better
help to describe the category of the domain.  As far as the domain names
themselves, it should be done the same way that a business name is chosen. 
You submit the name, and if nobody else is using it, then it's yours.  An
organization would be necessary to govern that aspect, but any type of
government control or monopoly type control beyond that would be
ludicrous.  The internet belongs to the people of the world.  It's
probably the only thing left that does!  I believe that's why the
government fears it. 


------------------------------------------------
Visit my website, "Crazylady's Lair", at http://www.cynet.net/crazylady/ 
and sign my guestbook!

###
Number:43
From:      Elizabeth Agawa <miko@wenet.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 10:00am
Subject:   future of domain names

A suggestion regarding structure of domain names is to get rid of
personal home pages ending with ".com." Most are literally personal,
mostly nonsensical and with no redeeming value to the general 'net
community. Take all of these and rename them something like .duh or .per

I have been on line for about 2 years now. I am the webmaster for my
company's web site (http://www.infointf.com) and I use the Internet
daily for information that helps run our business. Using the Internet as
a business tool I book travel, look up reference info, do research, buy
product and use e-mail.

Perhaps if some of the junk on the 'Net was cleaned up and put in its
own area it would become less congested and easier to access.

Best,

Elizabeth Agawa

###
Number:44
From:      Gerry Owen <gowen@sundial.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 5:51am
Subject:   Domain Names

Keep all facets of government completely OUT of trying to "help"
internet.  If government has a burning need to help any worse than they
are now, they could explore moving to Russia and leaving us alone..

Sign me Sick of government meddling

###
Number:45
From:      "John Driscoll" <jfd@prime-x.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 3:07am
Subject:   Internet Domain Registration

Dear NTIA;

As the owner of a small Internet Service Provider business in Wakefield,
MA, I'd like to express my opinion on the future of domain name
registrations in th U.S.A.

I am strongly against giving control of this vital interest to an
unelected, non-representative organization from another country. While I
agree that the domain name system needs some improvement, I believe it is
better addressed by American interests, at least as far as American
businesses are concerned.

My two cents...

John Driscoll
President
Prime Connections, Inc.
www.prime-x.net

###
Number:46
From:      "Tim S." <tims@oneimage.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 2:45am
Subject:   Request for comment on admin of domain name regist

Comments for:
Request for comments on administration of the Domian Name Services

It is my opinion that the U.S. government should completely and
permanently withdraw any participation or influence over any and all
aspects of the Internet. 

The administration of the Internet should be solely managed by the private
sector. 


Tim Soos
tims@oneimage.com

###
Number:  47
From:      "T.J. Smith" <twolf@cp.duluth.mn.us>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/4/97 12:17am
Subject:   Comments

I think that the only people that should have to pay for domain names
should be the businesses or people trying to sell stuff. I am trying to
start a non-profit org on the net, but we can't get a domain name because
WE DON"T HAVE ENOUGH MONEY FOR THAT. I REALLY think .org domain names
should be free. Non-profit orgs offer stuff for free, why can't we get some
stuff to help better serve the people for free?
                                                     ______
                     n,                             (  /   )         ___
                 _ /  |_                              /        _  |  |_
                / '  `'/         T.J. Smith          / \_/\_/ (_) |_ |
              <~     .'      3123 Restormel St.      
              .'      |     Duluth, MN 55806 USA
             _/       i        (218) 628-3517
           _/         :
 _____/___/     /__\  \ \       \        http://computerpro.com/~twolf/
/    (__.'\________)\__i_i         \         http://www.ABCtec.com/~HV/




###
Number:  48
From:      "Steve & Kelly Longsworth" longswos@mashell.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 11:03pm
Subject:   Control of DNS

As an Active duty Army SYSADMIN with my own Domain Controller I have no
problems what-so-ever with the current Naming Conventions. They allow for
standardized naming conventions and are easily understandable. The .mil /
.gov / .com / .edu /........ is an intuitive convention, However if the
.com crowd want to fight over who gets the "really HOT" names let them and
let them control (i.e. sell or lease) them  with a percentage of the
proceeds being returned to those who built the original backbone of the
entire system. A mandated pricing schedule would prevent gouging and or
exorbitant prices (i.e. first come first served for $X.xx per name)

           /S/
Steven W. Longsworth
SFC, USA
Systems Administrator
504th Military Police Bn.

###
Number:49
From:      "TERRENCE FITZPATRICK" TLFP@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 10:17pm
Subject:   Internet domain names

Please people, listen carefully.
Neither the Internet nor the World Wide Web is broken so please DON'T TRY TO 
FIX IT. Stay on it, if you like, but stay out of it. It's not yours to mess 
with. It belongs to the people of the world.

     Terrence FitzPatrick
     TLFP@msn.com

###
Number:50
From:      "Alex M. Hochberger" ahochber@iname.com>
To:        "'dns@ntia.doc.gov'" 
Date:      7/5/97 2:30pm
Subject:   Domain Names

Allow competition for the top level domains.  Require the root registers
to point to one another, and allow multiple organizations to support TLDs. 
There may be a way to only allow one company to use one TLD (for technical
reasons), but even that could be avoided.  Lets bring the costs down and
increase competition to allow more TLDs and easier names to remember. 

Alex Hochberger
Citrix Systems, Inc.
Pine Crest School '97
M.I.T. '01

###
Number:51
From:      "Andrew B. Cencini" andrew@cencini.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 1:24pm
Subject:   Request for Comments

Hello,

I am responding regarding the recent request for comments regarding domain
name administration.  In my humble opinion, I feel that the methods,
standards and practices of assigning TLD's, as well as the overall
administration of domain names, is far behind the current paradigm of
technology on the Internet.  

I will focus my opinions solely on the current administration of domain
names in the United States - more specifically, the ".com, .net, .org,
.edu, and .us" domains.  Also, my comments will reflect my feelings towards
how the registries have handled the management of public domain records.

First, I feel most strongly about how poor a job that NSI (The InterNIC)
has done in their administration of domains, as well as how arcane the
standards and policies are that they use as "guidelines."  

The InterNIC, being a private commercial organization, under government
contract, has a threefold obligation.  First and foremost, they have a
commitment to their customers, without whom they would be nonexistant.
Secondly, they have a commitment to helping manage the Internet in a way
which would most benefit the organizations and users of it.  Lastly, they
have a responsibility to satisfactorily complete the above requirements, as
well as meet the conditions put forth by the NSF in their cooperative
agreement.  Note, that clearly there is no single body of interest that
must be satisfied here, but rather a commitment to many groups of people.

CLearly, in my many experiences with the InterNIC, I have found my dealings
to be frustrating, maddening, and, quite frankly, to be excessively slow.
One could compare the service of the InterNIC to the judicial system - it's
slow and it rarely works.  If the InterNIC was in the business of
registering domains for free, then one could not complain.  As was said in
Shakespeare's great play, Hamlet, "Ay, therein lies the rub."  

The InterNIC charges a fairly outrageous fee of $100US per domain for 2
years of "service."  As a consumer, and as a member of the Internet
community, I feel more than justified in receiving service, promptly and
courteously, in return for my compensation of $100.  

I have received no such "service" or courteous treatment in my experience
with InterNIC.  

The solution?  Well, that is difficult to determine.  Clearly, the InterNIC
should be used as an example of what "not to do" when managing a domain
registry.  Their database services, customer services, and
assignment/dispute services are not really services, but more a haphazard
"system" by which more energy is spent "maintaining" the system, than
actually serving customers.  A new domain registry would have the following
properties, and their contract should require, amongst many other things,
that these stipulations are met:

1)  A clear, current policy for the assignment of domains is established,
in plain English, and an appeal policy that is swift yet thorough is in
place for the rare case in which two parties wish for the same domain.

2)  A fee structure consistent with the level of service is in place.

3)  An online registration system that is user-friendly, simple to use, and
much more thorough "where it counts" so far as validation is concerned
regarding the usage requirements of the domain.

4)  Said registration system is available on a high-speed connection to the
Internet, and is publicly accessible through many means 24x7.  The site,
even during peak hours should not be excessively slow or down.

5)  The database administration and design should be done logically and
thoughtfully, keeping in mind the considerations of the customer while
allowing easy administration.  

6)  Simple and intuitive tools through which the database may be searched
by many criteria while maintaining the highest of confidenatiality

7)  Courteous and prmpt service by phone, email or other means of
communication

8)  A wide variety of easy, common payment options, including check, credit
card and digital cash ONLINE.


One of the above stipluations raises one other issue regarding the
InterNIC's operation which I must personally comment on.  The current
system of assigning universities only to the "edu" domain is stupid and
inconsiderate.  Also, the policy of allowing "free" domains in the edu TLD
is quite silly.  Recently, I applied for an "edu" domain for a high school
with which I now am doing some Internet work.  All of the schools in the
area of equal merit have an "edu" domain, and we assumed we would be given
the same.  To make an extremely long and angering story short, after 6
months of form-letters and, quite frankly, rude and demeaning
correspondence from various InterNIC representatives, we appealed to the
IANA, who rendered a decision in virtually 48 hours following our final
submission to them.  

In the end, the IANA, whom I feel have done an excellent job managing and
overseeing many aspects of the Internet, overturned one of their own RFC's
in favor of our case.  That RFC, which was written 3 years ago, is what the
InterNIC uses as a "guideline" as ***** (name witheld) from the InterNIC
repeatedly told us as we were repeatedly turned away, despite the large
case in which such a "guideline" must be reconsidered.  

By not allowing schools in general to be registered in the edu domain
(currently, less than 5000 are in the edu domain, last time I checked), it
somehow reduces the integrity of the institution by considering it as an
"organization."  It would be much like requiring an ISP to register in the
"com" domain since they also sell T-shirts touting their services.

Given that also all of the adjacent "org, com and net" domains were taken
by "domain pirates" selling those domains, we had no other domains.  It
seemed that the InterNIC did no such research to verify that information,
but rather suggested an alternate "org" domain name which also was in use
(and was quite ugly, to boot).  In short, that policy should be seriously
re-evaluated given the current trend of Internet affairs.

All in all, had I a choice of domain registries, I would never have dealt
with the InterNIC.  Enough said.  Be my comments registered above.  One
final parting comment would be about the management of the US domain.

While the management of the US domain is a bit arcane, and could use a
touch-up so far as policy administration goes, I found the people I worked
with to be some of the nicest most generous, conscientious people who were
 knowledgeable about their work, and made every possible effort to
assist in my requests.  I found I even learned from some of my
correspondences!  I feel that the registrars of the US domain, (doing the
job for FREE, nonetheless) are doing a superb job, and deserve more funding
and a policy upgrade.

I apoligize for the long-winded and rambling note, but thank you for
registering my comments.

Cheers,

Andrew Cencini
Cencini Computer Services
andrew@cencini.com

###
Number:52
From:      Frank fb@badamitv.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 12:38pm
Subject:   Domain Names.

Open bidding in each state of the U.S. and have multi companies involved
in the Domain process.  The cost of a Domain Name should not be more
than $10. per person or business.

###
Number: 53
From:      "David E. Johnson" djohnson@goldrush.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 11:43am
Subject:   comment on upcoming internet changes

  The internet began with scientists and government entities and
consequently is incredibly secular.  It now seems to be fueled by business
interests.  It would be refreshing if the powers that be could create a
domain name or category that is exclusively for the religious community.

                                                David E. Johnson

###
Number: 54
From:      "David_H" david_h@webworldinc.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 11:06am
Subject:   Domain Names

Yes   you should add more names. 
And add  something like   .PER   for personal  names (private individuals)
And  all  Domain names  should  be """"FREE""""" -  or at most  a one time
processing fee of 'not' more that $10.00. - Somebody is making millions off
of us, and is not really
fair, partly because there is no compition.
Any name that is a registered trademark with the US or other country's
trademark
office  should automatically have the right to that name. (maybe with the
extention,
'.REG' , for registered.

Thank you

###
Number: 55
From:      mark2 mark2@yourgallery.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 11:02am
Subject:   domain names

Stay out of it. The Government has NO place being involved in this and
many more issues.

     STAY OUT. STAY IN BUGET. LEAVE AMERICA ALONE, WE ARE FINE
WITHOUT YOU.

     MARK GIERT
     407 ABNER CRUZE RD
     KNOXVILLE TN
     37920

###
Number: 56
From:      Mark Lautenschlager MarkL@pobox.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 8:54am
Subject:   Domain name issue

Gentlemen,

My input on this matter is simple. I am a consumer of Internet services,
not a supplier. I am only interested in one matter--how easy is it to find
the site you're looking for on the Net?

Right now, if I am looking for a company's web site, it's a safe bet that
"www.company name goes here.com" will yield positive results. When these
new top-level domain names are introduced, will I have to try .web and
.info, also?

If you make the Internet more difficult to navigate, you will stifle its
growth. Adding more top-level domains is fine, but you MUST PROVIDE SOME
EASY WAY FOR USERS OF THE INTERNET TO FIND THE SITE THEY ARE SEEKING.

If such a mechanism cannot be devised, then leave the present system alone.
Thank you.

###
Number: 57
From:      Matt mattgr@geocities.com>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/5/97 4:38am
Subject:   Internet Domain Name Comments

To Whom it May Concern:

I am a 27 year old Software Test Lead at Microsoft in Redmond, Washington. 
I first started messing with the net on a Linux box 4 years ago.

Here are my recommendations:
Don't be US centric. Make all URLs have a country specifier. Let companies 
choose their designator. Maybe Australia wants to be OZ and not AU
http://company.com.us
ftp://company.com.oz
URLs should not contain protocol specfic information. Take out the www/ftp 
etc. Let the server look at the protocol and redirect as necessary.
http://www.company.com.us really says it twice doesn't it?
Figure out more nets. net, com, edu, mil, why not lib (for library), lab 
(for research lab). Com really needs to be broken out.
GET ISPs OUT OF COM and put them into NET. COM is for COMpanies. NET is for 
companies that provide NET access.

If you need any major problems solved, just let me know. I have a pretty 
darn good sense of the right way to do things ;)

-Matt
http://www.geocities.com/SiliconValley/Pines/5444/

###
Number: 58
From:      Ian Ellis ian@iglou.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 3:39am
Subject:   Domain name registration cost.

$50 per year seems exorbitant - especially for a monopoly. Who chose
that amount?

Although $50 may be a sneeze in a bucket to McDonalds, small companies
and groups are hit much harder.

###
Number: 59
From:      "Michael McLeod" alie4251@email.msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 1:18am
Subject:   domain names

the federal government should help set laws regarding the internet however
with reguard to who handles a cental regestry of names 
i would like to see a commission funded strictly from registrations 
made up of members of various countries kind of like the UN but for the
internet
domain names  would be purchased and renewed thru this agency and laws and 
regulations and other areas of interest to the web would be placed as there
role also
though there recomendations would not be law the should be able to provide
Congress
and other fed agencies with recomendations that might become law and in
that process
also request responses at a central regestry where by votes could be
tallied from the
internet public as to yea/nay votes on any recommendations they will pass
along to congress via the agency their by allowing a public vote and only
one vote per regestered domain name.  as well as a general vote at large to
get a response from the internet communit(users) 

###
Number: 60
From:      Joyce jbulwinkle@geocities.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/5/97 12:18am
Subject:   Domain Names and IP's

I was reading someone's entry that said to make all XXX pages with the
extension .xxx That is a great idea, and could be less cumbersome to
make Programs to cut out the site, by simply telling it to block all
sites marked .xxx It would also be easier to have more Internet
Protocols other than zzz.zzz.zzz.zzz where zzz is a number in the range
of 0 to 255. As we know, A lot of people (mostly ISP's) purchase a Full
C. So they have say 199.73.4.zzz. They take up 256 of the IP's and
probably do not even use them all. There has to be an easier way of
managing IP's. Possibly to increase zzz from 255 to 999? If that is in
any way possible than it would be helpful.



###

Number: 61
From:      wallace koehler wkoehle@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 6:08am
Subject:   Request for TLD Comments

Attached in Word 6 are comments on your request for gTLD comments

I appreciate the opportunity

wallace koehler (willing@usit.net)

--

Response to Department of Commerce Request for Comments on Internet Domain Names

Wallace Koehler (willing@usit.net)

A. Responses to General/Organization Framework Issues:

A. Comment: There has been much interest expressed about and interest in modifications to the domain naming structure, particularly to the gTLD .com domain. This concern resulted in a set of recommendations by the International Ad Hoc Committee (IAHC) of the Internet Society (ISOC) as well as a continuing commentary and criticism of the process and its recommendations. For example, the IAHC maintained a listserv (archived at the ISOC site (www.isoc.org)) and the issue was the subject of some debate at the INET'97 Meeting (ISOC Annual Meeting) in Kuala Lumpur in June 1997.

A.1. Argument Foci. The argument as presently constituted revolves around two related issues: (1) domain naming space has become congested, and (2) domain names may represent a threat to the trademarks of established corporations. Arguments and proposed solutions include recognition that the current gTLD structure is inadequate to manage the naming requirements of commercial entities worldwide and that trademark issues are important. The IAHC solution, meritorious as it is, fails in one key aspect. It seeks to impose a solution maintained and administered by what is essentially a technical non-governmental organization on a regime that is inherently legal, political, and economic in nature. NGOs, particularly technical NGOs lack the expertise, authority, experience, and jurisdiction to regulate in that environment. The IAHC also was very limited in its scope and membership, and did not address (nor did it seek to address) wider domain naming issues beyond expansion of the com domain, trademarks, and related matters.

In addition to the IAHC recommendations, others have suggested (1) creation of a flat TLD structure, allowing registrants to choose individual TLDs without regard to "controlled vocabulary" or "indexing"; (2) elimination of the TLD topography by either eliminating alphanumerics and reverting to IP numbers only or by generating random TLDs; and (3) migration from the functional TLDs (gTLDs -- com, net, org -- and the edu, gov, mil TLDs) to an exclusive adoption of the geographic (ISO 3166) two-letter codes now employed largely but not exclusively (.us) outside the United States.

Option 2 would eliminate trademark issues but would prove unwieldy and unpopular. Neither option 1 nor option 3 would address trademark questions.

A. 2. Other Stakeholders. This debate tends now to be dominated by three groups: Commercial interests seeking to protect oftentimes legitimate and sometimes questionable trademark rights, the technical Internet community, and the root domain registrars -- both the established and the hopeful. There are other constituencies and stakeholders with significant interests in the outcome of the TLD naming debate. These include governments (that the Department of Commerce has requested comments on this issue speaks for itself), the information science and library community, and the non-commercial and quasi-commercial domain and virtual domain name owners, as well as others.

Unfortunately, these other stakeholders have tended to be ignored. I am one of those other "stakeholders" in that I find that the TLD and second-level domain (2LD) tags of URLs can be used as an important non-keyword Internet search methodology. In that light, neither the geographic TLDs as well as both the functional TLD status quo as well as the IAHC proposal do not threaten the methodology. Flat TLDs would destroy the utility of the method while IP numbers would render it perhaps hopelessly complex.

It is undesirable to destroy any search methodology that helps organize and regularize the Internet. Searching on "URL fragments" is one such approach, and is supported by several major search engines. If anything, "controlled vocabularies" and "indexing" (both timetested and honored vehicles for information management and retrieval) should be expanded in the Internet context. It could be expanded by more universal use of standardized 2LD and 3LD tags now employed by some but by no means all geographic TLDs. Examples include gob.mx (government servers in Mexico), co.jp (commercial servers in Japan) and ac.uk (academic servers in the United Kingdom). Other variants include [state postal code].us, fi.cr (financial entities in Costa Rica), and tm.fr (trademarks in France). A somewhat universal application of standard 2LD tags together with existing TLD tags could improve "quasi-set" creation and, as a result, search precision.

A.3. Responses to: Issues 1, 2, 3, 5, 8, 9, 10, 11, 13, 14, and F "Trademark Issues"

1. Advantages/Disadvantages of Status Quo. The status quo does not address trademark issues, it cannot regulate either trademark rights nor the distribution of domain names in general, and the size of the com TLD is unwieldy. On the other hand, the functional and geographic naming system provide some classification and categorization structure.

2. Improvements. Expand as necessary TLD tags, but restrict that expansion to manageable limits. Expand the use of 2LD and perhaps 3LD standard naming conventions. Consider the use of .tm (trademark) to indicate a "protected" domain -- <corporate_icon>.tm.TLD would be restricted and protected. Non-.tm 2LD might not carry the same level of trademark protection.

3. Administration of domain name systems. Technical NGOs are inadequate to the task. Perhaps the system could be managed by an arm of the ITU, advised by a board consisting of the interested stakeholders and constituencies. That board could be nominated by important NGOs, other IGOs, commercial entities and trade associations, governments, universities, governments, the intellectual property bar, etc.

5. Retire gTLDs. I see no compelling reason to do so. Some see gTLDs as indicating implicitly an American registry, others have accepted it as more universal. The geographic TLDs are sometimes interpreted, particularly in commercial circles, as more parochial or regional in character. As a consequence, non-US commercial entities sometimes adopt functional rather than geographic registrars. That may lead to minor confusion. However, many corporations have a global character and the functional TLDs may reflect that.

8. Transition to New System. Slowly, if at all.

9. Other issues. Use of 2LD and 3LD standard tags.

10. Technical, practical, policy restraints on new gTLDs. From a practical/policy perspective, gTLD proliferation can lead to confusion and perhaps a breakdown in its usefulness as an information organizing medium.

11. Create new gTLDs? Yes, or move to a 2LD system. But limit the number of gTLDs.

13. Separability of gTLD from ISO 3166 TLDs. Certainly there are jurisdictional and syntax differences between geographic and functional TLDs. gTLDs, other functional TLDs, and geographic TLDs are administered by different root registrars. That is manageable. However, all registrars need, no, must follow protocols and standards which facilitate Internet communication.

14. Other issues. Please consider the adoption of 2LD and 3LD standards as well as a reasonably rational approach to the allocation of TLDs by group and classification.

F, Trademarks. The trademark issue will dominate the TLD debate since interests are so vested and extensive. All sides in the debate make valid points. While trademark law is extensively developed, its application tends to be more national than international in scope. There does not yet exist an adequate body of international jurisprudence to mitigate the challenges resulting from the Internet, a largely unregulated and truly international medium. Reliance on national regimes will likely prove inadequate. Moreover, efforts by technical NGOs to regulate this issue will not only fail, but will probably significantly reduce the perceived competence of such NGOs in their established areas of expertise and proficiency.

B. Background

I am a student in the MSLS program at the University of Tennessee writing a thesis on the longevity and constancy of Web pages and Web sites. I hold a PhD in government from Cornell (1977). I am author/co-author of a number of papers on Internet searching, cataloging, and related issues. Most recently I presented at the Internet Society Meeting (June 1997) on search methodologies. I have also been employed by an information broker/consultant as a senior researcher to a US government agency to develop methodologies for WWW cataloging (for a list, my c.v. can be found at http://www.public.usit.net/willing)


###
Number: 62
From:      Surffing The Net rev@starnetinc.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 11:44pm
Subject:   Domain names

Yes you should control names, but for adult or porn sites it should NOT
HAVE A: .com, .gov, .org or any ext. like what we use. Its early in the
game of the internet and NOW YOU can do something. Make a new ext. for
all the "Adult" sites so our filters can avoid them. Our teens using
computers at schools and other public places can't get "adult" sites.
Don't take away freedom of the net. We can't look over what our teens
are seeing on the net, but we can do something about access to the
sites. Filters work but what if some teens want to learn about safe sex.
The filters we now have will not let the word "sex" go. 
Here, I have a new ext. for all the "adult" sites: .adt or .21
Please look into this.


Thanks for reading this. :)
  Ron Vikara        rev@starnetinc.com
  Villa Park Il.

###
Number: 63
From:      "David A. Matson" dmatson@bigfoot.com>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/6/97 8:08pm
Subject:   domain names

The best thing to do about domain names is just let go of them.  Let
competing technologies try to figure out what should be done and create a
De Facto standard.  Why? 

1. It won't cost the government any money.
2. It has worked for everything else on the Internet.
3. The best, or one of the best technologies will become the standard.
4. When privatized, almost everything becomes better.

I hope this helps.

David Matson
Dmatson@bigfoot.com


###
Number: 64
From:      Paul Nixon colt45@netvalue.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 4:30pm
Subject:   Re: Commerce Department Domain Name Proceeding


>"The Internet has thrived in an environment of communal discussion and
>consensual decision making, largely free from government regulation," said
>Commerce Secretary William Daley.  "Many believe that its extraordinary
>growth and success stem, at least in part, from its decentralized structure
>and bottom-up self-regulatory governance.  The Clinton Administration
>strongly believes that our challenge is to resolve these issues within that
>unique structure and governance."

The above is exactly why the Clinton administration, the Commerce Dept, and
the Federal Government as a whole should stay the heck out of any effort to
resolve this issue.  Let is resolve itself: it will, likely better without
bureaucratic involvement.


###
Number: 65
From:      Bonita Walker bonita@4dcomm.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 1:53pm
Subject:   Domain Names

I am not sure about alot of this but I was thinking about the porno on
line problem and  wondered it it would be feasible to end all the names
with .sex. That way browsers could have options not to let them in and
if they put it out with another ending they would be fined or something.
Just a thought.


###
Number: 66
From:      Michael Perelman michael@ecst.csuchico.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 11:44pm
Subject:   domain names

This is an area where public entities should be in control.  It should
be a matter of book keeping -- rather than letting a private company get
a monopoly.
-- 
Michael Perelman
Economics Department
California State University
Chico, CA 95929
 
Tel. 916-898-5321
E-Mail michael@ecst.csuchico.edu

###
Number: 67
From:      "Scott Novotny" cyberhusker@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 9:13pm
Subject:   Re: Domain Delema

Dr Barbara

Its about time.  

The Federal Communications Commission has experience in regulating Amateur 
Radio.  This experience would prevent the "Internet Domain Name Crisis" from 
becoming critical.  Licenses could be issued in the same way Amateur Radio 
licenses are currently issued.  Without a license a "Domain Name" would be 
bootleg or illegal.

It is important to note that Amateur Radio is currently self regulating by a 
group of Volunteer Examiners (VE).

In the 1910's the Federal Communications Commission (FCC), probably called
something different at the time, started regulating Amateur Radio
requiring registration, regulation, and testing for technical competency. 
Upon completion of FCC requirements for an Amateur Radio Station License,
a certificate was issued.  There have been fees (i.e. monetary charges)
associated with this "privilege" of conducting radio communication.  In
the case of the Internet, fees could be applied to administration of this
valuable resource. 

###
Number: 68
From:      Todd Terbeek ToddT@TechWave.com>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/7/97 7:31pm
Subject:   Domain names


My concern is not so much about who has control over handing out the new
names, but more the process that will be used to assign them.  My
company has been developing its business around several of the domain
names that we have secured.  It could hurt our ability to conduct
commerce on line if the new names are given out with a first come first
serve process.  If we build an online store at one of our names with a
.com or .net ending, and some one takes the .store version of that name
before we can, it could hurt our business.

I believe that a process needs to be put into place that gives companies
that own .com or .net domain names the first shot at those same names
with the new extensions.  There are a good number of companies like mine
who have taken a big risk to pioneer Internet commerce.  While I agree
that the ex

###
Number: 69
From:      Franklin Seal Franklin@sisna.com>
To:        NTIADC40.SMTP40("dns@ntia.doc.gov.")
Date:      7/7/97 7:16pm
Subject:   domain name registry opinion

Thank you for accepting public comments regarding the domain name registry
system.

I depend on the internet for my business as well as for much personal
information.  I have registered my company's name Handsondrums.com but have
yet to put it to use.  I paid $100 to reserve this name for a period of two
years.

In my opinion the system used to date has worked well but is no longer
appropriate.  I believe the system should be changed and should reflect the
following principles:

1. It should be an open system - 
     - not regulated by a government or by a commercial enterprise.
     - the database of registered names should be open and searchable by anyone
(what purpose does it serve keeping ownership of names from public view?)
     - aquisition of a particular name should be on a first-come-first-served
basis and should not be screened by any other process or group
     - any legal conflicts resulting from prior trademark registrations can be
dealt with by the same jurisdictions as would handle trademark violations
in any other medium (we don't create a separate trademark resolution
process for each of the older mediums - television, radio, newspaper, books
etc... so why do so with respect to the computer/networking medium?)

2. It should be an open-ended system -
     - if the registry database is open to all and can be querried in real-time
from any where in the internet there is no technical reason that the number
of top-level domain names be limited to any pre-set group (eg. the old 7
.com .net .gov etc..., or the new 15, or whatever number).  Barring
technical reasons for limiting the number of top-level names the rules for
adding a new top-level name should be kept to a minimum (eg. number of
characters as large as feasible) and the process should be as accessible
and as flexible as possible.  This way, if someone has already taken the
particular name you want within your desired top-level, you can simply
choose a different top-level name, or invent a new one if all of those are
taken.  Given that cyberspace is infinite or nearly-so, the only reasons to
limit the "real estate" in cyberspace is to create artifical scarcity for
commercial explotation.  In the interests of the general public, your
commission should avoid making decisions favorable to the creation of
artifical scarcity.  And don't be suckered by the arguements that without
it, capital will avoid investing.  Even in a world of unlimited cyber real
estate, corporations will still have plenty enough to gain from investing
in cyber development to motivate them.

3. The cost of maintaining the registration system should be spread as
evenly throughout the internet as possible.
     - an example would be to take the annual cost of maintaining the servers,
software development, administration etc... and divide the total by the
number of registered names.  Email the individual registered owners of each
name with the bill and give them a month to pay.  If they don't, the name
is up for grabs again.  Or if that is too unscaleable, bill each ISP or
host and they can just bury the cost in their fee.  It becomes part of the
price of the web server space.  The point is to keep the cost to a direct
portion of the actual cost of physically maintaining the system.  There is
no moral or economic reason for charging for the "privilege" of having a
name in cyberspace, anymore than there is a reason for charging people for
the privelege of having a personal name in society.

4. Given a registration system that is maximally open and inexpensive,
there would be a need to block individuals from trying to create an
artifical shortage of names by automatically registering millions of names
a day.  This could be accomplished by putting a limit to the number of
names registered per day/month/year by any given individual (in the same
fashion that banks put a limit to the amount of cash you can take from an
ATM within a single 24 hour period).

Thank you,

Franklin Seal

Franklin@Sisna.com
Hands On Drums
2691 Desert Rd.
Moab, Utah 84532
801-259-4811 

###
Number:70
From:      Greg Shields hawkmoon@mindspring.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 6:11pm
Subject:   RE: DOMAIN NAMES

I support the international plan to add new domain extensions.

I am against the monopolizing of domain name extensions by any
private source for profit.

                                      Thank you,
                                         Greg Shields


###
Number:71
From:      "David Bowser" jhadas@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:49pm
Subject:   Domain Names

Although I agree that the movement away from the US gov't control of the
domain naming is correct, the responsibilities should not be transfered
until the new organization meets a few key criteria: 

1. Internationally recognized as non-profit organization
2. Knowledgeable leadership within the organization (i.e. computer
scientists and academics with international experience, not bankers and
business people)
3. Accountability to some organization like the U.N. (but not the U.N.!)

The internet is as free as is gets and we don't need a bunch of
governments trying to mold it into their ideal image. 

Thanks for reading,

David Bowser

###
Number:72
From:      Marc Beauchamp mbeaucha@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:43pm
Subject:   Domain names

We don't need duplicative and chaotic domain names.  Neither do we need
an elaborate international bureaucracy to assign names and arbitrate
disputes.  Seems to me the procedure we've got right now is just about
right.  Except that the federal government can't leave a good thing
alone: i.e. the Justice Department's just-announced anti-trust
investigation of Network Solutions.  Which, like Microsoft, has done a
fine job thus far of keeping customers happy.

Marc Beauchamp
2231 Kings Garden Way
Falls Church VA 
22043
Email: mbeaucha@ix.netcom.com

P.s. I thought clinton said he wanted Washington to adopt a hands-off
approach to the Internet and electronic commerce??!

###
Number: 73
From:      Jay Glicksman jay@jg.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 4:05pm
Subject:   Comments on Internet Domain Names

Addressing item C. Creation of new gTLDs, in particular points
11. additional gTLDs; 13. gTLDs vs. ISO country codes; and 14. other issues

The issue I want to raise is that of domain names for individuals. I
strongly support a hierarchical gTLD for individuals to prepare for the
time when there are hundreds of millions of people on the net that want to
be uniquely identified.

- there is a proposed gTLD: .nom for individuals. That is a start but I
think it requires more structure.

- personally, I don't like .nom and would propose .ind (for individual) as
the name for this gTLD

- this gTLD should be separate from the ISO country codes since individuals
move between geographic entities

- individuals should only be able to register variants of their own names.
If your name is Bob Smith, you can not register WilliamClinton

- nicknames should be supported but need to be identified via its own gTLD
or perhaps a subdomain of ind (e.g. flash.nick.ind)

- some sort of hierarchy is needed to separate names to avoid the
bob987654321 "syndrome" found on AOL and similar services. I don't have a
particular proposal on this issue but think that it is important

- in the future "appliances" will have internet addresses, so subdomains
below the individual's name will be necessary. For example, my car could be
designated honda.jay.ind. A standard format would help clarify the name of
the appliance from the name of its owner

I am in favour of a limited number of meaningful hierarchical gTLDs, so
that addresses scale and have identifiable meaning. Individuals on the net
with their own non-commercial domains will be a major growth area in the
coming years and think that this is the appropriate time to develop the
appropriate nomenclature.

     Respectfully,

     Jay Glicksman
     jay@jg.org

###
Number: 74
From:      "Nate Lambeth" nlambeth@usa.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 3:17pm
Subject:   Request for Comments on Internet DNS

I believe that the DNS should be left as is. Either way it is managed will
inflame one party or another, so forget politics and leave the Internet to
manage itself. It has before, and it will continue to.

Nate Lambeth

###
Number: 75
From:      "admin2" admin2@caspers.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:34pm
Subject:   Domain Names

It is important to make it clear that the current naming system is
extremely over burdened and is in dire need of relief. Many of us who run
ISP's have found it difficult at best to deal with and/or work with the
current holder of the domain naming registrar of  the .com , .net . and
.org domains (Network Solutions). They have opposed all manners of reform
(adding more domains, splitting the current domains up to add better
service, etc.) myself and my associates find ourselves at the mercy of a
corporation that not only is acting as a money hungry tyrant but has
literally split in then face of the National Science Foundation, who did
not have to give them the contract in the first place, by stating they will
continue to hold control over the domains they currently administer. Well
we, the ISP's of the world having been talking between ourselves and we
pretty much agree that as soon as the new domains are in place we will push
to have our several million combined clients move away from the .com domain
in particular, we all, for the most part, got into the Internet for our
love of it and will tolerate no monopolies from Government or private
sectors what so ever. I will make one prediction you can bank on, those who
support openness and are genuinely so will prosper with our business, those
who don't will be a memory of what they could have been.

Shawn A Suzik
Caspers.Net
Network Admin.

###
Number: 76
From:      "Cay Villlars" cvillars@globaldialog.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:22pm
Subject:   Comments on IP address administration.

The issues I see are as follows:

Intellectual Property.  Although IP addresses were not originally designed
to be "intellectual property", as commerce on the net explodes it is clear
that they have become as critical part of a company's intellectual property
as a copyright, trademark or SMark, or even 1800 numbers.  Many of the
lessons learned from developing/managing these "properties" are applicable
in developing a method to managing IP addresses.   

IP addresses should, at a minimum, have some of the same features and
protections as Trademarks- you can apply in advance of use, but full
protection is only gained by actual use in a commercial venture, like
trademarks on a product. (to prevent IP hawks from buying up IP addresses
and selling at inflated prices) .  Like copyrights, continued coverage
requires continued use.

However assignments are made,  an IP address MUST remain unique (or there
should be an option even though it costs more).  That is, it is NOT
acceptable to have microsoft.com and microsoft.edu considered to be
different domain names.  Like a trademark, a company should be able to pay
more to exclude others from using any other Company.* designation that
would potentially cause "confusion". 

Sticky wicket-  obviously many companies have trademarks that are
identical, but acceptable, because they are in different class categories. 
(for instance FALCON, EXPLORER, etc.).  I don't have a brilliant suggestion
to address this, other than suggest that it may have to be resolved based
on FIRST commercial online use.

Access.  There should ALWAYS be free public access to search the IP
database to see if a name is available.

Affordability.  The question is, how to keep domain names that offer
"trademark-like" protection affordable?  The current fee of $100 for two
years is affordable. However, is this enough money to support a program
that would give domain names the same protection as a trademark?   I
suspect companies would pay a significant amount of money to insure
stronger protection for their domain name.  Perhaps their could be
different levels of protection that could be purchased.  Basic would be
$100, with higher levels of protection for company or tradenames.  Perhaps
a company could pay an extra $50 dollars when filing a trademark, S-mark
and get a "option" on  a IP address.  In order to become "active" the IP
address must be in use, say within 3 months of the Trademark registration. 
 

Speed and simplicity.  It seems that the current assignment process is
relatively quick and painless (it can be done online by the average person,
as opposed to paying an attorney). Can your agency help us keep it that
way, while providing the intellectual property protection that
entrepreneurial America desires? 

I think the pressure on your agency regarding this issue will be enormous,
and I wish you well in working it out.  I am  not an attorney, but have
delt with intellectual property issues as a marketing person for almost 15
years.   If I can help in any way, let me know.

Cay Villars 
Market Value Concepts
608-838-6533

###
Number: 77
From:      "Theonly.com" neweyes@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 11:03am
Subject:   Domain Names

I feel that there should be an unlimited # of domain name registrars. The 
Internet is about leveling playing fields not creating monopolies. Plus, 
if there we're many resistrars registrars will be able to help the people 
in their own countries much more effectively than one central company 
would be able to.

John Catlin
President, TheOnly.com
3 Shore Dr.
Shutesbury, MA 01072
413-367-2874
888-Newton-4

           John Catlin  ---  NewtonCentral
      john@theonly.com & neweyes@ix.netcom.com
        Daily news and updates for the Newton
             http://newton.theonly.com/

###
Number: 78
From:      Annie Keitz keitz@his.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 10:32am
Subject:   Domain Names

To Whom it May Concern:

I run the website for Viewers for Quality Television (http://www.vqt.org/).
 We are a low budget (shoestring actually...) non-profit organization
devoted to educating the public about the television industry.  As such we
are very much in favor of keeping the Internet as a place where the little
guys like us can rally the people.  Currently, Internic charges an
inordinate amount of money for a domain name -- and does not provide timely
quality service for the money they take from us.  We had to mail and fax to
Internic copies of credit card bills not once but three times to prove that
we had paid for our domain name, each time Internic threatening to cut us
off.  I'm certain that if Internic did not hold a monopoly on domain name
registration,  it be would cheaper to register domain names and the billing
process would not be so error laden.

Sincerely,



Annie Keitz
Annandale, VA USA
keitz@his.com

###
Number: 79
From:      "Ashton, Mark" Ashton@csi-health.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 9:52am
Subject:   naming schemes...

Top level domains should be to the internet what zoning strategies are
to a city. By glancing at a domain name, one should be able to tell
generally what one is getting. This helps users better understand the
sites they are thinking of visiting. The current system has not worked
out too well, since the majority of sites cluster in the .com domain.
Perhaps some differentiation among .com sites (perhaps along industry
lines) might be in order. I think an important domain that should be
added is something like .adt, for sites serving only adult material.
This would be equivalent to many city schemes for throwing adult stores
into one area of the city. It makes these sites easier to keep track
off, harder to simply stumble across, and keeps them out of more
legitimate areas.

-Mark

###
Number: 80
From:      "J. Woody Meachum" akawoody@imaxx.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 6:12am
Subject:   Domain Names

I am not opposed to the addition of more extensions.  In many ways it
will help the user better identify and police their individual systems.

One prime example of this would be for a topic that I have been
discussing with my wife who is a librarian.  They are require to NOT
limit access to the Internet for their patrons, but they have been
receiving complaints by parents for allowing children access to
pornographic material.

With an addition of a .PRN extension, this would allow be like putting
that type of material behind the counter at a convenience store. 
Children will know it is there, but they will also know that it is
probably something they shouldn't look at until a certain age.  Also,
policing software could more easily be constructed to block out the .PRN
material.

The Adult Entertainment business shouldn't be too opposed to this
either.  You are giving them their own section.  If someone wants that
type of information, they will know where to go.

It would be up to the Hosting Service to police their servers as far as
compliance of the rule.  I believe the government should not get
involved in the policing of this rule.

Other extensions we have discussed could be .MED (medical) and .MAG
(on-line magazines.

Thank you for allowing my input.


John E. Meachum
Oak Park, IL

###
Number: 81
From:      "Micha Hackett" mikehack@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:45am
Subject:   the US gov. must get out of domain name biz ... best left to UN
and the Swiss

US gov. must get out of domain biz ... leave it to UN and ITU.

###
Number: 82
From:      Herman Jusuf minkx@tamu.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:23am

let the international ad hoc committee do the job. stop the monopoly.
###
Number: 83
From:      "Robert Vasilik" robert2000@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 2:48am
Subject:   Domain Names

The current system of registering domain names is out of control. Neither 
InterNIC nor TABNet (The American Business Network) provide any notice to the 
user that he/she may, in fact, be committing trademark infringement by 
attempting to register a domain name.

A sytem must be put into effect which would make it mandatory for the domain 
registration PROVIDER to first check for trademark ownership before allowing a 
user to register a domain name. We can't expect millions of Americans to go 
online doing extensive trademark searches when the PROVIDER can accomplish 
this easily. 

I personally had to pay TABNet's $50 fee even after I notified them that my 
requested domain name was found to be in violation of trademark laws. Their 
attitude was one of disinterest. TABNet seems to be solely in the business of 
collecting as many $50 fees as they can get without regard to who may own 
rights to a similar name.

And what about the case of "XYZ Inc." which owns the trademark to "XYZ" and 
has the domain of "http://www.xyz.com?" Does another individual who registers 
"http://www.xyz.org," or "http://www.xyz.net" put themselves in jeapordy for a 
lawsuit for trademark infringement based on the usage of "XYZ"? 


