###
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
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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:
ú 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.
ú Seven new gTLDs:
ú firm -- for businesses or firms;
ú store -- for businesses offering goods to
purchase;
ú web -- for entities emphasizing activities related
to the World Wide Web
ú arts -- for entities emphasizing cultural and
entertainment activities
ú rec -- for entities emphasizing
recreation/entertainment activities
ú info -- for entities providing information
services
ú nom -- for those wishing individual or personal
nomenclature
ú 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.
ú 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:
ú 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.
ú 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.
ú 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.
ú 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:
ú 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.
ú 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.
ú 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.
ú 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.
ú 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.
ú 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.
ú 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.
ú 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:
ú Its alternative dispute resolution system's failure to
include coverage of the ISO 3166 country codes may create inconsistencies;
ú 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.
ú IANA's and ISOC's veto power on the POC is unworkable and
likely to alienate whatever Internet community exists;
ú 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;
ú Further attention needs to be given whether there will be
a way to pre- screen SLDs;
ú The impact, if any, of moving jurisdiction over the
administration of the Internet to Geneva needs to be evaluated.
ú 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.
ú 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 technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 08:22:02 EDT
Marcel Spiteri
"Valley View" flat,
Valley Str.,
Mellieha SPB14,
MALTA.
Free the net!!!
###
Number: 223
From: "fk@bln.de" <Frank.Kunkel@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 8:30am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Frank Kunkel do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 08:29:00 EDT
Frank Kunkel
###
Number: 224
From: "bonita@4dcomm.com" <Bonita.Walker@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 11:51am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Bonita Walker do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 11:50:20 EDT
Bonita Walker
###
Number: 225
From: "churn88@aol.com" <Janie.Angus@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 4:12pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Janie Angus do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 16:11:15 EDT
Janie Angus
###
Number: 226
From: "kjr@ap.net" <Kevin.Shepherd@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 7:20pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Kevin Shepherd do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 19:16:14 EDT
Kevin Shepherd
###
Number: 227
From: "ahochber@iname.com" <Alex.M.Hochberger@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 9:34pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Alex M. Hochberger do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 21:33:01 EDT
Alex M. Hochberger
305 NW 111th Ave
Coral Springs, FL 33071
###
Number: 228
From: "regwhit@yorku.ca" <Reg.Whitaker@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/9/97 11:08pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Reg Whitaker do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 9, 1997 23:06:26 EDT
Reg Whitaker
Department of Political Science
York University
Toronto Ont M3J 1P3
CANADA
###
Number: 229
From: instant@aracnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/10/97 4:17am
Subject: It is time to expand available domains
The addition of these additional domain names is imperative to the
continued growth of the web. I have a business called Instant Impact
Communications and can't get a domain that comes close to my commercial
name. The domain names instant.com, instant.org, instant.net, impact.com,
impact.org, impact.net and even imstantimpact.com are all taken by other
companies. A domain name trader recently offered to sell me the rights to
instant.com for several thousand dollars versus the original two-year
registration cost of just $100. Not only is this practice extortive, it
prevents my customers from associating my site name with my business. In
addition to expanding the available domains, the arbitration process for
copyrighted domain names should be streamlined to make certain that
companies with proprietary trademarks and business names don't lose their
domain names to Internet speculators. Please expedite the addition of new
top level domains on the Internet at your earliest opportunity.
Christopher Vetter
Instant Impact Communications
"Making the world a better place, one web site at a time."
cvetter@aracnet.com or 503-648-1529
###
Number: 230
From: "trend@worldaccess.nl" bruining@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/10/97 5:31am
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 bruining 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.
-------------------------------
Sunday, August 10, 1997 05:30:04 EDT
bruining
P.O.BOX 6051
3002 AB ROTTERDAM
###
Number: 231
From: "barto@ahk.nl" Bart.Oomen@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/10/97 7:47am
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 Bart Oomen 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.
-------------------------------
Sunday, August 10, 1997 07:45:45 EDT
Bart Oomen
O.Z Achterburgwal 55-1
Amsterdam
The Netherlands
###
Number: 232
From: <southbrook-lan@voyager.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 9:48pm
Subject: COMMENT ON INTERNET DOMAIN NAMES
First, minimize government mucking about - that which they do best,
mucking up the works, that is.
Second, minimize the cacademics' participation - this matter is not
one well suited to ivory tower hypotheses. We will be living with
the consequences for some time to come.
Third, make them manifestly meaningful, i.e., banking industry=bnk,
publishing of all natures=pub, smut=xxx, etc., with particular
consideration for transparent clarity English as well as as many
other languages as possible - with an
eye to (a) same or similar meaning, and (b) avoidance of contradictory
interpretation. (Remember the Chevy Nova that did not sell well in
Latin America because Nova comes across as "no go?"
Fourth, deeply involve those (techies and management) that will have
to explain the system as good and reasonable, and who will have to
make it work on a daily basis.
James B. Graves
Forbes Computer Co.
Post Office Box 427
Holt, Michigan 48842-0427
###
Number: 233
From: <FinanciaCo@aol.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 6:25pm
Subject: Domain names
A spectre is haunting America! The spectre of Internet Solutions, Inc.
Compounding the reckless registration policies of this outfit, unsupervised
by NSF, and abetted by ISPs that have capitalized on the mutual greed, a
govenment dictated solution to the chaos is needed.
The "first come - first served" exculpatory excuse by Internet Solutions does
not square with the real world of trademark and intellectual property laws
and customs. Do not believe any of Internet Solutions, Inc. policy on dispute
resolutions. It is a smokescreen that rivals Hitler's Goebles.
I am the victim of a thief registering my fanciful, distinctive, unique, and
now famous trademark that has been used in commerce since 1983. They now
mistakenly believe that they have property rights to my trademark by virtual
of their .com system. I have furnished sufficient proof of ownership
including the PTO sending a direct fax copy to their outside counsel. I have
refused sending the original PTO binding and and am perplexed at their latest
demand for a certified copy that is merely the same thing with a ribbon
affixed.
Their contributory infringement prohibits me from using the intuitive address
for FINANCIA that has worked well on AOL's members page but caused me to have
to use FinanciaCo on the www domain. Later when financia is available I will
have to give them another $100. and perhaps even another $100 to register
Financiainc. Is not this game in need of redress?
Sincerely,
Darrell J. Bird - Financia@aol.com
###
Number: 234
From: Louis Epstein <le@main.put.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 1:10pm
Subject: Domain Names...Too Easy to Get!
I note that you are accepting comments on the future administration
of domain name registration on the Internet.
In a nutshell,it is FAR too easy to get a domain name for insufficient
reason.For users to get their own domain names is the Net equivalent of
incorporating cities in their back yards.You do not need and should not
want a domain name unless you are going to support a large number of
users over an exclusive fixed internet link.The proliferation of
www.lookeelookeemamaIgotmyveryowndomain.com sites is bad namespace
usage and harms network performance.
Now there is pressure for more gTLDs,to further aid the unwarranted
prioliferation,which is of course promoted by those standing to make
money in the process.I say no...there should be no gTLDs not with
clear differentiation from all others in their function.
Obviously,administration has to be done in such a way as to prevent
duplication of names,or they become useless.The prevention of
price-gouging should be done by regulation,not by competition.
The registration of domain names may be a growth industry,
but unreasonable growth sprouts weeds and waste.Government
solutions should not be aimed at helping a feeding frenzy,
but at reining it in.
Louis Epstein
Putnam Internet Services
###
Number: 235
August 15, 1997
Patrice Washington
Office of Public Affairs
National Telecommunications and
Information Administration
Room 4898
14th Street and Constitution Avenue, N.W.
Washington, D.C. 20230
Re: Request for Comments on the Registration
and Administration of Internet Domain Names
Dear Ms. Washington:
This letter is in response to the Department of
Commerce's Request for Comments on the Registration and
Administration of Internet Domain Names, which appeared in the July
2, 1997 edition of the Federal Register.
A. Appropriate Principles
The domain name registration system is not best left to
the private sector. The assignment of a domain name carries no
inherently valuable commercial content any more so than does the
assignment of a telephone number, a post office box, or a postal
address. Private sector competition in the domain name
registration "business" would only serve to further confuse the
already complicated domain name system. Administration of the
domain name registration system by an international regulatory body
would be more efficient, fairer and make more sense.
B. General/Organizational Framework Issues
1. The principle disadvantage of the current domain
name registration system is that it, unlike the trademark
registration system, does not permit two entities in non-competing
businesses to use the same name, so long as there is no likelihood
of confusion. Thus, for example, a company which legitimately uses
the name "ABC" to sell furniture, could not register the domain
name "ABC.com" if it had already been registered by ABC News.