Robert Vasilik
robert2000@msn.com

###
Number: 84
From:      "Douglas A. Wright" darkwing@storycity.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:51am
Subject:   Domain names

I believe we should adopt new names. It would serve to clarify where you
are going & help new people to the Internet look for what they want.

I also believe Network Solutions Inc. in unjustified in their stance, they
are just worried about losing their monopoly.

Also I think something should be done about these upstarts that are
purchasing names they believe some Co. will want & then selling them for
exorbitant amounts. I'm all for free-enterprise but that's border-line
extortionism.

Douglas A. Wright



###
Number: 85
From:      Jason Brown farland_er@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 1:03am
Subject:   New internet domain names

I personally like the idea of new domains on the internet, especially
.store and .web.  I also think there should be a board or some such
group (internationally) to assign and maintain domain names, outside of
a company, because the internet is too big to be controlled by a
company...

###
Number: 86
From:      Alan Bleiweiss alanb@htp.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 1:30am
Subject:   Request For Comments - Domain Process

As an Internet Development Manager since 1994, I can simply state my
comments in one paragraph.  It is imperitive that the domain
registration process be freed of its current stranglehold by one
organization.  In order for the Internet to flourish and grow, as it
should, this process must be democratic and fairly distributed amoungst
many companies.  The present system is archaic, dictatorial, and
destined to cause severe havoc as the masses continue to move to this
new medium.
-- 
Alan Bleiweiss
Project Manager Web Implementation
NetHaven - The Internet Division of Computer Associates International

Chairperson, Long Island Webmasters Guild

###
Number: 87
From:      Michael Gersten michael@stb.info.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 2:27am
Subject:   DNS system comments

I want to support the EDNS style system, and the existing  
EDNS servers.

What are the benefits of the EDNS system? Simple. Anyone  
can start up a top level domain, by simply having a few  
basic, essential requirements taken care of. There is no need  
to be a big pocket, major cash player to play; it is very  
concevable that five or six different non-profit, hobbyist  
groups can get together and set up their own top level  
domains, at no cost to the users.

Compare this to Alternic's system, where you have to spend  
$1000 (I belive) to register a top level domain.

Or, compare this to the (now defunct) Postel Draft from  
IANA/ISC, where there was a 2% fee of any money collected  
from the registries, to support IANA (which now seems to be  
getting out of the business, although I may be mistaken  
here).

Are there drawbacks to the EDNS system? Yes. First, you  
have a first come, first served system, with non-shared top  
level domains. Is this a problem?

First come, first served, is (essentially) how the current  
system of domain registration is _SUPPOSED_ to work. In  
reality, the people currently running the .com domain (which  
is what most people consider to be the domain name  
system) will arbitrarily yank a name if they think that  
someone else might have a trademark status that would  
result in their (the registry) being sued in court; this policy  
has, in fact, resulted in suits from people who have lost a  
domain name.

Is there a problem to first come, first served on the top  
level? No more than on the second level. Just as someone  
registered television.com, (and someone else then registered  
tv.com), just as two different acme corporations have to get  
different names (only one acme.com), just as I have seen the  
name "Common Sense Computing" taken in two different  
counties as a name for a computer consultant (two different  
people), any sort of "one name per world" will have overlap.  
This is not a serious objection.

Is there a problem to non-shared registries? Not really. A  
shared registry ultimately is silly. Computers do not look up  
your name by the registry, they look it up by the zone file. If  
two different registries are serving the same zone file, they  
have to share the data, and there is *NO* difference as far as  
any user can see in the service performed, the only  
difference is the price to register. This is not enough of a  
reason to force a lot of changes on the system.

A bigger question, and one of far more importance, is who is  
to own the existing registries. Right now, existing top level  
domain names have been given to people who have,  or are,  
abusing it. Examples? The .us domain, which is geographical  
by state. One state was given to an ISP in that state; the  
cities in that state then organized, and wanted to each be  
listed (sorry, I don't remember the name of the state) at the  
third level. Because of the large number of cities in this state,  
the ISP refused, and would only allow a small number at the  
third level (below which it would delegate out to others at  
that level). That may be appropriate for county level division,  
but that's not how the .us domain works, normally. Consider  
that we do not say "los-angeles.la-country.ca.us", we say  
"la.ca.us".

Worse? One country is "lucky" enough to have the top level  
domain of ".tv". This is a little, poor country, offshore. This  
domain name is suddenly the most valuable asset it can  
have. Except that there is a private company, an ISP that  
was given control of that name.

I really think that fixing the existing bad delegations of  
names, away from ISP's, and towards the people who will  
actually USE the names, and who the names represent, is  
more important, in the long run, than worrying about  
expanding the top. And I think that a "no big pockets  
needed, simple and basic system" is the best way to go; this  
is the EDNS system (www.edns.com).

Note that I'm not saying that I think that the people in charge  
of EDNS currently are the best qualified to run the top. At  
some point, some one person or group has to be  
responsible for saying what is and is not in the top. EDNS  
has some seemingly straightforward restrictions -- a top level  
name may be rejected for unspecified reasons (example:  
had the CDA been upheld, the name ".sex" would not have  
been allowed), or for perceived copyright reasons (example:  
someone registering ".ibm" or ".toyota" without actually  
representing the company in question). Although these seem  
like reasonable policies, there's a lot of actual cases and  
details to be worked out. The actual policies used in practice  
may not be so good, and may require the people who  
determine "what's in the top" to be changed.

Finally, there's a bigger problem: The top level is global, not  
US. I personally don't think that the U.N. is the right group to  
control this, nor would I trust any multinational corporation.  
If I had to name an individual that I thought could do it  
properly, I'd name Jon Postel of IANA/ISC, but even he will  
die eventually. I have no clue as to how to determine any  
sort of long term solution to this problem.
--
Michael Gersten     michael@stb.info.com      http://www.stb.info.com/~michael
NeXT Registered Developer (NeRD) # 3860 
Without Prejudice, UCC 1-207
** HIRE ME: http://www.stb.info.com/~michael/work/

###
Number: 88
From:      wallace koehler wkoehle@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 6:07am
Subject:   gTLDs

NOTE: I sent this in Word 6. I went to check the quality of transmission
at your site and was unable to open it. Here it is enclosed in email.

Response to Department of Commerce Request for Comments on Internet
Domain Names
Wallace Koehler (willing@usit.net)

A. Responses to General/Organization Framework Issues: 

A. Comment: There has been much interest expressed about and interest in
modifications to the domain naming structure, particularly to the gTLD
.com domain. This concern resulted in a set of recommendations by the
International Ad Hoc Committee (IAHC) of the Internet Society (ISOC) as
well as a continuing commentary and criticism of the process and its
recommendations. For example, the IAHC maintained a listserv (archived
at the ISOC site (www.isoc.org)) and the issue was the subject of some
debate at the INET*97 Meeting (ISOC Annual Meeting) in Kuala Lumpur in
June 1997. 

     A.1. Argument Foci. The argument as presently constituted revolves
around two related issues: (1) domain naming space has become congested,
and (2) domain names may represent a threat to the trademarks of
established corporations. Arguments and proposed solutions include
recognition that the current gTLD structure is inadequate to manage the
naming requirements of commercial entities worldwide and that trademark
issues are important. The IAHC solution, meritorious as it is, fails in
one key aspect. It seeks to impose a solution maintained and
administered by what is essentially a technical non-governmental
organization on a regime that is inherently legal, political, and
economic in nature. NGOs, particularly technical NGOs lack the
expertise, authority, experience, and jurisdiction to regulate in that
environment. The IAHC also was very limited in its scope and membership,
and did not address (nor did it seek to address) wider domain naming
issues beyond expansion of the com domain, trademarks, and related
matters.

In addition to the IAHC recommendations, others have suggested (1)
creation of  a flat TLD structure, allowing registrants to choose
individual TLDs without regard to *controlled vocabulary* or *indexing*;
(2) elimination of the TLD topography by either eliminating
alphanumerics and reverting to IP numbers only or by generating random
TLDs; and  (3) migration from the functional TLDs (gTLDs -- com, net,
org -- and the edu, gov, mil TLDs) to an exclusive adoption of the
geographic (ISO 3166) two-letter codes now employed largely but not
exclusively (.us) outside the United States.

Option 2 would eliminate trademark issues but would prove unwieldy and
unpopular. Neither option 1 nor option 3 would address trademark
questions. 

     A. 2. Other Stakeholders. This debate tends now to be dominated by
three groups: Commercial interests seeking to protect oftentimes
legitimate and sometimes questionable trademark rights, the technical
Internet community, and the root domain registrars -- both the
established and the hopeful. There are other constituencies and
stakeholders with significant interests in the outcome of the TLD naming
debate. These include governments (that the Department of Commerce has
requested comments on this issue speaks for itself), the information
science and library community, and the non-commercial and
quasi-commercial domain and virtual domain name owners, as well as
others.

Unfortunately, these other stakeholders have tended to be ignored.  I am
one of those other *stakeholders* in that I find that the TLD and
second-level domain (2LD) tags of URLs can be used as an important
non-keyword Internet search methodology.  In that light, neither the
geographic TLDs as well as both the functional TLD status quo as well as
the IAHC proposal do not threaten the methodology. Flat TLDs would
destroy the utility of the method while IP numbers would render it
perhaps hopelessly complex.

It is undesirable to destroy any search methodology that helps organize
and regularize the Internet. Searching on *URL fragments* is one such
approach, and is supported by several major search engines. If anything,
*controlled vocabularies* and *indexing* (both timetested and honored
vehicles for information management and retrieval) should be expanded in
the Internet context. It could be expanded by more universal use of
standardized 2LD and 3LD tags now employed by some but by no means all
geographic TLDs. Examples include gob.mx (government servers in Mexico),
co.jp (commercial servers in Japan) and ac.uk (academic servers in the
United Kingdom). Other variants include [state postal code].us, fi.cr
(financial entities in Costa Rica), and tm.fr (trademarks in France). A
somewhat universal application of standard 2LD tags together with
existing TLD tags could improve *quasi-set* creation and, as a result,
search precision.

A.3. Responses to: Issues 1, 2, 3, 5, 8, 9, 10, 11, 13, 14, and F
*Trademark Issues*

     1. Advantages/Disadvantages of Status Quo. The status quo does not
address trademark issues, it cannot regulate either trademark rights nor
the distribution of domain names in general, and the size of the com TLD
is unwieldy. On the other hand, the functional and geographic naming
system provide some classification and categorization structure.

     2. Improvements. Expand as necessary TLD tags, but restrict that
expansion to manageable limits. Expand the use of 2LD and perhaps 3LD
standard naming conventions. Consider the use of .tm (trademark) to
indicate a *protected* domain -- (corporate_icon).tm.TLD would be
restricted and protected. Non-.tm 2LD might not carry the same level of
trademark protection.

     3. Administration of domain name systems. Technical NGOs are inadequate
to the task. Perhaps the system could be managed by an arm of the ITU,
advised by a board consisting of the interested stakeholders and
constituencies. That board could be nominated by important NGOs, other
IGOs, commercial entities and trade associations, governments,
universities, governments,  the intellectual property bar, etc. 

     5. Retire gTLDs. I see no compelling reason to do so.  Some see gTLDs
as indicating implicitly an American registry, others have accepted it
as more universal. The geographic TLDs are sometimes interpreted,
particularly in commercial circles, as more parochial or regional in
character. As a consequence, non-US commercial entities sometimes adopt
functional rather than geographic registrars. That may lead to minor
confusion. However, many corporations have a global character and the
functional TLDs may reflect that.

     8. Transition to New System. Slowly, if at all.

     9. Other issues. Use of 2LD and 3LD standard tags.

     10. Technical, practical, policy restraints on new gTLDs. From a
practical/policy perspective, gTLD proliferation can lead to confusion
and perhaps a breakdown in its usefulness as an information organizing
medium.

     11. Create new gTLDs? Yes, or move to a 2LD system. But limit the
number of gTLDs.

     13. Separability of gTLD from ISO 3166 TLDs. Certainly there are
jurisdictional and syntax differences between geographic and functional
TLDs. gTLDs, other functional TLDs, and geographic TLDs are administered
by different root registrars. That is manageable. However, all
registrars need, no, must follow protocols and standards which
facilitate Internet communication. 

     14.  Other issues. Please consider the adoption of 2LD and 3LD
standards as well as a reasonably rational approach to the allocation of
TLDs by group and classification.

     F, Trademarks. The trademark issue will dominate the TLD debate since
interests are so vested and extensive. All sides in the debate make
valid points. While trademark law is extensively developed, its
application tends to be more national than international in scope. There
does not yet exist an adequate body of international jurisprudence to
mitigate the challenges resulting from the Internet, a largely
unregulated and truly international medium. Reliance on national regimes
will likely prove inadequate. Moreover, efforts by technical NGOs to
regulate this issue will not only fail, but will probably significantly
reduce the perceived competence of such NGOs in their established areas
of expertise and proficiency.  

B. Background
I am a student in the MSLS program at the University of Tennessee
writing a thesis on the longevity and constancy of Web pages and Web
sites. I hold a PhD in government from Cornell (1977). I am
author/co-author of a number of papers on Internet searching,
cataloging, and related issues. Most recently I presented at the
Internet Society Meeting (June 1997) on search methodologies. I have
also been employed by an information broker/consultant as a senior
researcher  to a US government agency to develop methodologies for WWW
cataloging (for a list, my c.v. can be found at
http://www.public.usit.net/willing)

###
Number: 89
From:      Andrew Hofer ahofer@nstsystems.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 8:19am
Subject:   Comments on Domain Name Administration

I manage multiple domains for clients of my company, NST Systems, Inc. of
Stamford, CT. The paramount concern that I would have regarding a change in
administration of Domain names on the Internet is to make certain that a
SINGLE entity is responsible for registering and resolving names at the top
levels.

Please don't perpetrate another disaster on the American public in the name
of "antitrust" by breaking up a single, well-coordinated company into
dozens of competing, disorganized entities all vying for our attention and
screwing up our records.

When the US Government broke up the phone system, AT&T advertised only for
"corporate image" and otherwise ran a good system where the most important
feature was that you never had to think about their service... you just
took it for granted. Now the phone system has been a complete mess for
years, with hundreds of thousands of our dollars wasted on advertising to
get our business, dozens of little phone companies constantly trying to
switch our service and convince us that what we want is "choice." The
public doesn't want "choice" in what are perceived as utility services --
they just want SERVICE! The public doesn't care whether the service is
competitive -- the price we pay for competition is greater than what we pay
a monopoly! Just look into regulating these monopolies properly to keep
them reasonably fair, and otherwise don't bother them. If competition is so
great, why don't we allow alternative federal governments and let each
member of the public choose a governmental "service provider" according to
which government has the best rates and sales pitch? How effective would
THAT be as a way to run the country?

Andy Hofer
NST Systems, Inc.

###
Number:90
From:      "techmage" techmage@peganet.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 8:47am
Subject:   NSI

Network Solutions Inc, as it currently operates is a monopoly in its most
clasical form.  Its rates are way outside what its service entales. $100
per domain, per year is ridiculos, when you consider what is costs them to
perform this service. 

teckmage@geocities.com
The Dark Tower can be found at:
http://www.geocities.com/SiliconValley/Lakes/2669/ 

###
Number:91
From:      whetzel@kpmg.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 9:32am
Subject:   DNS

I would prefer that the commerce department maintain the spirit of the
Framework for Global Electronic Commerce.  Though the CD has been tasked
by the president in a backdoor maneuver to evaluate the DNS issue, let the
the non-government, non-profit organizations continue to oversee these
functions (in the spirit of the Internet not being burdened by government
regulations). 

The Internet is one area which I would prefer not to see "the law" forced
upon Internet users for the sole reason that certain individuals feel
"law" should be in place.  If the government starts regulating the DNS
issue, then it's foot is in the door -- a fox in sheeps clothing.  Don't
evaluate; don't recommend. 

William D. Hetzel
1029 Blvd East, #5
Weehawken, NJ 07087

###
Number:92
From:      Chrissy cmcguire@nkn.net
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 11:09am
Subject:   InterNIC

I work for an Internet Service Provider and am in charge of domain name
registration for our customers and have had nothing but trouble with
InterNIC's billing department.  I have had instances where InterNIC has
deposited our check and it has posted at our bank and then 3 days later,
they have put the domain that was paid for on hold for non-payment.  The
people that answer the phone are completely incompetent and all give
diferent answers to the same question.  I have then later talked with their
supervisors about it and they are just as incompetent and act like they do
not care.  Supposedly in April they overhauled their billing system but
nothing has changed.  I am so glad that they will not be handling domain
name registration after March of 1998.  My suggestion for the future of
domain name registration is to learn from all of InterNIC's mistakes,
especially their billing mistakes.  Thank you.

Christinia McGuire
NKN

###
Number: 93
From:      cardclb cardclb@swva.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 2:01pm
Subject:   Sincere suggestion for domain names.

Domain names should be set up like the phone book.

For ex.:

www.government should take us to a very patriotic and official page with
links to all gov't related sites (i.e. www.government/congress).

And:

www.church should take us to a page with every type of church. Then
www.church/catholic should explain the catholic faith and have links.

And:

www.computer should be related to the industry with appropiate links.

Finally:

www.personal would lead to www.personal.johnsmith

I would leave off that "www.", too, if it were me. 
Thank you for your time, if you bothered to read this far. -Chad

###
Number: 94
From:      Arlie Davis arlied@microsoft.com>
To:        "'dns@ntia.doc.gov'" 
Date:      7/8/97 3:23pm
Subject:   Comments on the InterNIC

I helped to found a small, successful Internet service provider.
Interaction with the InterNIC was a crucial part of the job.  So I am in
a good position to comment on the quality of the InterNIC's service and
their policies.

First of all, the quality of the service at the InterNIC has gotten much
worse since they started charging for domain names.  The service is, at
best, inconsistent.  Sometimes requests sent to the InterNIC would be
processed within a week; very often, requests would take more than a
month or would simply be lost.  The InterNIC argued that charging a
(very high) fee for its services would guarantee fast, professional
service.  It has completely failed to deliver on its promise.  As a
partner in a small Internet provider, our ability to serve our customers
(who needed domains registered) was severely hampered by the
inefficiencies and high cost of dealing with the InterNIC.

Second, the quality of the policies of the InterNIC are not
satisfactory.  There needs to be a system of arbitration for domain
names.  The responsibility for choosing who gets to register a domain
name needs to be separated from the companies that provide the
root-level name service.  The idea of a single, private company like
Network Solutions having absolute control over the namespace of the
Internet is abhorrent; imagine if a single company governed what other
companies were allowed to name themselves, or goverened how street
addresses were assigned in new cities.  This needs to be done by an
external body which does not have a financial interest in the outcome of
the decisions.

The InterNIC has no pressure at all on it to increase the efficiency and
decrease the cost of its services.  It is impossible for a competing
company to provide the same services.  The best solution would be to
separate the responsibilities of the InterNIC into two types of
organizations.  The first would necessarily be a single organization,
possibly an agency of the US federal government or an international
body.  This organization would govern the namespace of the Internet, and
would arbitrate disputes over domain names.  The second type of
organization would simply provide the actual network services required
to provide the Domain Name System; it would not make any policy
decisions.  Many different companies could act in this role; the
competition among them would necessarily allow for a cheaper, more
robust, and less easily-monopolized Internet.

Thank you for your time.

-- Arlie Davis

###
Number: 95
From:      calvin calvin@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 4:02pm
Subject:   government operation of domain name system

I personally don't see why the government couldn't continue to run the
domain name operations.  To feasibly run the system the government could
just turn part of the operations over to the patent office and when they
issue a company a patent on their trademark why not at the same time
issue the company a patent for a domain name with the same as that of
the trademark?  The other alternative is to set up a computer program
that would automatically generate a domain name based on the patent
number given to the company for their trade mark.  The latter of the two
solutions I suggest would eliminate squabbling over who gets what domain
name.  To pay for the government operation would also be quite easy. 
All the government would have to do is to add a small tax of say $.05 to
$.10 cents per month onto all personal ISP accounts and $.15 to $.20
cents per month onto all business ISP accounts.

###
Number: 96
From:      Glen McCourtie gfmccourtie@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 7:08pm
Subject:   Internet Domain Names

I believe the government needs to stay out of the Internet.  The
government has already, with little success, tried to "help" the
Internet.  But, it has caused more harm to the the Internet than any
"good intentions" it has tried to act upon.

Glen McCourtie
238 Ballard
Jackson, MI 49201

###

Number: 97
From:      "Thermopoly" thermopoly@worldnet.att.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/9/97 4:14am
Subject:   proposed TLD changes

I fully support allowing groups like AlterNIC, eDNS, uDNS, and any others
that have the capability of providing enhanced domain name services. 
Nearly 90% of the people can already access http://www.per so why not open
the process up to more.  We should not allow one group, chosen by a cabal
in some Swiss Chalet to control this valuable resource. 

###
Number: 98
From:      "George Michaud, President/CEO" musicmarketer1@worldnet.att.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/9/97 5:52am
Subject:   Re:  Domain Names in the Future... A Solution...

                    I have the perfect solution.  Let my Corporation
handle all the same
activities that InterNIC has done and we will give 50% of the funds to
Cancer Research and we will pay the other 50% to our employees that will
work hard to make it right. We are completely unbiased , have no motives at
all and would do a wonderful job of managing it now and into the next
century.   We would like to see a cure for Cancer by 2001 at the latest. 
With each new Domain Name the customer also would receive a FREE Tape or CD
of the most beautiful HarpMusic For Your Health in the world from the
magical fingers of the late, great Harpist Lloyd Lindroth.  This music is
designed to reduce stress and tension at home or the work place for anyone.
 It works.

Sincerely yours,

George L. Michaud
President/CEO
Harpland Music, Inc./a division 
Of Michlind Enterprises, Inc. 
**********************************************************************
Our WebSite for the "Music For Your Health", Beautiful 
Music. (Click Here)>> http://www.harplandmusic.com
SEE and HEAR sound clips from world famed Harpist, the late, great 
LLOYD LINDROTH and his Golden Harp. CDs and Tapes for
very own. Use your VISA or MasterCard. SEE and HEAR famed Drummer 
JIM WEINBERG.
  Copyright 1996-1997. All Rights Reserved.  Michlind Enterprises, Inc. , 

###
Number: 99
From:      Bing Associates bing@tiac.net>
To:        "'dns@ntia.doc.gov'" 
Date:      7/9/97 7:34am
Subject:   Domain Scam

I just dealt with a company, internic.com, which clipped me for an extra
$150.00 or a total of $250.00 for domain registration of Windsock.com. I
suppose I'm screwed but I thought I'd pass the info along. I saw no
disclaimer until after I had paid, that suggested that they were not
affliliated with interNIC.net. More info is available upon request. Glenn
G. 

###
Number:100
From:      Adam Rice adamrice@crossroads.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/9/97 5:26pm
Subject:   public comments on domain name registries

Thank you very much for soliciting public comment on this matter, and
making it easy for the public to comment.

Although there are a number of serious concerns that the Internet community
has with the way the current registry system works (such as lack of
competition and scarcity of TLDs), I believe that these issues are outside
the government's purview. The government should no more regulate the domain
name system than it should tell newspapers what brand of printing presses
to use.

That said, I believe it would be appropriate for the commerce department to
*encourage* (not mandate) open competition in domain-name registries, and a
vastly wider base of TLDs, to accomodate the many different companies with
overlapping requests for domain names. The ".com" TLD is being burdened
with every sort of commercial enterprise: it would make more sense to break
this up into many different categories of commercial enterprise (such as
communications industry).

Yours very truly,

    Adam Rice | adamrice@crossroads.net
Austin TX USA | http://www.crossroads.net

###
Number:101
From:      Mark Gage mgage@nw3c.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/9/97 8:00pm
Subject:   Comment on domain names

Goverment handels copywrites, trademarks and patents. It is not
inconsistent to have goverment assign domain names.

Mark Gage

###

Number:102
From:      John Horst johnhorst@worldnet.att.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/10/97 1:52pm
Subject:   Domain Name Conventions for next year

To whom it may concern:

Please accept the following suggestion concerning domain names as next
year's changes come upon us.

Many of us who are concerned over the easy access to pornography on the
Internet would like to see some effort made to keep material of this nature
on a distinct "section" of the Internet.  The intent of the CDA was good,
but I was not surprised to see it struck down by the Supreme Court.

If a top level domain called "adult" (e.g. http://www.name.adult) were
established, I would encourage my representative to initiate legislation
requiring all material that was to be covered under the CDA to be located
at an address that used this top level domain.  This would allow browser
programmers such as MS and Netscape to program their browsers to allow
blocking of all sites in the adult top level domain.  This would finally
make blocking a workable solution.  A legal requirement of this nature, I
believe, would also pass constitutional muster as it does not prevent
adults from accessing the information.

Thank you for the opportunity to contribute an idea.

John Horst
San Diego, CA
johnhorst@worldnet.att.net 

###
Number: 103
From:      "Jordan Rice" Jordan1@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/10/97 4:37pm

To Whom It May Concern:

Regarding the current debate on who shall allot domain names and which
suffixes will be added to the Internet, I have several comments.

First, these are clearly two separate debates.  In both, our small
consulting company shall likely be affected, as we are a legally formed and
registered company doing business in the State of Georgia having rights to
the name, "I-Med, LLC".  But we also control the domain name of
"www.i-medllc.com".  Since the name has not been Federally Trademarked and
since we have registered the name properly in the State of Georgia (which
has precedent setting laws protecting Georgia based companies doing
business on the Internet), who should say that we have no right to that
domain name, should there be another I-Med, LLC (which there are) who
contests the use of the name?  Our legal counsel advises us that we have
the right to use this name on the internet and to conduct business
nationally and internationally.  In addition, since the InterNIC has
accepted our domain name, what right do others have to that name in the
future as long as we renew our annual license?

Certainly, if other suffixes are added, there may be some confusion for our
new or existing clients.  But wasn't this the same issue that McDonald's
and other US companies faced when trying to establish trademarks and
service marks internationally?  And weren't there attempts by some
unscrupulous persons (most notably in Paraguay) to trademark these
internationally known names and block their use by trying to force huge
licensing fees from these multi-national companies?  What did the
Department of Commerce do for 25 years in that well known case?  

But many reasonable national governments have now enacted laws protecting
and observing the right of multi-national companies to be protected from
this "economic blackmail".  My wife worked for the Department of Commerce
in the US Embassy in Manila for 5 years and certainly I know the great work
that the DOC has done to promote US business abroad.  But how can you
impact this debate?  What laws can Congress enact and the President sign
into law that some renegade country would not usurp, such as Libya or Iraq,
if they so wished?  That is the problem with the internet at present.  Even
repressive governments, such as Singapore are finding it hard to curb
internet access to block negative political opinions of their government or
to block material they deem pornographic.  Look are how hard it has been
for national authorities to track down pedophiles who are clearly breaking
laws regarding child pornography.  If an area that 99% of the world's
population agree is unwanted and undesirable for viewing by all, then what
chance to regulate the European Economic Community or the ASEAN countries? 


This means that I do expect another www.i-medllc.?  (whatever the suffixes
end up being), but neither will we willingly give up a name that was in use
before anyone trademarked in the United States with our current suffix of
"com".   We are a small company, but we have used the name for several
years and we properly registered it as required by Georgia State Statutes.

These two issues are very difficult ones and I trust that the Commerce
Department will consider the long term ramifications of their actions to
all US businesses, large and small, new and old.  We cannot stop other
governments or international bodies from adding their imprint to the
Internet.  But we can try to develop international agreements and standards
that give everyone globally free access to the internet and yet maintain
some kind of order, so that there is not mass chaos as millions of Web
Sites come on line in the next few years.  Diplomacy and tact are the order
of the day and bullying tactics that worked in the Gulf War, simply will
not work on the internet.

You have a tough assignment ahead of you and I do not envy your task.


Sincerely yours,


Jordan Rice
President
I-Med, LLC
Lawrenceville, GA 

###

Number: 104
From:      Michael Macioch woody757@home.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/11/97 7:25am
Subject:   domain names

I am blind and use my computer at home, and even though the service I am
currently using is called Comcast@Home, it is my belief that that those
who use the internet at home should be able to use @home whether its a
non-profit org or a private citizen.  The use org should be for
non-profit groups only and com should be for the private citizens. Now
if you where to add the state abbreveation ex. john doe123@va.gov  and
for the non-profit groups ex. janedoe@ms.md.npg  and than the retired,
student, private citizen would now be like this: ex.
jimdoe@wmc.student.com  or tg@pikesville.md.com and the last is
mikedoe@myhome.com

Sincerely yours,
Michael Macioch
phone: 410-356-8977
fax: 410-356-2487
10008 Woodkey Lane
Apt. 2
Owings Mills,MD 21117-3923

###
Number: 105
From:      "Turner W. Rentz, III" treyr@atr.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/11/97 11:45am
Subject:   Comment: DNS TLD Registration - Favoured Method of Overseeing and
Control

I disagree strongly with the ARIN proposal and the further involvement
of NSI with the registration of TLDs -- 

I feel that the government, and not the commercial sector,
should continue to control and administer domain names.

The registration of a domain name is a diplomatic, and not commercial,
act. US International diplomacy depends on the noncommercial
administration of such domain names. Copyrights of single words are
stupid.

###
Number: 106
From:      "Anthony E. Greene" agreene@pobox.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/11/97 5:23pm
Subject:   Request For Comments on the Registration and Administration of  Internet
Domain Names

-----BEGIN PGP SIGNED MESSAGE-----

Following are my comments, marked with the paragraph and subparagraph of the 
section of the original document which they refer to:

B(2) The establishment of additional TLD's will ease some of the problem. 
Especially an establishment of additional TLD's for commercial organizations.

B(3) The registration entity should be a not-for-profit non-governmental 
organization that operates a primarily technical staff, with legal 
assistance. Parties that have a vested interest in DNS policies (ie 
business) should not be represented. Oversight by an executive agency of the 
government, in coordination with other national governments could ensure 
that policies were adhered to.

D(15) Each registrar should have exclusive control of one (or more) gTLD's. 
Dividing the responsibility of a gTLD among several entities is not good 
management policy. Responsibilities should be *clearly* defined. Keeping the 
responsibilities along gTLD lines is clean and simple.

 --
Anthony E. Greene
CMR 421 Box 361
APO AE 09056

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###

Number: 107
From:      PHD ATKMajic@iname.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/12/97 5:46pm
Subject:   Handling Domain Name controversy

Hi,
     I'm try to make my points brief, not because I don't want my time,
but because I know you must have much mail on this to read.
     First, the present INTERNic monopoly is definitely bogus. The
stated use of the $100 registration fee is to support the Nameserver
architecture, but the way nameservers are maintained, mostly by
educational and commercial entities that don't recieve any support from
INTERnic, has just meant a huge, momopolistic profit for Network
Solutions, and has been detrimental to the development of the internet.
This needs to end!
      Second, the .US domain registry has the right approach, keeping
the registration cost down to $10 per year, and allowing for a network
of registrars who are compensated out of the small fee, but the
COMPLEXITY of the .US naming system, and the long domain names it tends
to produce, severly limit the usefullness of that alternative. The
naming system is severly flawed!
     Third, there DOES need to be a system that allows for competition,
but by turning one monopoly into seven under the Internet Society
proposal does not seem to be any kind of guarentee that pricing will be
positively effected. It seems likely this hand picked group of seven
companies will just be splitting up Network Solutions unwarrented
profits.
      Alternatively, there SHOULD be a non- profit, possibly government
but non- government would be prefered, entity that will oversee the the
domain proccess of allowing other companies to take responsibility for
presenting new top level domains and allowing them to charge what they
feel they need to be profitable, while remaining competitive with other
top level domains. This could either be a system where a large number of
new domains being doled out to companies willing and able to provide top
level domain service, with specific criteria being set by the governing
body, but basically not limiting the number of such domains to an
arbitrary number. This would be based on the .US model, but instead of
following the arcane architecture of the .US system i.e. a server can
administer something like "boston.MA.US", would allow the sub- services
to offer their own unique top level domains i.e. .dog .bob .wow .aol
etc...
      Even though I feel the .US domain system has proven that a domain
registration system CAN be doled out to many hundreds of entities and
still function, to keep the situation from becoming chaotic a slight
variation might be desirable. Using a system similar to the above, with
a Non- profit organizing the specifications for the system, but
auctioning off a fixed number of domains to the LOWEST bidders, on a
limited year contract basis. i.e. allowing maybe 50 new top level
domains (this is not as chaotic as may seem, people already have to
remember the first part of addresses, and often can end up in the wrong
place by assuming it is a .com, a larger number of top level domains
would actually lead to fewer situations, as with the recent internic.com
passing themselves of as internic.net, the real INTERnic), with
allowances in the standards and specifications to allow that number to
increase over time. And LOWEST bidder would be based on the amount per
year the company will charge customers, not what they will pay the new
non- profit oversite organization, the non- profit should recieve a
small set fee per registration to pay for it's costs. Using .US as an
example, maybe $5 per registration going directly to the non- profit,
this fee being adjustable upwards or downward to cover ACTUAL costs, but
limited to a certain percent increase per year.
     This system allows for true competitiveness, as any company wishing
to enter the game could bid on the domains. Since not huge profit, but
reasonable profit, would be the driving force, the fees to customers
would be more in line with actual cost plus a reasonable profit, not the
unwarrented profit that INTERNic has been handed.
     There also would seem to be plenty of incentive for companies to
enter the domain business as a value added approach. i.e. An ISP or
online service could secure a top level domain that reflects the service
i.e. America Online could secure .aol and while not making huge profit
on actual registrations, offer the advantage of a cheap domain
registration only to customers of their online service, increasing the
value of joining the particular ISP or online service. It seems on
reflection that under this type of system, more than 50 top level
domains in the future would be easier to manage than it may first
appear.
     I'll be formulating this a little better and trying to get support
from other users in the future, but I hope you will at least take a good
look at this as it is written now. I know there are kinks in it, but it
seems doable and would allow true competition and lead to more
reasonable registration fees for the expanding number of users wishing
to register a domain.
     Thanks for your time,
      Paul H Desmond Jr.

ATKMajic@iname.com
http://www.geocities.com/Area51/Zone/2090/index.html
[The above email address and URL are (most likely) permanent. You should
always be able to reach me there.]

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###

Number: 108
From:      Kevin Cooter kcooter@usa.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/13/97 10:41am
Subject:   Someone has flat out stolen our trademarked company name and is extorting us
for money

Hello.

I understand you might be interested in public comment on this issue so
I thought I would write to you.  Our small company (less than $1M) has
struggled for the last year to free up our company name (UltraStat) to
be used for our web site (currently cyberstat.com).  The first person
who had it we paid $500 and some company stock to get him to free it up
IN WRITING to us, which he did.  The problem is that internic wouldn't
accept this by normal mail, they demanded I get a response via E-Mail
which this first guy wasn't willing to do, I guess.  I asked them if I
couldn photo copy his signed letter giving us the name (ultrastat.com)
and they told me no.

Great... So while I wasted another 6 months trying to work it out the
way I understood I needed to with internic some other bozo comes along
and somehow (knowing the ropes) attached ultrastat.com.  How? I don't
know and internic won't help me figure it out.

But this new group says they'll let me have it for $1,500 !!!! Can you
believe it!!??? Grrrrr.  That's just plain wrong.  It's useless now. 
They don't use it (they can't because I own the patents, copyrights, and
trademarks) and we won't be extorted.  

If you need any further information or details please feel free to
e-mail me.  Also, check out our sight at www.cyberstat.com.

Best wishes,

Kevin

###

Number: 109
From:      "Thomas Andrew Hart" Thomas-Hart@email.msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/14/97 12:46am
Subject:   internet naming

All federal state and city/county government agencies are "GOV" by
definition. so the use of such a naming convention is "by definition"
DUMB. The agencies all have their names like EPA,DOE,DOD, DOD.NAVY, DOD.AF
etc. That seems more intuitive to me. If I needed to get information from
the Dept of Justice, Marshals office, san Diego California I would look
for something like www.DOJ.USMARSHALS.SD.CA. I have no idea what to us for
them at this sitting. No clue at all. That is just an example. 

For companies the www.sears.retail.store or www.sears.dept.store makes
intimate sense. www.wabc.tv or www.kfmb.tv or www.kabcnews.tv. IS easy to
make up and try to find instead of wasting valuable connect time to find
out if some store, company, or other legal entity exists on the i'net. 

As for someone that sells good or services over the i'net exclusively then
an address like www.internetsellersname.retailpage that identifies that
the site dosen't exist in a storefront someplace. 

Also the use of credit cards over the internet should be outlawed since
there seems to be too many "robberies" on the i'net. 

Times up gotta go.
Thomas-Hart@msn.com

###


Number:110
From:      Michael Bernstein michael@cascadilla.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/14/97 9:30am

The most important aspect of any future domain name rules, as far as
my company is concerned, is that .com domains be made portable just
like 800 numbers.  If there is more than one provider for .com domains,
and you can shift between providers, that will go a long way towards
curbing InterNIC's abuses and hostility towards smaller companies.

Sincerely,
  Michael Bernstein
  Cascadilla Press
  michael@cascadilla.com

###
Number: 111
From:      "Stephen Albanese" salbanes@enterprise.cybersurf.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/14/97 5:34pm
Subject:   Comments on the Registration and Administration of Internet



I think that whoever administers the domain registry in the future
should limit a customer's choice to their company name, personal name
or trademark.  To allow one person to register the name of another
company, product or person is simply ridiculous.  

Who benefits from such a policy?
The registrar does from increased fees.  The person who makes the
registration request benefits on the likelihood that the name
registered will be needed by another party at some point in time.  But
surely the final holder of the domain name doesn't benefit.  

I'd be furious to find out that my name or my company name had been
registered by some speculator thinking I'd pay money to use it.  For
the InterNIC to currently allow such a practice is a discredit to
everyone involved.


Steve Albanese
Manager, Network Services

Cybersurf Inc
312, 1212 - 31 Ave. NE                          
Calgary, Alberta                                 403-777-2000
T2E 7S8                          steve.albanese@cybersurf.net       
                                  

###


Number: 112
From:      David Blunt db@2100.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/15/97 8:46pm
Subject:   Domain name registry

The domain name registry should be an automated system monitored by a
non-profit group formed out of the internet committee and others
interested and involved in the internet.

Network Solutions has exhibited nothing but incompetence in my dealings
with them.  I have a long list of problems with their lack of service,
from failing to move domains to billing payment systems which report
incorrect invoice numbers and won't allow payment when workers there
repeatedly claim that the invoice numbers are correct to fax machines
which never answer, phones which don't answer, and e-mailed requests to
call an extension number which their own phone system says doesn't
exist.

An example of an efficient online registration system as opposed to the
archaic and unresponsive e-mail based system used by Network Solutions
can be found at http://tonic.to which is run by Tonga.  The Tonga system
allows registration, moves and information changes to be done instantly
online.  It's an excellent system, and one which I use as an alternative
to Internic whenever possible.

Thank you,

David Blunt

###


Number: 113
From:      Matthew Tapper matthewtapper@hotmail.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/15/97 10:29am
Subject:   Domain Name Servers

I am concerned over the issue of who controls the rights to assigning
names on the internet. The internet is a worldwide community of
individuals and institutions who would be happy with a clear simple
solution.

With telephones, we are assigned numbers arbitrarily unless we pay for a
specific number. License Plates are the same way. Trademarks are
registered for their value and legal protection. Domain names are simply
the phone numbers of the future - so everyone should pay the same amount
to register a name - and I think the current $50 a year is fine. If you
want to buy someone else phone number because it is more popular then be
prepared to pay for it...

As to how it is administered, Public Trust means Public funded and
administered by representatives of The Public. The United Nations might
be a good place to put such a trust - just a thought.

Anyway,
Thanks for listening,
Matthew Tapper

###

Number: 114
From:      gruponig@lchr.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/16/97 6:23pm
Subject:   website addresses


     I think US sites should end in ".us", just like other countries.  It 
     seems a little arrogant, implying that we're some kind of default 
     nation (although I guess the reason is, the internet was launched 
     here, but that's not a justification).
     Also, I wish ".com" weren't used so much; even non-profits (which 
     could use ".org") sometimes use it.
     Also, though I realize the borders are blurry, I think sites that are 
     mainly informational should have their own ending (".info," you 
     suggest).
     You suggest using the ending ".firm," and maybe that could clear up 
     some of the confusion.
     
     Thank you.
     
     dns@ntia.doc.gov

###
Number: 115
From:      Mo Freedman 76660.2571@CompuServe.COM>
To:        USDOC NTIA Public Affairs 
Date:      7/16/97 1:58pm
Subject:   Soliticitation of public comment

Despite the Clinton administration's stated support for the unfettered, 
unencumbered, self-regulating development of the internet is it not vain to 
hope that your office's role in collecting, and disseminating public comment 
on issues relating to the internet will be an entirely benign one? Should it 
even be the Department of Commerce's responsibility to mediate concensus 
building? The questions arise due to our government's practice of mostly 
accommodating the venality of powerful corporations at the expense of the 
public interest.

Very truly yours,

Moses Freedman
Washington, DC
V: 202-363-5821
F: 202-363-2284
E: 76660.2571@compuserve.com

###

Number: 116
From:      calvin calvin@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/17/97 8:00am
Subject:   domain names

I believe that the federal government or the united nations would be a
wise choice for this endeavor.  If either of these bodies were to be
involved in the process I think they could do a similar job of
regulating the internet the same way that the fcc licenses and regulates
the airwaves.  The scope I must admit should be much more limited to
just governing the DNS part of the internet.  The reason I feel that the
scope should be this limited is that at this time there aren't presently
ways of broadcasting content to an end-user unless they choose to go to
a particular type of site.  I do however believe that as push technology
matures the bodies mentioned above might have to broaden their scope to
decide what content would be apropriate for broadcast through push
technology.  I do want to stress however that there should be very
strict guidelines(at first) and legislation(to follow) that would limit
any censorship to what is broadcast through push technology and that
would explicitly state that any individual or company could put whatever
they want to put on their pages but that they shall not be allowed to
advertise using any content that would not be suitable for broadcast on
a TV network.

###
Number: 117
From:      Garrett M Datz  gdatz@charm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/17/97 1:34pm
Subject:   Domain Name Service Comments


Domain Name Registrations and ownership on the 'net is something that we
must remember started out as a tool, not an asset.  DNS was created with
the purpose of taking a number such as 198.49.199.2 and calling it
www.ntia.doc.gov

DNS was created to make commonly visted sites easier to remember.  At the
time of creation, very few corporate entities were a part of the 'net.  IF
the system has orginally been designed with commercial purpose in mind,
a different evolution would have occurred.  Take the University of
Maryland for instance.  Registered 12 years ago they posses the relatively
simple umd.edu for domain purposes.  However, look at the name
chevychasebank.com and realize that this has gotten a little out of hand.

Possesion of rights on the Internet legally can be difficult.  Can Apple
computers legally claim all uses of the word apple for domain purposes?
In court they won, but a common dictionary word?  Under the system,
someone could have registered that name 10 years ago with no mal-intent
and Apple computers would not have cared.  Why?  No interest in the
Internet.  1994 comes along and all of a sudden its copyright infrigement.

By the way the system is designed, DNS services are a first come, first
serve and should remain that way.  Large corporatation are striking fear
and lashing out into smaller businesses simply for beating them to the
Internet game.  It often appears that there exists a level of perceived
insult from these companies because the 'little' guy took what they
considered to be their 'inherently claimed' domain name.  I wonder how
many businesses in Maryland have Chevy Chase in their officially
registered and trademarked business name.  I know of at least 10.  

My final opinion is that the system is insufficient to handle to demands
and requirements that businesses have.  There is a virtual limit to the
number of possible 'simple', easy-to-remember, common word names that can
have a .com attached to it.  Take baltimore.com and inbaltimore.com.
Comcast attempted to push us out of it by claiming some form of trademark.
How can a public-domain name of a city be owned by anyone?

The registering of 100's of DNS's for the purpose of making a profit
should be altogether stopped.  Enforce a limit of 5 or 10 addresses per
individual or company and make the penalty immediate suspension and
surrender of all DNSs.   Release a strong statement saying that the
registration of a domain name for association with a business is separate
from any other form of commercial trademark and property.  The same with
corporate law, no two companies can posses the same busineess name, no two
can have the same DNS name.  However indicate that they are separate and
distinct.

We must remember that the Internet was created for fostering research,
communication and growth.  It was a tool of the universities and for
research facilities.  Free ideas and free speech was the basis.  DNS is
past its time.  A new concurrent system needs to be designed that will
address the needs of businesses on the Internet.  It is inevitable.
Simply adding more .xxx domains won't help a damn thing.

And the guy at home who may have registered a domain for himself because
he though it was a cool thing to do a few years ago should be protected
from million dollar lawsuits because some company feels infringed upon.

Garrett M Datz
gdatz@charm.net

|------------------------------------------------------------------------|
|  Garrett M Datz          Charm Net, Inc.         Voice: (410) 558-3900 |   
| Director of Sales     2200 E Lombard Street      Fax  : (410) 558-3901 |
|   and Marketing        Baltimore, MD 21231                             |
|------------------------------------------------------------------------|
| Email: sales@charm.net                       URL: http://www.charm.net |
|------------------------------------------------------------------------|

###
Number: 118
From:      "Jay R. Ashworth" jra@scfn.thpl.lib.fl.us>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/17/97 4:18pm
Subject:   Comments concerning the Internet DNS NOI

-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-
Follow my comments on the Notice of Inquiry concerning Domain Name
Service management.  I speak as a commercial consultant on
internetworking and computer systems design with 15 years experience.

I've used the "call and response" format customary to Internet email;
hopefully, my responses will be comprehensible, rather than compost.

>    The Government seeks comment on the principles by which it should
>    evaluate proposals for the registration and administration of Internet
>    domain names. Are the following principles appropriate? Are they
>    complete? If not, how should they be revised? How might such
>    principles best be fostered?
>    
>    a. Competition in and expansion of the domain name registration system
>    should be encouraged. Conflicting domains, systems, and registries
>    should not be permitted to jeopardize the interoperation of the
>    Internet, however. The addressing scheme should not prevent any user
>    from connecting to any other site.
>
>    b. The private sector, with input from governments, should develop
>    stable, consensus-based self-governing mechanisms for domain name
>    registration and management that adequately defines responsibilities
>    and maintains accountability.
>    
>    c. These self-governance mechanisms should recognize the inherently
>    global nature of the Internet and be able to evolve as necessary over
>    time.
>    
>    d. The overall framework for accommodating competition should be open,
>    robust, efficient, and fair.

These first four points are platitudes... but they're well thought out
platitudes.  :-)

>    e. The overall policy framework as well as name allocation and
>    management mechanisms should promote prompt, fair, and efficient
>    resolution of conflicts, including conflicts over proprietary rights.

This is well phrased, but will be quite difficult to manage in
practice.  The precise reasons why, I'll take up shortly.

>    f. A framework should be adopted as quickly as prudent consideration
>    of these issues permits.

In light of the current travails with NSF contractor Network Solutions,
yeah, this is a good idea, too.

>    B. General/Organizational Framework Issues
>    
>    1. What are the advantages and disadvantages of current domain name
>    registration systems?

From an operational standpoint, the major disadvantage to the current
registration system is that Network Solutions appears, based on reports
from a statistically significant number of its customers, incapable of
providing reasonable customer service, from a standpoint of response
time if no other.

If a request is at all out of the ordinary, the systems in place at
NetSol are guaranteed to both mishandle it and delay it.  Even normal
requests are often troublesome.

For example, NSI apparently has an undocumented policy of allowing
the "Host Registration" necessary to use a host as a DNS server to be
done only once for any given IP address.

I'm involved in a situation right now where administrative control of a
network is about to change hands, and I attempted to register two hosts
in that domain to use as servers.  The two registration templates
templates were sent out within 60 seconds of one another, the
"automated acknowledgement" messages came in 2 and 9 hours later
respectively, and 3 _days_ later, _one_ of the registrations was
acknowledged.  The other registration vanished into limbo, and 60
minutes of toll phone calls a week later were necessary to discover
that the registration was bounced "because another host is already
registered with that address".

Inasmuch as the very DNS system these registrations were intended to
support allows multiple names for one address, this is puzzling, but
the lack of response, the lack of documentation, and my total
inability to successfully contact anyone in authority to discuss the
matter are unconscionable.

It _has_ to be possible to provide better customer service than this...
with a $50M+ annual revenue stream.

From a _structural_ standpoint, the current Domain Registration system
is deficient primarily in it's centralization.  Many other components
of the Internet have evolved over the course of the last 20 years, but
DNS and registration administration is just now reaching it's adolescence.

The other major, and probably insoluble, problem is that the DNS system
uses names as addresses.  The problem is that names can change, and
addresses usually shouldn't.  The quintessential example of this is
professional service companies like law firms.

When Trenam, Simmons, Kemker, Scharf, Barkin, Frye and O'Neill loses a
partner and becomes Trenam, Kemker, Scharf, Barkin, Frye, O'Neill and
Mullis, what do you do with all that stationary... and more to the
point, all those bookmarks and web index engine entries, that say
"trensim.com" (or "tsks.com", or whatever)?

But it's _way_ too late to do anything about this now, and I'm not sure
there ever was a time when it wasn't.

>    2. How might current domain name systems be improved?

Caution is needed here; what's at odds is primarily the registration
systems that underlie DNS, not the technology itself.

It's difficult to answer this question without getting "personal" about
NetSol; the primary improvement I can see at the moment would be for
NSI to start earning the incredible amount of money they unilaterally
decided to charge for domain registration service.  This is
particularly true in light of the several major root nameserver outages
which have occured in the week or so since I started composing these
comments.

The other answer to this question is global, and the primary target of
this NOI; I'll return to it after building some more ground work.

>    3. By what entity, entities, or types of entities should current
>    domain name systems be administered? What should the makeup of such an
>    entity be?

There have been half a dozen proposals made for a restructuring of the
DNS registration services infrastructure.  Of all the approaches I've
investigated, I believe that the Denninger/Postel Internet Draft on the
topic is the best thought-out, and most comprehensive.

Extreme care is necessary here: one of the reasons that the Internet
has successfully scaled to the degree that it has in the short amount
of time it took is that the underlying foundations of the protocol
designs and their implementations were subject almost entirely to
engineering discipline; commercial and (say it softly) political
concerns were ignored.

Make no mistake, the expansion of the DNS registration infrastructure
which everyone agrees is necessary must take commercial concerns into
account... but it _MUST_ be designed by engineers; it's an engineering
issue.

We don't allow politicians to design interstate highways.

>    4. Are there decision-making processes that can serve as models for
>    deciding on domain name registration systems (e.g., network numbering
>    plan, standard-setting processes, spectrum allocation)? Are there
>    private/public sector administered models or regimes that can be used
>    for domain name registration (e.g., network numbering plan, standard
>    setting processes, or spectrum allocation processes)?

These issues are covered in the Denninger/Postel draft, but I'll note
that while the primary concerns are infrastructural, and thus engineering,
the main secondary, operational, concern is that of validation of
registration entities, providing for a common set of clearly enumerated
policies (for things like trademark disputes) which all registration
entities must agree upon(/have imposed on them).

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

From an operational standpoint, there _must_ be some centralized agency
with responsibility for the "ownership" of the root of the DNS
namespace (commonly, but incorrectly, referred to as ".").

However, this agency's sole duty should be to delegate it's authority
to TLD registries and arbitrate disputes.  The design of the system and
the charter of this board should be such as to make it structurally
immune to litigation about issues like, for example, trademarks.  It
must have both the authority and the resources to reassign or
temporarily support any domain whose registrar become unable to continue
it's services.

Two points are important here: 

1) Registry services and DNS service provision are related but need not
be combined: it's possible to envision an enviroment in which
registries contract out the actual provision of DNS root services to a
technically competent third party, thus isolating customers from
business problems at the registry entity, and

2) Regardless of the legalities, domain names are being viewed as
property by their holders, and substantial investments are being made
in them, primarily in publicity, but also in customer mindshare.  The
nature of the net is such that it depends on this behavior, and
therefore it must be taken into account when prioritizing such items as
continuance of service.

>    5. Should generic top level domains (gTLDs), (e.g., .com), be retired
>    from circulation?

I think not, for the reasons enumerated above.  Many companies are
actually _named after_ their domain names; and while "no law guarantees
that anyone will be able to continue making his living in a certain
manner" (Judge Learned Hand), neither are flag days looked upon kindly;
justification for such things must be reached by consensus.

>                      Should geographic or country codes (e.g., .US) be
>    required?

See above; ie: no.

>              If so, what should happen to the .com registry? Are gTLD
>    management issues separable from questions about International
>    Standards Organization (ISO) country code domains?

I don't see any good reason to need to separate the topics; the
parallel structures don't seem to be what is causing the problem.

>    6. Are there any technological solutions to current domain name
>    registration issues? Are there any issues concerning the relationship
>    of registrars and gTLDs with root servers?

The current issues appear to be architectural and commercial, rather
than technical and operational, and therefore require architectural solutions.

>    7. How can we ensure the scalability of the domain name system name
>    and address spaces as well as ensure that root servers continue to
>    interoperate and coordinate?

These are mostly technical questions, and I don't claim to be an expert
on the topic, but if I don't see the names Vixie, Halley, Margolin, and
Liu on any paper asserting to answer this question authoritatively,
I'll assume it doesn't know what it's talking about.  That is: there
are experts on these topics, and anyone in authority who flouts them,
or worse, ignores them, does so at the peril of the entire Internet.

(Note to readers: there are other DNS experts, obviously; I simply
picked the top 4 I see on the mailing list as examples.)

>    8. How should the transition to any new systems be accomplished?

This is already taking place.  There are root nameservers which are
_not_ authoritative for .com and the other domains currently run by
NSI; this experiment seems to be working.  There are also currently
operational root servers for views of the namespace which include
alternate TLDs, these include alternic.nic.  In short, as long as the
current operators of the DNS roots (which primarily means NSI) help
rather than hinder, a transition will be a Small Matter of Administration.

It should be noted that the operators of Alternic have apparently
demonstrated poor business judgement in a denial of service attack
agains NSI this past week; this doesn't impugn their technical prowess,
but it _does_ illustrate the importance of the topic, and the degree of
discontent with NSI's current operations extant in the net.

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

Mostly, the size of the TLD tag.  Traditionally, these have been 2 or 3
characters; the D/P draft suggests a maximum of 4 or 5, which seems
sound, but does impose an absolute limit. 

Also, this limit is smaller than it might seem it ought to be: all
components of domain names _must_ be pronounceable.  This is more a
social limitation than a technical one (indeed, the software doesn't 
care), but it's a requirement nonetheless.

>    11. Should additional gTLDs be created?

Let's be careful here: the same namespace issues apply to TLD's that
apply to Usenet newsgroups: creating new ones without extensive
discussion and justification ought to be _expensive_ and _time
consuming_.  Much too little concern is given to namespace control...
which isn't suprising; it's an architectural issue, and most people
aren't architects.  But it's nonetheless crucial to the ongoing
simplification and "consumerizing" of the net of the net.

Case in point example: ".firm".  Is there really anyone who's
_thinking_ about this, who doesn't know which company will register
"ibm.firm" the second it hits the table?  They've probably got an
employee whose job is nothing else, by now.  That is to say,
"horizontal" segmentation of the namespace will not work; the problems
are identical to those in the botched release of the 888 toll free NPA.

Who owns 1 888 FLOWERS?

And ".nom" is simply stupid.

However, in the grand scheme of things, yes.

>    12. Are there technical, business, and/or policy issues about
>    guaranteeing the scalability of the name space associated with
>    increasing the number of gTLDs?

Well, it's likely that as long as the scaling doesn't go too fast, the
technology and policy issues involved can keep up with it.  Ensuring
this is probably the job of whatever group gets appointed to own the
root of the namespace.

And I'll say this again.  This is an architectural function.

Would _you_ want to live in a house designed by a politician?

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

No; ISO3166 registries already exist, and by their nature, probably
should have their policy making continue unimpeded by any except
technical considerations.  The only control that appears necessary is
the "we're the new government, delegate to us now" sort of incident...
and this is large enough that it doesn't really matter _who_ has the
responsibility... professional diplomats will be the implementors.

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

I should think that it would be difficult to have more than one
registrar for a TLD.

The difficulty can be better illustrated by observing that there are
three functions performed by registrars:

1) Policy and administration,

2) registration operations, and

3) nameserver operation.

The first is the largest problem -- policy must be uniform across a
given TLD, and for technical reasons, the current implementation of DNS
makes division of number 3 difficult as well.

>    16. Should there be threshold requirements for domain name registrars,
>    and what responsibilities should such registrars have? Who will
>    determine these and how?

Yes, there should.  There is some merit to the idea, possibly original
to me, that these threshold requirements should be a contractual issue
between the registry and its clients (with the exception of
grandfathered TLD's, of course).

Since these requirements are to protect the clients, the only reason I
can see for externally-imposed requirements are in the event that more
than one entity applies to host the same TLD name simultaneously.

Arbitrating these types of disputes would be another job of the root
operators.

>    17. Are there technical limitations on the possible number of domain
>    name registrars?

Only the available number of registerable TLDs.

>    18. Are there technical, business and/or policy issues about the name
>    space raised by increasing the number of domain name registrars?

Hmmm...  technically, yes.  It becomes necessary to uncouple the root
nameservers from the TLD nameservers.

Business?  Making sure that customers see a _reasonably_ coherent view
of the TLD namespace, from a registration policies standpoint.

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

I believe that this is a question of workload and the ability to handle
it.  I _do_ think that a raw numerical limit wouldn't work the way it
was intended, as there are groups of TLD's that comprise a "concept",
which probably ought to be administered together... like, for example,
.am, .fm, .tv, .news and .mag.  These also comprise a good example of
TLDs which ought to have special policies; I, for example, would allow
in the first three categories only customers who could document an FCC
broadcasting license for the appropriate domain.

>    20. Are there any other issues that should be addressed in this area?

Probably, but I'm pretty certain that the D/P draft addresses them.

>    E. Trademark Issues

Oh, God.

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

This is probably the single biggest problem with the current .com
domain.  As long as the policy is stable, and well documented, and
_doesn't change on a whim_, I'm not sure it matters.  The market will
fix any inequities here.

The reason this is really a problem, though--as is a surprise to no
one--is one of jurisdiction.  There are hundreds of geographical
jurisdictions for trademark control, and usually, the geographical
separation involved is enough.  "Smith's Plumbing" in Alaska probably
cares very little about competition from "Smith's Plumbing" in
Arkansas.

And then along came the net.

There's no perfectly satisfactory solution... 

But disabling a domain name's service that a customer has both paid for
and advertised extensively, without warning, or right of contest --
NetSol's policy -- is simply _not_ acceptable.  NSI has, in fact, this
week violated its own published policy on this topic, suspending
"NASA.COM" with no notice whatever on a complaint from NASA... which
domain had been in service continuously for 2 years previous to the
incident.

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

Nothing would ever get registered.  _Everything_ conflicts with
something, somewhere on the globe.  In the course of ordinary business,
these factors are the responsibility of the business, I see no reason
why they shouldn't stay there.

>                          If so, what standards should be used? Who should
>    conduct the preliminary review? If a conflict is found, what should be
>    done, e.g., domain name applicant and/or trademark owner notified of
>    the conflict? Automatic referral to dispute settlement?

Anything except the sudden "On Hold" will be fine, thanks.

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

Alas, (I say alas because countries have a disturbingly long history of
not being able to agree on these topics), I don't think anything except
an international body of some kind will have jurisdiction.  Understand
that I am not sure I _like_ that answer...

>    24. How can conflicts over trademarks best be prevented? What
>    information resources (e.g. databases of registered domain names,
>    registered trademarks, trade names) could help reduce potential
>    conflicts? If there should be a database(s), who should create the
>    database(s)? How should such a database(s) be used?

This is actually a question of intellectual property rights management,
not one of technology per se, nor the Internet, per se.

Check with Carl Oppedahl; he makes a living on this stuff.  :-)

>    25. Should domain name applicants be required to demonstrate that they
>    have a basis for requesting a particular domain name? If so, what
>    information should be supplied? Who should evaluate the information?
>    On the basis of what criteria?

This is a difficult question to answer.  It might help, but I feel that
the net is a hotbed of opportunity for entrepreneurialism, and
entrepreneurs often do the legal paperwork last.

Besides, this would impose one more load on potential registrars.

No, it's probably a good idea, but I'm not sure it's feasible.

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

I think the root-ops would have to make the appropriate arbitration
policies and require TLD registries to adopt them as part of their
contracts.

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

Nope.  Modify the name in some fashion.  A client is an Allied Van
Lines moving agent.  When Allied went to request a domain name, 
{allied,avl}.{com,net} were all taken.  On bad advice, they registered
alliedvan.net, which they've since modified to the more expected
alliedvan.com.  It isn't great, but the other registrants had good
trademark claims to the other names, as well, so Allied Did The Right
Thing, and solved it's problems by clever _use_ of the technology,
rather than in court.

Note that that's not a "technological fix"...  it's simply an
intelligent _use_ of technology that already exists.

Another example: that client is on the net as well.  When they went to
apply, they discovered that "blocker.com", the appropriate domain name
for this 99 year old company, was already taken...  by some "name
registry company" in Canada for an unknown, and possibly non-existant
client.  So, taking advantage--again--of a little common sense, they
registered "blocker100.com", "in recognition of their upcoming century
anniversary".

>    28. Are there any other issues that should be addressed in this area?

Dozens, but they haven't all come up yet.

Copies of the Denninger draft are available from www.alternic.net, the
Postel inet-draft is in the usual places.

And in closing, allow me to compliment NTIA for soliciting, and indeed
_allowing_ the submission of comments electronically; this much
improves the chances you'll get what you're looking for.  Hopefully, my
comments will prove useful, informative... and not too derogatory to
NSI.  :-)

Cheers,
-- jra
-- 
Jay R. Ashworth       High Technology Systems Consulting              Ashworth
Designer            Linux: Where Do You Want To Fly Today?        & Associates
ka1fjx/4    "...short of hiring the Unabomber, how can I       +1 813 790 7592
jra@baylink.com              get back at them?" --Andy Cramer        NIC: jra3
-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-
-- 
Jay R. Ashworth                                                jra@baylink.com
Member of the Technical Staff             Unsolicited Commercial Emailers Sued
The Suncoast Freenet      "People propose, science studies, technology
Tampa Bay, Florida          conforms."  -- Dr. Don Norman      +1 813 790 7592
-- 
Jay R. Ashworth                                                jra@baylink.com
Member of the Technical Staff             Unsolicited Commercial Emailers Sued
The Suncoast Freenet      "People propose, science studies, technology
Tampa Bay, Florida          conforms."  -- Dr. Don Norman      +1 813 790 7592


CC:        Alan Petrillo 

###
Number: 119
From:      Peter Bachman peterb@support.psi.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/17/97 10:01pm
Subject:   The "other" Internet namespace, c=US.

Dear Sirs,

Allow me to introduce myself, I am Peter Bachman, X.500 Manager
of the c=US public directory namespace, which has been maintained by
PSINet with the cooperation of other entities since 1988. I come
not to "replace" DNS, but offer something that increases the
value of the Internet.

For reference, my url is http://usdsa.psi.net.

Consider for the moment that the c=US namespace, (part of
the X.500 namespace Directory Tree) is a superior
graft to the current DNS Tree if one considers security
and international scope. Of course it has not garnered the
popularity of the DNS namespace but as someone who is both highly
involved in setting up nameservers, debugging nameservers,
and the X.500 system, it is clear that many benefits could
be accrued from a linkage between X.500 standards, and the
DNS system. As you may know, the major user of the X.500 system
is the U.S. Government. 

The X.500 Directory offers the value of unique objects that
can accessed from anywhere in the world. It has not gathered
a level of popularity due to it's complexity. X.400 addresses
offer security, but are not easily memorized, or guessed. In
many popular Internet mail packages, X.400 acts as the "Glue"
between different mail systems. Gateways aleady exist to
transfer between X.400 and SMTP DNS addresses.

I have been working with federal agencies such as the GSA, to explore
the potential for the exploitation of this directory namespace. This can
be a key component to "reinventing government" by listing government
services down to the local town hall, ems, fire station, etc. Within
that community is also room for Main street.

The Internet
has sufficiently "grown up", to require the sophistication
and flexibility of a secure system, as many major corporations have
already discovered. This namespace and related protocols, such
as X.509 Certificates will be a significant cornerstone of
the 20-200 Billion dollar world economic transactions of
electronic commerce over the Internet. It's the same
technology that allows your browser to go to "secure mode" to
send a credit card, or the protocols behind how "SET" work. Poke
under the hood of the Internet and you see it everywhere.

Within the X.500 community we also have been forced to grapple
with issues such as user security, privacy, and uniqueness. Like
the Internet was, the X.500 namespace is now largely populated by 
Government agencies, Universities, National Research Labs, and
some corporations. Much of the namespace is not available to
the public. This has also been a significant drawback
that is being solved.

In order to further and continue goals that were set in place
by the NSF, the X.500 namespace needs to protect the security
that exists in sensitive areas such as DOD, CIA, etc. and
can continue to do so with little public input. However the
same goals that those agencies have, are now being demanded by
the public, unique identification, remote operations, certified
namespace, avoidance of namespace collisions and certification
of transactions using X.509 Certificates for encrypted commerce.

I am willing to talk with stakeholders to expand the role
of X.500 directory services, which can serve up such information
as an X.400 email address, a RFC822 email address, a Uniform
Resource Indentifier, (the newer form of URLS, like http://), public
keys for secure commerce, and much, much more. 

I have requested
from the IANA that linkages to the X.500 namespace be located in the TLD
reserved for international treaty organizations and international
databases, .INT. This effort is beyond the scope of even a major ISP
such as PSINet, which also operates a root nameserver for the
Internet. We have a working relationship with GSA which is
currently managing a challenge project using '93 X.500 technology
which offers even more security, and which the c=US will migrate 
towards.

This technology was far to much ahead of it's time when it
was introduced and the overhead to produce and consume it
was too much, and largely unwanted outside of "mission critical"
applications. DNS remains, and will remain to be a viable system.
However, now we are considering alternatives!

With the introduction of a commercial c=US, that can
not only hold domain names, but people and other objects, all
uniquely indentifed, and linked to other international servers,
users will benefit greatly. The pilot project's usefulness
has largely ended. It is now time for the technology to emerge
from it's comfortable scientific womb where it serves the soldiers,
scientists and scholars, to the glare and popularity of the public eye. 

The complexity of the system will be ecapsulated in the web browser
and other tools using LDAP, the Lightweight Directory Access Protocol
also funded by the NSF at the University of Michigan and promoted
now by major http browsers by Microsoft and Netscape.

Shall we "sleep" this technology much longer? Or shall we
dust it off and take off to a networked world where a
name really means something?...

To paraphrase Charles Babbage:

"What's in a name, it's only a box until you put something
in it"

For everyone who "missed" getting their corporation into the DNS 
namespace, I'd suggest you consider this very seriously. You
could go from the mailroom to the executive suite.

(standard disclaimers, relating to my own personal opinion).

thanks.

-pb

###

Number: 120
From:      Earl Tyson earlt@strato.net>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/18/97 1:42pm
Subject:   Domain Names

I cannot see how one organization - whether governmental or commercial -
can have a monopoly on such a thing as domain names - especially when we
are talking about an international entity such as the internet.  I am not
sure I even understand the National Science Foundation's ability to award
such a monoply in the future, since the internet seems to have transformed
more of a commercial / educational / recreational focus, instead of a
scientific / defense focus. 

I do not feel that governments, businesses or individuals have the right
to monopolize more common names, such as "five" or "street" or "house",
for example.  But if a company or other entity has a trademarked or
legally recognized name, I do not feel that this should be violated by
infringements by others.  The need for sanity in assigning and monitoring
domain names is now very evident - perhaps reassigning of some domain
names is now in order. 

###
Number: 121
From:      enquiry@allmi-care.co.uk>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/18/97 4:07pm
Subject:   Whither DNS registrations after InterNic

I have read with interest the comments on both sides concerning the
future of domain registrations, and feel that the only way to go is
through the IAHC/WIPO proposals. I recognise that there are some
people who feel that it is undemocratic and outside of the control
of any one national government, but this is in my view just the
moaning of a few money-grubbing concerns. The plans outlined by
WIPO will mean that a true market will open up with competitive
pricing, instead of the monopoly that exists at the moment.

I am all for the Ad Hoc Committee's proposals. In my view any plan
which does not have widespread support across the whole world will
just convince many that the internet is an agent of American world
domination and will signal the end of internet business before it
has had a chance to grow.

Yours Sincerely,

Godfrey N Nix  C.Eng. MBCS B.Sc.Tech(Hons) Dip. Ed.
Network Operations Manager
East Midlands Network Ltd
Nottingham, England

dont forget to remove the spamguard befor replying to this message!


###


Number: 122
From:      "Donna Kay McKinney" 457844958@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/19/97 12:32am
Subject:   Management of Domain Names

Please do not let what happened to the phone company happen to the Internet.  
Considering the millions of people who use it, it runs extremely efficiently.  
Only one company at a time should handle the registration of domain names.

Donna Kay McKinney

###
Number: 123
From:      "Philip H Mills" philm@txdirect.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/19/97 9:38am
Subject:   Domain Name  Comment/Opinion/Suggestion

The current controversy over domain names is occuring simply because of the
scarcity of such names under the current system.  

My suggestion is rather mundane.  I hope it can be accomplished.
Throw numbers into the domain name.
Instead of  just .com   how about  .com1, .com2,.....  com346 and so on.
The same for  .gov or .net. or whatever the domain name is.   America
On-Line uses a combination of letters and numbers to allow for unique
naming of each of its 2 million+  individual users.   You would be
surprised how well users can remember or find a name if displayed on
television today or record as their favorite or priority website no matter
how complex it is. 

My second suggestion is for names within the United States (or perhaps one
day the whole planet earth) you might want to link the names to the zip
code, giving the user some immediate idea where the address is actually
located.....
for example   .com78244 would be a commercial address in San Antonio,
Texas.
This suggestion is not in line with the first unless it was broken out
further, such as 
.com346-78244, indicating a rough defiintion of "commercial business
registered in the com346 series, headquartered or residing with the 78244
zip code area." 

And so on. 

Phil Mills, 7930 Sonny Ridge, San Antonio, Texas 78244

###
Number: 124
From:      "Wes Saunders" 42west@email.msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/19/97 1:15pm
Subject:   domain names survey

As a avid and frequent user of the internet, both for business and
pleasure, it occurs to me that no single corporation, business, enterprise
or individual should have "exclusive" rights to domain names and the
subsequent master data.  It should be recognized that any holder of a web
site or page, places that information on the internet and at that point,
becomes "public domain".  Any exclusivity would violate the main intent of
the purpose of internet communication.  The internet and it's content are a
public domain, however management of such a huge source of data can be
extremely complicated (as noted w/ the events of Thursday, July 17,1997) 
One upper level administrator caused a severe breach in the flow and
control of information on the super highway, causing a major traffic snarl.
 But from this, we learned that the process, along with it's operators, are
human, and thusly, are subject to mistakes and errors.  This, in my
opinion, is what makes the internet the place that it is. The high tech
world is very "in-human", but it has to be controlled "by humans"  ,
because the down side would be, or could be, total, world dominance by a
newly created "cyber society" of machines.
 One solution to the domain name game, would be an international
Association of Internet Traffic Engineers (IAITE) (Does not exist)  Who's
main task would be the organization and management of upper level domains
throughout the internet world.
An association funded by attachments to the advertising income off all who
use the net for business interests. This, on the whole, would amount to a
very small percentage (less than 1%) of all the advertising dollars earned,
but would adequately fund the Association in order to operate.  Management
of the Association would be by International Professional Registry, and
election, via the internet, of the main body.  Each individual, holding the
upper management positions, would be bound to the other, with no individual
manager having autonomy.  Domian names could then be randomly registered
via the Associations mainframe, in a timed entry basis.
The mainframe's base program and it's associated error checking systems,
would be created by the first body elected to the association, with
subsequent association chair-persons having ammendment authority by quarum
vote.   The base program itself, would use the most current, logical, and
effecient methods currently available to create the domain names and
registries.
 It is understood that this is just a foot note in the massively
complicated internet world, however, it is imperative that the greatest
minds and developers of these programs and systems have the opportunity to
manage and administer the net.
We, as a people, do not need any type of Government intervention, political
connections, or other non technical body attempting to run an international
information and technology system.  This is a golden opportunity to begin a
true world education, which will enhance our chance as a world society, to
learn and create the fundamental understanding required to bring peace and
enrichment to all of the people of this small planet.

Wes Saunders
Raleigh, NC USA

###


Number: 125
From:      "Randy Huggins" randy@hdsi.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/20/97 12:54pm
Subject:   Commerce's Request for Internet Domain Name comments

Below please find my response to the Department of Commerce's request for
comments on Internet Domain Names.  In addition to addressing Commerce, I
have also CC'd this message to my state Senators and Representative, as
well as the author of the original MSNBC article.

The DNS software system is inherently hierarchical, and therefore lends
itself to distributed control and almost limitless scaleability.  The DNS
software isn't the problem; the problem is that we haven't structured the
domains to parallel any real-world control system hierarchy. We're still
struggling with a naming scheme which only made sense for the United States
based "Arpanet" of twenty years ago.

The first part of the solution seems obvious to me: The United Nations
needs to take over control of the top-level (and only the top-level) domain
names, and base them on country abbreviations.  Its the ONLY thing that
makes any sense.  ".COM", ".EDU", ".GOV", and the like at the top-level
must go away.  There is no central control authority on a global basis to
parallel such a naming structure, contrary to what the IAHC might believe.

Until the UN (or IAHC) takes over the DNS server computers which resolve
top-level names, I contend that market forces will provide an interim
solution.  Nothing in DNS says there has to be an InterNIC, only that there
has to be a way to resolve the top-level domain names.  Let market forces
decide if the Network Solutions company continues to have any customer base
for serving ".COM", ".EDU", etc. names after its National Science
Foundation contract expires.

Even without the UN control authority in-place, the United States has to
move toward a system which puts our names under the ".us" top-level domain
name which already exists.  The few thousand huge, multinational companies,
with their household names like "IBM.COM" loose, but I contend there is no
miracle nor acceptable compromise which will solve this problem, and it
can't be allowed to impede progress toward something that can be made to
work.  Market forces may again prevail and fill the transition void here,
as some enterprise like Network Solutions may continue to serve ".COM"
names (assuming there isn't a country named ".COM" by the UN).

In terms of the present debate, the US government must fund or let a
contract for somebody to administer our top-level (".US") domain name
server computers.  Fortunately, in this design, this administration doesn't
include much in the way of processing new requests for domain names, since
a federal control authority will already have dictated what they are.  The
work done by the contracted service organization is primarly the "care and
feeding" of the DNS server computers for the ".us" domain and their
connected networking paraphenalia.

In the architecture described herein, there are at least two naming schemes
for the second tier which might make sense.  The first would be based on
state/commonwealth with a ".fed" thrown in for completeness.  The second
would be at least partial preservation of the ".COM", ".EDU", ".MIL"
hierarchy we have now, only underneath a ".US" top level domain.

I'm partial to the state-based second-tier myself.  Companies and
educational institutions are chartered by the states, and it seems obvious
that the states should be the control authority for their own third-level
domain names  (e.g. IBM.NY.US or NYU.NY.US).  A given state may or may not
want some part of the "COM", "EDU" hierarchy within its own state (e.g.
IBM.COM.NY.US or NYU.EDU.NY.US), and control the entities through their own
departments of Commerce and Education, for example. The point being that
this approach has a state-based control authority which parallels the
second-tier domain names.  In this approach, each state would fund or
contract out the work of administering its own domain and running the
associated DNS computers.

The competing idea within my architectural concept is that we preserve some
of the current commercial, educational, and government naming concepts in
the second tier, but force a correspondence between each second-tier name
and a government control authority.  It makes some sense to allocate ".COM"
to the Department of Commerce, ".EDU" to the Department of Education, and
".MIL" to the Department of Defense, giving us names like "IBM.COM.US",
"MIT.EDU.US", and "AF.MIL.US".  Others might proliferate, but it doesn't
matter as long at there is a parallel control authority.  The states might
be their own second level domains (e.g. "NY.US") or might be allocated
third-tier stature under ".GOV.US" (e.g. "NY.GOV.US"), administered by the
Department of the Interior.  Here, each government agency control authority
would fund or contract out the work of administering its own domain and
running its associated DNS computers.

The political strengths and weaknesses of the two approaches will be more
apparent to others than to the author.  On more pragmatic grounds, a
state-based approach is the only one that really makes any sense.  In
addition to adhering to the management precept of delegating as much
responsibility as possible, the state-based approach puts the control and
administration of corporate and educational institution DNS names where
those entities are chartered.  Further, on purely technical grounds, the
state-based approach will be a better performance choice by reducing the
bottleneck that a centralized ".COM.US" domain scheme would perpetuate.

Conclusion:  The domain naming scheme which was good for the tiny
"Internet" of twenty years ago must be abandoned.  The foundational
architectural design of DNS scales quite nicely to global proportions, but
the tiers of domain names must be re-designed to parallel world-wide
hierarchical control authorities.

Randy Huggins
VP Engineering, HDSi
randy@hdsi.com
Tel: 1.610.692.4109



CC:        NTIADC40.SMTP40("senator_specter@specter.senate.go...

###
Number: 126
From:      "Kevin Kelly" natsuo@hotmail.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/20/97 4:49pm
Subject:   Domain Names and the Company with the Monopoly

I think the fact that Network Services Inc. is monopolizing domain name 
services is wrong. They are providing a service. It isn't their decision 
who we as the global community pick to provide that service, whether it 
be one company or several.

--Kevin Kelly
natsuo@hotmail.com

______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com

###
Number: 127
From:      "Steve Janss" Jansys@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/20/97 6:48pm
Subject:   Domain Names

1.  Maintain support for the current top-level domain names (.com, .edu, 
etc.).  The current economic viability of the Internet Market relies heavily 
on consistancy in this arena.  Changing these top-level domains will 
significantly, and unnecessarily wound the Internet Market.

2.  Add additional top-level domain names to ease crowding and domain-name 
disputes.

3.  Increase the number of TCP/IP addresses from four three-digit numbers to 
six three-digit numbers.  Make it backwards-compatible by adding the 
additional six digits to the end.  In other words, 132.43.253.224 would become 
132.43.253.224.000.000.  Why increase the numbers by a million?  Why not?  Why 
back everyone into the corner of having to do it again in another twenty 
years?  Think ahead!  It's going to be expensive enough as it is...

Steve Janss, Jansys Information Systems
jansys@msn.com

###


Number: 128
From:      Brett M Hogden hogden@rge.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/21/97 9:52am
Subject:   Comments on domain names

-----BEGIN PGP SIGNED MESSAGE-----

[The address to which I am sending was listed in an MSNBC article
http://www.msnbc.com/news/84135.asp, as of 21 JUL 1997.]

I have been passively following the "controversies" for more than a
year, wading through the thousands of e-mail messages sent to the
three or four mailing lists that are most frequently used to discuss
Domain Name system policies, reforms, &c.

I am unsure what form the comments being requested should take.
However, at the very least I would like to submit my comment to the
effect that the gTLD Memorandum of Understanding (MOU) put forth by
the International Ad Hoc Committee (IAHC) seems the most reasonable.
If the required format for comments is something more formal than
this, please let me know.

As a citizen of the United States of America, I am happy to see our
country take an *interest* in how things work out.  I do believe, tho,
that we are just one country in the world and that the Internet is a
world resource.


Thank you,
brett
===
Brett M Hogden, Distributed Systems Architect, Rochester Gas & Electric Corp.
e-mail: hogden@rge.com       vox: +1 716 724 8729        fax: +1 716 724 8227
     Key fingerprint = B1 8D 7E 77 7D 0A 84 AE  C2 49 A4 CC 2E 1D B5 94

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###
Number: 129
From:      "Joseph Geretz" JGeretz@ucs.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/21/97 12:07pm
Subject:   Net Infrastructure

The best model for the identification of a particular individual or
organization across the globe is already in existence in the form of the
global phone system. Every phone number is uniquely identified by Country
Code, Area Code, Exchange Group and sequence number. This method eliminates
the competitive edge which is arbitrarily assigned by giving a favorable
domain name to a single user across the US while disenfranchising other
organizations with the same business name.

As for searching for a site by user friendly name, each domain should be
allowed the use of up to a certain number of keywords. The same
restrictions on the use of domain names can be imposed on keywords (e.g. no
use of someone else's registered trademark).

I would be happy to discuss this with you in more depth if you wish.

Thank you,

Joseph Geretz
(JGeretz@ucs.net)

###


Number: 130
From:      Carl Oppedahl carl@oppedahl.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/21/97 9:21pm
Subject:   comments

The Department of Commerce has requested comments on the current and
future system(s) for the registration of Internet domain names. 

I am Carl Oppedahl, a partner in the intellectual property law firm of
Oppedahl & Larson.  Our firm's web site is http://www.patents.com>.  I am
submitting these comments via email as requested by the Department of
Commerce.  In addition, these comments are available in HTML on our firm's
web site at http://www.patents.com/nsi/ntia.sht>, with active links to the
URLs cited herein. 

It should be appreciated that this proceeding has the potential on the one
hand to cement into place NSI's monopoly on COM domains and its
multimillion-dollar income stream as well as its flawed policies regarding
trademarks, and on the other hand to remove NSI's monopoly and render its
policies irrelevant.  Thus, the stakes are extremely high.  I have no
monetary interest in the outcome of this multimillion-dollar struggle.  My
interest in this struggle is only as a member of the Internet Community,
and as a critic of NSI's flawed trademark policies.  (An account of NSI's
flawed trademark policies may be seen at
.) I have written two law review articles
that discuss many of these issues:  "Analysis and Suggestions Regarding
NSI Domain Name Trademark Dispute Policy", 7 Fordham Intellectual
Property, Media & Entertainment Law Journal 73 (1996), draft available at
. 

"Remedies in Domain Name Lawsuits:  How is a domain name like a cow?", 15
John Marshall Journal of Computer & Information Law 437 (1997), draft
available at http://www.patents.com/pubs/jmls.sht>. 

As a general matter, I observe that the present comment request from the
Department of Commerce is too little and too late.  This ground has
already been well plowed, and most issues well settled, in the open
comment proceedings of the Internet Ad Hoc Committee
http://www.iahc.org/>.  Thousands of comments were received in that
proceeding and all the issues raised now by the Department were fully
aired previously in the IAHC comment proceedings.  (The comments may be
seen at http://www.iahc.org/contrib/dns-cont.html>.) There is the very
real danger that the Department's present proceedings will harm the
Internet rather than help it, by injecting uncertainty into the process
during the critical remaining months between now and the expiration of the
NSI contract in March of 1998.  It is crucial that the Department conclude
its proceedings and arrive at its recommendations promptly, well before
the end of 1997. 

In the comments that follow, I have set off the NTIA text with ">"
characters so that the reader can see what questions were posed by NTIA
and what answers I have offered.  >A. Appropriate Principles

>Are the following principles appropriate?  Are they complete?  >If not,
how should they be revised?  How might such principles >best be fostered? 

>a. Competition in and expansion of the domain name registration >system
should be encouraged.  Conflicting domains, systems, and >registries
should not be permitted to jeopardize the >interoperation of the Internet,
however.  The addressing scheme >should not prevent any user from
connecting to any other site.  >b. The private sector, with input from
governments, should develop >stable, consensus-based self-governing
mechanisms for domain name >registration and management that adequately
defines >responsibilities and maintains accountability. 

>c. These self-governance mechanisms should recognize the >inherently
global nature of the Internet and be able to evolve >as necessary over
time. 

>d. The overall framework for accommodating competition should be >open,
robust, efficient, and fair. 

>e. The overall policy framework as well as name allocation and
>management mechanisms should promote prompt, fair, and efficient
>resolution of conflicts, including conflicts over proprietary rights. 
>f. A framework should be adopted as quickly as prudent consideration >of
these issues permits. 