3. Because of the international nature of the Internet,
domain name registration systems should be administered by an
international organization, in a manner similar to the operation of
the ISO. The makeup of such an international entity should include
representatives from both the public and private sectors in various
countries in which the Internet is being used.
4. Currently, the disputes over domain names are caused
by the fact that many Internet users expect to find a particular
company's site simply by entering that company's name with the
".com" top level domain name extension. However, once an Internet
site is known to a user, that user no longer has a need to remember
the domain name, because the user can simply "bookmark" the site in
his or her web browser. In addition, as the Internet comes into
wider use, it will become increasingly difficult for companies to
use domain names that are easily recognizable or memorable.
Therefore, Internet search engines and indices will become more
important and more prevalent in the way users of the Internet
locate sites of interest. Therefore, I would suggest that a more
sensible way of allocating domain names would be to entirely
eliminate the domain name system, and replace it with the numerical
system used for IP addresses. In fact, the current use of host
domain names is simply a surrogate for the IP numbers, to which the
domain names map. By using the essentially random IP numbers,
instead of domain names, many of the disputes over domain name
registrations would disappear. In this manner, domain names would
be no more distinctive then telephone numbers.
8. The transition to the new "numbers only" system
should be accomplished in a phased but rapid manner. The Internet
is always fast-changing, and the change in the domain name system,
though radical, would quickly be absorbed and adopted by users.
Thus, the new "numbers only" system could probably be transitioned
into use over a period of only a few months.
C. Creation of New gTLDs
11. New gTLDs should not be created. If new gTLDs are
created (such as .inc, .ltd, .firm, .store, or any of the other
suggested gTLDs), companies are likely to respond by simply
registering the same second level domain name across several top
level domain names (i.e., ABC.com, ABC,inc, ABC,firm, etc.) Thus,
creation of gTLDs as alternatives to ".com" would only cause
companies to register their company's name across several top level
domain names.
E. Trademark Issues
24. Conflicts over trademarks in the domain name context
can best be prevented by simply eliminating the source of the
conflicts by using a "numbers only" domain name system.
Very truly yours,
David Leit
cc: Mike Heltzer
INTA Government Relations Program Coordinator
International Trademark Association
1133 Avenue of the Americas
New York, NY 10036-6710
###
Number: 236
From: "antoine@eci.com" <Anthony.Tong@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 3:16pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Anthony Tong do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Monday, August 11, 1997 15:05:25 EDT
Anthony Tong
###
Number: 237
From: "rick@rickster.com" <Rick.Frankel@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 3:28pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Rick Frankel do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Monday, August 11, 1997 15:26:41 EDT
Rick Frankel
###
Number: 238
From: "zod@walrus.com" <Charles.Hope@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 6:59pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Charles Hope do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Monday, August 11, 1997 18:57:59 EDT
Charles Hope
###
Number: 239
From: "Vic O'Dell" <webmaster@thesmokies.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 12:34am
Subject: Public Comment on the Domain Names
I think that the domain name extensions should reflect geographic location
(i.e. domain-name.com.423 or domain-name.net.932 or domain-name.gov.55).
Where a number such as an area code or country code separates the
businesses or organizations and decentralizes trademark/domain-name
problems to a smaller area for better control. The Internet is a
decentralized communication system and should not be governed by a
centralized organization. If there arises an issue on the national or
international level, then a central organization can act as arbitrator to
settle a dispute.
For example, some business names are so popular that they resurface in each
state in the US. You can have an "AAA Automotive" in New York and Texas or
"AAA Automotive" can decide to form a national chain and apply for a
foreign license in each state, thereby protecting their business name.
Vic O'Dell
###
Number: 240
From: "ivo@reporters.net" <Ivo.Skoric@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 11:05pm
Subject: Comments on Domain Names
Just recently there were five more Top Level Domain names added to the
meager list of already available options. The administration that guides
that standard admits to its inadequacy system and to the technical
feasibility of the pgMedia proposal. Therefore, unless there are some moral
or political reasons that we are not aware of in a democracy, there should
be no obstacles in adopting and implementing their idea.
-------------------------------
Tuesday, August 12, 1997 23:03:00 EDT
Ivo Skoric
###
Number: 241
From: "100131.2223@compuserve.com" <Tilman.Baumgaertel@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 5:05am
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 Tilman Baumgaertel 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.