These are all important principles.  The Internet has come to be accepted
and embraced by academics, business people, governments, and the world
population generally, in large part because it is *not* controlled by any
one government or post office or corporation or telephone company.  The
early structure of the Internet, designed so that loss of any one node due
to war would not keep the Internet from continuing to function, now serves
admirably to deny any government or post office or corporation or
telephone company a choke-point on the Internet.  This denial of
choke-points has allowed the Internet to serve as a communications channel
for human-rights advocates in troubled countries, and is likely to promote
the free flow of ideas even in countries that resist it. 

The Internet is the strongest technological agent of social change in this
decade, transforming entire industries and media and educational systems. 

March 31, 1998 is a critical day for the Internet.  It is the expiration
day of a five-year contract in which the National Science Foundation
entrusted administration of an important part of the Internet, the
registration of domain names ending in COM, to a contractor called Network
Solutions, Inc.  COM domains existed before NSI entered into its five-year
contract to administer them, and COM domains will exist after the
five-year contract reaches the end of its term.  What will happen to COM
domains on that day?  There are two possibilities:  1.  NSI may continue
administering COM, but instead of answering for its actions to the
National Science Foundation, it will answer to no one.  Such
administration would presumably continue indefinitely.  NSI would be free
to devise new and even more flawed trademark policies, and would be free
to set any prices it chooses for the continued use of COM domains.  NSI
would have a choke-point on the Internet.  NSI, which has always been
secretive, will presumably devise its new policies in secret, disclosing
them to the Internet community only after the policies are set.  2.  The
administration of COM would pass to a competition-based system in which no
single company would have a choke-point on COM domains, a system in which
decisions are made on an open record. 

As I write these comments and consider the two possible futures for the
Internet community, I am reminded that Hong Kong has just a few weeks ago
been absorbed into the People's Republic of China due to the arrival of
the expiration date of a treaty between the United Kingdom and PRC.  PRC
has shut down Hong-Kong's elected government and has replaced it with a
new government, the members of which are appointed by PRC. 

Close study of the text of the five-year contract between NSF and NSI
shows that NSF made clear provision for an orderly succession of power
over COM upon the expiration of the contract.  (The contract may be seen
at http://rs.internic.net/nsf/agreement/agreement.html>.) Under the
contract, NSF can write a letter to NSI, ordering it to hand over "a copy
and documentation of any and all software and data ... in such form and
sufficient detail as to permit replication of the work by a reasonably
knowledgeable party or organization".  Among those members of the Internet
community who have been following this issue closely, this is referred to
as "The Letter".  If NSF sends The Letter, then NSI has to hand over
everything required for NSI's successor to take over the administration of
COM.  If NSF fails to send The Letter, then NSI, due to its unique
position as physical possessor of the software and data, will be capable
of denying anyone else the ability to administer COM, and NSI will
continue indefinitely as the administrator of COM.  NSI will no longer
have a contractual relationship with NSF, and will not be obligated to
answer to NSF. 

Thus, the most critical event of this decade for the Internet community is
whether NSF does or does not send The Letter to NSI.  And if NSF fails to
send The Letter (or fails to do so in timely fashion, which amounts to the
same thing) then that will be the end of the matter.  I was, frankly,
dismayed to learn of this NTIA comment proceeding, and of the recent
establishment of a committee of US government administrative agencies to
discuss the future of the Internet.  I was dismayed because comment
proceedings and government committees have a way of dragging on for months
and then years before anything meaningful happens.  We don't have years,
and we don't have many months, in which to influence the future of the
Internet.  If this comment proceeding is to benefit the Internet community
rather than harm it, this proceeding will have to reach completion well in
advance of the critical date of March 31, 1998.  >B.
General/Organizational Framework Issues

>1. What are the advantages and disadvantages of current domain >name
registration systems? 

At present the Internet has approximately 180 domain name registration
systems, and each has its own advantages and disadvantages.  Most of those
approximately 180 domain name registration systems are associated with
two-letter country codes and are administered within the respective
countries.  As such, they fall outside the purview of this comment
proceeding.  The only domain name registration systems within the scope of
this proceeding are (1) the US domain, and (2) the domains presently
administered by NSI under the contract ending March 31, 1998, namely COM,
EDU, GOV, ORG, and NET.  Nobody fights over EDU or GOV domains;  they are
noncontroversial and the part of the database containing EDU and GOV
doesn't change very often.  What people fight over is COM domains, and to
a much lesser extent they fight over NET and ORG domains.  By far the
majority of Internet domain names are COM domains, which makes it
important to talk about the advantages and disadvantages of the current
domain name registration system for COM.  It is also relevant to discuss
the domain name registration system for US. 

The advantage of the current COM domain name registration system is,
briefly, that the trains are running on time.  People who sign up for a
new domain name often find that the new domain is working within just a
day or two. 

It is also true that DNS lookups are fast and efficient, but this is not
to NSI's credit.  DNS lookups are fast and efficient due to the efforts of
the Root Level Servers, the majority of which are not run by NSI and will
presumably continue to provide fast and efficient service regardless of
what happens on March 31, 1998.  (A list of the Root Level Servers may be
seen at http://www.patents.com/nsi/roots.sht>.)

The chief disadvantages of the current COM domain name registration system
are several.  First, there is the great risk that the present system will
develop into a permanent monopoly held by NSI.  Such a monopoly would
subject the Internet community to NSI's whims regarding trademark policies
and annual fees.  If NSI's track record in these areas were favorable, one
might not fear such a monopoly very much.  But NSI has a poor track record
in both areas.  The chief disadvantage of the current US domain name
registration system is that it forces a geographic specificity that is
unworkable for many businesses.  A company located in Manhattan (and has a
domain name COMPANY.NEWYORK.NY.US) that later moves to Plano, Texas will
not want to change its web sites, email addresses, stationery, and
business cards to COMPANY.PLANO.TX.US. 

Other disadvantages of the current US domain name registration system are
that it is fragmented and that various sub-registrars have unpredictable
pricing for their services.  >2. How might current domain name systems be
improved? 

The main area for improvement would be the transfer of COM away from a
monopoly registrar to a shared-database set of registrars.  A related area
for improvement is the elimination of NSI's flawed domain name trademark
policy. 

>3. By what entity, entities, or types of entities should current >domain
name systems be administered? What should the makeup of such >an entity
be? 

COM domains should be administered as a shared resource, just as North
American toll-free numbers are shared among long-distance carriers.  The
IAHC proceedings, in which this was all fully considered, recommended this
many months ago. 

>4. Are there decision-making processes that can serve as models >for
deciding on domain name registration systems (e.g., network >numbering
plan, standard-setting processes, spectrum allocation)?  >Are there
private/public sector administered models or regimes >that can be used for
domain name registration (e.g., network numbering >plan, standard setting
processes, or spectrum allocation processes)?  >What is the proper role of
national or international governmental/ >non-governmental organizations,
if any, in national and international >domain name registration systems? 

There was a time when all toll-free numbers in the United States came from
AT&T;  it was a monopoly provider of such services. 

Then the FCC noted that there is simply no good reason for AT&T to be a
monopoly supplier of such services. 

The transition that the FCC followed went like this.  First, the FCC freed
up some numerical combinations (e.g. 800-444 and 800-777) that had
previously been "reserved" and not used by AT&T.  These combinations were
given to competitors such as MCI and Sprint.  During this phase of the
transition, anybody who wished to get a toll-free number from a carrier
other than AT&T was stuck using a number in the range permitted to the
alternative carrier.  For anyone who already had a well-established
toll-free number, such as 1-800-FLOWERS, the "competition" was unhelpful
-- such a customer could obtain non-AT&T service only by giving up the
established telephone number and switching to a different one that no one
had ever heard of before. 

After some years, the transition moved along further, and "800 number
portability" became possible.  A customer that had an 800 number
administered by AT&T could, if desired, switch that number over to MCI or
Sprint.  And it's that way today.  A person hoping to sign up for a new
toll-free number can call any of several carriers, and that carrier (which
need not be AT&T) can check to see if the number is available.  If it is,
then the carrier can place the number into service for the customer. 
Later, if the customer wishes, the customer can move that number to a
different carrier. 

What NSI proposes for the future of COM is that NSI will run COM forever,
answering to no one.  This proposal, if followed, would be very good for
NSI and very bad for the Internet community.  It would freeze the Internet
forever in a terrible condition that is quite comparable to the mid-phase
of the FCC's toll-free transition:  anyone who has a well-established
domain name, such as flowers.com, can obtain non-NSI service only by
giving up the established domain name and switching to a different domain
name that no one has ever heard of before.  This might not be so bad if
NSI's behavior had generally been good.  But, as discussed elsewhere in
these comments, NSI's behavior has been bad.  NSI is forcing a terribly
flawed trademark policy down the throats of its customers.  And NSI
charges annual fees that have been criticized by many.  There is no
assurance that NSI will, in future, confine itself to its present flawed
trademark policy -- for all we know it will continue to revise it and make
it worse.  And there is no assurance that NSI will refrain from increasing
its annual fees, perhaps unreasonably.  The American market for toll-free
telephone service differs from the market for domain name registration
services ("DNRS") in that for telephone service there is a clearly defined
regulator whose power extends indefinitely into the future, namely the
FCC, while for DNRS the only regulator with clearly defined power is the
NSF, and NSF has stated that it will abdicate its power in 1998.  Thus,
while there was "all the time in the world" to set right whatever there
was that needed setting right with telephones, in the case of DNRS we can
take all the time we want as long as we figure it out by about December of
1997. 

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

Many commenters have pointed out that the present fixation by much of the
Internet community on COM domains is, in large part, a result of
unfortunate aspects of the historical management (more clearly,
mismanagement) of the US domain.  If there had been a COM.US domain years
ago, for example, instead of a COM domain, it seems likely that many of
today's difficulties regarding COM would not have come to pass.  COM.US
would be squarely within the power of the US government to control, for
example, where COM is by its nature more multinational (or non-national). 
But history is history;  the past cannot be changed and all we can do is
try to figure out what to do next.  The plain reality is that the Internet
and the Web rely, for their function, on stable domain names and URLs.  It
would be extremely disruptive to eliminate any top-level domain or any
large class of higher-level domains.  The social cost of eliminating
existing COM domains would be profound, in the billions of dollars.  (This
is part of why NSI's monopoly, if permitted to go on forever, would be so
valuable to NSI.) There is much to be said for closing off new COM
registrations and grandfathering the existing COM domains.  This would not
disrupt the Internet or the Web at all, and would have the healthy effect
of diverting future domain name registration activity to the ISO country
code domains.  NSI will, of course, fight this closing-off notion tooth
and nail for obvious reasons.  And the fact is that there probably is a
role in the Internet for non-country-specific domain names, so long as it
can be administered in a fair and reasonable manner.  (For reasons
discussed elsewhere in this Comment, it is suggested that fair and
reasonable administration of COM and other gTLDs is only possible if NSI's
monopoly is kept from continuing forever.) Two futures, then, are
acceptable:  thwarting NSI's monopoly on COM, or closing off new COM
registrations.  The third choice, permitting COM to be monopolized by NSI
forever, is unacceptable. 

>6. Are there any technological solutions to current domain name
>registration issues?  Are there any issues concerning the relationship
>of registrars and gTLDs with root servers? 

The North American Numbering Plan (NANP) for toll-free numbers is a simple
and straightforward example of a technological solution to be emulated. 
There is a central database of toll-free numbers administered by a neutral
party (Database Service Management, Inc., a subsidiary of Bellcore, which
interestingly has recently been purchased by the same company that owns
NSI).  Someone who wants a toll-free number can go to any of several
long-distance carriers (e.g. AT&T, MCI, Sprint) and the carrier makes a
query to the DSMI database and registers the toll-free number.  DSMI's
database is paid for by contributions from the long-distance carriers and
its costs are modest, playing almost a nonexistent role in the prices
charged by the long-distance carriers. 

NSI would have us believe that the database it administers is somehow a
natural monopoly -- that administering it is rocket science and it would
be a mistake ever to change it.  But the database which NSI administers
(under a five-year contract that expires in 1988, recall) is only a little
over a million records.  It would fit easily on the hard disk of a
personal computer.  The NANP toll-free database, by comparison, handles
some ten million toll-free number records.  The database is an order of
magnitude bigger than the NSI-administered database.  It works fine, and
has worked fine for several years now.  It is a "shared" database and the
sharing works fine.  It is evident from this that there is no "natural
monopoly" regarding the administration of COM that should somehow justify
standing idly by and letting NSI have a permanent monopoly on COM.  The
existing technical solutions for sharing North American toll-free numbers
are more than adequate for sharing COM among registrars. 

A related issue raised in this question is the relationship to the root
level servers.  Ever since before NSI's five-year contract began, the
system was set up that the contractor (presently, NSI) would perform its
updates on a single server called the "A" root level server.  Then on an
automated basis, the other root level servers would obtain the updates
from the "A" server.  In this way, any member of the Internet community
would get the same results (e.g. viewing a web site or sending a piece of
email) regardless of which root level server that member might query. 
This system has worked extremely well from the days before NSI to the
present.  A similar relationship exists for NANP toll-free numbers.  DSMI
updates a central server indicating *which* carrier is responsible for
each toll-free number that is in service.  These updates are coordinated
from the various long-distance carriers that offer toll-free telephone
service.  This database is propagated in an automated way to telephone
switches all over North America.  The result is that you can throw a dart
at a map of North America, go to that location, dial a toll-free number,
and get the same result as if the dart had landed elsewhere.  It is
commonplace to order a toll-free number in the morning and have it working
across all of North America by afternoon. 

The shared COM future would work out the same way.  Competing registries,
offering COM domain registration services, would provide inputs to a
neutral registrar.  The registrar would maintain the "A" server (or its
successor if some territory battle with NSI takes place).  The other root
level servers would then take their updates from that server just as they
do now.  Recent service lapses by NSI illustrate that NSI is not
infallible in its administration of the database. 

In early July 1997, NSI made an unpublicized decision to make it
impossible for the general public to download copies of the previously
publicly accessible COM database.  The reprogramming by NSI had the
unintended effect of making it impossible for the root level servers to
obtain *their* updates from NSI's "A" server.  Thus, for several days
members of the Internet community would get inconsistent results when
looking up domain names, depending on which of the several root servers
they happened to query.  People with newly created domain names or
recently updated IP address information were randomly unaccessible to the
public.  It was only after someone outside of NSI (Paul Vixie, operator of
one of the root servers) happened to notice the malfunction that NSI
corrected its programming to permit the root level servers to obtain the
updates.  The incident highlights a striking difference between NSI's way
of doing business and the traditional ways of the Internet community.  The
Internet has heretofore been consensus-driven.  Any change in the software
that supports the Internet has normally taken place only after it has been
discussed by the community.  In this way, imminent mistakes are often
identified and corrected before they cause harm.  In contrast, NSI reached
its decision to change the access permissions to the database in secret,
and did not reveal the change until days later, after Mr. Vixie noted the
out-of-date status of data in the non-A root level servers and asked NSI
what was wrong. 

In another incident, this one in mid-July 1997, NSI corrupted its root
server file.  NSI loaded the corrupted file into its "A" server and passed
the corrupted file to the rest of the root servers.  What followed was a
severe disruption of Internet traffic that reached the front page of the
New York Times.  The disruption was first noticed in Europe, where
early-morning emails and web requests were incapable of being handled.  By
mid-day in the U.S., members of the North American Network Operators Group
(a cooperative body of operators of systems connected to the Internet)
were discussing the problem and trying to figure out how to work around
it.  It appears that NSI first heard of the problem from persons outside
of NSI and corrected the problem only afterwards.  It was not until late
in the day that all of the root servers had been reloaded with current,
non-corrupted data. 

To reiterate, NSI would have everyone believe that administration of the
COM domain name system is difficult and that it would be a mistake to
entrust it to anyone else.  But NSI is fallible, just like anyone else.  A
concern for proper operation of the database should not lead to a decision
(actively, or by inaction) to give NSI a perpetual monopoly over COM.  >7.
How can we ensure the scalability of the domain name system name >and
address spaces as well as ensure that root servers continue to
>interoperate and coordinate? 

Present-day off-the-shelf database tools are scalable to accommodate the
needs of the Internet community.  Those who have programmed the
present-day DNS software of the Internet have the skills and experience to
provide whatever is needed.  Fortunately for the Internet community, none
of this requires NSI's cooperation in case NSI decides to refuse to
cooperate with changes.  >8. How should the transition to any new systems
be accomplished?  Most importantly, all members of the Internet community,
including the US government and its agencies, must support a non-monopoly
plan for Internet administration.  This means reaching consensus early on
that an NSI monopoly is not only unnecessary but must be prevented.  This
means that NSF must write The Letter (the letter directing NSI to hand
over the databases required for a successor registrar to take over COM),
and must do so well in advance of March 1998.  This means that there has
to be a successor registrar.  At present the only viable candidate for
this responsibility is the IAHC/MOU.  Unless some other non-monopoly
entity, acceptable to the Internet community, comes into existence well in
advance of March 1998, this probably means that the IAHC/MOU entity is the
only viable successor to NSI to administer COM, which means NSF must write
The Letter designating IAHC/MOU as the successor.  >9. Are there any other
issues that should be addressed in this area?  >C. Creation of New gTLDs

>10. Are there technical, practical, and/or policy considerations >that
constrain the total number of different gTLDs that can be created?  If the
floodgates were to be opened with creation of a potentially unlimited
number of gTLDs, this would lead to chaos.  To the extent that domain
names do any good, it is because they are capable of being remembered from
the moment one sees a domain name on a television screen to when one types
it in on a keyboard.  At present we have about 180 top-level domains and
it is just barely within human ability to remember a domain name.  Adding
a few dozen more would probably not degrade this substantially.  Adding a
thousand more would make domain names supremely unmemorable. 

>11. Should additional gTLDs be created? 

My view is that there is no problem for which adding gTLDs is the
solution.  The address space of COM is already infinite, and it is just as
easy to add or fiddle with characters to the left of the "dot" as to add
or fiddle with characters to the right of the "dot".  It is also true that
adding a limited number of new gTLDs probably doesn't harm things.  And it
is also true that there are many in the Internet community who feel
strongly that some new gTLDs should be added.  Since it is possible to do
it, and since some people really want to do it, and since it doesn't cause
harm (at least in limited numbers) then we might as well permit it to
happen.  Any new gTLDs must be shared, not monopoly-controlled.  The
IAHC/MOU plan, to its credit, calls for any new gTLDs to be shared, not
monopolized. 

>12. Are there technical, business, and/or policy issues about
>guaranteeing the scalability of the name space associated with
>increasing the number of gTLDs? 

The main issue is that new gTLDs ought not be monopolized.  They ought to
be shared, just as North American toll-free numbers are shared.  At one
time all NANP toll-free numbers began with "800".  Later, "888" was added. 
Wisely, the "888" numbers ended up shared just like the 800 numbers, and
no single long-distance carrier had monopoly control over the new prefix
(call it a gTLD if you wish). 

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

In some ways, yes, in other ways, no.  A domain name that offends because
it contains a trademark (e.g. EXXON.COM owned by someone other than Exxon)
will not be rendered non-offensive by setting up the domain name to end in
an ISO country code (e.g. EXXON.CO.JP).  All domain names are accessable
from all geographic locations.  To the extent that there is a problem that
needs fixing (in connection with trademarks and domain names), putting an
ISO country code at the end of the domain name does not fix the problem. 
>14. Are there any other issues that should be addressed in this area? 
>D. Policies for Registries

>15. Should a gTLD registrar have exclusive control over a particular
>gTLD?  Are there any technical limitations on using shared registries
>for some or all gTLDs?  Can exclusive and non-exclusive gTLDs coexist? 
There is no natural or system-driven reason why a gTLD registrar such as
NSI should have exclusive control over a particular gTLD such as COM. 
Just as NANP toll-free numbers are non-exclusively controlled by a
plurality of long-distance carriers, so should gTLDs such as COM be
non-exclusively controlled by a plurality of registrars.  >16. Should
there be threshold requirements for domain name registrars, >and what
responsibilities should such registrars have?  Who will >determine these
and how? 

IAHC/MOU and its commenters have devoted substantial time and energy to
these issues.  It would be better not to replow this ground now, but
instead to adopt the recommendations of IAHC/MOU on these issues, or at
least to give great weight to the IAHC/MOU recommendations. 

>17. Are there technical limitations on the possible number of domain
>name registrars? 

No.  Off-the-shelf database products permit databases to be shared by
arbitrarily many entities.  Competent programmers will have little
difficulty scaling the software, and crafting such additional software as
is needed, to handle as many registrars as may come to exist.  >18. Are
there technical, business and/or policy issues about the name >space
raised by increasing the number of domain name registrars?  One issue that
arises (assuming that COM becomes shared) is "what will happen to domain
names that NSI has wrongly placed on hold under its flawed trademark
domain name policy?"  This issue will fix itself, I suspect.  There will
necessarily be a mechanism for domain name owners to transfer the
administration of their domain names from one registrar to another, just
as the owner of an 800 number can switch it from AT&T to Sprint.  The
wronged domain name owners will presumably simply switch their domain
names to registrars other than NSI, who will then reactivate the domain
names. 

This is, of course, little consolation to those domain name owners whose
businesses have been destroyed by NSI's wrongdoing.  But for the ones that
have remained in business despite NSI's wrongdoing, at least it will mean
they can start over in attempting to make use of their domain names. 

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

There should be no exclusively-controlled gTLDs.  If, somehow, a registrar
comes to control a gTLD exclusively (as NSI does now and proposes to do
forever with COM), then that registrar should not be allowed to control
any additional TLDs. 

>20. Are there any other issues that should be addressed in this area? 
>E. Trademark Issues

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

Internet conduct is subject to trademark laws, just like any other
conduct.  Someone whose conduct violates trademark rights will answer for
it in court, whether that conduct has to do with a toothpaste package, the
text of a web site, a fourth-level domain name (e.g. exxon.oil.com.us), or
a second-level domain name.  It is aberrational that so much attention has
fixated on second-level domains when there are so many other ways for
someone to infringe a trademark via Internet conduct.  The main reason
that so much trademark attention has fixated on second-level domains is
NSI's flawed policy, first put into place in July 1995.  NSI's policy has
wrongly prompted trademark owners everywhere to believe (or to pretend to
believe) that mere text identicality between a trademark and a domain name
gives rise to the power to cut off and take away the domain name.  While
the courts have slowly tried to get out from under the wrongly-directed
momentum created by NSI (most recently in the Lockheed case cited below)
the harms caused by NSI's policy will take a long time to be undone.  >22.
Should some process of preliminary review of an application for
>registration of a domain name be required, before allocation, to
>determine if it conflicts with a trademark, a trade name, a geographic
>indication, etc.?  If so, what standards should be used?  Who should
>conduct the preliminary review? 

The Internet, for better or worse, is non-geographic in nature.  Any web
site anywhere in the world can arouse the anger of any trademark owner
anywhere in the world.  Nothing about a domain name (even if it is an ISO
domain name) can insulate a web site owner from legal liability if the
conduct gives rise to liability that a court is willing to impose and
enforce.  Thus, a domain name registrar that might set a goal of screening
all domain name applications for trademark trouble would face the task of
searching the trademark records of all of the 180 or so countries in which
there are trademark systems.  The majority of those countries do not have
online records and the only way to do trademark searches is by going in
person and physically searching physical (paper) records. 

In the US, at least, the law is clear that such searching is unnecessary,
and that a domain name registrar is under no general duty to screen
applications for trademark problems, any more than a stock exchange would
be under a duty to screen proposed stock trading ticker symbols for
trademark problems.  See Panavision v. Toeppen, 96 cv. 3284, US. Dist.
C.D. Cal. December 2, 1996, at 10 "NSI is under no general duty to
investigate whether a given registration is improper [citing MDT]".  See
MDT Corp. v. New York Stock Exchange, Inc., 858 F. Supp. 1028, 1032 (C.D.
Cal. 1994) which held that the New York Stock Exchange was under no
general duty to screen proposed stock exchange ticker symbols for possible
trademark infringement.  In the US the law is also clear that mere text
identicality between a domain name and a trademark does not give rise to
liability under the trademark laws: 

     The Court begins with the observation that "unlike 
     a patent or copyright, a trademark does not confer 
     on its owner any rights in gross or at large." MDT 
     Corp. v. New York Stock Exchange, Inc., 858 F. 
     Supp. 1028, 1032 (C.D. Cal. 1994) (citing Traeger 
     v. Gordon-Allen, Ltd., 71 F.2d 786, 768 (9th Cir. 
     1934)); see also Anheuser-Busch, Inc. v. Balducci 
     Publications, 28 F.3d 769, 777 (8th Cir. 1994) 
     (noting that "unlike copyright and patent owners, 
     trademark owners have no rights in gross"). Therefore, the law does
not per se prohibit the use of trademarks or service marks as domain
names. Rather, the law
     prohibits only uses that infringe or dilute a trademark or service
mark owner's mark. Moreover, innocent
     third party users of a trademark or service mark have no duty to
police the mark for the benefit of the mark's owner. MDT, 858 F. Supp. at
1034. Consequently,
     the mere fact that a person registered a SKUNK 
     WORKS or a variation thereof as a domain name 
     does not mean that the person infringed or diluted 
     Lockheed's mark. (Lockheed Martin Corp. v. NSI, 
     96-cv-7438, C.D. Cal., March 19, 1997.)

It is ridiculous to suggest that a domain name registrar should screen
domain name applications, one by one, for possible infringement.  As the
Lockheed court indicates, a text match does not mean that there is
infringement or dilution. 

> If a conflict is found, what should >be done, e.g., domain name
applicant and/or trademark owner notified >of the conflict?  Automatic
referral to dispute settlement?  From the preceding discussion, it's clear
that the domain name registrar would not and should not be "finding"
conflicts.  It is up to a trademark owner to police the world of domain
names just as with toothpaste packages or any other possible trademark
use.  If the trademark owner purports to find fault with a particular
domain name, the registrar should play no active role other than providing
contact information between the parties (see RFC 1591).  This has been the
rule on the Internet since before NSI crafted its flawed policy. 

It's also important to distinguish between "conflicts" that are perceived
by a trademark owner at the time a domain name is registered, and
"conflicts" that are perceived months or years later.  If a domain name
owner has been using a domain name for many years, it is unfair to propose
cutting off the domain name simply because someone who sat idly by for
those years now suddenly wishes to assert that there is a "conflict". 

A domain name registrar that receives a brusque letter from a trademark
challenger demanding that the registrar cut off a domain name, should
politely but firmly decline to sit in judgment on the domain name but
should instead invite the would-be challenger to present its claim in a
competent tribunal, such as a normal court or, perhaps, a WIPO tribunal. 
>23. Aside from a preliminary review process, how should trademark rights
>be protected on the Internet vis-a-vis domain names?  What entity(ies),
>if any, should resolve disputes?  Are national courts the only
>appropriate forum for such disputes?  Specifically, is there a role for
>national/international governmental/nongovernmental organizations?  The
one thing that may be said with confidence is that NSI is the wrong party
to decide such disputes.  NSI has a long track record of frequently
getting the wrong answer as to what should be done when a trademark
challenge arises. 

As for the selection of forum, one must not forget that if a dispute has
to do with, say, a toothpaste package, the only generally applicable forum
is a national court.  The same is true on the Internet for all types of
disputes relating to web site content, third- or fourth-level domain
names, email content, news posting content, and almost everything else
that is capable of being done on the Internet. 

It is odd that of all the things that can be done on the Internet, exactly
one (that is, the selection of a second-level domain name) is thought by
some (including NSI) to be peculiarly appropriate for extrajudicial
treatment. 

The IAHC and MOU proceedings have proposed a WIPO-based dispute resolution
mechanism.  As with anything new, it is not easy to know or to predict
with certainty how that mechanism will work out in practice.  There is
really no way to find out other than to try it and see if it turns out to
be fair and just.  It would surely be fairer and more just than what NSI
does now.  >24. How can conflicts over trademarks best be prevented?  What
>information resources (e.g. databases of registered domain names,
>registered trademarks, trade names) could help reduce potential
>conflicts?  If there should be a database(s), who should create >the
database(s)?  How should such a database(s) be used?  The best
preventative step regarding conflicts over domain names is education of
the legal community and of the Internet community.  Lawyers and lay people
need to read and re-read the quotation above from the Lockheed case.  It
is a simple fact of life that the majority of trademarks are non-unique,
that is, more than one person or entity uses the mark.  All but one of
them will have to survive without ownership of "mark.com".  Text
identicality does not mean trademark infringement or dilution, and someone
who has been using a domain name for years without infringing anybody
else's trademark rights should not have to give it up simply because a
latecomer to the Internet covets it. 

Although the vast majority of trademarks are non-unique, a very small
fraction (well under one percent) are unique.  Unique and coined marks
such as Exxon and Kodak and Xerox may be created and asserted without
depriving anyone of the use of dictionary words, and such marks probably
deserve strong protection generally.  See particularly my article
"Remedies in Domain Name Lawsuits:  How is a domain name like a cow?", 15
John Marshall Journal of Computer & Information Law 437 (1997), draft
available at .  It is also
well-established that the databases of domain name registrations need to
be public records.  There is a great need for people to be able to search
the databases for many reasons including checking for possible trademark
infringements.  NSI has urged, rather unconvincingly, that it "owns" the
COM domain name database.  As a consequence of this assertion of
ownership, NSI has refused to make the COM database available to trademark
search firms and has intimated that this ownership interest somehow means
that no other entity can ever administer COM without NSI's permission
(which permission NSI has said it will not give). 

The ownership claim by NSI fails for many reasons.  First, NSI is merely a
five-year government contractor.  The database existed before NSI began
the contract, and will exist after the contract runs out.  Under the
contract, NSF (as discussed above) can simply order NSI to hand over the
database to the successor registrar. 

Second, the database was authored not by NSI but by the hundreds of
thousands of domain name owners who authored the records that make up the
database.  NSI's contribution was little more than alphabetization of the
records.  Under the Feist US Supreme Court case, the copyright law does
not give protectable rights to NSI. 

>25. Should domain name applicants be required to demonstrate that >they
have a basis for requesting a particular domain name?  If so, >what
information should be supplied?  Who should evaluate the >information?  On
the basis of what criteria? 

Some registries do this now.  See the comprehensive survey of registration
policies compiled by Geoffrey Gussis at
.  >26. How would the number of
different gTLDs and the number of >registrars affect the number and cost
of resolving trademark disputes?  The effect of adding TLDs or registrars
would be small compared with the effect of educating the public and the
legal profession about trademark law, and the effect of rendering NSI's
flawed policy irrelevant by keeping NSI from getting a permanent monopoly
on COM.  It might be thought that "cybersquatters," that is, people who
register domain names identical to unique or coined names, will see new
gTLDs as a fertile new ground for cybersquatting.  There are two reasons
this won't happen.  First, what must not be forgotten is that there are
already over 180 TLDs, and cybersquatters tend to prowl only in COM. 
Adding a few new TLDs won't change the fixation of many on COM to the
exclusion of other TLDs.  Second, the window of opportunity for
cybersquatters has come and gone.  COM became trendy several years ago,
and some cybersquatters picked up on it before some big companies with
unique or coined names.  But that won't happen again -- the "trendiness
gap" between those who perceived the value of the Internet and those who
didn't, has closed.  Any company with a coined or unique name that feels
it must have a domain name (that is, a COM domain name) has already done
so.  >27. Where there are valid, but conflicting trademark rights for a
>single domain name, are there any technological solutions?  The question
seems poorly stated.  Valid trademark rights don't conflict; this is part
of the definition of valid trademark rights.  Perhaps the question can be
rephrased as "when there are two or more parties that wish they could have
the same domain name, what can be done?"  One of the difficulties about
this question is that in general, one of the parties registered the domain
name and only later did the other party come to wish to possess the domain
name.  I have been involved in a number of settlement negotiations between
such parties, and in several cases the parties arrived at comfortable
resolutions such as agreements to provide cross-links each to the web site
of the other. 

Some commenters propose that neither party, in such a case, be permitted
to use the domain name, and that some sort of "pick the company you want"
menu be provided in place of the web site previously provided by the (now
ex-) domain name owner.  To force such a change would be wrong.  It
disserves the Internet community because it breaks previously functional
links, and disrupts the flow of email.  It ignores the valuable goodwill
that may have accumulated around the domain name, web address, and email
addresses. 

The public, and the legal profession, are slowly coming to understand that
search engines and directory services exist, and that the day has passed
when a company with a non-unique, non-coined name could hope that people
would guess at the domain name by typing the company name into the browser
window.  Search engines, voluntary cross-links, and the like will reduce
the need for "guessability". 

>28. Are there any other issues that should be addressed in this area? 


###

Number: 131
From:      Rick Gordon stilgar@doitnow.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/22/97 1:10am
Subject:   extentions

YES! YES! YES! Please add more extentions.As a new business owner with
the business having it's own domain name,i can see the need for more
extentions.I couldn't get the name that i wanted because it was in
use,with more extentions maybe i could have had the one that i wanted.
       Thanks for asking.



###
Number: 132
From:      Rob Cummings robio@earthlink.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/22/97 12:46pm
Subject:   Could Keywords replace domain names?

Please take a look at http://www.keyword.com, a new site, and a new
concept in internet navigation.

Keyword.com takes users to sites (and better yet, any specific page on a
site) without ".this" and ".that" and without extensions i.e.
"/name.index.htm". 

All users need to go to a site is a word, phrase, name or number. And
these "keywords" can be of any length with any punctuation. This
eliminates the current restrictions of the internic registry.

Keyword.com works just like the phone book. Why can't the internet work
the same way? 

Certainly there are two companies called "Acme" in the phone book, yet
one lists itself as "Acme Computers" and the other lists itself as "Acme
Carpet". The phone book never needed extensions. As a "find" engine,
keyword.com takes users who know where they want to go, directly to the
page they want to go to. Since this is the case, registrants
automatically register the most descriptive keyword to take users to
their site or page.

Furthermore, with all the talk about new suffixes and alternate
registries, a registered keyword could continue to send users to a site
or page regardless of what happens with the domain name issue.

HERE'S HOW KEYWORDS WORK

Any word or phrase can replace the URL to send consumers directly to any
web site or page. Keyword.com works with all browsers and requires no
additional software.Keywords are registered by advertisers as well as
those with personal pages who want to make their names easier to
remember and mre accessible.

Here*s one example: In its print/radio/television ads and on the
internet, Volvo promotes the
tag: *for more information, go to keyword.com and enter *Volvo S70* or
"Volvo V90".  By entering either keyword (*Volvo S70* or "Volvo V90") at
keyword.com, consumers go directly to the specific page related to that
Volvo model. By entering "Volvo" alone, they go directly to Volvo's home
page without having to enter or remember www.volvo.com. A slogan or a
special offer might send consumers to a page associated with a special
promotion. Keyword.com's keywords can send consumers to any page on the
Volvo site which is associated with the keyword Volvo selects. Without
keyword.com, Volvo can only send consumers to their home page.

Here's another example: Catalogs can now send consumers directly to any
page on a web site for
more information, or a larger or more detailed photo of the product.
Here's how it works: The words "go to keyword.com and type "product
name" or "catalog number" for more information" are added to the product
description. By entering the appropriate keyword, consumers go directly
to the specific web page related to that specific product. A slogan or a
special offer might send consumers to a web page associated with a
special promotion. Keyword.com's keywords can send consumers to any page
on the site which is associated with the keyword the catalog producer
selects. Without keyword.com, the catalog producer can only send
consumers to their home page.

Here's a third example: A shared site can now be neatly divided without
the necessity of lengthy and confusing extensions. A page on
www.shared.com can be accessed with a single word or phrase, acting as
if it were the main page of a URL. Without keyword,com the address will
likely look like www.home.shared.com/~username/index.html.

Since there are no restrictions on character length or punctuation,
keywords can be very descriptive. Since this is the case, there should
be fewer problems with registrants obtaining a unique keyword since
there are more options available.
                               
There are many other applications. See
http://www.keyword.com/faqs.htm and click on "What Can I Do With
keywords?" to see other ways sites use keywords. Advertisers pay a small
fee of $75. to register keywords on keyword.com*s automated keyword
registry. Information and registration are available at
http://www.keyword.com. In Netscape, consumers can enter "keyword"
alone.


Please comment.

Rob Cummings/Keyword.com
714-249-2519
e-mail: robio@earthlink.net

###
Number: 133
From:      Rudy Nadilo rudy.nadilo@norwalk.ct.us>
To:        "'dns@ntia.doc.gov'" 
Date:      7/22/97 11:29am
Subject:   The US Domain

Recently, there has been a lot of talk about the naming confusion surrounding 
the use of .COM. The situation will only get worse, as the name limitations of 
the .COM structure continue. But, a simple solution exists that everyone is 
ignoring. The .US Domain...

According to the US Census 95% of American households have a phone. Just as 
everyone needs conventional mail addresses and telephone numbers, everyone will 
need an E-mail address, for both personal use (at home) and for business use 
(at work). The .COM is by far the most common and widely used Internet Top 
Level Domain. However, the "real" domain for the United States, is .US. This 
domain was established, prior to the .COM, under International agreement that 
Internet domains for all countries would operate under the international 
two-digit ISO country code. The US Domain is an official top-level domain in 
the DNS of the Internet community. The US Domain Registry at the Information 
Sciences Institute of the University of Southern California (ISI) administers 
it, under the Internet Assigned Numbers Authority (IANA). US is the ISO-3166 
2-letter country code for the United States and thus the US Domain is 
established as a top-level domain and registered with the InterNic the same way 
as are other country domains.

During the rush by businesses to develop and market via the Internet, the Top 
Level Domain .US was overshadowed by the highly promoted Top Level Domain .COM. 
Several issues that have held back awareness and use of the .US domains are:

Internet purists promoted the .COM as a way to identify, control and isolate 
the commercial users of the Internet during the early development in the 90's.

Many of the initial Internet service providers (ISP's), and "techies" who were 
guiding the development preferred the three digit suffix as it easily fit their 
programming and file naming convention, eight characters followed by three. 
(i.e.: letter.doc)

The US Domain Registrar initially had restrictions that prohibited any 
commercial use of the .US.

These barriers have been relaxed and the US domain is now actively being 
promoted and implemented by ISP's as an alternative, and more logical domain 
for local communities, residents and businesses and the Internet in general.

Why the .US Domain is Better
The viability of the .COM address is rapidly diminishing. This is because only 
one unique series of characters can exist and the ability for a business or 
individual to register their name in the .COM domain is becoming close to 
impossible.

For businesses (or individuals) who seek to have a Web Site presence on the 
Internet, it is almost impossible for a company to register their actual brand 
name. This has forced companies to create less than appropriate addresses, 
making themselves hard to locate and their address difficult to recall. A good 
example is The Coca-Cola Company; coke.COM and coca-cola.COM are not owned by 
Coca-Cola. The company had to settle for the domain coca.COM as their Internet 
corporate address.

For individuals seeking an E-mail address, current E-mail addresses are 
extremely confusing with no logical way to identify the E-mail address with the 
person. Examples of typical addresses; hdavie@mmgroup.com, kballard@aol.com, 
carlson@ct2.nai.net, mcd@connix.com, etc.

The .US domain represents are better, more intuitive, more logical addressing 
system because it is based upon geography. People, by nature, are 
geographically oriented:

we live or work at a specific location
we address our mail based upon geographic location
we can find people and businesses by geographic location (their address)
we seek and recall phone numbers by geographic orientation ("area" codes are a 
numeric representation of a geographic location)
we identify things and people by their geographic locations (Northeast, 
Southwest, West Coast, East Coast)

.US Domain based Web Site Domain Examples:

www.rayspizza.chicago.il.us
www.rayspizza.nyc.ny.us
www.rayspizza.mystic.ct.us
www.acme.shelton.ct.us
www.applied.software.norwalk.ct.us

Note that unlike the .COM domain where there could only be one (1) RaysPizza, 
there can be multiple domains for RaysPizza since each address has a unique 
geographic designation.

.US Domain based E-mail Address Examples:

john.smith@maple.norwalk.ct.US
john.smith@park.norwalk.ct.US
john.smith@elm.norwalk.ct.US
nic.baldwin@katy.wilton.ct.us
melissa.shorter@lark.norwalk.ct.us

Again, note that unlike the .COM domain where there could only be one (1) John 
Smith within each domain, there can be multiple E-mail accounts for RaysPizza 
since each address has a unique geographic designation.

The .US domain structure is implemented world-wide and allows anyone to 
register a unique personalized domain and related email address, without 
conflict or dependency on a commercial domain belonging to another party. There 
is no similar product in the marketplace and there will be none in the future. 
There can only be one US Geographic Domain simply because the domains are based 
on the state and local address.  The .US Domain allows every community, and 
every individual and business within the community, to be able to have their 
own "personalized" intuitive domain and E-mail addressing without conflict.

Clearly, the .US Domain naming system and structure are FAR superior to the 
cumbersome limitations imposed by the .COM structure. We are the only country 
in the World that uses .COM. It's time we woke up, joined the rest of the world 
and utilized the best Internet naming structure around. The .US Domain.

Sincerely,

Rudy Nadilo
rudy.nadilo@norwalk.ct.us


###
Number: 134
From:      Foodie & Family beatrice@MO.NET>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/22/97 11:55pm
Subject:   New Domain Reg. Authorities

First of all, to allow Network Solutions to continue as the sole
authority
it a BLATANT anti-trust problem.  Second, Network Solutions is ANYTHING
but a friendly company.  I would INSTANTLY switch authorities, were
this option available.

Regardless of the NS problems in the customer service arena, I wish
to restate the anti-trust problem:  They has a literal (not even a
"virtual") monopoly on this, and they have already shown a VERY
willing propensity to abuse that position.  To allow it to continue,
ESPECIALLY with Gov't assistance, is itself criminal.

[Image]foodie@chef.net

###

Number: 135
From:      Billy Bennett Billy.Bennett@ncmail.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/23/97 11:35pm
Subject:   DNS reform

Sirs:

     I administer the DNS for the state of North Carolina.  I have had
severe problems with the
charter of the internic determining how I will delegate names (limiting
me with an arbitrary 50/500
rule), and restricting delegation of a domain that should belong to the
state (nc.us).  I do not mind
following guidelines they would establish (ci.name.nc.us, state.nc.us,
et al) but feel as the domain
administrator for NC I should be able to delegate other domains
(mail.nc.us, abuse.nc.us, etc.)  The
current structure for the US domains make all the names unnecessarily
long, and are illogical (the
counties are designated co.name.nc.us instead of name.co.nc.us as
heirarchical naming dictates).  In
addition, companies have been registering county names and trying to
bill counties and cities, and
private organizations have been registering alternative names (such as
nc.net, nc.org, etc).  These
names are clearly like the mcdonald's or nasa names, and should be
delegated for the state to administer (giving them to isps if they want
to have the services outsourced).

I would like to see:

      The xx.us domains delegated to the states for administration with
guidelines from the internic.

      (At least) the xx.org and xx.net domains delegated to the states
for their use.

      The 50/500 rule become the 50/500 suggestion.

Thank you
=Billy Bennett
Internet Services, North Carolina


###
Number: 136
From:      David DeGeorge dld@degeorge.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/24/97 7:58am
Subject:   Domain registration 

My belief is that the current situation should be preserved. The USG
should be the sponsor  of the domain and address registration authority. 
Just as the FCC is responsible for radio frequencies and call signs a
similar governmental organization should contract for administration of
the internet.
David DeGeorge


###
Number: 137
From:      Peter Rony rony@usit.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/24/97 4:48pm
Subject:   Registration and Administration of Internet Domain Names

I have been following the various problems -- specially the ones that
have reached legal status -- associated with the NSI domain dispute
policy.  I believe that the basic problem is the existence of
international top-level domains.  I also believe that the gTLD-MoU
exacerbates the basic problem of international TLDs.

My recommendations would be to:

(a) Eliminate the COM, ORG, NET, EDU, GOV, MIL, etc. top-level domains
in favor of second-level domains
underneath two-letter country-specific TLDs.  Thus, the United States
would rearrange and expand its domain name structure to include the
following organizational domains:

COM.US
ORG.US
NET.US
EDU.US
GOV.US
MIL.US
ARPA.US
TOYS-R.US (just kidding)

Non-U.S. corporations that have registered under the international TLDs
could all re-register with the registries of the countries in which
their headquarters are respectively located, or in the countries in
which they are incorporated.   

When the dust settles, the "international" aspect of domain naming would
cease.  All domain names would become country specific.  IAHC-proposed
iTLDs such as WEB, REC, ARTS, INFO, FIRM, STORE and NOM would become
useless and immediately obsolete, as they should be. 

Further, all future domain disputes would become country-specific
disputes handled by the law and the courts of individual countries.  

The idea of "international top-level domains" was a mistake made while
the Internet was in its middle age.  Perhaps it was a mid-life crisis
type of action by those friendly Internet folks. 


(b) Thwart the proposal of Network Solutions, Inc. that domains should
be "branded".  In my opinion, this is a proposal of surpassing stupidity
and self-interest. I quote Carl Oppendahl's very fine commentary on the
Network Solutions, Inc. proposal:

------------------------------------------
MAURA VOLKMER'S INQUIRY (July 23, 1997): "So NSI keeps going on about
how they have intellectual property rights in the .COM database, and how
they want non-shared TLD's so that registries can develop "brand name"
recognition for their TLD's.  What's to stop NSI from registering .COM
as its trademark (or service mark)?  Or NSI might even argue that is has
common-law trademark rights in .COM since it has been using it in
commerce.  Once NSF leaves the picture, it looks a lot less as though
NSI is merely performing a service under contract to the federal
government, and it becomes more difficult to distinguish NSI from any
other commercial enterprise . . ."   

CARL OPPENDAHL'S RESPONSE (July 23, 1997):  "What's to stop NSI are
several things."

"NSI didn't originate .COM.  NSI assumed a five-year fixed term (a
contract with NSF) of administering .COM, that started in 1993 and will
end in 1998. Before NSI was administering .COM, SRI was administering
.COM.  NSI cannot claim to be surprised that in 1998 NSF might have
given the next contract to someone other than NSI.  Now, as it happens,
NSF has stated rather vaguely that after its contract expires,
appropriate entities in the Internet Community will determine what
happens next with .COM"

"No matter how it is sliced, NSI cannot claim to be surprised that when
it signed its five-year contract, it was a contract to administer, only
for five years, a system that had previously been adminstered by someone
else and that subsequently might be administered by someone else."

"I have plenty of clients who obtained their domain names from SRI,
NSI's predecessor in administration of .COM."

".COM is not something in which NSI (or anyone else) has common-law
trademark rights, any more than AT&T had common-law rights in "800" when
the FCC mandated that toll-free numbers would be competitively supplied
by
more than one long-distance carrier."

"The owners of the million or so .COM domains, many of them have
common-law trademark rights (and, in many cases, registered trademark
rights) in their domain names, including the ".COM" at the end"

"NSI has not been "using .COM in commerce" to indicate the origin of
goods or services.  NSI has used "NSI" in commerce to indicate the
origin of goods or services, NSI has used other trademarks such as its
logo in commerce to indicate the origin of goods and services."

"When NSI landed its five-year contract, it was rather like a
concessionaire landing a contract to operate a snack bar in a national
park for five years.  The concessionaire knows (or should know) that
when the five years is up, it has to hand the snack bar over to the next
party."

"NSI's grab here is impressive for its cheekiness.  It is as if NSI had
gotten a five-year contract to operate a snack bar at the overlook of
the Grand Canyon, and then when the five years is almost up it announces
that it is simply going to stay there and not answer to the Park 
Service any more.  (And continue to cut off domain names unfairly,
etc.)"  
---------------------------------------------------------------------------

###

Number: 138         
From:      "Captain Trips" <capntripz@hotmail.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/26/97 12:33pm
Subject:   DNS Monopoly 

RE:  B 3. "By what entity, entities, or types of entities should current 
domain name systems be administered? What should the makeup
of such an entity be? "



  It is my personal belief that DNS administration should be conducted 
first and foremost by not-for-profit entities, and all efforts should be 
made to reduce the registration and maintenance fees for securing a 
domain name.  

  With the current InterNic prices for domain registration ranging 
upwards of one hundred dollars, individuals and small organizations are 
often financially excluded from having a personal domain that will 
remain constant despite changes in geographic or service provider.

  The current InterNic monopoly is analogous to every telephone user on 
the planet being required to buy their phone number from one omnipresent 
corporation, unfettered by tenets such as universal access.  

  Just as in the past, telephone access was considered to be all but an 
inalienable human right, so too should domain names become as easily 
available as possible.  

  In selecting a new DNS system, I hope that the goals of expanding 
domain accessibility and deflating registration fees will be a major 
consideration.


  Thank you.


______________________________________________________
Get Your Private, Free Email at http://www.hotmail.com

###
Number: 139
From:      "brandon rosner" <johndoe@ez-net.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/26/97 12:10am
Subject:   domain names

i think that a company that has a Copyright or Incorporated has the first
shot at that domain name. any "patented product" has first dibs at that
domain name...or else from now on a company should take extensions like
.inc or .firm .auto (for car dealers) and so on...categorize businesses
and .per for personal sites .news for information sites


###
Number: 138         
From:      "SELDON & SCILLIERI, LLP" <seldon@IDT.NET>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/28/97 12:36pm
Subject:   domain name questionaire

If two entities want the same domain name (e.g., acme.com) it seems
simple enough to have a governing body set up an opening page containing
icons for both entities which identify each by name, address, etc.  The
user selects the icon of choice and is linked to a sub-site.

The cost of creating and maintaining the opening page is born by the
junior entity.  The senior (i.e., first) entity gets a free ride.  Each
subsequent entity wishing to join the opening page because it uses the
same name, would have its icon added at a fee to be set by the
administrator  (e.g., the fee paid by the second entity).

Since the administrator would need international authority, I suggest
either the U.N. or an international commission under the body which
administers international telelcommunication standards.

I assume others have suggested this and there is a techinical reason why
it cannot be done.  Maybe not.  It would seem to eliminate all trademark
infringement actions based upon web names.

Sincerely yours, 
Robert A. Seldon

###
Number: 141         
From:      "Michael Dopps (Volt Computer)" <a-michdo@microsoft.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/29/97 11:42am
Subject:   DNS ISSUE

Domain names should stay as they are.  Com, Net, and ORG are that best
possible means of dividing up the top level domains.  Even if we had 1
million top level domians we still would not be close to having to many.
In working with many of the largest networks here in the United States I
have experience to speak from and wish to remain anonymous since I work
for Microsoft.

I do understand the need for WorldWide variancs of the domain
registration process.  However to keep things consistent we need to set
up a task force to monitor and maintain compatibility and standards
across the board with every registered, "Domain Registering
Organization" around the globe.  Otherwise our idea of communication
through the internet will be no more.

Disputes can and will cause illegal domain names which will send the
flaky at best internet structure to ashes.  In turn the consequences
will divide up all countries and force Internet Service Providers, at
large, to file bankruptcy.

     This topic should be a closed subject and discussed only on
technical terms.  This dispute about domain names should be considered
by the most knowledgable source (The Internic).  This organization
obviously has more experience setting up large domains and experience
with internet structure.  Therefore I feel their opinion should be more
valid than any one involved.  To my knowledge they have always been
credible and have solved many problems for thousands of companies.  
     Organizing a company to manage a network the size of the
internet is no easy task.  I challenge anyone to attempt to set up an
organization to manage the internet and be successful right from the
very start.  Even a group of the most knowledgable will make mistakes to
start out with that will be potential hazardous, this is why Network
Solutions should be considered the authority on this issue hands down!!!


     Thanks for you time!


###
Number: 142
From:      Sanders Kaufman <bucky@ns1.cmpu.net>
To:        "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date:      7/29/97 4:14am
Subject:   re:  Comments on Domain Names

I'm submitting these comments in regard to the article on Domain Names
published by Paul Chavez of MSNBC. 

I was always taught to buy land because "they ain't makin' no more of it". 
It was something I heard a lot in the early days of the Internet with
regards to domain names.  I didn't believe it then and I don't believe it
now. 

Land is a scarce natural resource, but information technology is not. 
Each is valuable, but we can create as many domain names as are necessary
to supply the entire market.  Because we can't do that with arable land,
millions of people are starving. 

The current domain name structure allows for more than enough domains to
go around, and the proposed naming structure will have absolutely no
impact on that number - therefore there is no technical reason not to
allow the addition of a few Top Level Domains. 

With a saturated market, as we have with domain names, where everyone can
have as much as they want, the one with a monopoly on that market is
guaranteed to make money.  Anybody else who enters this market will not be
able to offer a "better" or "cheaper" product since the product is based
on an open standard which anyone may use. 

Allowing open competition will change neither the level of service, nor
the price.  Competition helps keep the market leaders honest by shining
light on their activities.  Anyone entering the market would do so out of
a motivation for administering domain names, rather than for large profits
- a noble intention. 

Do not restrict entry into this market.  It is very capable of keeping
itself level. 




CC:        "'inetcauc@hr.house.gov'" <inetcauc@hr.house.gov>

###

Number: 143
From:      Peter Seebach <seebs@taniemarie.solon.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/30/97 3:34pm
Subject:   About domain names...

Here's my commentary:

I don't care that much how many domain names there are.  I don't care
that much who administers them.

However, I want, more than anything else, for there to be choice.

Right now, there is no choice.  If I want a domain name, I can go to
Network Solutions.  Network Solutions has the worst service I've experienced
from any company.  Ever.

They have cut off service due to billing errors on their part.  They
have double-billed.  They have triple-billed.

I have spent *THREE MONTHS* trying to get a double-bill on a domain I
administer resolved.  They do not call me back, or respond to voice
mail.  They ignore the fact that they have $50 of money they haven't
earned.

When our domain was cut off due to a billing error, there was a two day
period (business days, even) during which our domain was still marked
as "on hold", but the customer service representatives insisted, for the
entire two days, that the record was *not* on hold, and that it would take
at most another fifteen minutes to propagate.  They made statements like
"yes, the database is being forwarded out as we speak", even though
their own systems were showing it still crippled.

This could not, and would not, survive in a free marketplace.

As an administrator of several domains, and a small ISP, I want, most of
all, for there to be freedom of choice among name service providers.

Network Solutions has had a couple of years to show us a vision of what
domain name service should be like; they have shown us incompetence,
dishonesty, and flagrant lack of interest in the functioning of the
service they provide.

I don't object to NS being in business; I merely object to being required
to do business with them.  Let the other companies who want to do this
compete, and we'll see a healthy marketplace evolve.

-s

###
Number: 144
From:     Russell Nelson <nelson@crynwr.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/1/97 7:15pm
Subject:  dns issues

I do not believe that multiple competing top-level international names
are sensible.  First, because it's not possible to map national
trademark laws onto an international registry.  Either you have to
give up on applying U.S. trademarks to domain names (which I would
heartily encourage but which I doubt would happen) and regard the DNS
as a separate namespace from any existing trademark system, OR you map
the domain name system into the national trademark laws.

The existing system, of mapping *every* national trademark onto the
DNS, is clearly broken.  Yellow Pages is a trademark in the UK, but
public domain in the US.  A direct mapping won't work either.  Take
the case of the US system.  Apple Records and Apple Computers both
have a trademark on "Apple".  No conflict in the trademark laws since
they are in different name spaces.  Not possible with the top-level
international .com namespace.

Even if you think the existing system is working, replicating it will
not.  If you allow competing top-level international registries,
you'll get *exactly* the same effect that you see with 800/888
numbers.  Everyone with a mnemonic 800 number wants the same 888
number.  If you allow .WEB, .BIZ, .SHOP, you'll find yourself with
PEPSI.WEB, PEPSI.BIZ, and PEPSI.SHOP.  Ownership of any such registry
will be a license to print money, so you will see a LOT of pressure to
create MANY top-level registries.

My recommendation is to have a one-year transition period from .com to
.com.us (&etc).  During the length of this period, no new names will
be allowed in .com.  At the end of the transition period, .com will no
longer function.

.arpa is an exception because it is programmed into many operating
systems for reverse resolution of domain names.

-- 
-russ <nelson@crynwr.com>    http://www.crynwr.com/~nelson
Crynwr Software supports freed software | PGPok | good luck, have fun!
521 Pleasant Valley Rd. | +1 315 268 1925 voice | taxes feed the naked
Potsdam, NY 13676-3213  | +1 315 268 9201 FAX   | and clothe the hungry.

###
Number: 145
From:     Thomas Leavitt <leavitt@webcom.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/1/97 2:27pm
Subject:  DNS

My opinion is that this should be an entirely free-market system;
Carl Oppendal's analogy of the 800# system a good example.

The U.S. Government has no business and no authority to impose it's
particular opinions on the Internet. Neither does any other
nation-state.

With regards to NSI... they're simply incompetent. Talk to any ISP
that deals with them on a regular basis, and the technical staff will
spout horror stories at you non-stop. They're got no incentive to
do anything else. They have a "premier" support service... which
they don't charge anything for, but require that you sign a contract
which gives them substantial advantages relative to any newly
emerged competitors, for a three year period (as I recall). The contract

struck me, when I read it, as an unfair exploitation of their existing
monopoly.

The day NSI loses it's monopoly, they're toast... tens of thousands
of registrants will immediately switch. Until then, they are pretty
much free to charge whatever the market will bear, provide lousy
service, and tie up ISPs and service providers with contracts that
grant NSI substantial long term preferences, in the hope of improved
service. Very lame.

Simply require reciprocal references for TLD root name servers...
enable any TLD, within a defined standard (i.e., TLDs must be
no more than xxx letters long), and leave it at that. Require all
root servers to service all TLDs, and allow second level domain
holders to transfer service from one root server company to another,
as transparently as they can transfer 800 or 888 #s.

If NSI would simply make the AlterNIC's name root name server a
recognized
root server, and refer all queries for TLDs hosted by it, the problem
would be solved over-night. Make it a requirement that all 'NIC's
accept registrations for any second level domain, under any TLD,
and you've got a free market. I don't see what the problem is here...
technically, DNS is pretty simple to operate and configure.

Regards,
Thomas Leavitt
Executive Vice-President
Web Communications
(speaking for myself)

###
Number: 146
From:     Ron Fitzherbert <ron@penguin.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/1/97 11:10pm
Subject:  DNS Comments (Attached, ASCII)



  ---------------- Ronald J. Fitzherbert, President ---------------
                  Flying Penguin Productions Limited
              Arlington, Virginia & Austin, Texas  (USA)
  -------------------- http://www.penguin.net/ -------------------- 

DEPARTMENT OF COMMERCE 

[Docket No. 970613137-7137-01] 

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

A. Appropriate Principles 

a. The statement is acceptable as given within certain bounds.
Competition should be encouraged no matter what.  However, expansion of
the domain name space needs to be carefully managed.

b. The statement is acceptable provided that input from government(s) is
encouraged, but government(s) in and of themselves do not set policy.
Policy should be developed independant of government(s).

c. The statement is acceptable.

d. The statement is acceptable.

e. The statement is acceptable.

f. The statement is acceptable.

B. General/Organizational Framework Issues 

Note: It is unclear whether these questions pertain to the current
system(s) (post-IAHC) or not.  Responses to the questions assume that they
pertain to post-IAHC activities.

1. The advantages are the global nature and self-governing system.  The
disadvantages are the US-centric costs involved (both to register in some
domains as well as to participate at the registrar level).

2. The current system could be improved by it being sanctioned by
international treaty and for costs to be based upon locality rather than a
global value.

3. The current domain name systems should be administered by non-profit
entities, which could include governments and could include underwriting
by the private sector or governments.  However, costs should be spread
across all entities involved (to take into account locality costs).

4. Currently there are structures in place to accomodate these needs.  The
only role government(s) should play would be to sanction these
organizations via international treaty.

5. No, generic top level domains should not be retired.  gTLD and ISO
domains are separate issues.

6. The open model should address most if not all of the technological
concerns that exist currently under the current closed model.  gTLD
registrars should not operate or control root servers, root server are a
truely global asset.

7. Mechanisms to ensure this are already in place, however there could be
problems as there currently are registrars who operate/manage root servers
which is recommended against above.

8. Any transition should be accomplished with minimal impact.  The
question does not specify what transition is in question and therefore no
firm answer can be given.

9. Thousands, but the 8 above cover most of the main points and there are
already organizations in place to address them as they arise.

C. Creation of New gTLDs 

10. There are no technical constrants that can not be overcome.  However,
the purpose of domain names is to make it easier to remember and identify
an IP address so one would think that the oversaturation of TLDs would
ruin the purpose behind domain names.

11. Yes, but the number of them should still be open to discussion.

12. No, unless too many gTLDs are created (see 10 above).

13. Yes.

14. (see 9 above)

D. Policies for Registries

15. No, all gTLDs should be open and shared by their very nature of being 
global. However, there could be a new classification of TLDs created that
had a limited role that would not be shared (such as the current .GOV,
.MIL, .EDU and .INT).

16. Yes and there is already mechanisms in place for this purpose.

17. No.

18. Yes, primarily in the business arena, however that is due to the lack
of requiring non-profit registrars which is highly recommended.
Individuals or corporations do not need to make a profit off of a global
resource.

19. No, gTLDs should all be shared.

20. Yes, the currently contracted registrar will be (and is) collecting
fees from registrants that go beyond the end of its contracted period
(which has already been staed by the NSF will not be renewed). This causes
an unfair challange to new registrars by allowing the current contract
holder to collect monies beyond a period when it will be authorized to
registrar names.

E. Trademark Issues 

21. Internet names should require International mark registration
separate from national registration in order to receive
recognition/protection.


22. A review should be conducted based on #21 above, and the same
International body who issues the marks should handle disputres and all
disputes should be resolved prior to the registration being completed.

23. (see #21 above).  National courts do not have the ability or autority
to act globally.

24. (see #21 above).

25. Yes, by using mechanisms provided for by the entity described in #21
above.

26. Costs would be carried by the registrant if the steps above were
followed.  The registrar would only need to verify a database to see that
the name was "usable".

27. No, no technological solutions to two parties using the same name.

28. (see #9 above).


Sincerely,

Ronald J. Fitzherbert
President
Flying Penguin Productions Limited
Austin, TX (USA)
ron@penguin.net

###
Number: 147
From:      Hal Varian <hal@alfred.sims.berkeley.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/1/97 3:55pm
Subject:   Re: Electronic Filing of Comments on Internet Domain Names

              Comments on Internet Domain Name System
                         Carl Shapiro
                         Hal R. Varian
                         UC Berkeley

[This is an extract from a longer document entitled "US Government
Information Policy" which was sponsored by the Office of the Assistant
Secretary of Defense (Command, Control, Communications and Intelligence).]


The Domain Name System (DNS) links up ``domain names'' such
as {\tt info.sims.berkeley.edu} with IP addresses such as
{\tt 123.45.67.8}.  The purpose of this system is to allow users
to refer to use meaningful names when referencing Internet sites
rather than difficult-to-remember lists of digits.  Originally domain
names were assigned on a first-come-first-served basis by the Internet
Network Information Center (InterNIC) at no cost.  By the mid-90s, the
size of this task had become quite larger and the InterNIC was allowed
to charge a fee to register and maintain names.

One of the problems with the current system of domain name
registration is its interaction with trademark law.  There can be only
one {\tt sun.com} even though Sun Oil and Sun Microsystems might both
like that name.  Recently, the Internet Ad-Hoc Committee (IAHC) has
proposed adding several new top-level extensions ({\tt firm}, {\tt
store}, {\tt web}, {\tt arts}, {\tt rec}, {\tt nom} and {\tt info})
to enlarge the set of names available.
  
Unfortunately, this doesn't really help much with the trademark
problem.  Large firms will simply attempt to register their names in
all of these top-level domains.  It also doesn't help users find what
they want: how do I know whether I am looking for a {\tt firm} or a
{\tt store}?  A better long-run solution would be to harmonize the
top-level domain names with an industrial classification systems such
as the \htmladdnormallink{Standard Industrial Classification
  (SIC)}{http://www.nordexent.com/codes.htm}.  This would yield names
like {\tt sun.oil-gas} and {\tt sun.computer}, which would allow for
harmonization with trademark law {\it and\/} would help avoid user
confusion.

Difficulties arise with ``trademark dilution'' for very well-known
trademarks (like {\tt disney.com}) but dilution cases could be handled
on an ad hoc basis, as they are now.

The other problem would be achieving consensus on appropriate
shortened forms of the names and the appropriate granularity.  There
are 10 top level categories in the SIC codes with about 97 distinct
categories at the two-digit level.  What is important is that the
Internet names map onto the SIC classifications in a reasonable way,
not that the mapping be perfect.  It also may make more sense to use
UN industry classifications in order to encourage international
acceptance.  \htmladdnormallink{Agmon, Halpern, and Paulker
  [1996]}{http://www.law.georgetown.edu/lc/internic/domain1.html}
suggest essentially the same idea using the
\htmladdnormallink{International Trademark
  Classes}{http://www.naming.com/icclasses.html} defined by the World
Intellectual Property Organization (WIPO).

Related problems arise in other aspects of managing the Internet.
Despite the fact that the Internet is highly decentralized, both
respect to its technology and its management structure, there are some
areas that could qualify as natural monopolies.  For example, the
Internet Assigned Number Authority (IANA) ensures that each Internet
domain has a unique IP address.  Although this process can be
decentralized to some degree, there should be some final authority for
resolving problems.  Such an authority would likely have to have some
legal standing, which would presumably be backed by the courts.  There
are other issues, such as the Domain Name System mentioned above,
where industry efforts at coordination that arise need to be
legitimized by legislation.

Such coordination roles may well involve some degree of monopoly
power, though the amounts of money involved are often quite small.
Deadweight loss considerations are much less important that quality of
service and operations efficiency.  One sensible solution is to put
the contract out for bid in the same way that local communities
contract for trash collection.  Tasks such as domain name registration
could be divided among a few contractors and their performance could
be compared.  This kind of ``yardstick competition'' may help provide
efficient and cost-effective service.  

###
Number: 148
From:     "David Barker" <jaeckyl@globaldialog.com>
To:       NTIADC40.NTIAHQ40(dns)
Date:     8/4/97 11:54pm
Subject:  TLD's

 I hope this message has been properly directed.  I am concerned with the
issue of DNS entries being owned by one group or another.  As it stands in
my understanding .com , .net , .org are all controled by one company. 
This I feel is wrong, they are the most recognized letters on the net. 
The US is a capatalistic state and I beleive that no one company should be
allowed to monopolize these entries. 

###
Number: 149
From:     Jim Tippins <jimt@digital.net>
To:       NTIADC40.NTIAHQ40(dns)
Date:     8/4/97 10:14am
Subject:  Electronic Filing of Comments on Internet Domain Names

1. Extend the address standard to at least 1024 bit length addresses.

2. Eliminate the monopoly on net IP's by current service providers/big
companies. (This will happen if net address restrictions in #1 above
changes.)

3. Allow "first come" philosophy to select net names, regardless of
"Name infrignment" lawsuits.

Jim Tippins

###
Number: 150



August 4, 1997

Ms. Patrice Washington
Office of Public Affairs
National Telecommunications and
Information Administration (NTIA)
Room 4898
14th Street and Constitution Avenue, NW

Washington, DC 20230

Dear Ms. Washington:

The International Trademark Association (INTA) is pleased to provide you with its response to the "Request for Comments on the Registration and Administration of Internet Domain Names" [Docket No. 970613137-7137-01], as published in the July 2, 1997 Federal Register. INTA is a not-for-profit organization comprised of 3,400 members from over 117 countries. The Association's membership crosses all industry lines and includes manufacturers, retailers, law firms, and professional and trade associations. What this diverse group has in common, is the understanding that trademarks are a company's most valuable asset -- a simple yet effective means of communicating with consumers in the global marketplace.

In addition to our official response, we are pleased to provide you with a "special edition" of INTA "White Paper:" The Intersection of Trademarks and Domain Names. This INTA publication has been prepared by the Association's Internet Subcommittee as a source of information on the meeting between the world of trademarks and the new world of cyberspace. Most importantly, Appendix II of the "White Paper" contains a complete version of INTA's proposal for a new domain name assignment system. All documents being provided by INTA are contained on computer diskette (WordPerfect 6.1) which has also been enclosed.

INTA appreciates the opportunity to present its views on this important and highly complex issue. Please do not hesitate to contact Mike Heltzer, INTA's Government Relations Program Coordinator, if you require further information.

Thank you for considering our submission.

Sincerely,

David Stimson
President

Enclosures



Appropriate Principles

INTA has answered a, b, c, d, e, and f

Competition in and expansion of the domain name registration system should be encouraged. Conflicting domains, systems, and registries should not be permitted to jeopardize the interoperation of the Internet, however. The addressing scheme should not prevent any user from connecting to any other site.

Ans: INTA recognizes the importance of competition and the importance of inter-operation. It is essential, however, that the administration of Internet domain names recognize that the important and valuable legal rights of trademark owners not be harmed.

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

Ans: INTA generally agrees with this principle and, toward that end, participated in the International Ad Hoc Committee (IAHC) and currently has a representative on the interim Policy Oversight Committee (iPOC) -- the body that oversees implementation of the IAHC plan.

These self-governance mechanisms should recognize the inherently global nature of the Internet and be able to evolve as necessary over time.

Ans: Although the Internet was conceived of and raised from infancy by the U.S. government, it has grown well beyond its borders, and the U.S. government should not now attempt to treat the Internet as a U.S.-asset. Instead, the U.S. government should work with the private sector, as well as other governments and international organizations to permit the Internet to evolve into a truly global asset.

d. The overall framework for accomodating competition should be open, robust, efficient, and fair.

Ans: INTA supports open, robust, efficient and fair competition with appropriate mechanisms to protect the rights of trademark owners.

e. The overall policy framework as well as name allocation and management mechanisms should promote prompt, fair, and efficient resolution of conflicts, including conflicts over proprietary rights.

Ans: INTA agrees that the overall policy framework for domain name allocation and management should promote prompt, fair and efficient resolution of conflicts, including those involving intellectual property. Toward that end, INTA believes that the IAHC plan is a positive step.

The IAHC plan also includes administrative domain name challenge panels (ACPs), that will not take the place of national or regional sovereign courts, but will assist trademark owners in the protection of their well-known trademarks. In addition, the IAHC procedures require detailed contact information of domain name applicants (and those renewing domain names), prepayment for domain names, annual renewal, and procedures for the immediate publication of domain names, all of which should assist trademark owners with their efforts to police against trademark infringement.

f. A framework should be adopted as quickly as prudent consideration of these issues permits.

Ans: INTA supports an early resolution of the problems relating to registration and administration of domain names. The need for an early resolution becomes more critical as the Spring 1998 termination date of NSI's contract with the National Science Foundation (NSF) approaches. However, INTA also notes that the issues that must be resolved involve new and complicated legal and technical concerns that must be carefully considered before arriving at a fair solution.

IAHC has created the necessary framework for the continued evolution of the domain name system. INTA encourages the U.S. government to support the IAHC plan, recognizing the accomplishments of the process, while permitting further evaluation of some of the elements of the plan, including the decision to increase the number of generic top level domain names (gTLDs), and the standards to be applied by administrative challenge panels (ACPs).

B. General/Organizational Framework Issues

INTA has answered questions 1, 2, 3, 4 (part), 5, and 8

1. What are the advantages and disadvantages of the current domain name registration system?

Ans: The Disadvantages

The current system established by Network Solutions, Inc. (NSI) is inadequate to combat "cybersquatters." "Cybersquatters" are online pirates who routinely register domain names in bulk, without regard for the rights of trademark owners and with no other purpose than to ransom the names to the highest bidder. NSI procedures are also not equipped to handle cases where two companies own the same mark, or where an individual's name may be the same as a company's mark. In addition, NSI does not require sufficient information from the domain name applicant.

At the core of NSI's problem is its position that domain names have no legal significance, but are used only to address various sites in cyberspace. Further, NSI has stated that its only purpose is to register domain names, not perform trademark searches or arbitrate trademark rights. NSI contends that it is not equipped or funded to perform such searches and that it should not be responsible for any infringement that takes place involving the domain names it registers. This aspect of NSI's policy is disappointing to trademark owners, since like a trademark, domain names serve as a "shorthand" reference tool to locate information concerning a specific product and learn about the company offering the product for sale. Trademarks in cyberspace deserve the same level of protection they are afforded in the "real-world" of commercial activity.

Instead of being familiar with just a single policy, there is a potential requirement for trademark owners to be familiar with hundreds -- if not thousands of dispute policies. This system represents an unnecessary expenditure of money and manpower. Finally, some registrars do not even have a dispute policy.

Advantages

The disadvantages outlined above make it evident that there are few, if any real advantages for trademark owners under the current domain name registration system. Notwithstanding, there are a select few aspects of NSI's application policy that represent a step in the right direction: (1) an applicant must submit a document that states, to its knowledge, the domain name requested does not interfere with or infringe the rights of third parties and (2) an applicant must have a bona fide intention to use the Internet domain name on a regular basis.

Finally, the ability to get a domain name put on hold may be considered an advantage.

2. How might the current domain name system be improved?

Ans: INTA has circulated a proposal for a new domain name registration policy, portions of which have been incorporated into the IAHC plan. A complete version of the INTA proposal can be found in "Appendix II" of INTA "White Paper:" The Intersection of Trademarks and Domain Names (see attached).

Highlights of this proposal include:

  • Publication of domain name applications on a publicly available Web site for 90 days before the registration becomes effective, with full particulars of the domain name applicant, enabling trademark owners to monitor infringements of their marks.


  • A renewal process, similar to the application process, with a sworn statement by the applicant individual or the officer/general partner of the applicant business entity setting forth the actual use which has been made of the domain name since the application or last renewal period should be required. Renewal should be required every 12 months. This renewal process would help remove "deadwood" from the register.


  • Submission by the applicant to subject matter jurisdiction in an action brought under trademark or unfair competition law, or analogous laws, arising out of actual or intended use of the domain name. Also submission to personal jurisdiction in any competent tribunal in the country in which the registrar through which the domain name registered would be located. Finally, a waiver of the right to challenge either jurisdictional predicate.


  • Agreement that, in the event of a dispute, the registrar would not engage in the resolution of the dispute, but will abide by any order of a tribunal or arbitration panel having jurisdiction.


INTA also supports the plan developed by the International Ad Hoc Committee (IAHC).

3. By what entity, entities, or type of entities should current domain name systems be administered?

Ans: INTA encourages the U.S. government to support the plan of the IAHC and to promote regulation by the private sector.

4. Are there decision-making processes that can serve as models for deciding on domain name registration systems (e.g., network numbering plan, standard-setting processes, spectrum allocation)? Are there private/public sector administered models or regimes that can be used for domain name registration (e.g., network numbering plan, standard- setting processes, or spectrum allocation processes)? What is the proper role of national or international governmental/nongovernmental organizations, if any, in national and international domain name registration systems?

Ans: In accordance with the IAHC plan, INTA supports a system which is industry-driven. The Association does however, support the role of international governmental organizations such as the World Intellectual Property Organization (WIPO) in the administration of on-line mediation and dispute resolution procedures.

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

Ans: Given the current dependence of the commercial world on existing gTLDs, particularly .com, the economic costs of retiring gTLDs would be too great. It is too late to delete mnemonics entirely and use only random numbers based on names. Likewise, requiring country code TLDs alone is not a realistic alternative give the historical use of gTLDs and industry's enthusiasm.

Management issues pertaining to gTLDs are separable from questions of ISO country code domains for two reasons: one historical and one political/practical. The historical reason is that gTLDs and ISO country code domains simply have been treated separately over time by the Internet Assigned Numbers Authority (IANA). The political/practical reason is one of sovereignty and self-determination. INTA believes that the latter remains important in some respects, but the former does not. INTA would like to see all registry policy uniform on questions of second level domain (SLD) assignment and dispute resolution.

8. How should the transition to any new system be accomplished?

Ans: INTA supports the revisions to the existing system contained in the IAHC plan. This plan is currently being implemented by the interim Policy Oversight Committee (iPOC). As a member of IAHC and now iPOC, INTA has been involved in developing the new system and providing input which reflects the needs and concerns of trademark owners from around the world. In May 1997, INTA signed the gTLD Memorandum of Understanding (MoU) acknowledging its support for the IAHC system.

INTA believes the following aspects of the IAHC proposal will be beneficial to trademark owners:

  • Publication of domain name applications on a public Web site, with full particulars of the domain name applicant, enabling trademark owners to monitor infringements of their trademarks.


  • An online challenge process that will permit a trademark owner to contest the granting of a particular domain name.


  • Elimination of registrar discretion in dispute resolution.


  • An admission of both personal and subject matter jurisdiction to overcome the problem of obtaining jurisdiction over the challenged domain holder.


In light of the benefits to trademark owners which are listed above, INTA urges the U.S. government to issue a statement which acknowledges its full support of the IAHC plan. INTA further urges the U.S. government to ensure that the gTLDs which are currently administered exclusively by NSI (.com, .org and .net) as per a cooperative agreement with the National Science Foundation (NSF), be made a part of the shared registry system developed by the IAHC.



C. Creation of New gTLDs

INTA has answered questions 10, 11, 12 and 13

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

Ans: Some proposed domain name plans call for hundreds, even thousands of new generic top level domains (gTLDs). This scenario presents a policing problem for trademark owners, requiring them to spend countless hours monitoring for infringing use of their marks. "Cybersquatters," the pirates of the Internet, would also be given more opportunities to infringe on the good names of trademark owners.

11. Should additional gTLDs be created?

Ans: Not at this time. INTA advocates a "go-slow approach" and views the seven new gTLDs (as proposed by the International Ad Hoc Committee) as an experiment, the results of which, particularly in terms of the increased policing burden on trademark owners, must be considered prior to adopting any more gTLDs.

12. Are there technical, practical, and/or policy issues about guaranteeing the scalability of the name space associated with increasing the number of gTLDs?

Ans: See answer to question 10.

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

Ans: The issues relating to gTLD management are separable from questions involving ISO country code domains for two reasons, one historical and one practical. The historical is that gTLDs and ISO country code domains simply have been treated separately over time by the Internet Assigned Numbers Authority (IANA). The political/practical reason is one of sovereignty and self-determination. INTA believes that the latter remains important, in some respects, but the former does not. INTA would like to see all registry policy uniform on questions of second level domain (SLD) assignment and dispute resolution.



D. Policies for Registrars

INTA has answered questions 18 and 20

18. Are there technical, business and/or policy issues about the name space raised by increasing the number of domain name registrars?

Ans: There are significant business and policy reasons that caution against increasing the number of domain name registrars. It cannot be emphasized enough that domain name registrars must serve in a critical position of worldwide public trust. If one registrar fails to keep that trust, the entire domain name system will suffer.

A policy to support a large (or unlimited) number of registrars bears a likelihood of unintentionally creating economic incentives that will injure trademarks and the overall interests of the domain name system. Because a high number of newly created registrars would be competing for the finite resources of domain name applicants, such registrars would be motivated purely by financial considerations to urge the creation of more and more gTLDs over time to ensure profitability. Registrars would seek to create more gTLDs regardless of the effect upon trademark rights or the needs and best interest of the Internet as a whole.

Numerous registrars competing for profit and for finite resources, also create the potential for a variety of other abuses. For example, a registrar, motivated by financial gain, could misuse proprietary information in a shared registry database to encourage its own applicants to "lock up" certain names. Registrars located in countries whose laws are not as favorably disposed to protecting trademark rights, could also take advantage of the current lack of harmonization in international trademark laws by encouraging extortionists and infringers to take advantage of the jurisdictional advantages afforded under the laws of a particular country. For these reasons alone, the number of domain name registrars must be limited.

It is also instructive to look to the Final Report of the International Ad Hoc Committee (IAHC) for guidance on this issue. That report had proposed the creation of no more than 28 new registrars, based on a regional quota and selected by lottery. One key feature of that proposal was the requirement that the applicant agree to locate the registrar only in countries that are party to the Paris Convention for the Protection of Industrial Property, or are members of the World Trade Organization (WTO) and comply with at least Article 2 of the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS). At an absolute minimum, it is critical to ensure that registrars be located in countries that respect trademark laws.

20. Are there any other issues which should be addressed in this area?

Ans: Registrars should also be subject to a consistent set of registration and dispute resolution policies. INTA has proposed a domain name registry policy for second level domain names that encourages meaningful and effective procedures for (1) ensuring accountability by domain name registrants, (2) allowing complainants sufficient information through an application, pre-screening and publication process to pursue appropriate legal remedies against extortionists and infringers, (3) reducing "deadwood," i.e., unused domain names, (4) increasing the available pool of domain names, (5) ensuring fair and legally supportable decisions regarding domain names; and (6) reducing Network Information Center (NIC) exposure and costs by taking NIC out of the dispute resolution business. INTA endorses the procedures discussed in its proposal and recommends that it serve as the mode to be adhered to by all approved registrars. A complete copy of the INTA proposal can be found in Appendix II of the INTA "White Paper."

E. Trademark Issues

INTA has answered questions 21, 22, 23, 24, 25, 26 and 27

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

Ans: INTA believes, that under certain circumstances, trademark rights need to be protected vis-a-vis domain names. The issue should not be categorized in terms of whether trademark rights stem from common law rights or registration but rather whether a party can lay any claim to superior rights. It is important to note that trademark registration does not confer trademark rights in the U.S. and certain common law countries, but rather merely constitutes rebuttable evidence of those rights. In the U.S., substantive trademark rights arise from actual use as a trademark. In civil code countries, trademark rights exist only through registration. Under trademark law, most trademark owners do not own the right to use the mark in question to the exclusion of all others -- many similar and identical marks coexist happily and peaceably in commerce because rights are very often limited by dissimilarities of products or services, and by jurisdictional territory.

Additional problems arise in the context of the Web. Because people use domain names to locate Web resources, companies doing business online want domain names that are easy to remember and relate to their products, trade names and trademarks. For example, a florist might find the domain name flowers.com very valuable to identify it as a source of flowers. Likewise, owners of famous trademarks (such as Microsoft) typically register their trademarks as domain names (such as microsoft.com). This kind of identification can be highly important to a business that conducts commerce on the Internet. Moreover, many consumers who do not know the domain name of a company often will first choose the principal trademark of such company to locate the company's Web site.

However, the Internet was not created solely for commercial enterprise, and domain names should not be the exclusive province of trademark owners. Thus, those with legitimate non-trademark interests in second level domain names have to be accommodated along with the rights of trademark owners. Similarly, the interests of owners of trademarks which exist in commerce concurrently for non- related products or services must be considered, as do those of well-known marks.

22. Should some process of preliminary review of an application for registration of a domain name be required, before allocation, to determine if it conflicts with a trademark, a trade name, a geographic indication, etc., if so, what standards should be used? Who should conduct the preliminary review? If a conflict is found, what should be done, e.g., domain name applicant and/or trademark owner is notified of the conflict? Automatic referral to dispute settlement?

Ans: After significant study and consideration, INTA concluded that Network Solution's (NSI) domain name dispute resolution policy is unworkable and cannot be "fixed," because neither NSI, nor any other future registrar or network information center should be a tribunal for trademark dispute resolution or be expected to be a specialist in trademark matters.

INTA believes that the issue of whether a domain name conflicts with a trademark or trade name or otherwise is violative of some fundamental principle of trademark law, would best be determined in the manner that trademark rights in general are determined by established judicial and alternative dispute resolution methods. Under the INTA plan (see Appendix II "White Paper"), the proposed domain name would be published on a publicly available and well- publicized database prior to its activation for a period of 90 days. During this time, a potential challenger would have the opportunity to take whatever action it deemed necessary with respect to an applied for second level domain name (SLD), including seeking appropriate relief in the courts. It is anticipated that the publication period would afford potentially adverse parties the opportunities to resolve their differences without litigation.

Generally, it is impractical to assume that satisfactory results will result if domain name conflicts are automatically referred to any dispute settlement mechanism. There is no single, international trademark law, so it not possible to reserve disputes involving trademarks and domain names to a body applying a globally recognized body of law. Therefore, in case of an automatic dispute referral system, the dissatisfied party will often seek to have its rights adjudicated in a national court.

INTA believes, however, that the alternative dispute mechanisms contained in the plan created by the International Ad Hoc Committee (IAHC) may be practical tools for cost-effective resolution of a number of international domain name disputes.