-------------------------------
Tuesday, August 12, 1997 05:03:58 EDT
Tilman Baumgaertel
###
Number: 242
From: "pkalocsa@counsel.com" <Paul.Kalocsay@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 11:17am
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 Paul Kalocsay 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.
-------------------------------
Tuesday, August 12, 1997 11:16:01 EDT
Paul Kalocsay
###
Number: 243
From: "kaas@usa.net" <Kelsey.Francis@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 1:45pm
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 Kelsey Francis 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.
-------------------------------
Tuesday, August 12, 1997 13:44:24 EDT
Kelsey Francis
###
Number: 244
From: "jrives@mindspring.com" <Joel.M.Rives@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 4:24pm
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 Joel M. Rives 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.
-------------------------------
Tuesday, August 12, 1997 16:22:03 EDT
Joel M. Rives
###
Number: 245
From: ajs6f@virginia.edu <adam soroka@zero.tolerance.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 4:49pm
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 adam soroka 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.
-------------------------------
Tuesday, August 12, 1997 16:48:07 EDT
adam soroka
###
Number: 246
From: admin@imail.org <Warwick Berg@zero.tolerance.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 6:17pm
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 Warwick Berg 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.
-------------------------------
Tuesday, August 12, 1997 18:15:04 EDT
Warwick Berg
###
Number: 247
From: "water@ddgn.com" <Julietta.L.A.@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 6:53pm
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 Julietta L.A. 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.
-------------------------------
Tuesday, August 12, 1997 18:52:28 EDT
Julietta L.A.
22 Bushwick Ave. #3
###
Number: 248
From: "cernyr01@doc.mssm.edu" <Rosaria.Cerny@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 8:57pm
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 Rosaria Cerny 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.
-------------------------------
Tuesday, August 12, 1997 20:55:49 EDT
Rosaria Cerny
###
Number: 249
From: "SUDIVA@aol.cvom" <Colleen.Cortes@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 8:59pm
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 Colleen Cortes 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.
-------------------------------
Tuesday, August 12, 1997 20:58:11 EDT
Colleen Cortes
###
Number: 250
From: "abodor@flotsam.com" <Andrew.Bodor@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 9:03pm
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 Andrew Bodor 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.
-------------------------------
Tuesday, August 12, 1997 21:01:42 EDT
Andrew Bodor
NYC
###
Number: 251
From: "colleenwerthmann@hotmail.com" <Colleen.Werthmann@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 9:13pm
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 Colleen Werthmann 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.
-------------------------------
Tuesday, August 12, 1997 21:12:00 EDT
Colleen Werthmann
c/o Werth-Mania!
166 Suffolk Street #2B
NYC, NY 10002
###
Number: 252
From: "Jas1001001@aol.com" <Jason.Zuzga@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 9:48pm
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 Zuzga 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.
-------------------------------
Tuesday, August 12, 1997 21:45:47 EDT
Jason Zuzga
###
Number: 253
From: "mooses@aol.com" <Jack.Aronson@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 9:51pm
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 Jack Aronson 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.
-------------------------------
Tuesday, August 12, 1997 21:51:04 EDT
Jack Aronson
New York, NY USA
###
Number: 254
From: "dsolomon@xs4all.nl" <D.A.Solomon@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 10:16pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I D.A. Solomon 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.
-------------------------------
Tuesday, August 12, 1997 22:15:09 EDT
D.A. Solomon
###
Number: 255
From: "dmilford@interport.net" <Doug.Milford@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/12/97 10:45pm
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 Doug Milford 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.
-------------------------------
Tuesday, August 12, 1997 22:43:41 EDT
Doug Milford
632 East 11th Street, Apt. 13
New York, NY 10009
###
Number: 256
From: <ALLENJS@detroitedison.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 4:17pm
Subject: DNS management
Sirs:
I believe that the administration of top-level domains should be opened
to organisations which can compete on basis of service and cost. The
Internet is too important a resource to leave at the mercy of a bumbling,
beauracratic, monopoly such as network solutions, inc., who has no
commitment whatsoever to customer satisfaction.
peace,
Joshua Allen
###
Number: 257
From: "mpreven@pipeline.com" <Marc.Preven@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 1:17am
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 Marc Preven 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.
-------------------------------
Wednesday, August 13, 1997 01:15:51 EDT
Marc Preven
###
Number: 258
From: "misfits@gol.com" <Tom.NAGAE@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 1:35am
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 Tom NAGAE 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.