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

Ans: Ideally, trademark disputes involving domain names should be settled voluntarily by the parties. Whether by direct negotiation or mediation, these voluntary solutions should be highly favored whenever possible. INTA is a strong supporter of alternative dispute resolution.

The IAHC, of which INTA was a member, recognized that trademark owners rights arise under national trademark laws because there no single, universal international trademark law. The IAHC and INTA also recognize, that involving the registrar as an arbiter of disputes, no matter how well-intentioned, summarily confers upon a non-judicial body the discretion to essentially grant an injunction against a continued use of a second level domain, without any adjudication of the merits of the trademark owners claim against the domain name holder. Therefore, at this time, the INTA believes that national courts serve as the appropriate forum within which trademark rights can be fairly adjudicated if all voluntary efforts fail.

The IAHC, recognizing the demand for some kind of streamlined dispute resolution, at least in the case of disputes involving a well-known mark, has recommended the creation of administrative domain name challenge panels. These panels do not substitute for national or regional sovereign courts; they have authority over the domain names only, not the parties. Unlike courts, however, the challenge panels would have the ability to exclude certain names such as well- known trademarks from all generic top level domains (gTLDs). These standards by which such panels would operate are still being developed. INTA believes that such an approach may prove to be an effective tool against "cybersquatters."

24. How can conflicts over trademarks best be prevented? What information resources (e.g., data bases of registered domain names, registered trademarks, trade names) could help reduce potential conflicts? If there should be a data base(s), who should create the data base(s)? How should such a data base be used?

Ans: Conflicts over trademarks in cyberspace can best be prevented through traditional means. A party wishing to protect a trademark throughout the world, should register the trademark in as many countries as possible and otherwise attempt to publicize the proprietary status of the trademark. The importance of national trademark registrations is not diminished under INTA's proposed policies, as national trademark courts will continue to look to national laws, which primarily rely on trademark registrations as indications of a mark's protectability. Trademarks which are well-known around the world can be protected in countries in which the mark is not registered under the provisions of Article 6 (bis) of the Paris Convention to which nearly all trademark jurisdictions are signatories.

Trademark owners will continue to have a duty to police the use of their marks throughout the world. Vigilant policing and early detection of infringement usually prevents disputes from becoming litigations.

The IAHC plan (and INTA's proposed domain name registration policy) mandates that an application to register a second level domain name be quite detailed, as explained in response to question 25. Under INTA's proposal, all of these details would be published by the local registrar on a central publicly available Web site for 90 days before the registration becomes effective and before the registrant may begin use. The publication period would commence no later than one week after the registrar receives a fully completed application, including the fee. The publication period would allow potential challengers to take appropriate action. It is assumed that commercial searching services and smart agents/robot searching programs would be sufficient to monitor the publication Web site. In fact, such agencies already actively monitor the registration of new domain names and the use of trademarks on the Internet. The purpose of the database would be for potential challengers to a SLD to determine if sufficient cause exists to object to or take any action against the issuance of the new domain name, preferably, within the 90-day publication period.

25. Should domain name applicants be required to demonstrate that they have a basis for requesting a particular domain name? If so, what information should be supplied? Who should evaluate the information? On the value of what criteria?

Ans: Applicants should be required to identify the basis for their particular domain name request. As further described in INTA's proposed registry policy (see Appendix II of INTA "White Paper"), INTA believes that standard registration procedure should require the applicant to disclose the following information:

  • The applicant's name, business or residential address, telephone and fax numbers and e-mail address.


  • The state or country of incorporation or partnership (if applicable).


  • Certified copy of the certificate of incorporation or partnership (if applicable).


  • The name and address of an agent for service of process, which can be the applicant in the case of an individual. Service on the agent will constitute an effect upon the registration of the domain name.


  • A sworn statement by the individual applicant, or by an officer of the applicant corporation or general partner of the partnership:




* That there is a bona fide intention to publicly use the domain name within 60 days of its registration and a bona fide intent to continue such use for the foreseeable future.

* That the domain name will be used for a [stated] use (e.g., for a web site to advertise the applicant's business, namely,________.) (This can be a very broad statement and is not intended to restrict actual use.)

* That the applicant believes that the domain name is available and does not infringe the rights of any other party.

* That the applicant submits subject matter jurisdiction in an action brought under trademark or unfair competition law, or analogous laws arising out of the actual or intended use of the domain name, and also submits personal jurisdiction in any competent tribunal in the county in which the registrar to which the domain name would be registered is located, and waives the right to challenge either jurisdictional predicate.

* That the basis for the claim could be the applicant's trademark, or business name, or nickname, or child's name, etc.

The INTA domain name registration policy would also mandate a renewal process, similar to the application process, with a sworn statement by the applicant individual or the officer/general partner of the applicant business entity setting forth the actual use of the domain name since the application or last renewal period.

It is not the purpose of the registrar to evaluate the information. The information would be made publicly available so that owners of trademark rights or other potential challengers of the second level domain may fully evaluate the basis on which the domain name has been requested. It is INTA's belief that a great deal of litigation can be avoided once it is made clear that a domain name applicant's intended or actual use does not conflict with any trademark rights of the potential challenger. Additionally, INTA strongly believes that a potential domain name holder will be very hesitant to commit acts of piracy when, as opposed to the present time, it is forced to disclose extensive information under oath and subject itself to services of legal process and jurisdiction.

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

Ans: Creating multiple gTLDs may result in more problems for the owners of trademarks by imposing an enormous policing burden on the trademark owner requiring them to spend additional fees for monitoring each new international top level domain (TLD) for potential infringement/dilution. Further, as long as registering another's trademark as a domain name is considered lucrative, each new gTLD creates the opportunity for valuable trademarks to be misappropriated.

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

Ans: A directory of domain names could assist in alleviating likelihood of confusion, but this is not a complete solution. A directory would assist in situations where legitimate trademark owners would normally co-exist without confusion in industry. For example, apple.com could legitimately be owned by companies such as Apple Computers, Apple Records or Apple Bank. A directory appearing on the screen at the outset when "apple" is typed could assist the user in locating the correct company. However, a directory will not help in the case of an extortionist who registers a well-known mark as a domain name. Further, a directory would not assist in instances where the user does not have enough information in the directory to figure out which company it is seeking: e.g., XYZ, Inc., XYZ Company, XYZ Industries. Consequently, INTA supports development of directories, but maintains it only addresses one part of the domain name problem.


###
Number: 151
From:     Darrell Greenwood <Darrell_Greenwood@mindlink.net>
To:       NTIADC40.NTIAHQ40(dns)
Date:     8/4/97 3:21pm
Subject:  Comments - Registration And Administration Of Internet Domain Names


                            Before the
                  U.S. DEPARTMENT OF COMMERCE
    National Telecommunications and Information Administration
                       Washington, DC 20230



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


  Comments of Darrell Greenwood




                                                 (signed) by Darrell Greenwood
                                                 Aug 4, 1997

                                                 Darrell Greenwood
                                                 3985 Dundas, Burnaby, BC
                                                 Canada, V5C 1A6

                                                 Retired


                                                 Aug 4, 1997

------------------------------ break ------------------------------


                        TABLE OF CONTENTS

     Summary

     A. Appropriate Principles
        Principles a-f
        Other principles

     B. General/Organizational Framework Issues
        Questions 1-9

     C. Creation of New gTLDs
        Questions 10-14

     D. Policies for Registries
        Questions 15-20

     E. Trademark Issues
        Questions 21-28

     F. Other Issues
       [List other issues addressed]


------------------------------ break ------------------------------


                              SUMMARY


I support the principles of the gTLD-MoU at
<http://www.iahc.org/gTLD-MoU.html>.  I reproduce these principles
below for ease of reference;


SECTION 2. - Principles

The following principles are adopted:

     a. the Internet Top Level Domain (TLD) name space is a public
resource and is subject to the public trust;

     b. any administration, use and/or evolution of the Internet TLD
space is a public policy issue and should be carried out in the
interests and service of the public;

     c. related public policy needs to balance and represent the
interests of the current and future stakeholders in the Internet name
space;

     d. the current and future Internet name space stakeholders can
benefit most from a self-regulatory and market-oriented approach to
Internet domain name registration services;

     e. registration services for the gTLD name space should provide
for global distribution of registrars;

     f. a policy shall be implemented that a second-level domain name
in any of the CORE-gTLDs which is identical or closely similar to an
alphanumeric string that, for the purposes of this policy, is deemed
to be internationally known, and for which demonstrable intellectual
property rights exist, may be held or used only by, or with the
authorization of, the owner of such demonstrable intellectual
property rights.
       Appropriate consideration shall be given to possible use of
such a second-level domain name by a third party that, for the
purposes of this policy, is deemed to have sufficient rights.


------------------------------ break ------------------------------

                            Before the
                  U.S. DEPARTMENT OF COMMERCE
    National Telecommunications and Information Administration
                       Washington, DC 20230



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


  Comments of Darrell Burtt Greenwood


I, Darrell Greenwood, respectfully submit comments in this proceeding.

I am a retired telecommunications manager and internet user who
participated fully in the IAHC-discuss mail list, reading all
submissions to the mail list during its life, reading  related
material and commenting to the mail list as appropriate.

I have no financial or other interests in any internet, ISP, or
registrar business and submit these comments as an internet user.


------------------------------ break ------------------------------

A. APPROPRIATE PRINCIPLES


     a. Competition in and expansion of the domain name
     registration system should be encouraged. Conflicting
     domains, systems, and registries should not be permitted to
     jeopardize the interoperation of the Internet, however. The
     addressing scheme should not prevent any user from
     connecting to any other site.

Yes.

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

Yes.

     c. These self-governance mechanisms should recognize the
     inherently global nature of the Internet and be able to evolve
     as necessary over time.

Yes.

     d. The overall framework for accommodating competition
     should be open, robust, efficient, and fair.

Yes.

     e. The overall policy framework as well as name allocation and
     management mechanisms should promote prompt, fair, and
     efficient resolution of conflicts, including conflicts over
     proprietary rights.

Yes.

     f. A framework should be adopted as quickly as prudent
     consideration of these issues permits.

Yes.


------------------------------ break ------------------------------

B. GENERAL/ORGANIZATIONAL FRAMEWORK ISSUES


     1. What are the advantages and disadvantages of current
     domain name registration systems?

Disadvantage - NSI monopoly.

     2. How might current domain name systems be improved?

Eliminate monopolies.

     3. By what entity, entities, or types of entities should current
     domain name systems be administered? What should the
     makeup of such an entity be?

The gTLD - MoU covers this well.

     4. Are there decision-making processes that can serve as
     models for deciding on domain name registration systems (e.g.,
     network numbering plan, standard-setting processes, spectrum
     allocation)? Are there private/public sector administered
     models or regimes that can be used for domain name
     registration (e.g., network numbering plan, standard setting
     processes, or spectrum allocation processes)? What is the
     proper role of national or international governmental/non-
     governmental organizations, if any, in national and
     international domain name registration systems?

The gTLD - MoU covers this well.

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

It is not practical to retire the gTLDs.

     6. Are there any technological solutions to current domain
     name registration issues? Are there any issues concerning the
     relationship of registrars and gTLDs with root servers?

The gTLD - MoU covers this well.

     7. How can we ensure the scalability of the domain name
     system name and address spaces as well as ensure that root
     servers continue to interoperate and coordinate?

The gTLD - MoU covers this well.

     8. How should the transition to any new systems be
     accomplished?

The gTLD - MoU covers this well. Direction is needed from NSF or
appropriate agency to NSI to cause NSI to cooperate in making the
transistion to the system outlined in the gTLD - MoU.


     9. Are there any other issues that should be addressed in this
     area?

I have no further comments in this area.


------------------------------ break ------------------------------

C. CREATION OF NEW gTLDs


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

No.

     11. Should additional gTLDs be created?

Yes.

     12. Are there technical, business, and/or policy issues about
     guaranteeing the scalability of the name space associated with
     increasing the number of gTLDs?

Yes. The issues are handled by the gTLD - MoU.


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

Yes.

     14. Are there any other issues that should be addressed in this
     area?

I have no further comments in this area.

------------------------------ break ------------------------------

D. POLICIES FOR REGISTRIES


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

A gTLD registrar absolutely should *not*, repeat *not*, have
exclusive control. This would have, and has had, a major negative
impact on domain name holders.

     16. Should there be threshold requirements for domain name
     registrars, and what responsibilities should such registrars
     have? Who will determine these and how?

The threshold requirements should be as low as practical. Ideally
every ISP should find it possible to be a registrar if they wish.

     17. Are there technical limitations on the possible number of
     domain name registrars?

No. No practical limitation in the near future, other than not having
too many during the startup period.

     18. Are there technical, business and/or policy issues about the
     name space raised by increasing the number of domain name
     registrars?

Yes. The gTLD - MoU handles this well.

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

No, there should be no limit on the number of different gTLDs a
registrar can handle.

     20. Are there any other issues that should be addressed in this
     area?

I have no further comments in this area.

------------------------------ break ------------------------------

E. TRADEMARK ISSUES

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

Minimal trademark rights should be protected. In this case the gTLD - MoU
is possibly more protective than it should be in my opinion, but I
can live with 'internationally known' trademarks being protected as
detailed in the gTLD - MoU.

     22. Should some process of preliminary review of an
     application for registration of a domain name be required,
     before allocation, to determine if it conflicts with a trademark,
     a trade name, a geographic indication, etc.? If so, what
     standards should be used? Who should conduct the
     preliminary review? If a conflict is found, what should be
     done, e.g., domain name applicant and/or trademark owner
     notified of the conflict? Automatic referral to dispute
     settlement?

gTLD - MoU is the best solution for these questions. In the long run
policies should be adopted by the POC of the gTLD - MoU which
eliminates the profitablity and existence of  domain name hoarders.

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

The gTLD - MoU covers this well.

     24. How can conflicts over trademarks best be prevented?
     What information resources (e.g. databases of registered
     domain names, registered trademarks, trade names) could help
     reduce potential conflicts? If there should be a database(s),
     who should create the database(s)? How should such a
     database(s) be used?

A domain name should not be considered a trademark item any more than
a 'vanity' automobile license plate is considered a trademark item.

     25. Should domain name applicants be required to
     demonstrate that they have a basis for requesting a particular
     domain name? If so, what information should be supplied?
     Who should evaluate the information? On the basis of what
     criteria?

No.

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

If there is minimal interaction between trademarks and domain names as
there should be, the number of different gTLDs and number of registrars
will have no effect in the number and cost of resolving trademark
disputes. 

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

No.

     28. Are there any other issues that should be addressed in this
     area?

I have no further comments in this area.

------------------------------ break ------------------------------

F. OTHER ISSUES


I have no comments in this area.
------------------------------ break ------------------------------

                              Annex 1
                           SERVICE LIST

[List parties to whom you provided courtesy copies.]

None.

###

Number: 152
 From:     "Justin T. Youens" <aggie@cleaf.com>
To:  NTIADC40.NTIAHQ40(dns),NTIADC40.SMTP40("aggie@clea...
Date:     8/4/97 12:23pm
Subject:  dns comments

my comments on dns setup

I think that the current system is reliable at best. We need faster
and more solid processing on domain services. My company is a victim of
the sluggish and "forgetful" registration process. One request for a 
modification, registration, or deletion should be all that is needed, and
a response should happen instantly, with processing shortly there after.
We all know where technology is right now, and it is certainly capable of
going through a database, no matter the size, and making a couple of 
changes in a couple of minutes.  Yet we must wait weeks for even a reply 
that the request was recieved! I thought E-Mail worked faster than that!
I guess it doesn't, my friends just see into the future and write me 
replies to my mail weeks in advance. This also applies for NIC Handles,
DNS information, and everything. I think that the future of the net needs
to be a little more concerned about the businesses that make up, support, 
and rely on it. 

As for organization of domains. There needs to be more defining 
extentions. Lets make so new ones that reach out further and divide
the people having fun from the businesses. Make a new one for "tourist
attractions" maybe ".fun". One for porn, maybe ".xxx". One for public
schools, maybe ".pub". This would make things so much easier if someone
would sit down and think up who has domains, and how to catagorize them.
I know it would make programs such as Net Nanny easier to opperate, and
it could even be incorporated into browsers easier. Schools could simply
lock out all "????.xxx" and not have to worry about it. Then enforce it.
No one can put commercial stuff on ".fun", and no porn unless its on a 
".xxx".  If someone breaks the rules, take their domain. Or make a 3 
strikes you're out program. Or if its a user on an ISP, make the ISP 
cancel their web page abilities. Also have the ISPs check their own space
so that the work can be divided up. And if they don't, or they slack off,
penalize them.  We can't have the net a place of anarchy, but we 
shouldn't try to be dictorial about it either.

My 2 pence.

John Daniels
I-Pagez Internet Creations
jdaniels@ipagez.com (as soon as my domain gets its modification processed)
here@juno.com
aggie@cleaf.com

###
Number: 153
From:      Barry Cohen <becohen@halldickler.com>
To:             "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date:           8/4/97 4:03pm

 

Attached please find the CASIE Response to the Department of Commerce 
request for Comments regarding the Internet. The format of the document is 
WordPerfect 6X for windows. Please call me at the number below or send 
email if you have any problems accessing this file.

Barry Cohen
Director of Information Technology
Hall Dickler Kent Friedman & Wood LLP
909 Third Avenue
New York, NY 10022-4731
212-339-5456




Coalition for Advertising Supported Information and Entertainment
(CASIE)
Submission to the Department of Commerce Request for Comments on the
Registration and Administration of Internet Domain Names

Docket No. 970613137-7137-01

To: Patrice Washington, Office of Public Affairs, National
Telecommunications and Information Administration (NTIA), Room 4898, 14th
St. And Constitution Ave., NW, Washington, DC 20230

From: Douglas J. Wood, Esq., CASIE Legal Counsel, Hall Dickler Kent
Friedman & Wood LLP, 909 Third Ave., New York, NY 10022.  Telephone: (212)
339-5400; Telecopy: (212) 935-3121; email: dwood@halldickler.com. 

     This submission to the Department of Commerce Request for Comments on
the Registration and Administration of Internet Domain Names is filed on
behalf of the Coalition for Advertising Supported Information and
Entertainment (CASIE), a joint effort of the U.S. based Association of
National Advertisers (ANA) and the American Association of Advertising
Agencies (AAAA or 4A's), the members of which have and continue to spend
millions of dollars per year on Web sites and electronic commerce.  They
are among the true users of the Internet. 

  Before commenting on the specific questions posed by the Department,
some general observations are in order. 

  I.  CASIE and Its Involvement

     Since January, 1996, CASIE has been monitoring and evaluating changes
to the Internet that may become effective as early as this fall.  This
included attendance at key meetings in Geneva, Switzerland, Washington,
D.C. and New York City.  These meetings included sessions with
representatives from both the International Ad Hoc Committee ("IAHC") and
Network Solutions, Inc. ("NSI"), the two main proponents of change. 

     
          


                       The proposed changes may have a profound impact on
the Internet.  Unfortunately, the IAHC, now known as the Interim Policy
Oversight Committee ("iPOC") and NSI have become polarized in the debate. 
The polarization is largely due to NSI's failure to participate in the
public forums in Geneva and elsewhere sponsored by, or held on behalf of,
the iPOC.  This lack of open communication and debate by and between the
two primary players in the controversy has created the troublesome
possibility of disruption -- or worse yet fragmentation -- of the
Internet.  This could mean e-mail does not get delivered, security is
compromised, and Web sites become inaccessible from some computers.  Given
the fragility of the Internet and its unproven performance as an effective
form of media for advertisers, the present situation has received close
attention by the U.S. advertiser and advertising agency communities who
collectively have contributed the bulk of funds thus far invested in the
Internet. 

     II.  The Historical Perspective

          While CASIE does knows that the Commerce Department is aware of
much of the history of the Internet that has brought us to the present
situation, it is nonetheless helpful for CASIE to outline its
understanding of that history.  If there is any material error in its
understanding, CASIE welcomes corrections. 

          Historically, Internet administration was primarily under the
auspices of the Internet Architectural Board ("IAB") and the Internet
Assigned Number Authority ("IANA").  IAB was responsible for the technical
architecture of the Internet and the IANA was responsible for
administering the allocation of Internet addresses among various
registrars that dealt with those in the public who wanted to establish a
presence or Web site on the Internet.  From the outset, IAB and the IANA
worked with the National Science Foundation ("NSF"), an agency within the
U.S. government dedicated, in part, to the development of new businesses
in the science and technology sector. 

          As the Internet grew, the NSF decided some existing roles could
be subcontracted to the private sector.  In 1992, the NSF called for
private sector bids to administer registrations under the .com, .net, and
.org. gTLDs.  NSI won the bid.  The contract expires in March, 1998. 

          Upon winning the bid, NSI took control of InterNIC, the body
that dealt with the public in the registration process in a nonprofit
status.  At the same time, two other "NIC's" were operating, ApNIC,
covering the Asian Pacific area, and RIPE,

covering most of Europe, although the geographical coverage of each was
technically not exclusive.  Nonetheless, InterNIC focused primarily on the
United States where the greatest growth occurred.  NSI invested millions
of dollars in developing .com, .net, and .org.  It was .com, however, that
saw the greatest growth, now with more than 1.4 million registrants and
new registrants coming aboard at a reported pace of nearly 100,000 per
month. 

          All this ran smoothly until 1996 when the NSF granted NSI
permission to charge a fee to new registrants and to require renewal fees
from those already on the Internet and to become a profit-making entity. 
Not surprisingly, NSI started making significant revenues, much to the
consternation of some members of the Internet community. 

          The prospect of profits also caught the attention of many
would-be entrepreneurs hoping to cash in on the bonanza.  They took a
number of forms.  First, an entire industry of Web site designers and
access providers was born.  Today, it is probably the most robust industry
associated with the Internet.  On a somewhat parallel course to the
InterNIC, the Alternic was formed by a loose association of companies
offering access to the Internet via their own network servers, using any
variety of top level domain names to entice registrants.  Some of the
Alternic's TLDs included .corp., .web, .arts, and .sex, each name intended
to indicate the nature of materials a consumer might find within the given
gTLD.  The Alternic, however, never really took off and is rumored today
to be largely a thing of the past, although some of the organizations that
first formed the Alternic are supposedly trying to form yet another
network that will access the Internet. 

          The NSF added more confusion to the situation when it announced
in April, 1997 that upon expiration of its contract with NSI in March,
1998 for the administration of its gTLDs, the NSF would not renew NSI's
contract and would no longer stay involved in Internet administration,
leaving it to the private sector to sort it all out.  This abandonment
allowed NSI to claim brand ownership of .com, .net, and .org, the
underpinning of NSI's competition model. This is a somewhat curious
position.  Clearly, when NSI was awarded the contract, it did not own the
gTLDs it administered under the terms of its contract with NSF.  Its
position, however, is that it built the gTLDs into the brands they are
today.  In NSI's words, "it invested millions in developing personnel,
policies and infrastructure to run domain name registrations.  Through its
own efforts alone, NSI has taken full risk on profit and loss,
with no assurances of profit."  It is under this theory that NSI
presumably believes it has a right to claim ownership of its gTLDs.  This,
however, would depend upon applicable local trademark laws. 
          
          During this process, it also became apparent that the second
level domains ("SLDs") were very valuable commodities.  Since the Internet
is a technical environment, no two SLDs can be identical within the same
gTLD.  For example, there can be only one cocacola.com. 

 While that may seem logical insofar as The Coca-Cola Company is
concerned, the issue is far more complicated in other examples.  Who
should have the right to delta.com?  Delta Airlines or Delta Faucets?  Who
should have the right to united.com?  United Airlines or United Van Lines? 
This dilemma gave rise to cybersquatters, individuals who rushed to
register as many SLDs with names associated with famous trademarks or
companies as they could with the hope of later selling them to the highest
bidder.  Trademark owners revolted and demanded that NSI address the
situation.  In response, NSI set up a rigid procedure whereby a
disgruntled trademark owner could challenge a domain name holder on the
basis of its superior trademark rights.  If victorious, the trademark
owner would have the right to the disputed SLD.  While the NSI challenge
process served to solve some of the problems, it created new ones as well,
particularly since it depended on the judicial system if a matter could
not be settled.  According to NSI, the result has been twenty six lawsuits
naming NSI as a defendant.  All but four of the suits have reportedly been
settled.  NSI points out that this is a relatively insignificant number
given the more than 1.4 million registrants.  Not within the number of
lawsuits, however, are the unknown number of private battles between
claimants to the same or similar SLDs and the unknown number of would-be
registrants who have abandoned a claim to a previously claimed SLD even
where they might have had a valid claim.  Add the business disruption that
lawsuits cause, and the "insignificance" of the problem is put into better
perspective. 

          As the phenomenon of cybersquatting grew, it became apparent
that SLD space was a very valuable commodity that grew scarcer every day
as more and more names were registered with InterNIC.  Amid all this
controversy, there was also a concern among some in the Internet technical
community, that the .com domain was growing too fast and that its growth
could undermine the structural integrity of the network.  It should be
noted that NSI disputes the conclusion that huge growth within the .com
domain threatens the stability of the Internet. 

          

          From this was born the IAHC.  While it is not altogether clear
how the IAHC was formed, its goals were to establish a centralized
administrative structure for the Internet and to introduce competition to
NSI in domain name registration and administration. 

          To understand the next stage of the controversy precipitated by
the organization of the IAHC requires some basic understanding of how the
Internet works. 
          Composing the heart of the Internet are the primary root
servers.  There are presently nine primary root servers operating, eight
in the United States and one in Sweden.  There can be as many as thirteen
primary root servers under the present structure of the Internet, the
technical reasons for which are unnecessary to this discussion.  These
primary root servers are designated with the first thirteen letters of the
alphabet -- "A" through "I" (most of which are maintained by uncompensated
volunteers who consider IANA the ultimate authority).  It is to the
primary root servers that the Internet Service Providers ("ISPs") and
Internet Access Providers ("IAPs") connect to access the Internet and
begin the journey of a given message from one remote computer to another
somewhere else in the world.  Perhaps the easiest way to understand the
structure is to picture the primary root servers as a multi-line
telephone, with the "A" server representing the first line and the
remaining servers, "B" through "I" representing the balance of the lines. 

          In order for the Internet to work, all registrants in all TLDs,
including the ISO 3166 country codes, must have their Internet addresses
entered first on the A server's database and then downloaded to the B
through I servers.  By doing so, whenever a Web user accesses the Internet
through his or her ISP or IAP, that Internet provider's connection to any
of the primary servers enables a search of the primary root server
databases until the location of the address the Web user requested is
found and the connection completed.  At present, NSI owns and controls the
"A" primary root server.  Every day, thousands of new Internet addresses
are loaded into its database by registrars of the ISO 3166 country codes,
its own InterNIC database of new registrants, and any new registrations
from APNIC or RIPE.  These are in turn downloaded into the databases of
the other primary root servers.  Thus, new addresses, including any new
gTLDs and associated SLDs attached to those gTLDs, cannot get into the
Internet unless they are first entered into the NSI's primary root server. 



          Recently, however, NSI has publicly taken the position that it
does not have the authority to accept new gTLDs, citing that such
authority must come from a consensus within the Internet community. 
Contrary to previously understood "protocol," it has become apparent that
NSI no longer recognizes the IANA as the authority over the authorization
of new TLDs, despite the fact that NSI accepted that authority for years
under what is described as a cooperative agreement between NSI and the
IANA.  Since the IANA is a part of the IAHC and a proponent of the IAHC
competition model, it would be inconsistent for NSI to propose its own
plan and at the same time take instructions from the IANA, despite its
history of doing so.  On the other hand, the IANA clearly believes it has
authority to unilaterally authorize the new gTLDs, although a letter has
been circulated by NSI from legal counsel for the University of Southern
California where the IANA resides that denies the IANA unilaterally has
such authority, again citing that such authority must come from a
"consensus" within the Internet community.  The problem with both NSI's
and USC's legal counsel's position is that NSI can effectively veto any
additional gTLDs if it disagrees with their implementation since NSI is a
material part of the Internet community whose disagreement with a given
course destroys the prospect of consensus. 

          This is where the real confusion starts. 

          The IANA has publicly said it does not believe NSI will violate
its long-standing cooperative understanding with the IANA and refuse to
program the new gTLDs into the Internet Domain Name Service.  The IANA has
posted a number of warnings to NSI regarding what the IANA believes to be
NSI's obligation in that regard.  NSI, however, continues with its public
position of lacking authority to implement the IAHC proposal.  In the face
of this, it is rumored that the IANA could order a realignment of the
primary root servers so that the one maintained by NSI is no longer the
"A" server from which all programming of new Internet addresses emanates.
The problem with that scenario, however, is that nothing would force NSI
to include the new programming on its server, thereby "splitting" the
Internet so that .com could not, for example, communicate with .firm and
vice versa.  The IAHC proposal calls for the new gTLDs to become active as
early as fall 1997.  If the stalemate between NSI and the IANA is not
resolved by then, the Internet community may face a disruption of the
Internet. 



          It is also important to remember that among the original group
of Internet founders are those who are very passionate about the integrity
and stability of the Internet.  Should NSI or any other organization play
an active role in any disruption, the "old timers" on the Internet, many
of whom are very technically savvy, may strike back by creating even more
disruption with "spamming" or other destructive programming.  It is
possible that, should the IANA "program out" NSI's "A" server, the
remaining servers comprising the Internet might be significantly more
vulnerable to hacker attacks.  Such knee jerk reaction by Internet
fanatics is not unprecedented. 

     III.  The Competing Proposals

          A.  The IAHC Proposal

               The IAHC has proposed a number of profound changes in the
present structure of the Internet.  The key changes are: 

                        Basic administration of the Internet by the
Policy
                     Oversight Committee ("POC") whose members are
appointed by a group of trade associations and quasi-governmental
organizations.  The POC will be physically based in Geneva, Switzerland. 
The iPOC is
                     in place until the full POC is appointed later this
year. 

                        Seven new gTLDs:

                       firm -- for businesses or firms; 
                       store -- for businesses offering goods to
purchase; 
                       web -- for entities emphasizing activities related
to the World Wide Web
                       arts -- for entities emphasizing cultural and
entertainment activities
                       rec -- for entities emphasizing
recreation/entertainment activities
                       info -- for entities providing information
services
                       nom -- for those wishing individual or personal
nomenclature

                        The addition of new registrars to compete with
InterNIC via a shared database of all SLD registrations worldwide.  Under
the iPOC proposal,
                         SLDs are "portable" -- a company can choose to
use
                         any registrar to register and/or administer its
SLD
                              and can change registrars at any time.  Such
a move
                         would not require a change in an Internet address
                              and would be transparent to consumers, much
like
                              a change in long distance telephone
carriers. 

                                         The establishment of a
self-regulatory process to resolve disputes over the ownership of SLDs in
instances where the owner of an "international
                      trademark" disputes a SLD registrant's right to a
particular domain name.  The procedure also
                     allows for the owner of an international trademark to
                     petition for a special ruling that its international
trademarks can be used only by it in any or all of the
                         gTLDs.  

          A.  The NSI Proposal

               In response to the IAHC proposal, NSI released its own
plan.  The key provisions in the NSI proposal are the following: 

                        Basic administration of the Internet by the
Federal Advisory Committee initially under the sponsorship
                         of a U.S. government agency and later shifted to
an
                         organization sponsored by an entity like the U.N. 

                        SLDs would not be shared in a common database. 
NSI would continue to "own" .com, .net, and .org and all
                         the SLD registrations within those domains. 
                     Marketplace demands would dictate whether
                     new registrars are formed to compete with
                     NSI's InterNIC.  If a company desires to enter
                     the market as a registrar, it would create its own 
                     gTLD and "own" it and the SLD registrations 
                     within it.  Thus, SLDs are not portable among 
                     registrars unless an owner is willing to change 
                     the gTLD, e.g., cocacola.com would become 
                     cocacola.firm.

                        Unlike the IAHC proposal, no new gTLDs are
immediately proposed.  New gTLDs would be
                     added as new companies chose to become registrars
                     as marketplace demands dictate.
          
                        Much like the present procedure, there is no
centralized SLD dispute resolution system in the
                     NSI plan.  Fights over who has the right to a given
                     SLD would be determined primarily by local courts.

     IV.  CASIE's Review and Conclusions

          In the end, CASIE's primary concern is that the Internet be a
stable medium for delivery of product and service information and
commercial messages to consumers.  Any system must also respect brands,
minimize consumer confusion, and avoid unnecessary administrative expenses
in doing so.  The IAHC proposal is one approach.  NSI's is another.  The
fact remains that many individuals, organizations, and companies very new
to the Internet only learned of the IAHC/NSI debate in December, 1996, the
timing of which made it very difficult to focus on given the holidays. 

          In the ensuing months, however, CASIE has had the opportunity to
review both the IAHC and the NSI proposals and to meet with the principals
of both organizations as well as attend key meetings on the future of the
Internet.  CASIE feels it is very competent to voice its opinion on the
various proposals. 
  
          On the basis of that review, CASIE believes that the IAHC plan
is a sound beginning and that the NSI plan is fatally flawed and should be
rejected as a viable structure for the Internet for numerous reasons,
including the following: 

                The NSI proposal has more government involvement and
oversight than the IAHC proposal.  Contrary to the rhetoric in the
marketplace, the IAHC has less government oversight and involvement than
the NSI proposal.  Indeed, the entire underpinning of the NSI proposal is
initial sponsorship by a U.S. government agency.  While the IAHC proposal
has quasi-government organizations involved, their role is not pivotal and
is less intrusive.  Interestingly, NSI describes the IAHC proposal as "too
bureaucratic."  Yet NSI's proposal has just as many bureaucratic layers. 

                The NSI proposal will allow for virtually uncontrolled
proliferation of gTLD's without a common SLD dispute resolution system in
place.  Since increasing gTLDs will undoubtedly become a reality in the
near future, it is better that it be controlled by a single source rather
than by the whims of entrepreneurs.  Otherwise, there is no assurance that
a given gTLD will be here one day and fail the next, leaving registrants
in the lurch. Thus, the NSI proposal is not attractive for brands and
brand protection for at least two reasons: 

                    > There is potential for consumer confusion as gTLDs
are added without centralized control or efficient directories, e.g.,
consumer confusion in trying to remember which gTLD serves a given SLD and
whether it has changed. 

                    > Because the NSI proposal has no viable provision for
centralized SLD dispute resolution, it leaves controversies to present
judicial systems where brand protection is spotty and expensive and where
each country may have entirely different approaches to trademark
protection. 

                The lack of portability of an SLD together with its
corresponding gTLD poses a significant problem for brand owners.  Since
brand names are often embedded in the domain address, changes are
undesirable.  In addition, the task of notifying consumers of a change
should a registrant change to another gTLD is unnecessary and cumbersome. 
Under the NSI proposal, if a registrant is dissatisfied with its
registrar, it must change its address to a new gTLD should it "relocate." 
This would in turn require "change of address" notices to Web browsers and
consumers, revising Web page content, and loss of immediate connection by
those consumers who have bookmarked the prior location.  Under the IAHC
proposal, a change in registrars would be transparent to the consumer. 
The result is better for both the domain owner and the public. 

                The competition model in the IAHC proposal is better. 
Based upon competition at the SLD level, the IAHC proposal will create
more robust competition.  Pricing and service will be the keys to
distinguish one registrar from another under the IAHC proposal.  Under the
NSI proposal, competition is at the gTLD level.  Given the inability to
migrate an address, a registrant is somewhat captured by a registrar under
the NSI proposal.  Clearly, it is less desirable to change a gTLD under
the NSI proposal than it is to change a registrar under the IAHC proposal. 
The latter is invisible to the consumer, the former requires Web page
content changes, explanations to consumers, and additional expenses.  NSI
argues that the "IAHC proposal does not recognize the need for market
branding in the commercial world.  Legitimate corporations will not invest
time, stockholder capital, and other resources in 'shared' brands."  While
it may be true that a given company may be more motivated to invest in
servicing a gTLD if it owns it, there are plenty of marketplace examples
where servicing shared databases has made for very healthy competition. 
The battle for long distance telephone carriage is but one of them.  NSI's
conclusion is a generality that does not pass muster under examination. 

                Contrary to perception, the key players in the iPOC are
U.S. based and thereby maintain, at least philosophically, a U.S.-centric
Internet.  While the NSI proposal is also U.S.-centric, it is dominated by
government, not business.  It is inaccurate to characterize the IAHC
proposal as a power grab to remove the U.S. from its dominant position
within the Internet community.  The first chair of the iPOC is a well
respected and accomplished trademark attorney from a Chicago law firm. 
Without doubt, the United States is well represented in the IAHC plan. 

                NSI has been less than forthcoming in its public
statements regarding the issues surrounding the IAHC proposal.  For
example, NSI has repeatedly claimed in written materials that "The White
House, State Department, European Commission, CIX (the largest ISP
organization with 170 members), and dozens of other commercial and
international organizations outright reject or have serious concerns with
the IAHC proposal ..."  At best, this statement can be described as
exaggerated; at worst misleading.  At meetings in Geneva when this
statement was read into the record, the United States representative and
the European Commission delegate denied the characterization.  Their
positions have been that they take no position -- positive, negative, or
neutral -- on the proposal.  That is a far cry from saying they "outright
reject or have serious concerns" with the proposal. 

                NSI has not participated in the open meetings conducted
by the IAHC in Geneva despite opportunities to do so.  It is disingenuous
at best to criticize a competing program while refusing to publicly debate
the opposing side when given the opportunity to do so.  NSI has said it
did not participate because it did not want to give the impression that it
recognized the IAHC as having authority to propose or implement any of its
proposed changes.  Such a position is nonsense.  The members of the IAHC
are as much a part of the Internet community as NSI.  NSI should have
given them the mutual respect of open discussion.  It would have prevented
much of the rhetoric that clouds the issues at hand. 

                NSI's proposal is motivated primarily by its desire to
protect its investment and market share, particularly in light of its
recently announced plans for an initial public offering.  That is entirely
understandable.  Were they to adopt the IAHC proposal, it could result in
corporate suicide.  Follow this scenario.  The IAHC proposal is endorsed
by NSI and its database of registrants becomes part of the shared database
available to all registrars.  Among the new registrars are the likes of
Digital, MCI, and other telecommunications giants.  Overnight, NSI would
move from a dominant to an insignificant role.  Given that not unrealistic
scenario, one can understand NSI's position.  What is best for NSI's
market position, however, is not necessarily what is best for the Internet
community.  The players in the IAHC proposal do not appear, however, to be
in the game for money.  Two of the IAHC members -- ITU and WIPO -- are
quasi-governmental agencies.  The remaining members -- the IANA, INTA,
ISOC, and IAB -- are non-profit entities.  While it is true they seek
power, that power appears to be motivated not by economics but by their
collective perception of what is best for the stable operation of the
Internet.  One may disagree with many parts of their proposal, but it is
clearly a plan by a group far more representative of the Internet
community than NSI. 

          In CASIE's support of the IAHC plan, however, it should not be
assumed that CASIE does not have material concerns about that plan as
well. 

          In CASIE's opinion, the following issues should be debated and
resolved before the IAHC plan is implemented: 

                Its alternative dispute resolution system's failure to
include coverage of the ISO 3166 country codes may create inconsistencies; 

                The POC should be more representative of the Internet
community and include members of the marketing community, third world
countries just beginning to take part in Internet commerce, and
international chambers of commerce, to name a few. 

                IANA's and ISOC's veto power on the POC is unworkable and
likely to alienate whatever Internet community exists; 

                The lack of formal legal status of some of the bodies
within the IAHC structure creates due process and jurisdictional issues
that need to be resolved; 

                Further attention needs to be given whether there will be
a way to pre- screen SLDs; 

                The impact, if any, of moving jurisdiction over the
administration of the Internet to Geneva needs to be evaluated. 

                France's concern expressed in Geneva at the late May
meeting that the IAHC proposal SLD dispute resolution system as submitted
may be hard to enforce, is time consuming, and may be too expensive should
be evaluated. 

                NSI properly points out that the IAHC proposal does not
"address the total situation."  NSI claims IAHC fails to address three
important areas: the allocation of IP addresses, the management of
Internet identifiers, and the administration of the "dot" (that part of an
Internet address that helps route a message or request).  While these
areas may be matters the iPOC will take up later or considers to be within
the present IAHC proposal, its position in respect to these issues needs
to be clarified. 

          Without doubt, the IAHC stumbled when it initially proceeded too
quickly and did not allow full participation by the Internet user
community.  They have begun, however, to mend their ways.  It now appears
that the iPOC is considering a more participatory period of discussion and
debate.  That remains to be seen. 

     V.  CASIE's Formal Response to the Questions Posed by Commerce

          The following constitutes CASIE's formal reaction to the policy
statements and response to the questions posed by the Department of
Commerce, lettered and numbered to correspond to the form published by the
Department: 

               A.  Appropriate Principles -- Are the following principles
appropriate?  Are they complete?  If not, do they need revision and might
they be fostered? 

                    a.  Competition in and expansion of the domain name
registration system should be encouraged.  Conflicting domains, systems,
and registries should not be permitted to jeopardize the interoperation of
the Internet, however.  The addressing scheme should not prevent any user
from connecting to any other site. 

                         CASIE Response:  CASIE believes competition in
the domain name registration system is long overdue.  Without competition,
services will not improve and prices will remain inelastic.  CASIE agrees,
however, that it is crucial that change and competition not impact on the
integrity of the Internet.  Therefore, the change must be slow and
controlled.  Of the two proposals presented, the IAHC proposal is the most
controlled with a central body determining the timing for new gTLDs.  The
NSI proposal is potentially too unsettling by permitting new gTLDs at the
whims of would-be entrepreneurs.  Controlled growth like that proposed by
the IAHC is one way to ensure fluid and transparent communication among
consumers and users of the Internet. 

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

                         CASIE Response:  CASIE agrees that the private
sector, with appropriate input from governments throughout the world, is
the best structural alternative.  The Internet has become a global
phenomenon, beyond the exclusive regulatory control of any one government. 
While the U.S. government certainly has the greatest claim to the
Internet, it should adopt an open, leadership role  in fostering private
sector control of the network. 

                    c.  These self-governance mechanisms should recognize
the inherent global nature of the Internet and be able to evolve as
necessary over time. 

                         CASIE Response:  This principle is a critical
part of any evaluation of Internet governance.  The Internet is a truly
global communications network without boundaries.  Its growth can only be
ensured if the various interests in the Internet community learn to work
together with evolving self-governance.  Both the IAHC and the NSI
proposals seek such a structure, the only primary difference between the
two being the greater degree of government supervision in the NSI
proposal. 

                    d.  The overall framework for accommodating
competition should be open, robust, efficient, and fair. 

                         CASIE Response: CASIE agrees with this policy
statement.  The structure for competition, however, should be focused on
what will best serve the interests of the Internet user, not those
competing for the business.  Thus, the NSI proposal of registrars "owning"
gTLDs must be rejected.  It is fundamentally unsound both for competition
and for service to the Internet user. 

                    e.  The overall policy framework as well as name
allocation and management mechanisms should promote prompt, fair, and
efficient resolution of conflicts, including conflicts over proprietary
rights. 

                         CASIE Response:  Obviously, CASIE agrees with
this policy statement.  The mechanisms, however, will have to evolve over
time and everyone must be patient.  The present judicial systems among the
various countries throughout the world differ widely.  It will take years
to sort out the many differences.  For that reason, self-regulatory models
should be tried and revised.  Over time, a system for the "prompt, fair,
and efficient resolution of conflicts, including conflicts over
proprietary rights" will evolve. 

                    f.  A framework should be adopted as quickly as
prudent consideration of these issues permits. 


                         CASIE Response:  A rapid resolution of the issues
is important.  Otherwise, the rhetoric and misinformation will only
continue, further undermining the confidence the advertiser and
advertising agency communities have in the Internet.  In this respect, it
would seem advisable for the NSF to utilize the six-month "flexibility
period" between April 1, 1998 and September 30, 1998 provided in the NSI
contract to orchestrate an orderly transition to new governance of the
Internet. 

               B.  General/Organizational Framework Issues

                    1.  What are the advantages and disadvantages of the
current domain name registration systems? 

                         CASIE Response: (i) Advantages -- with one
predominant commercial domain, i.e., .com, communications to and from
consumers is simple.  Assuming a particular second level domain name owner
is first to claim its name, consumers can easily find it by coupling the
second level domain name with .com.  For those owners who captured their
second level domains early, the system is fine.  There is little, if any,
advantage to them to see change.  (ii) Disadvantage -- unfortunately, the
bulk of potential users of the Internet who might want their own SLDs is
increasing exponentially.  As a result, the "space" within .com for
appropriate SLDs that in some manner identify the owner is becoming an
ever declining commodity.  This is a distinct disadvantage to new users. 
They must adopt names that a consumer can only find through search
engines, themselves overloaded with countless variations within the .com
domain.  For them, new gTLDs are necessary and desirable.  In addition,
the current NSI SLD dispute resolution procedure is inequitable and
contravenes accepted principles of trademark law.  NSI insists it is not
an arbiter of rights to SLDs, yet NSI can and will reassign or place on
indefinite "hold" a well-known SLD simply because the owner of a trademark
registration for the same name demands it.  NSI's procedure automatically
favors the trademark owner, even when the cited registration is not for
Internet-related services and the owner is not using the mark on the
Internet.  NSI also disavows any liability to, and demands indemnification
from, the registrant for suspending an SLD, even if the disruption damages
or destroys the registrant's business and NSI suspends the SLD with
reckless disregard for the registrant's legal rights.  Earlier this year,
the International Trademark Association's Internet Subcommittee released a
paper which "propose(d) that the current NSI Dispute Policy be recognized
as a failure and eliminated, (and) that domain name disputes be left to
the courts."  Regardless of whether one prefers the courts or the SLD
dispute resolution plan proposed by the IAHC, it is clear that NSI's
procedure is unacceptable. 

                    2.  How might current domain name systems be improved?

                         CASIE Response:  Controlled addition of new gTLDs
is one solution that appears to have the most support.  At the May/June
meeting of the World Intellectual Property Organization in Geneva,
however, two alternatives to the addition of new gTLDs were proposed.  A
number of the European countries appear to favor an emphasis on the ISO
3166 country codes.  There are nearly 200 such TLDs, one for virtually
every country.  According to those country representatives who supported
this approach, using the country codes instead of the existing or proposed
gTLDs would alleviate the present SLD conflict.  That position is
incorrect for at least two reasons.  First, the use of gTLDs like .com is
too widespread and accepted to turn back the clock.  Second, and more
importantly, focusing emphasis on the ISO 3166 country codes presents a
nightmare for brand management with each country separately determining
the fate of a given brand name.  A smaller group of countries suggested
abandoning unique SLDs entirely and making all SLDs random numbers.  This
would eliminate the trademark issue since it would be impossible to use a
brand name.  While this alternative may have been viable at the inception
of the Internet, it's far too late to introduce that now.  Too much equity
has been built up by companies in both the gTLDs and the ISO 3166 domains
to reverse the trend.  Therefore, the only viable solution appears to be
the addition of new gTLDs.  Another improvement would be the creation of a
central, searchable directory of SLDs, much like an on-line telephone
book, that would provide a simple mechanism for Internet users to
determine SLD owners.  The present "Whois" search does not cover the ISO
3166 domains and does not allow searches by corporate names rather than
exact SLDs. 

                    3.  By what entity, entities, or types of entities
should current domain name systems be administered?  What should the
makeup of such an entity be? 

                         CASIE Response:  (i) It seems to be universally
agreed upon that governments should not be the administering bodies.  Both
the NSI and the IAHC proposals suggest predominately self-regulatory
systems.  Upon close analysis of the two proposals, there is not much
difference in their respective approaches.  CASIE believes that the
self-regulatory philosophy is sound and that either proposal could
eventually evolve into an acceptable administration model, although the
IAHC proposal appears to be more aggressive in that regard while the NSI
proposal starts off with more significant U.S. government oversight. 
CASIE questions whether that oversight is needed or desired given the
global nature of the Internet and its many years of self-regulation
without significant disruption.  (ii) The entities that are involved in
the administration should be representative of the Internet community and
evolve as the Internet grows.  The IAHC proposal only begins that process. 
The proposed structure of the Policy Oversight Committee ("POC") should,
however, be shuffled to allow for participation of other sectors of the
Internet community, e.g., the commercial sector, third world nations, etc. 
The NSI plan is not clear on the mix of participants, but it is assumed
that the same basic policy applies. 

                    4.  Are there decision-making processes that can serve
as models for deciding on domain name registrations systems (e.g., network
numbering plan, standard-setting processes, spectrum allocation)?  Are
there private/public sector administered models or regimes that can be
used for domain name registration (e.g., network numbering plan, standard
setting processes, or spectrum allocation processes)?  What is the proper
role of national or international governmental/non-governmental
organizations, if any, in national and international domain name
registration systems? 

                         CASIE Response:  (i) CASIE believes that
self-regulation and dispute resolution systems that avoid formal judicial
process are well suited for the Internet.  The WIPO has established
procedures for arbitration and mediation, together with an experimental
process, the Administrative Challenge Panels ("ACPs"), for the resolution
of second level domain name disputes on the Internet.  The WIPO system is
very worthy of consideration.  Other self-regulatory bodies may propose
similar systems, but the WIPO process is an established, global system. 
The fears of some "U.S.-centric" companies and individuals that the WIPO
system undermines the U.S. judicial system must be alleviated, however,
through more thorough discussions with representative from the WIPO than
thus far have occurred.  (ii) An increased role of national or
international governmental organizations in national and international
domain name registration systems should be avoided.  The Internet has
largely been a self-regulated system for most of its existence.  To now
impose significant government oversight would be disruptive.  There is
also no apparent reason that it is necessary.  There is a role, however,
for certain quasi-governmental organizations like the U.N. bodies or other
such global organizations.  Such organizations, however, should play more
of a supportive role than a governance responsibility.  Governance should
be placed with non- governmental trade associations, businesses, and
organizations that are the primary users of the Internet. 

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

                         CASIE Response:  (i) CASIE strongly believes that
the present gTLDs, i.e., .com, .org, and .net, should not be retired. 
Many companies and individuals have invested millions of dollars in
developing their Web sites at these gTLDs.  By retiring them, such
companies are deprived of their investment for no logical reason.  Nor
would it be logical to retire those domains for new registrations, leaving
the present owners intact.  Despite the ever declining "inventory" of
available SLDs, .com is a robust and active gTLD.  Nothing should, or
needs to, be done to undermine it.  (ii) As discussed earlier, requiring
ISO 3166 country codes will not solve the problems at hand.  First, the
present gTLDs are too established.  Second, requiring new addresses that
include the ISO 3166 designation will only confuse Internet users and cost
millions in unnecessary investment.  (iii) As stated, the .com domain
should remain intact.  There is no reason to undermine or diminish its
worth.  (iv) CASIE believes that the ISO 3166 country codes must
eventually come within the same governance umbrella as the gTLDs.  In this
respect, it would appear that the NSI proposal is better than that
proposed by the IAHC where ISO 3166 governance is not addressed.  As a
first step, however, it may be necessary to start with governance of the
gTLDs and evolve into full governance of both the gTLDs and the ISO 3166
country codes.  That evolution, however, needs to be debated and should
not be left unresolved as is currently the case in the IAHC plan. 

                    6.  Are there any technological solutions to current
domain name registration issues?  Are there any issues concerning the
relationship of registrars and gTLDs with root servers? 

                         CASIE Response:  (i) CASIE lacks the expertise to
opine on whether there are any technological solutions to the current
domain name registration issues.  (ii) CASIE strongly believes that if a
registrar controls a primary root server there is an inherent conflict of
interest.  The owner of a root server can directly affect the routing of a
given gTLD and its corresponding SLDs.  If a given owner of a root server
is also a registrar, it could disrupt other registrars' customers. 
Therefore, the root servers should be independent from the registrars. 


                    7.  How can we ensure the scalability of the domain
name system name and address spaces as well as ensure that root servers
continue to interoperate and coordinate? 

                         CASIE Response:  CASIE lacks the technical
expertise to respond to this question. 

                    8.  How should the transition to any new system be
accomplished? 

                         CASIE Response:  While the various dimensions of
this question are not clear to CASIE, any transition should be carefully
considered.  Clearly, the National Science Foundation should play a
leadership role, together with its historical partners in the Internet,
the Internet Assigned Number Authority, the Internet Architectural Board,
and NSI.  The transition must also involve the members of the former IAHC. 

                    9. Are there any other issues that should be addressed
in this area? 

                         CASIE Response:  It is unclear in either the NSI
or the IAHC proposal how the administrative functions are going to be
financed.  Proper administration under both plans will require full time
staffs and many volunteers.  Who will be compensated?  By whom?  How will
they be financed?  Who will administer the administrative funds? 

               C.  Creation of new gTLDs

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

                         CASIE Response:  CASIE lacks the technical
expertise to respond to this question. 

                    11.  Should additional gTLDs be created?

                         CASIE Response: For the reasons stated in the
answer to question 2., CASIE believes that the addition of new gTLDs is a
sound alternative. 

                    12.  Are there technical, business, and/or policy
issues about guaranteeing the scalability of the name space associated
with increasing the number of gtlDs? 

                         CASIE Response:  CASIE lacks the technical
expertise to respond to this question. 

                    13.  Are gTLD management issues separable from
questions about ISO country code domains? 
                         
                         CASIE Response:  As stated in its answer to
question 5., CASIE believes the gTLD and ISO 3166 country code management
issues, while separable, must some day come under one, centralized
administration. 

                    14.  Are there any other issues that should be
addressed in this area? 

                         CASIE Response:  CASIE has no further comments on
Section C of the request. 

               D.  Policies for Registries

                    15.  Should a gTLD registrar have exclusive control
over a particular gTLD?  Are there any technical limitations on using
shared registries for some or all gTLDs?  Can exclusive and non-exclusive
gTLDs coexist? 
                         
                         CASIE Response:  (i) CASIE cannot over-emphasize
its belief that no registrar should have exclusive control over a
particular gTLD.  Allowing such control is contrary to the best interests
of the SLD owner and the clear trend of portability in global
communications.  NSI's position that companies will not invest in gTLDs
they cannot "own" does not withstand scrutiny.  Certainly, the competition
among long distance carriers for service of consumers illustrates how
portability best serves the consumer.  In addition, the International
Telecommunications Union and other international governmental and non-
governmental bodies have clearly adopted the idea of portability in
telephone numbers as the wave of the future.  Why would there be any
reason not to adopt the same concept to the coupling of SLDs to gTLDs? 
(ii) CASIE lacks the expertise to evaluate whether there are any technical
limitations on using shared registries for some or all gTLDs.  (iii)
Allowing exclusive and non- exclusive gTLDs will only cause confusion. 
Since there is no justification to allow exclusivity in the first place,
placating the internal financial fears of the present registrars is poor
management and a flawed decision. 

                    16.  Should there be threshold requirements for domain
name registrars, and what responsibilities should such registrars have? 
Who will determine these and how? 

                         CASIE Response:  (i) While CASIE would support a
minimum financial requirement for registrars (provided that requirement
did not act as an unreasonable barrier to entry for companies interested
in becoming registrars), CASIE has insufficient knowledge to determine
what minimum capitalization a given registrar should have. 
 (ii) Presumably, NSI, NSF, and the members organizations of the IAHC have
the collective expertise to set the minimum standards. 

                    17.  Are there technical limitations on the possible
number of domain name registrars? 

                         CASIE Response:  CASIE lacks the technical
expertise to respond to this question. 

                    18.  Are there technical, business and/or policy
issues about the name space raised by increasing the number of domain name
registrars? 

                         CASIE Response:  (i) On the technical side, CASIE
lacks the expertise to respond to this question.  (ii) CASIE believes
that, in principle, increasing the number of domain name registrars should
not create business or policy issues, provided registrars follow
standardized procedures and utilize a centralized database that insures
the integrity of the Internet.  Presumably, the greater the number of
registrars, the more robust the competition. 

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

                         CASIE Response:  (i) CASIE is unaware of any
business or policy reasons a registrar should be limited in the number of
gTLDs it administers.  CASIE lacks the expertise to determine if there are
any technical reasons a registrar should be limited in the number of gTLDs
it administers.  (ii) As CASIE has stated in its answer to question 15.,
it strongly believes there is no logical justification for a system of
both exclusive and non-exclusive gTLDs.  Therefore, the answer to the
second question is moot. 

                    20. Are there any other issues that should be
addressed in this area? 

                         CASIE Response:  CASIE has no further comments on
Section D of the request. 


               E.  Trademark Issues

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

                         CASIE Response:  SLDs that utilize established
brand names or variations thereof should be afforded full protection under
trademark laws.  The very purpose of an SLD owner in using its established
trademarks or variations thereof is to denote a source of goods or
services that can be found on the World Wide Web.  In that sense, the SLD
is used as much as a trademark as it is as an Internet address.  In
addition, it is clear that misuse by third parties of such established
trademarks that do not have legitimate rights therein dilutes the value of
the trademark and causes consumer confusion when a Web user attempts to
find the Web site of a particular trademark owner only to find that the
site is either unavailable or controlled by a totally unrelated party. 
The extent of the protection should be subject to established principles
of trademark law.  Thus, geographic designations should be afforded little
protection unless strong secondary meaning has been established through
use, registration, and other extrinsic evidence.  Similarly, common law
trademarks would not be expected to have the same broad protection
afforded federally registered trademarks. 

                    22.  Should some process of preliminary review of an
application for registration of a domain dame be required, before
allocation, to determine if it conflicts with a trademark, a trade name, a
geographic indication, etc.?  If so, what standards should be used?  Who
should conduct the preliminary review?  If a conflict is found, what
should be done, e.g., domain name applicant and/or trademark owner
notified of the conflict?  Automatic referral to dispute settlement? 

                         CASIE Response:  (i) The idea of a process for
preliminary review of an application for registration of a domain name was
extensively discussed at the WIPO May/June meeting in Geneva.  There are
considerable complications in adopting a pre-screening process, the least
of which is the lack of adequate global databases that incorporate
trademark registrations from around the world.  While there are some
companies that have apparently made progress in this regard, e.g.,
Internet Computer Bureau Plc., Bridge House, 181, Queen Victoria Street,
London EC4V 4DD, United Kingdom, tel: 0171 837 6889, e-mail:
Paul.Kane@ICB.co.uk., a comprehensive database appears years away.  Until
it is in place, pre-screening is not realistic.  (ii) Until a viable
database is in place, establishing standards is premature.  (iii) Just as
is the case in the present U.S. system, the first review should be by the
applicant before it files an application.  Once filed, the registrar would
then compare the name against the existing database for an identical name. 
Assuming there is no exact match, the SLD should be issued.  (iv) This
should be followed by publication on the Internet at a location that can
be easily accessed and searched by trademark owners.  By periodically
searching this location, trademark owners will be able to determine
whether any potential infringements have been registered.  If so, the
trademark owner may then take appropriate measures to protect its
trademark rights.  There should be no affirmative obligation by the
registrar to notify anyone.  (v) The concept of an automatic referral to
dispute settlement is an unnecessary administrative burden.  It should not
be the responsibility of a registrar to police the trademark rights of
non-registrants or other registrants.  Trademark owners should bear the
responsibility of initially policing their trademark rights. 

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

                         CASIE Response:  (i) The resolution of SLD
disputes via a self-regulatory system as an alternative to local courts
should be available.  It should not, however, be mandatory.  Trademark
rights are territorial.  No "global" trademark law exists.  While over
time, case law developed through the self-regulatory system may develop
global principles for the Internet.  But in the short term, trademark
owners should have the right to resort to the judicial system.  There
should also be a mechanism like that proposed by the IAHC that allows
global protection of internationally known trademarks.  The procedures for
such protection, however, require far more debate than has occurred thus
far.  (ii) The IAHC's ACP format is an example of an alternative dispute
resolution system, although its relationship with local courts needs to be
carefully reviewed.  CASIE is unaware of any other viable proposal.  (iii)
Without doubt, national courts are not the only appropriate forum for such
disputes.  Virtually every modern judicial system recognizes the wisdom
and value of alternative dispute resolution systems.  The Internet is no
less an environment for ADR than any other forum.  (iv) While CASIE
believes there is a role for national/international governmental
organizations, the primary focus should be on nongovernmental alternatives
given the unique global nature of the Internet. 

                    24.  How can conflicts over trademarks best be
prevented?  What information resources (e.g., databases of registered
domain names, registered trademarks, trade names) could help reduce
potential conflicts?  If there should be a database(s), who should create
the database(s)?  How should such a database(s) be used? 

                         CASIE Response:  (i) At present, preventing
conflicts over trademarks on the Internet is an evolving dilemma.  Over
time, principles will be established both in courts and through
self-regulatory systems.  It is far too early to state any definitive
manner to prevent conflicts short of adopting random numbering for SLDs,
an alternative that has little, if any, viable support in the Internet
community.  (ii) Clearly, comprehensive databases of SLDs and trademarks
(both registered and common law) are desirable.  The precise configuration
of such databases requires much discussion and debate.  Most importantly,
however, progress in resolving the gTLD/SLD controversy should not be
delayed for lack of adequate information resources.  (iii) Preferably, the
databases should be created by the private sector.  Some companies have
already begun the task.  Clearly, private sector efforts will be faster
and more comprehensive than governmental efforts.  (iv) It is premature to
decide how such databases should be used.  Until we know what those
databases should or will include, how they would be used is idle
speculation. 

                    25.  Should domain name applicants be required to
demonstrate that they have a basis for requesting a particular domain
name?  If so, what information should be supplied?  Who should evaluate
the information?  On the basis of what criteria? 

                         CASIE Response:  (i) While CASIE believes that
applicants should file requests in good faith, any requirement to
"demonstrate" a basis for requesting a particular domain name should be
minimal and inexpensive.  Otherwise, access to the Internet is limited by
economics.  (ii) Similar to the present system used in the Untied States
for federal trademark registrations, applicants should be required to file
an affidavit that attests to their good faith belief that they have the
right to claim ownership of the SLD and that their registration and use of
it will not infringe upon the rights of any third parties.  Beyond that,
little more can be expected until viable databases are in place that allow
for economical pre-screening.  (iii) At present, other than comparing the
requested SLD against the database of previously registered SLDs in a
given gTLD, registrars should not evaluate the information included in an
application.  Requiring more would be an unnecessary administrative
burden.  Furthermore, there presently are no comprehensive databases that
allow for a viable review.  (iv) In CASIE's view, since requiring an
evaluation of the information included in an application is unrealistic,
establishing criteria is unnecessary. 

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

                         CASIE Response:  This question poses the "Catch
22" of adding new gTLDs.  While new gTLDs are necessary to allow
legitimate owners of trademarks to adopt SLDs that are associated with
such marks, the corresponding need to police all of the gTLDs for
trademark infringement increases the cost of marketing on the Internet. 
It remains unclear whether increasing the number of registrars will
similarly increase costs.  Assuming, however, that all the registrars use
a shared database and follow centralized, consistent rules regarding
disputes, the number of registrars should have little bearing on costs. 

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

                         CASIE Response:  CASIE lacks the technical
ex-pertise to respond to this question. 

                    28.  Are there any other issues that should be
addressed in this area? 

                              CASIE Response:  CASIE has no further
comments on Section E of the request. 


###

Number: 154
From:      "Andrew K. Martin" <akmartin@coastalmicro.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/5/97 11:10am
Subject:   domain management

Regarding management of generic top-level domains:

These, as well as all other issues of identification on the internet (e.g.
IP addresses) should be handled privately and non-exclusively through more
than one organization.  There should not be a monopoly for both economic
and technological reasons.  Just as a single, monopolistic entity cannot
be trusted to insure fairness to the consumer, neither can it be entrusted
with the sole management of these resources, upon which the transfer of
vital and non-vital information depends.  Provision should be made to
allow several (possibly a limited number) of organizations manage
top-level domains and these organizations should succeed or fail based on
their fiscal viability and their commitment to provide quality services to
consumers.  Each of these should be allowed to manage any and all domains
as per the request of the consumer.  That one organization established or
provided prior service to a domain should not limit management of that
domain to that organization.  If that organization fails to meet the needs
of the consumer in a satisfactory manner, the consumer must have the
option to easily, quickly, and without penalty, transfer the management of
the domain to another organization, subject to, of course, any applicable
costs of service to the new manager of the domain. 

Andrew K. Martin

###


Number: 155
From:     "John R. Mathiason" <mathiason@netstep.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/5/97 6:38am
Subject:  Comments on theDomain Name System

Please find attached my comments on the issue of the Domain Name System.


Document available at: <http://_________________>
                           Before the
                  U.S. DEPARTMENT OF COMMERCE
   National Telecommunications and Information Administration
                      Washington, DC 20230



      In the Matter of                    )
                                          )
      REGISTRATION AND ADMINISTRATION OF  ) Docket No. 970613137-7137-01
      INTERNET DOMAIN NAMES               )
                                                  
 
               Comments of Dr. John R. Mathiason
                                
                                          
    
    John R. Mathiason
    P.O. Box 48
    Mt. Tremper, NY 12457
    Adjunct Professor of Public Administration
    July 26, 1997
   

TABLE OF CONTENTS

       Summary 
       A. Appropriate Principles
       Principles a-f 
       Other principles 
       B. General/Organizational Framework Issues
       Questions 1-5, 8-9 
       C. Creation of New gTLDs
       Questions 11, 13
       D. Policies for Registries
       Questions 16-17
       E. Trademark Issues
       Questions 21-27
    
     

SUMMARY

1.  The issue of domain name regulation is related to the wider issue of
public responsibility for the Internet and within this the role of
international organizations.  Maintenance of the fundamental openness of
the Internet on the basis of universal access and fair competition
requires that this essential public good has reasonable regulation to
ensure a level playing field for all users.  As a new, borderless entity,
the Internet can neither be regulated effectively by national governments
nor by self-governance of its many and diverse users.  2.  The
registration of domain names system is the administrative heart of the
current Internet. The system is not working, because as constructed it
cannot cope with the volume of use, the growing disputes about trademarks
and a growing sense among many users that its institutions were not
legitimately founded.  The Memorandum of Understanding on generic Top
Level Domains has been a start in the right direction and should be
implemented.  It needs, however, further work to legitimize the structure
and to link the domain name system framework to a larger framework.  3. 
The role of the International Telecommunications Union and the World
Intellectual Property Organization are crucial to the improvement of the
domain names system, but further consideration needs to be given to the
nature of their role and the need to adapt to a policy environment in
which non-governmental and private sector entities as well as governments
have to be active participants in decision-making and where all users,
governments, non- governmental organizations and individuals need to feel
that they are involved in oversight as a%means of ensuring legitimacy. 

                           Before the
                  U.S. DEPARTMENT OF COMMERCE
   National Telecommunications and Information Administration
                      Washington, DC 20230



      In the Matter of                    )
                                          )
      REGISTRATION AND ADMINISTRATION OF  ) Docket No. 970613137-7137-01
      INTERNET DOMAIN NAMES               )
                                                  
 
               Comments of Dr. John R. Mathiason

1. John R. Mathiason respectfully submits comments in this proceeding. Dr.
Mathiason is an adjunct professor at the Robert F. Wagner Graduate School
of Public Service of New York University where he undertakes research and
teaching in the field of international public management including the
role of international organizations in the regulation of the Internet. He
has begun a study of the issue of domain names as a case study of the role
of the international public sector in the management of a complex
transnational public service.  As managing director of a consulting firm,
Associates for International Management Services, which includes
assistance in the use of the Internet for advocacy and training, he has a
direct concern with Internet management.  For over twenty-five years he
was a career staff member of the United Nations Secretariat and knows well
the strengths and weaknesses of international organizations. 
 



A. Appropriate
Principles


    a. Competition in and expansion of the domain name registration system
    should be encouraged. Conflicting domains, systems, and registries
    should not be permitted to jeopardize the interoperation of the
    Internet, however. The addressing scheme should not prevent any user
    from connecting to any other site. 

  1.  The Internet has evolved as an almost pure market that is also an
almost pure public domain.  Transcending national borders, with a
technology that can permit universal- accessibility, it is a public space
for communication that has never previously existed and for which there is
little precedent in law and institutional practice.  It has, however, a
minimum set of structures where regulation is necessary to provide order. 
The domain name registration system is at the heart of these structures. 

  2.  Use statistics show that the number of domain names is growing
geometrically.  From 165 .com domains in October 1991; through 600 .com
domains in March 1993, 11,000 in Janury 1994, 30,000 in January 1995 and
232,000 in February 1996; the number reached 1,222,000 in May 1997.  There
were, in June 1997, an estimated 22 million hosts on the Internet.
Assigning names in the context of this growth requires a structure that
can itself transcend borders and involve all of the parties who are the
users of the Internet.  These include governments, international
organizations and public entities like educational institutions, but more
importantly they involve provide sector firms, non-governmental
organizations and individuals.

  3.  If the Internet is to be orderly, it must have regulation.  An
unregulated Internet can invovle major costs as a result of unfair
competition, unresolved disputes and litigation, slowing of transmission
and reduction in access growth.  That regulation must be provided by an
institutional structure that can accomodate existing parties and the
growth that can be expected.  The principle, therefore should be:  a
freely and universally accessible Internet, open to fair competition which
is orderly on the basis of universally-accepted norms and standards. 

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

  1.  As noted in a.1-a.3, the Internet transcends national borders.  It
enters what Johnson and Post call a new kind of territory, not bounded by
geography and thus not easily subject to laws that are based on physical
place.  The question can fairly be asked, in a world where the private
sector either exists in a national environment subject to national laws,
or in the form of transnational corporations who, by moving from country
to country, can largely evade national laws, can self-governing mechanisms
work?  There is no reason to believe that, by themselves, they will be
stable.  The recent litigation between InterNic and AlterNic indicates how
fragile is the current system.  Nor is there an easy private sector
mechanism for arriving at a normatively binding consensus about
registration -- or for that matter anything else on the Internet.  The
disputes about the Memorandum of Understanding clearly show that there are
different parties with different conceptions of how the Internet should be
managed.
  2.  In any case, the Internet is a public good, not a private
one.  While private use of public goods is a normal practice, so too is
public regulatory authority.  It is within this public regulatory
framework that any self-government is achieved.  Thus, self-government in
the private sector -- or more properly, in Civil Society -- must take
place within a public framework, where the underlying consensus is worked
out.
  3.  This public framework, which at the national level, is built on
a combination of governmental institutions and public input, needs to be
applied to the Internet.  This has not yet been done. 

    c. These self-governance mechanisms should recognize the inherently
    global nature of the Internet and be able to evolve as necessary over
    time. 

  1.  The inherently global nature of the Internet means that the
self-governance mentioned in principle b has to be evolved within the
public framework of international institutions.  It is now time to
recognize the need for that broader framework and begin to take steps to
create it.  
2.  A institutional base exists in the organizations of the
United Nations system.  With universal membership, politically neutral
professional Secretariats and evolved and agreed procedures, they can
serve to organize the necessary dialogue among governmental, non-
governmental, private sector and individual stakeholders in the Internet. 
The fact that both the International Telecommunications Union and the
World Intellectual Property Organization are already involved in the
domain name question testifies to their utility.  However, the issues of
Internet regulation are only partially technical, and it will be necessary
in due course to see whether these are the most adequate mechanisms. 
Certainly, however, for the question of domain names, which has up to now
been posed as a technical question of assignment methods and dispute
resolution, these two institutions provide a base.  
3.  As the Internet
evolves, particularly in its international commercial use, other
institutions will have to be involved.  The fact that the World Trade
Organization has seen fit to begin negotiating specific agreements in the
information sector is an indicator of an evolving response to changing
requirements.  There will be more, some related to technology (and within
that satellite-based transmission system), some will be related to the
control of crime, others with issues of content regulation.  
4.  At that
point, the issue of coordination among the various regulatory schemes will
have to be raised.  The international public sector differs from the
national in that it is inherently non- hierarchical.  It has no sovereign
center or chief executive, it component parts are all formally equal in
status, and therefore different rules apply.  It depends, in fact, on the
legitimacy of action that comes from consensus decisions.  This requires
different institutional structures, as some national analyses have found. 
At that point, the institutional framework will have to be revisited. 

    d. The overall framework for accommodating competition should be open,
    robust,
    efficient, and fair. 

  1.  The idea that the framework should be open, robust, efficient, and
fair is indisputable.  It must be recognized, however, that while openness
and fairness are clearly linked, there may be a tradeoff between fairness
and efficiency.  Fairness means, in the context of the Internet, that the
interests of the many diverse users are represented in the design of the
framework and in the monitoring of its implementation.  So diverse are the
users, that normal institutions will not achieve this.  It will be
necessary to create a new class of institutions at the international level
that permits participation.  This will, inevitably, be less efficient than
current government-based structures (where it is only necessary to
accomodate 185 countries who would normally negotiate in three to four
blocs).  However, to the extent that a consensus- based legitimacy is the
foundation of self-governance, it will be more effective, however
inefficient it may be. 

    e. The overall policy framework as well as name allocation and
    management mechanisms should promote prompt, fair, and efficient
    resolution of conflicts,
    including conflicts over proprietary rights. 

  1.  In national jurisprudence, resolution of conflicts always bears in
mind that justice delayed is justice denied .  For conflicts in the
Internet, where rights have historically been defined in terms of national
jurisprudence, but where the conflicts will inevitably be transnational,
prompt resolution will require the elaboration of international
instruments, norms and procedures that will permit fair resolution. 

2.  Whether promptness can be achieved will depend on the care with which
the overall policy framework and its mechanisms are worked out
internationally and with the participation of whom. 
    
   f. A framework should be adopted as quickly as prudent consideration of
    these
    issues permits. 

  1.  As noted in previous comments, the framework should be adopted as
quickly as the various parties involved can be brought together
internationally to reach a consensus. 

    Other principles

  1.  A central principle should be that the policy framework and
regulatory mechanisms should reinforce the globalization of the world
economy, accelerate interdependence among peoples and strengthen
international public institutions in the interest of all of the world s
people. 

2.  Recognized in a cascading series of conventions, agreements and
declarations in a wide variety of fields, and embodied in a growing number
of international institutions to implement these agreements, the increased
interdependence that characterized the end of the 20th century and will be
the leitmotiv of the 21st.  This has meant that the size and context of
international public space has grown.  This borderless world can have
incalculable benefits to everyone, but may be particularly important to
Americans, many of whose national ideals are reflected in the way
international space has been defined, and whose economic well-being
increasingly depends on development elsewhere and whose physical
environment both affects and is affected by people outside its physical
boundaries.  The United States, therefore, has a special responsibility to
encourage the development of international institutions that reflect our
values. The Internet was a creation of US technology and, in its free and
open structure, based on fair competition, reflects fundamental American
principles.  But it has passed into the international domain:  it belongs
to the whole world.  It is imperative that we help create international
institutions whose structures and processes are consistent with our
values. 

B. General/Organizational
Framework Issues

    1. What are the advantages and disadvantages of current domain name
    registration systems? 

  1.  The main advantage to the current system has been its almost
seamless functioning. 

2.  Its main disadvantage is that it is not adapted to cope with the
physical growth and internati/nalization of the Internet and has begun to
develop systemic weaknesses in dealing with conflict.  It now appears
poorly adapted to the rapid changes that are occuring in international
communications and seems no longer to reflect a clear consensus among
users of the Internet.  Absent that consensus, the domain name
registration system is beginning to lapse into a costly and divisive
competition among parties with different perspectives about the Internet. 

    2. How might current domain name systems be improved? 

  1.  An agreed international policy framework for the systems, that
involved all groups of users, needs to be adopted at an authoritative
level.  To an extent that has been done by the Memorandum of Understanding
on gTLD s.  The difficulty with the procedure followed, which was probably
unique in international public agreements, is that key parties did not
join the consensus, and some, like Network Solutions, have actively
opposed it.  Absent an agreed international policy framework, which among
other things would link the management of the domain name systems to wider
issues and norms, it will continue to be difficult to make the system
work. 

2.  A clear and understood structure of international governance into
which the domain name registration system can be fitted is essential to
improvement. 

    3. By what entity, entities, or types of entities should current
    domain name
    systems be administered? What should the makeup of such an entity be? 

  1.  As noted above, for the system to be administered effectively, it
must be accepted by the diverse groups of users of the Internet, and it
must have a governmental connection since it deals with a public good. 
The proposal in the gTLD MoU goes a long way in that direction: it gives a
coordinating role to two international public organizations with universal
membership, but it is governed by a board that includes representatives of
the main civil society groups. 

2.  What the arrangement lacks is a legitimate way of selecting those
representatives.  The current lineup may well be the best, but it was
created without the kind of transparency of agreement that provides for
legitimacy.  It needs to be ratified (and possibly modified) by a public
means.  The ITU is one such means, but not the only one.  It might be
possible to refer the ratification process to the United Nations (where
the Economic and Social Council has on- going work on informatics), but
that would have to be done with extreme care to avoid linking domain
registration with issues that are related but not entirely relevant, such
as technology transfer. 

    4. Are there decision-making processes that can serve as models for
deciding on
    domain name registration systems (e.g., network numbering plan,
standard-
    setting processes, spectrum allocation)? Are there private/public
sector
    administered models or regimes that can be used for domain name
registration
    (e.g., network numbering plan, standard setting processes, or spectrum
allocation
    processes)? What is the proper role of national or international
governmental/non-
    governmental organizations, if any, in national and international
domain name
    registration systems? 

  1.  The way in which both ITU and WIPO function to implement their
respective treaties and agreements is the best current model, although
they would clearly have to be modified to accomodate the role of civil
society (especially the large private sector firms that provide the
telecommunications hardware for the Internet, and the diverse community of
individuals who make up an autodenominated world of netizens . 

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

  1.  The gTLDs reflect the new reality of the global economy and society: 
they are inherently transnational.  To retire them would be to deny that
reality.  Moreover, by now many of the existing domain names have taken on
the character of tradenames that are indelibly imprinted. It would be
inconceivable to imagine the disappearance of yahoo.com or microsoft.com.
Moreover, while many sites holding generic gTLDs are essentially national
(the reach of my Internet provider in Kingston, New York, netstep.net,
includes only Ulster and Dutchess Counties), their content and users are
inherently international.  There are many sites that are inherently
transnational (un.org for example).  Moreover, the existence of the
generic top level domains is a protection for the openness of the
Internet, since country code domains would presumably be easier to control
in a negative way. 

2.  Clearly gTLD management issues go beyond the ISO country code domains. 

    8. How should the transition to any new systems be accomplished? 

  1.  Practically speaking, any new system that is built on, as an
extension or addition, to an old system can make the transition by putting
all new transactions into the new system while gradually phasing out the
old.  The exception would be to those gTLDs whose administrator is not
part of the new system.  In that case, an arrangement would needed to be
made to make a complete handover to the new administrator of that part of
the system by a certain date. 

    9. Are there any other issues that should be addressed in this area? 

  1.  There are two other issues that need to be born in mind, if not
addressed directly.  First, there is a need for oversight and reporting on
the new mechanism that will involve the main groups of users.  This
includes procedures for determining who will represent those groups.
Second, the extent to which the domain name system is linked to other
systems and other issues needs to be spelled out and procedures worked out
to allow domain name system representatives to participate in the other
foru s. 

C. Creation of New gTLDs

    11. Should additional gTLDs be created? 
  1.  The proposals in the gTLD MoU make great sense to me.

    12. Are there technical, business, and/or policy issues about
guaranteeing the
    scalability of the name space associated with increasing the number of
gTLDs?

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

  1.  The gTLD management issues are related to, but separable from, the
ISO country code domains.  Relationships exist in terms of the use of
trademarks in ISO country code domains and the extent to which sites with
gTLDs can or should be controlled by national authority. 

D. Policies for Registries

    16. Should there be threshold requirements for domain name registrars,
and what
    responsibilities should such registrars have? Who will determine these
and how?
  The definition of threshold requirements and responsibilities clearly
have to be built into the policy framework.  Much of the answer is already
provided in the gTLD MoU. 

    17. Are there technical limitations on the possible number of domain
name
    registrars? 

  1.  Whether there are technical limitation or not, a major consideration
is that the more domain name registrars exist, the greater the difficulty
in maintaining oversight and accountability and the more complicated the
decision-making process.  In this case, it is not a matter of too much ain
t enough but rather too much is too much. 

E. Trademark Issues

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

  1.  The fact that the Internet is transnational means that an
international standard needs to be applied.  Currently, trademark law is
essentially national, but interdependence of the global economy has led an
increasing number of countries to make national law square with the
international conventions administered by WIPO.  The WIPO standard should
apply to protection and national laws should be brought into line with
those standards. 

2.  With this principle, international mechanisms can be set in place to
protect recognized trademark rights. 

    22. Should some process of preliminary review of an application for
registration of
    a domain name be required, before allocation, to determine if it
conflicts with a
    trademark, a trade name, a geographic indication, etc.? If so, what
standards
    should be used? Who should conduct the preliminary review? If a
conflict is
    found, what should be done, e.g., domain name applicant and/or
trademark
    owner notified of the conflict? Automatic referral to dispute
settlement?

  1.  The answer here is clearly yes and the appropriate preliminary
review should be done by WIPO, which already has a dispute settlement
procedure that could be adapted to the needs of the Internet. 

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

  1.  As noted above, national courts will have an increasingly more
difficult time solving disputes, since these are likely to be
multi-national in nature (if dealing with ISO country domain names) or
involving gTLDs whose international character is by definition.  The
primary role should rest with WIPO, monitored and assisted by
non-governmental organizations.  To the extent that enforcement may be
required, thought will have to be given to a mechanism whereby resolved
disputes are communicated to national authorities and applied by national
courts in accordance with the provisions of relevant conventions. 

    24. How can conflicts over trademarks best be prevented? What
information
    resources (e.g. databases of registered domain names, registered
trademarks,
    trade names) could help reduce potential conflicts? If there should be
a
    database(s), who should create the database(s)? How should such a
database(s) be
    used? 

  1.  The technology exists to have data bases of data bases.  There is no
longer any need for a single centralized, Big Brother type database.  What
is needed, however, is an international focal point to help direct
searches.  Obviously WIPO would be a possibility and, in any case, should
be involved.  An institutional framework in which the databases would be
developed by private parties, universities, trade associations or even
governments would be needed and a central point to bring them together
designated. 

2.  Such a data base system could be searched for conflicts prior to
registering the domain name, using standard protocols developed by the
relevant international organization.  In fact, applicants could be
encouraged to search the data base themselves for conflicts as a means of
minimizing the work of the WIPO or whoever else would be designated to
make the official search. 

    25. Should domain name applicants be required to demonstrate that they
have a
    basis for requesting a particular domain name? If so, what information
should be
    supplied? Who should evaluate the information? On the basis of what
criteria?

  1.  Clearly with regard to the generic TLDs, some proof that the
criterion of the level is met, e.g. an organization clearly must not be a
commercial enterprise to obtain the .org designation. This means that the
criteria have to have been spelled out and agreed, again at the level of
an international organization.  Application of the criteria could then
easily be done by the registrars. 

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

  1.  Given an accessible system of data bases, there should be
little%incremental cost per registrar for resolving trademark disputes. 

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

  1.  The issue of trademarks is not technological.  A set of words and
symbols are attached to a product or company in the minds of customers. 
Adding additional generic names or subcodes would not solve this problem. 
The fact that the Internet is globally accessible viciates the normal
flexibility of trademarks in national law, as was also noted by Johnson
and Post. 

                            Annex 1
                          Service List

Mr. Richard Beaird, Department of State, Rm. 4826, Washington, D.C.
Dr. Jo Ivy Buford, Dean, Robert F. Wagner Graduate School of Public
Service, New York University
Hon. Maurice Hinchey, Member of Congress
Mr. Riel Miller, SGE/AU, Organization for Economic Cooperation and
Development, Paris
Prof. Kurt Mills, American University of Cairo, Egypt
Prof. Michael Schechter, Michigan State Univeristy
Prof. Tim Sinclair, University of Warwick, United Kingdom
Prof. Dennis Smith, Director, Public Policy Program, Robert F. Wagner
Graduate School of Public Service, New York University



John Mathiason
Adjunct Professor
Robert F. Wagner School of Public Administration
New York University


###
Number: 156
From:      Bill Spencer <BSpencer@peabodygroup.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/6/97 6:43pm
Subject:   re: Domain Name Issues

Sirs and Mesdames:

I understand that the Commerce Department is seeking comment regarding issues
with the Internet's Domain Name system and its administration.
I fervently believe that, without further administration or regulation from the
governments (U.S. or UN), the commercial parties will solve this to their mutual
satisfaction and to the successful usability by the world's populace.
Computer users have a history of viciously eliminating bad solutions and
rewarding good ones, using the capitalistic marketplace.
In this particular case, should another company start issuing domain names, they
will succeed only to the extent that they convince the rest of the Internet
infrastructure to set their Domain Name Servers (DNS) to point to the issuing
company. Similarly, Internet Service Providers (ISP) and other parts of the
Internet infrastructure will have incentive to offer their subscribers as many
domains as possible, yet to simultaneously offer only one unique resolution of a
given domain name (i.e., one issuing company per domain) and to have an
organized and efficient naming system.
The same industry that reached the recent Digital TV solution, and historically
a great many other ANSI, IEEE, ISO, and other standards, should have no problems
achieving sufficient practical standards here. Keeping the government from
having to worry about these standards will also lead to more flexibility as the
technology inevitably evolves.

Thank you for consideration of these comments.

Bill Spencer
401 Crest Ave.
St. Louis, MO  63122-5602
Bill5@lumencontrols.com
314-342-7504 (work)

PS: I am a computer software design consultant (though I am only an Internet
user, not a consultant in Internet design) with G.A.Sullivan, currently working
at Peabody (Coal) Holding Co. I have 22 years experience in the software
industry, and I am the holder of the domain name "lumencontrols.com".



###

Number: 157
From:      Adrian Tymes <atymes@lts.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 4:26pm
Subject:   DNS comments

A point-by-point response to
http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm :

A. Appropriate Principles 

a. A useful method to encourage this would be to set up a central
registry of DNS
servers, preferably under the control of an appropriate body (the
Internet Ad Hoc
Council, the Internet Engineering Task Force, or a council formed by the
current DNS
administrators [after forced expansion from just Network Solutions],
seem like the best
choices for this, possibly as advised - but not controlled - by the UN
and the WIPO).
All top level DNS servers would be obliged to contact the other DNS
servers on this list
if their own database does not contain a domain name that it has
received a request for.
Any DNS servers that refuse to participate in this system would not
offer access to most
of the Internet, and either be forced to change or lose customers as a
result.  The
choice of the central server administrator should be made with extreme
caution, as this
administrator may be the ultimate enforcer of nettiquite (the Internet
version of law).

b. As in A.a.  Emphasis should be placed on "with input from
governments" as opposed to
"as ordered by governments", since placing power over the entire
Internet in any
government's hands has proven to, almost without exception, degrade the
Internet.

c. This is the reason for my suggestion of the IAHC and/or IETF.  They
are global, can
evolve, and have proven to be effective but non-restrictive
"governments" (to the limit
that the Internet can tolerate governance without breaking down).

d. Any solution will have to be robust and efficient for people to
accept it; if no one
buys into the solution, then it will not work.  However, "open" and
"fair" are subject
to interpretation, and as such, might not be the best standards.  A
typical
religious/military dictator of a small country would probably say that
the current
standards are neither open nor fair because he can not dictate that, for
instance,
anyone using the .mil domain (except for his military) be put to death,
and yet anyone
reading this comment would probably find such a demand to be ridiculous
in the extreme.

e. See A.c and A.d; my comment here can easily be deduced from those
two.

f. In addition to adopting a new framework, care must be taken to switch
current users
over with a minimum of hassle.  Abruptly shutting down the current DNS
system, if that
is called for, would result in massive disruption, and should thus be
avoided if
practical.  Adding to the current system, or automatically rerouting DNS
calls to
names which used to be valid, would alleviate this concern.

B. General/Organizational Framework Issues 

1. Perhaps the primary advantage is the simplicity of domain names. 
"www.x.com" might
result in a lot of headaches, but it is a lot simpler to remember (and
thus, for human
beings to use) than "www.x.sf.ca.us" or "101.32.224.132".  The primary
disadvantage is,
as has been pointed out by several others, intense competition for the
"x.com" DNS from
all companies named X, and an unclear resolution process if multiple
companies with the
same name are in different countries.  Other advantages disadvantages
exist, but again,
those have been pointed out, and are not as important, so I shall not
waste space by
repeating them here.

2. For DNS lookups, see A.a and A.b above.  For domain names themselves:
     * Force ISPs and network connectivity providers to use the .net domain
name.
          This is why .net was implemented in the first place; ISP insistence on
          .com is only making the pressure for that top level domain (TLD)
worse.
     * Implement alternate TLDs such as .biz, and forbid the same
organization from
          registering itself in both .com and .biz.  If this forbidding is not
          implemented, legal council for most companies will, as others have
          pointed out, suggest that the safest course of action, and thus the
one
          that companies will take, is to register themselves in all applicable
          TLDs, thus negating most of the benefit of multiple TLDs.
     * Require valid contact information for a domain name, and do not
activate new
          domain names until this information has been verified.  It should be
          possible to shut down those who abuse the Internet, even if they can
          not be punished (as in the case of a spammer using a domain name with
          false contact information and going through another service: the first
          would be denied, and the other service can at least try to stop the
spam
          traffic as soon as it is notified of it).

3. See A.a and A.b above.

4. See A above.  National organizations should only be responsible for
national TLDs.
International organizations should be responsible for international
TLDs, such as .com.
These organizations should reflect the will of those who use the
Internet.  Those who
have not bothered to expend the minimal effort required to learn the
true issues, or
even to touch the Internet, should not have a voice in governing the
Internet until they
have done so.  Recent history (for example, the "cyberporn" scare and
the encryption
debate in the USA) serves as evidence of what will happen otherwise. 
Since governments
speak for all of their people, not just the Internet literate ones,
governments should
probably not be in direct control (except, of course, of their national
TLDs, as these
were set up specifically for them).

5. No.  The .com TLD is in such widespread use, its retirement alone
would probably
cause too much disruption.  A similar, though weaker, case can be made
for .net, .edu,
and .org.  Of the remaining non-national TLDs, .int is not really
generic, but .gov and
.mil are inappropriate.  These two domains should be moved to .gov.us
and .mil.us.  As
currently used, they are potentially confusing - since .com means a
company anywhere in
the world, does .gov mean a government anywhere in the world?  Only the
UN and similar
organizations qualify for that title.  Non-national TLDs are inherently
separable from
national (country code) TLDs: national TLDs were created to be the
property of their
nations, while non-national ones are explicitly not the property of any
government.

6. See A above, especially A.a and A.f.

7. The system proposed in A.a is infinitely scalable.  If one TLD
becomes too crowded,
as .com has, another server can open up with another (or another few)
TLD(s).  Newcomers
wishing to acquire a domain name, upon finding that, for instance,
"x.com" is already
taken, can simply take "x.biz" with minimal fuss (assuming that, to
protect its
trademarked name, the first X has not taken "x.com", "x.biz", "x.net",
"x.org", and so
on for all other TLDs - which, for this reason, it must be prevented
from doing).

8. A table of DNS entries, mapping all second level domains (SLDs) in
retired TLDs to
new domains, would not be too hard for those who currently operate the
main DNS servers
to construct, and since they are (mostly) American institutions, it
would be even
simpler for the American government to order them to do so, if desired. 
Queries to the
old TLDs could simply be referred to this table.

9. I am sure that there are, but I can not think of any at the moment.

C. Creation of New gTLDs 

10. Under the system proposed in A, none, as long as SLD hogging
(gobbling up the same
domain name in all gTLDs) is both forbidden and actively prevented.

11. Yes, if for no other reason than the current .com domain is growing
crowded, and
breaking it up would be impractical.  Again, the system proposed in A
makes it easy.

12. See 10.

13. See the last part of 5.

14.  See 9.

D. Policies for Registries 

15. New gTLDs would probably work best if the proposing registrar
maintains exclusive
control over them.  Current gTLDs that are not retired should probably
be shared,
especially .com.  The only technical limitations, so long as all
participating servers'
listings are consulted by each other for all requests (or, at least, as
many as are
necessary to answer the request), is handling two different entiries for
something like
"x.com".  Perhaps the simplest technical fix for this is to forbid
adding an entry for
"x.com" if it conflicts with a current entry for the same name.  This
could be added as
a technical fix to the DNS servers to prevent accidents, but if one of
the server
administrators wanted to deliberately create chaos, it could probably be
circumvented
(although the effort to do so would still serve as a minor deterrent). 
Exclusive and
non-exclusive gTLDs can coexist with ease: exclusive gTLDs are routed to
one server,
while non-exclusive are routed to a group of servers, each of which
checks the others if
it can not find the answer on its own.

16. Yes: irresponsible DNS administrators do more harm than good, and
thus should not be
allowed to become such.  Under the plan in A, the central server
administrator will
logically determine the requirements.

17. No, as with the number of TLDs under the plan in A.

18. Obviously yes, but I have addressed the ones that I can think of
elsewhere.

19. Probably no more than a handful (two to five, the exact amount is
arguable)
exclusive gTLDs, as well as being able to participate in any number of
non-exclusives.
The same requirements that allow an organization to become a DNS
administrator should
also qualify it to participate in the non-exclusive gTLDs, should it
choose to do so.

20. See 9.

E. Trademark Issues 

21. Only those recognized by international law.

22. Experience indicates that this is a good idea; the DNS administrator
issuing the
domain name would probably be the best reviewer.  However, to aviod
beauraucratic
snafus, something along the following lines should be appended:
     * If the review, for any reason, takes over two months from the time
that the
          applicant has submitted a request for a new domain name, the
          application should be assumed not to violate any other trademarks
unless
          and until evidence to the contrary is provided.
If a conflict is found, the applicant should definitely be notified.  It
the applicant
holds an applicable trademark, the application should go through.  If
not, the
application should be denied.  Note that this is seperate from the case
of multiple
"x.com" registrations - in that case, if both applicant and holder have
relevant
trademarks, the application should be denied.

23. National courts are only appropriate if both parties reside in the
same nation.  If
they do, then national courts are probably best.  If they do not,
international
arbiters (for instance, courts) are the only appropriate recourse if
disputes between
trademark holders can not be resolved without arbitration.  Note,
however, that under
the proposal in A, the central DNS administrators are de facto
international arbiters
for this purpose.

24. The easiest solution would be to abolish trademarks entirely, but
that could
probably not be enacted even if it were feasable.  An international
registry of
trademarks - one which the trademark offices of all countries can submit
their own
trademarks to, without requiring local companies to go to the expense of
re-submitting
their trademarks in every single country, and which all countries will
take as
legally binding - would probably be the best resource here.

25. No.  Requiring this would cut down on the alternate domain names
that a particular
organization could get, which is especially important in crowded TLDs
like .com.  On
the other hand, if proof-less applications are allowed, they should be
subject to
slightly more stringent trademark searches, since they will be violating
any trademarks
currently held.  (Perhaps domain names should, themselves, be considered
trademarks?)

26. Under the plan in A, it would not.  An organization would be allowed
to duplicate
its tradmark in only one domain; it could not then prevent the use of
its name in
other domains by those who hold similar trademarks.  (Of course, if only
one company
has a particular trademarked name, then no one could use its name for
other domains
without filing another trademark for that name - which is fair, assuming
that filing
said trademark is easily possible for another organization with the same
name.)

27. Unfortunately, no, as trademarks are entirely a legal issue.  There
are ways of
addressing the symptoms through technology, but they do not remove the
underlying
problem.  "First come, first served" is the method of dispute currently
used, and under
the proposal in A, it would work - the second to come merely uses the
same SLD, but in
a different TLD.

28. See 9.

###

Number: 158
From:      "Scott K. Johnson" <scott@zworx.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 8:20pm
Subject:   The DNS Issue

 To Whom It May Concern,

I am a WebMaster and President running a very small Internet based company.
We are running on a very tight budget (as a matter of fact we anticipate to
lose money for the next little while) and our domain name is as important as
our company name.  With all the political rigmarole that has been going on
lately with the domain name issue, we are concerned that one private company
(with maniacal tendencies) has the power to turn our name on and off at a
whim.  We would certainly like to see the administration of domain names
turned over to several non-profit organizations, or to several companies.
We feel that would help to spawn competition and thus better prices and/or
service.

We also feel that there should be some minor government regulations (laws)
that enforce the integrity of these institutions.  After all, no one would
"turn-off" the name McDonalds's one day without some serious ramifications.
As it stands now, we are at the administrators whim....

Thank you for your time,


----------------------------------------------
Scott K. Johnson
NNI Networx NewMedia Inc.
http://www.zworx.com

###

Number: 159
From:      "Sibert, Scott" <SSibert@yokohamatire.com>
To:        "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date:      8/7/97 12:19pm
Subject:   Top-level domains

I've been using the Internet since 1990.  The current method of
top-level registration is easy to understand and it is easy to know
where to go for information.

The top-level registration process should be widely distributed.
Possibly it could be spread over maybe two or three companies each doing
different domains but it should be somewhat centrally-controlled.  With
the anarchic nature of the Internet in its loose controls and easy
access to information, there should be some kind of central place for
the name registrations.  This should not be controlled by the government
of the United States or any other country, although the company or
companies doing the controlling should be subject to the United States
government.

On the matter of additional top-level domains, any new domains must be
easily recognized as to what they represent.  The proposed .store and
.firm will be confusing.  "Should I check www.landsend.com or
www.landsend.store or www.landsend.firm?"  And what is .nom?  It does
not immediately, or after some thought, look like anything in
particular.  What is the purpose of .web?

These proposed top-level domains look like someone is wanting to make
the internet addressing look like reversed Usenet groups.  The only one
that might be of some use would be .info but the rest are unneeded.

Scott A. Sibert
Oracle Development Lab
YTC, Salem Plant

###

Number: 160
From:      "mark2@yourgallery.com" <Mark.Gierth@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 10:57pm
Subject:   Comments on Domain Names

Please stay out of this issue, in most casses the market

will take care of itself.



There is no way to justify government intervention on this

issue also.



PLEAS STAY OUT OF OUR LIVES AND LEAVE US ALONE!



YOU COULD CUT YOUR BUGET BY 90% BY ISSUING THE NATIONAL MESSAGE

OF:





CONSUMER BE WARE!



Spend the 10% left on the educating of the public on bad

products, and telling the American people that it is time

that they thought for themselves, and need to look into any

thing that they spend money on.



That is all that is needed, so stay out of the the internet

naming issue.



Mark Gierth

-------------------------------
Thursday, August 7, 1997 22:55:56 EDT
Mark Gierth

Mark Gierth

407 Abner Cruze Rd.

Knoxville TN

37920



###

Number: 161
From:      "shadow@mediafilter.org" <CHRIS.PALMER@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 8:08pm
Subject:   Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I CHRIS PALMER 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.

-------------------------------
Thursday, August 7, 1997 20:06:19 EDT
CHRIS PALMER


###

Number: 162
From:      "smatic@mediafilter.org" <Satomi.Sugishita@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 11:47pm
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 Satomi Sugishita 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.

-------------------------------
Thursday, August 7, 1997 23:45:23 EDT
Satomi Sugishita



###

Number: 163
From:      "metzger@bway.net" <Richard.Metzger@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 11:40pm
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 Richard Metzger 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.

-------------------------------
Thursday, August 7, 1997 23:38:44 EDT
Richard Metzger



###

Number: 164
From:      "burke@northweb.com" <Joe.Burke@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 11:13pm
Subject:   Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I Joe Burke 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.

-------------------------------
Thursday, August 7, 1997 23:11:59 EDT
Joe Burke






###

Number: 165
From:      "vaxen@x-net.net" <ROLLAND.D.ALBA@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 9:34pm
Subject:   Comments on Domain Names


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

(The New Paradigm for the Old DNS)


     I ROLLAND D ALBA 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.

-------------------------------
Thursday, August 7, 1997 21:32:39 EDT
ROLLAND D ALBA

260 Cooper Rd
Westminster, SC
          29693






###

Number: 166
From:      "zone@desk.nl" <Zvonimir.Bakotin@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/7/97 8:32pm
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 Zvonimir Bakotin 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.

-------------------------------
Thursday, August 7, 1997 20:26:43 EDT
Zvonimir Bakotin

Amsterdam NL

###




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

To Whom It May Concern;

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

Adam Prall

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

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

Dear Ms. Wellbery:

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

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

Thank you for your concern.

Sincerely,
John Schaub

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

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

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

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



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

To Whom it concerns,

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

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

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

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

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

Howard Leshner



###


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

Please accept my comments on your subject RFC.

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

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

Respectfully submitted,

Doug Lakin
TeleCommerce, Inc.

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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

Box 775544
St. Louis, MO 63177





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

Boston, MA





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

Speco, Inc.
3946 Willow
Schiller Park, IL
60176





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

http://dondersteeg.free.zone





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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








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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






###


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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

San Juan, Puerto Rico





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

Luetticher Strasse 34    D-50674   Cologne





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

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





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

New York City

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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

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





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

22998 E. Crenshaw St.
Tampa, Florida 33610





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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








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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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






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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

41 Murdock St
Brighton, MA 02135
US





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


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

(The New Paradigm for the Old DNS)


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

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

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

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

Description of the name.space(tm) service:

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

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

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

Issues and Answers

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

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

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

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

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

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

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

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

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

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

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

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

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

617B College Hwy. Southwick MA 01077





###
Number: 204
From:      "hleshner@map.com" <Howard.Leshner@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:15pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Howard Leshner do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:12:20 EDT
Howard Leshner

PO Box 974 Southwick MA 01077





###
Number: 205
From:      "106576.113@compuserve.com" <Ralph.Beloch@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:12pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Ralph Beloch do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:10:27 EDT
Ralph Beloch






###
Number: 206
From:      "mystic.one@mci2000.com" <Daniel.Prather@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 12:05pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Daniel Prather do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 12:03:27 EDT
Daniel Prather

3521 Florida Avenue
Panama City, Florida
32405-3324






###
Number: 207
From:      "adeen@parsons.edu" <Anthony.Deen@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 11:22am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Anthony Deen do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 11:20:52 EDT
Anthony Deen

500 West End Avenue
New York, NY 10024





###
Number: 208
From:      "john@theonly.com" <John.Catlin@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:34am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I John Catlin do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:32:33 EDT
John Catlin

3 Shore Dr.
Shutesbury, MA 01072





###
Number: 209
From:      "feldmann@metronet.de" <Martin.Feldmann@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:08am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Martin Feldmann do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:06:45 EDT
Martin Feldmann






###
Number: 210
From:      "jbdomic1@msn.com" <Jorge.B.Domic@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 10:02am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jorge B.Domic do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 10:00:45 EDT
Jorge B.Domic






###
Number: 211
From:      "jwkckid1@ix.netcom.com" <Jeffrey.A.WIlliams@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:57am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Jeffrey A. WIlliams do hereby support the design of the expanded
toplevel Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 09:55:46 EDT
Jeffrey A. WIlliams

1333 west Cambel rd.  #176
Richardson, Texas, 75080


###
Number: 212
From:     "bwarden@rmci.net" <Brett.Warden@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 7:34pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Brett Warden do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 19:32:52 EDT
Brett Warden



###
Number: 213
From:      "123@pobox.com" <Mark.Whitby@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/8/97 9:17pm
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Mark Whitby do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 21:15:48 EDT
Mark Whitby

###
Number: 214
From:     "hawkmoon@mindspring.com" <Greg.Shields@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 10:44pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Greg Shields do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 22:42:43 EDT
Greg Shields

###
Number: 215
From:     "jrscott@hotmail.com" <John.R.Scott@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/8/97 6:36pm
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I John R. Scott do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Friday, August 8, 1997 18:34:46 EDT
John R. Scott





###
Number: 216
From:      Milton Mueller <milton@usthk.ust.hk>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/9/97 11:56pm
Subject:   Comments -- Internet Domain Names Notice

The attached document is a Word 6.0 file containing 
my comments for "Registration and Administration of 
Internet Domain Names" (Docket 970613137-7137-01)

Please acknowledge receipt.

Milton Mueller

--



Before the

U.S. DEPARTMENT OF COMMERCE,

National Telecommunications and Information Administration

Washington, DC 20230


In the Matter of                     )
                                     )
REGISTRATION AND ADMINISTRATION      )    Docket No. 970613137-7137-01
OF INTERNET DOMAIN NAMES             )
                                     )


Comments of Dr. Milton L. Mueller

Milton L. Mueller
Syracuse University
School of Information Studies
Syracuse NY 13244


Associate Professor
18 August, 1997

TABLE OF CONTENTS

* Summary 2

* A. Appropriate Principles 3

* B. General/Organizational Framework Issues 4

* C. Creation of New gTLDs 6

* D. Policies for Registries 7

* E. Trademark Issues 8

SUMMARY

1. NTIA is to be commended for initiating this Request for Comments. There is growing confusion and conflict over Internet administration. Key resources and agencies are stranded in a legal vacuum. Because of its historical responsibility for the funding and organizational framework of the Internet, U.S. Government action of this sort is overdue.

2. This comment supports privatization and additional competition in the top-level domain namespace. It recommends adding freedom of expression to the list of appropriate principles used to evaluate proposals. The comment calls for the definition of procedures that would allow new TLDs to be created in response to entrepreneurial activity and market demand. It strongly opposes the proposal to phase out gTLDs in favor of compulsory national TLDs. It also refutes the equation of domain names with trademarks or brands, and rejects attempts to forge inappropriate links between domain name registration and trademark protection.

Before the

U.S. DEPARTMENT OF COMMERCE,

National Telecommunications and Information Administration

Washington, DC 20230

In the Matter of                     )
                                     )
REGISTRATION AND ADMINISTRATION      )    Docket No. 970613137-7137-01
OF INTERNET DOMAIN NAMES             )
                                     )




Comments of Milton L. Mueller.

1. Dr. Milton L. Mueller respectfully submits comments in this proceeding. Dr. Mueller is Associate Professor and Director, Graduate Program in Telecommunications and Network Management, School of Information Studies, Syracuse University. He is the author of numerous scholarly works on telecommunications policy and regulation, including issues related to Internet economics and administration. He has also served as consultant to governments and businesses in the United States and Hong Kong on regulatory policy issues in telecommunication.

2. The views expressed here are those of an individual faculty member and do not necessarily represent the views of Syracuse University or its School of Information Studies.

A. Appropriate Principles

b. The private sector, with input from governments, should
develop stable, consensus-based self-governing mechanisms for
domain name registration and management that adequately defines
responsibilities and maintains accountability.

3. This statement reveals a degree of confusion about the existing situation and the proper role of government. The current crisis in domain naming is a product of a legal and administrative vacuum for which the US government is directly responsible. The domain name problem is about ownership and allocation of valuable resources; specifically, root name servers and top level domain names. No existing entity has direct, unambiguous property rights over these resources.

4. In particular, the commercialization of the Internet has stranded the Internet Assigned Numbers Authority (IANA) in an ambiguous position. IANA does not have a clear legal right to manage the root as a private, commercial entity. Nor has the root been declared a public resource to be managed by government(s). Nor has IANA been given any legal or procedural mechanism for distributing relevant property rights to competing firms in the private sector. This legal vacuum does not encourage "self-governance;" it only perpetuates confusion and invites the Internet equivalent of land grabs and squatting. As for "consensus," it is evident from the growing number of lawsuits, the angry rhetoric on listservs, and the growing schism between the key institutions of Internet administration that no consensus exists.

5. In this context, loose references to "self-governance" and "private sector initiative" are not helpful. They only obscure the legitimate and unavoidable role governments must play in the definition, enforcement, and adjudication of property rights. Without clearly defined property rights, there is no "private sector." Without stable rules governing the nature and use of resources, there can be no "self-governance."

6. As an alternative formulation of principle (b.) I respectfully propose the following: The U.S. government must play an active role in moving the core resources of the Internet out of the US-based public sector and into a competitive, private sector-driven, global institutional framework. Only government can establish the legal and institutional basis for private sector competition and ongoing self-governance. Because of its historical responsibility for the central authorities of Internet administration, the US government must take the lead in this process.

Other principles

7. A new principle should be added to this list. Domain names must be recognized as a form of expression or communication. Domain names convey ideas and transmit organizational identities. They can be put to creative uses. They are often selected to attract attention, and in some cases form phrases. Domain names can make references to people, institutions, and events. In formulating public policy, therefore, considerations of freedom of expression and of the proper level of restraint upon personal and public communication must be taken into account. Many governments around the world are hostile to freedom of expression. I urge the US government to uphold the principles embodied in its own Bill of Rights and clearly recognize the principle that freedom of expression is implicated in its treatment of domain naming.

B. General/Organizational Framework Issues

4. Are there decision-making processes that can serve as models
for deciding on domain name registration systems (e.g., network
numbering plan, standard-setting processes, spectrum allocation)?

8. One significant model is the system of company symbols adopted by the stock exchanges in the United States. The analogy is relevant because:

a) Names have some semantic relationship to the actual company name;

b) There are competing, privately-run exchanges, but all exchanges manage to make their naming conventions consistent and avoid collisions;

c) Most importantly, the exchanges do not simply hand out symbol strings at random or passively upon application, but actively manage their namespace. For example, NYSE reportedly is reserving the symbol "M" for Microsoft in an attempt to lure it from NASDAQ. This kind of active management of the resource in an environment that combines competition with cooperation is applicable to DNS.

4. (continued) What is the proper role of national or international
governmental/non-governmental organizations, if any,
in national and international domain name registration systems?

9. In establishing rules for privatization of the global namespace, the US government needs to find an appropriate forum in which to coordinate its efforts with other governments. The World Trade Organization is the most appropriate international organization for this purpose. The WTO is free of the sectoral vested interests that characterize, for example, the International Telecommunication Union (ITU) or the World Intellectual Property Organization (WIPO). As a vehicle for commerce and communication, the future of the Internet is vital to the growth of free trade in services and is also likely to have an impact on trade in commodities. Internet-related services themselves form a growing part of world trade. It is best, therefore, for international coordination around the domain name issue to be approached as an instance of trade in services, and the international framework established through WTO agreements.

5. Should generic top level domains (gTLDs), (e.g., .com), be
retired from circulation? Should geographic or country codes
(e.g., .US) be required? If so, what should happen to the .com
registry? Are gTLD management issues separable from questions
about International Standards Organization (ISO) country code
domains?

10. Generic TLDs should not be retired from circulation, and ISO-3166 codes should not be compulsory. Such a course of action would be the most disastrous mistake that could come out of this proceeding.

11. A regime of compulsory national TLDs is unfriendly to users. The primary purpose of domain names is to make addresses easier to use than numbers. ISO-3166 codes are only marginally better than numbers. The codes themselves are often counter-intuitive and confusing. For example, ".au" could be Austria or Australia; ".il" could be Iceland, Ireland, or Israel.

12. Another aspect of user-unfriendliness is the additional hierarchical levels that a country-code system imposes on users. National TLDs usually have a second-level hierarchy with additional "generic" categories inside them. (If country codes were compulsory then all of them would need generic second, and possibly even third, -level hierarchies.) Under a national TLD regime, expansion of the namespace can only occur by adding additional levels. The economic premium placed on existing gTLDs, especially ".com", by multinational companies is largely attributable to the shorter, more easily remembered name. A very large number of users have demonstrated a clear preference for shorter domain names.

13. Elimination of gTLDs eliminates all innovation in naming conventions. It fixes the total number of TLDs and imposes a single top-level categorization scheme upon the entire Internet, regardless of user demand. Ideas such as the ".nom" or ".per" space for personal names, or the ".num" space for telephone numbers, could not be implemented on a global basis.

14. Most importantly, a regime of compulsory ISO-3166 codes threatens to give national authorities the same bottleneck control over the Internet that they have traditionally enjoyed over post, telephone, telegraph and broadcasting systems. That is, domain name policies and conventions would be set by national governments or national registration monopolies. Naming conventions could be subordinated to the desire of national governments and/or network administrators to control and monitor the activities of Internet users. One virtue of gTLDs is that they create a global competition for names and registrations. It is ironic that a form of "Internet nationalism" would be proposed now, when telecommunications and broadcasting industries are slowly extricating themselves from the constraints and inefficiencies of a regime organized around national monopolies and national boundaries. Forcing Internet TLDs into a hierarchical framework organized around nation-states invites the politicization of Internet governance. It is also totally out of synch with the global, borderless nature of Internet communication, and the regional and local boundaries of language and culture.

15. A high level of coercion would be required to implement Internet nationalism. Tens of thousands of gTLD domains would have to be migrated into national TLDs. Many registrations under national TLDs would also have to change. There are at least 50 country-code registries that now accept registrations from hosts not resident in that country. This practice would have to be ended and policed.

C. Creation of New gTLDs

10. Are there technical, practical, and/or policy considerations
that constrain the total number of different gTLDs that can be
created?

16. Technically, there seems to be no significant disagreement with the proposition that there could be 500-600 TLDs (i.e., 250-350 more than currently exist). After that, expert opinion varies, but it is not uncommon to hear technically supportable claims that the system could sustain up to 10,000 new TLDs.

17. By way of background it is worth noting that in February 1996 IANA's Jon Postel, someone who could reasonably be considered an authority on the operational aspects of the Internet, proposed adding 300 new TLDs over a period of five years, with 150 new TLDs added in the first year.

18. Trademark protection is sometimes cited as a reason against creating new TLDs. In fact, additional TLDs help to decouple domain names from brands and trademarks and thus improve this alleged problem. This argument is developed in greater detail in the section on trademark protection.

19. User "confusion" is also cited as another reason to restrain or limit the number of TLDs. This argument assumes that domain names need to be part of a controlled, exhaustive classification scheme. In fact, there is no empirical evidence that users benefit substantially from a controlled classification scheme in the top level. All that matters is whether the TLD is easy to remember and gives users some semantic clues as to the nature of the address (e.g., ".biz," ".sex").

20. The most important practical considerations are not technical but economic and administrative. Specifically, the procedure for distributing the right to create and administer new TLDs must be carefully defined. If this process is open and continuous, as it should be, poorly defined procedures in the early stages of implementation may result in "land grabs" that could create injustices and threaten the connectivity or operational integrity of the network.

11. Should additional gTLDs be created?

21. Yes. More precisely, a procedure that allows new TLDs to be added continuously in response to consumer demand, entrepreneurial effort, and market evolution should be defined. More TLDs should be created because:

a) it reduces conflicts over desirable or popular names or expressions

b) it increases competition for registry services

c) it reduces the incentives for name speculation

d) it provides an additional channel for entrepreneurial innovation in value-added registration services and naming structures

e) it will eventually provide a mechanism for domain names based on non-Roman alphabets

13. Are gTLD management issues separable from questions about ISO
country code domains?

22. The real issue is the creation of new TLDs, not new "g"TLDs. Until and unless there is a consistently enforced policy that every name must end in a national TLD, there is no important distinction between "generic" TLDs and national TLDs. At the present time users still have the choice of registering in a "g"TLD or in alternative national TLDs. As long as this is true, national TLDs are nothing more than badly truncated, semantically unattractive generic TLDs.

D. Policies for Registries

15. Should a gTLD registrar have exclusive control over a
particular gTLD? Are there any technical limitations on using shared registries for some or all gTLDs? Can exclusive and
non-exclusive gTLDs coexist?

23. Shared registries may reduce users' risk of losing any sunk costs they invest in a particular domain name. In a competitive marketplace, this may make shared TLD registries an attractive option to users. However, there is no reason why all TLD registries should be required to be shared. There are no technical or administrative barriers to the co-existence of shared and exclusive TLD registrars. Hence, the choice of a shared or exclusive TLD registrar can be left to end users.

19. Should there be a limit on the number of different gTLDs a
given registrar can administer? Does this depend on whether the
registrar has exclusive or non-exclusive rights to the gTLD?

24. In the initial distribution phase of TLD rights there must be fairly stringent limits imposed on the number TLDs given to each registrar, otherwise applicants will have an irrational incentive to claim as much of the top-level namespace as possible regardless of their real capability to administer it, in order to pre-empt competitors and/or profit from a secondary market.

E. Trademark Issues

21. What trademark rights (e.g., registered trademarks, common
law trademarks, geographic indications, etc.), if any, should be
protected on the Internet vis-à-vis domain names?

25. A great deal of nonsense has been written about this issue. There is a pervasive fallacy that domain names are the same thing as brands or trademarks and that textual identity of a domain name and a trademark is equivalent to a violation of intellectual property. The issues surrounding trademark rights will never be resolved justly until these fallacies are disposed of.

26. The "trademark-like" status of second-level domain names has been greatly exaggerated by the artificial restriction on the supply of gTLDs devoted to business. As long as ".com" was the only game in town, naive Internet users could assume that typing in "www.<companyname>.com" was a reasonable way to find the web site of a particular company. Browser software reinforced this assumption by automatically filling in ".com" when users typed in an unadorned company name. In this environment, it was rational (if not ethical) for name speculators to take advantage of the huge gap between the low cost of registrations and the high potential economic value of famous company name registrations under ".com". Given the monopolistic status of ".com" it was also rational (if not legally correct) for the affected companies to see such speculative registrations of their name by third parties as a dilution of their brand identity or trademark.

27. Expansion of the TLD space is the only permanent solution to this problem. As alternatives to ".com" proliferate, the putative equation of domain names, brand names, and trademarks is progressively weakened. As TLD space expands, it becomes increasingly unlikely that the mere presence of a "famous name" in the second or third level of a domain name will attract attention or dilute the value of a brand.

28. The domain name/trademark debate seems to have lost sight of some fundamental facts about the Internet. There are millions of web sites out there. The number is doubling every six months. Users do not flock to a particular web site merely because of the character string in a domain name. Site content must be promoted and updated, and the site address advertised, cross-linked and bookmarked to attract significant, recurring attention. Owners of internationally famous names and brands have the resources to promote their own Internet sites and to forge a strong link between their Internet domains and their own unique brands and trademarks. Similarity of domain names per se does not constitute dilution or passing off unless the offending domain name holder also engages in systematic efforts to exploit the famous name and confuse users.

29. The only legitimate link between trademark/IPR protection and Internet domain names and sites occurs when domain names contribute to the defrauding of customers or users. That is, if a company other than Microsoft acquires a domain name with "Microsoft" in it and organizes its information, products or services in ways that deceive users into believing that they are interacting with the "real" Microsoft, then and only then does a legally actionable trademark problem exist.

30. Trademark protection must be balanced with the principle (proposed above in paragraph 9) that domain names are a form of expression. It is legitimate for companies, organizations, and individuals to use domain names to refer to other companies, organizations, events, or individuals, as long as no attempt at deception or "passing off" is involved. For example, a group of disgruntled Microsoft customers has a perfectly legitimate claim to register the domain "microsoft.org" and set up a web site at "wehate.microsoft.org." In this case the domain name can be construed as a reference to the Microsoft Corporation, in the same way that one would use the term "Microsoft" in writing or talking about that company. Just as Microsoft's ownership of its trademark does not give it a right to prevent people from using its name in all documents or speech, so domain names per se must not be equated with brands or trademarks.

22. Should some process of preliminary review of an application
for registration of a domain name be required, before allocation,
to determine if it conflicts with a trademark, a trade name, a
geographic indication, etc.?

31. No. This question assumes that the mere textual identity between a domain name and a trade name creates a legal or economic conflict. That assumption is totally invalid for the reasons explained in paragraphs 28-32 above. More generally, re-organizing the whole world's domain name registration system in order to give major multinational trademark holders veto power over all name allocations represents an unwarranted expansion of the power of trademark and a grotesquely disproportionate response to a fairly minor problem. Furthermore, such an approach would exacerbate rather than resolve trademark conflicts. Current domain name categories bear no relationship to the jurisdictional, industrial, and geographic boundaries of trademark protection. Those who conduct such a preliminary review thus have no solid legal basis for resolving conflicting claims.

23. Aside from a preliminary review process, how should trademark
rights be protected on the Internet vis-à-vis domain names? What
entity(ies), if any, should resolve disputes? Are national courts
the only appropriate forum for such disputes? Specifically, is there a role
for national/international governmental/nongovernmental organizations?

32. When real trademark violations occur on and through the Internet, they can be handled in the same way as international intellectual property violations are handled now. There is nothing unique about Internet domain names in this regard. There is simply no evidence for the presumption that mere textual identity or similarity between a domain name and a brand name somehow gives intellectual property violators sweeping powers to reap illicit gains at the expense of IPR holders. Real trademark violations involve sustained sequences of actions designed to pass off or defraud. The adoption of a domain name, by itself, cannot accomplish this.

25. Should domain name applicants be required to demonstrate that

they have a basis for requesting a particular domain name? If so,

what information should be supplied? Who should evaluate the

information? On the basis of what criteria?

33. This is a helpful question, but needs to be reframed. The answers to these questions can only come from the policies name registries adopt to prevent name speculation and to control the secondary market for names. Name speculation is a form of arbitrage. The speculators attempt to exploit the gap between the price of registering a name and the higher value of that name to some other potential user. Name speculation thus provides a clear signal that the primary distributor of name registrations is not exploiting the full economic value of its name resources.

34. The best long-term solution to this problem is privatization of name registration and expansion of TLD space. It is in the rational self-interest of commercial registries to manage name resources actively rather than passively. Just as airlines or movie theater owners do not allow aggregators and wholesalers to buy up all available seats and resell them to end users, so it seems unlikely that private, profit-motivated name registries would allow speculators, rather than themselves, to exploit the full economic value of their namespaces. As the namespace becomes privatized and commercialized, it seems likely that more active monitoring of who is applying for names and why would take place. Administrative policies such as this are much preferable to intellectual property law as a solution to problems of name speculation.

26. How would the number of different gTLDs and the number of
registrars affect the number and cost of resolving trademark
disputes?

35. As noted above, additional TLDs reduce legitimate conflicts over name allocations. If there are fifty additional generic TLDs devoted to businesses, then United Airlines, United Van Lines, and the United Hardware Store of Wahoo, Nebraska can all find unique, second-level domain names based on the string "united". What additional TLDs do not do is make it possible for one of those three companies to stake a global claim to all possible uses of the string "united" in the second level of the hierarchy. In fact, no one should be able to do that--unless, of course, they are willing to pay the full market price for the name resources they exclude others from using.

36. Apologists for multinational trademark holders have attempted to argue that additional TLDs "worsen" the "trademark problem" by making it more difficult for them to reserve or register a famous name in all possible TLDs. This argument is fallacious. There are about 250 TLDs in the world now. In response to the demand for name protection, intermediary companies such as NetNames have already established "international Internet name registry" services that offer multinational firms registrations of their desired names in the world's top commercial domains. In other words, global name protection is readily available for companies that are willing to pay for it. When these companies lobby for elaborate bureaucratic mechanisms to vet domain names, and/or for artificial restrictions on the supply of TLD namespace, they are simply asking the world's governments and Internet users to subsidize their own private commercial objectives. This is unfair and unnecessary.

37. Creating additional TLDs will probably make global name reservation/protection services more expensive (although competition and improving market organization may have countervailing effects). But for well-intentioned companies, it should also reveal the futility and irrationality of the notion that they need to control all possible uses of particular character strings in all domains.

27. Where there are valid, but conflicting trademark rights for a
single domain name, are there any technological solutions?

38. Again, the assumption that mere textual identity between a domain name and a trade name creates a legal or economic "conflict" must be rejected. Valid, conflicting claims for the same second-level domain name will undoubtedly arise. This problem must not be confused with a conflict over "trademark rights." United Airlines, United Van Lines and possibly hundreds of other companies have a perfectly legitimate claim to "united.com." When such conflicts arise, the solutions are semantic and economic. For example:

a) The loser can choose an alternative formulation of its name. (e.g., united-van.com; united-vanlines.com; move-united.com)

b) The person who wants "united.com" the most can bid a higher price for it.

c) The excluded party can move to an alternative TLD (e.g., united.firm, united.biz)


###
Number: 217
From:     "bluefin@thing.net" <Hatsumi.Asaka@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 12:53am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Hatsumi Asaka do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Saturday, August 9, 1997 00:51:37 EDT
Hatsumi Asaka



###
Number: 218
From:     "jagware@ibm.net" <Joe.Givens@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 1:20am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Joe Givens do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Saturday, August 9, 1997 01:18:49 EDT
Joe Givens

Since this country was founded on competition, why should we be subjected
to the monoploy of the internic??  Name.space fosters competition in this
burgeoning industry, IMHO




###
Number: 219
From:      "MTM@aon.at" <ads.GmbH.-.Peter.Kuhlang@violet.xs2.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      8/9/97 1:57am
Subject:   Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I ads GmbH - Peter Kuhlang do hereby support the design of the expanded
toplevel Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Saturday, August 9, 1997 01:55:36 EDT
ads GmbH - Peter Kuhlang

MTM@mycity.at
we hace registrated:
MTM.firm
ESC.firm


###
Number: 220
From:     "adler@sachsen.de" <Mathias.Adler@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 3:53am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Mathias Adler do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Saturday, August 9, 1997 03:51:54 EDT
Mathias Adler

01157 Dresden
Meissner Landstrasse 127

###
Number: 221
From:     "scharn@il.us.swissbank.com" <N.Scharnagl@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 5:27am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I N.Scharnagl do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".

     Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server.  During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name".  The registrant
has the option to choose whether or not its personal contact information
will be publicly listed.  All other account information, of course, remains
confidential.  The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications.  Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol.  The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.

Issues and Answers

     Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars.  Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.

     These gTLDs may be added or removed based on public demand.  Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.

     All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system.  As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced.  The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."

(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)

Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded.  The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

     The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm.  Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names.  The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature.  The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.

     With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties.  However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

     Fees for registration services should be dictated by the market.  Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).

     In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.

     The name.space(tm) system is a reality today.  The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .

     I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.

-------------------------------
Saturday, August 9, 1997 05:25:49 EDT
N.Scharnagl


###
Number: 222
From:     "mspiteri@maltanet.net" <Marcel.Spiteri@violet.xs2.net>
To:  NTIADC40.NTIAHQ40(dns)
Date:     8/9/97 8:23am
Subject:  Comments on Domain Names


PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES

(The New Paradigm for the Old DNS)


     I Marcel Spiteri do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).

     The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS").  The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.

     pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries.  The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.

     The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.

Description of the name.space(tm) service:

     On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace).  All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries.  The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.

     Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge.  (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD).  IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any