-------------------------------
Wednesday, August 13, 1997 01:34:09 EDT
Tom NAGAE
###
Number: 259
From: "kossatz@thing.at" <Max.Kossatz@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 11:01am
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 Max Kossatz 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.
-------------------------------
Wednesday, August 13, 1997 10:59:57 EDT
Max Kossatz
###
Number: 260
From: "wizard@muu.autono.net" <Ville.Venell@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 5:38pm
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 Ville Venell 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.
-------------------------------
Wednesday, August 13, 1997 17:36:57 EDT
Ville Venell
###
Number: 261
From: "aah@thing.ch" <Andreas.A.Hagenbach@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 6:03pm
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 Andreas A.Hagenbach 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.
-------------------------------
Wednesday, August 13, 1997 18:01:42 EDT
Andreas A.Hagenbach
Erlenstrasse 20
CH-4058 Basel
Switzerland
###
Number: 262
From: "crunch@host.net" <John.Draper@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 6:26pm
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 Draper 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.
-------------------------------
Wednesday, August 13, 1997 18:25:28 EDT
John Draper
Waco, TX
###
Number: 263
From: "state505@escape.com" <hagop.tumayan@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 6:29pm
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 hagop tumayan 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.
-------------------------------
Wednesday, August 13, 1997 18:28:14 EDT
hagop tumayan
###
Number: 264
From: "foo@tiac.net" <Fumi.Itoyama@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 7:04pm
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 Fumi Itoyama 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.
-------------------------------
Wednesday, August 13, 1997 19:02:34 EDT
Fumi Itoyama
###
Number: 265
From: "mbills@versionmedia.com" <Mitchell.Bills@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 9:16pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Mitchell Bills 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.
-------------------------------
Wednesday, August 13, 1997 21:14:26 EDT
Mitchell Bills
Connecticut
###
Number: 266
From: "xander@escape.com" <Alexander.Clifton@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 9:25pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Alexander Clifton 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.
-------------------------------
Wednesday, August 13, 1997 21:24:14 EDT
Alexander Clifton
###
Number: 267
From: "sugerbean@sprynet.com" <yutaka.sato@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/13/97 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 yutaka sato 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.
-------------------------------
Wednesday, August 13, 1997 12:16:33 EDT
yutaka sato
###
Number: 268
From: <Pabatan@kiki.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 6:04am
Subject: Comments On Domain Name Strategies
Comments on Internet Domain registration :
I have a company registered as Business Information Technology Management,
abbreviated as BITMAN. However, there is a graphic design company already
registered as WWW.BITMAN.COM. In order to resolve issues like this it will
be better if domain names could be registered according to the industry
sector they operate in for example, in situation the graphic art company
will registered as :-
www.graphics.bitman.com
While my company that is in the IT sector will be registered as :-
www.it.bitman.com
And if there is a law firm with the same name it will be :-
www.law.bitman.com
The company I currently work for is called Knowledge Insight and normally
call themselves KI, which means you will expect their web site to be
www.ki.com, but this site is already used by another company.
I believe that this will do a great deal in actually distinguishing
organizations and resolve conflicts among domain name systems. Please
contact me on Peter@KIKI.COM if you are interested in my ideas, or you
want me to do more research work on this issue.
Sincerely,
###
Number: 269
From: "Gymer, Keith" <GymerK@hlcec1.agw.bt.co.uk>
To: 'NTIA - DNS COMMENTS' <dns@ntia.doc.gov>
Date: 8/14/97 7:53am
Subject: BT Response to US Government RFC - Part 1 - A (a to f)
This is the formal response on behalf of British Telecommunications plc
(BT) to the US Department of Commerce Request for Comments on the
Registration and Administration of Internet Domain Names. For
convenience, the questions raised in the document are reproduced
indented >, with BT's responses in plain text below. BT has responded
to all questions.
Owing to email limitations the response is being sent in three parts.
In the event of any problems with this email, or for clarification or
further comments on any of the issues raised here, please contact:
Keith Gymer
BT Group Legal Services
Intellectual Property Department
8th Floor, Holborn Centre
120 Holborn, London
EC1N 2TE, UK
Tel: +44 171 492 8129
Fax: +44 171 242 0585
>DEPARTMENT OF COMMERCE
>
>[Docket No. 970613137-7137-01]
>
>Request for Comments on the Registration and Administration of Internet
Domain Names
>
>AGENCY: Department of Commerce.
>
>ACTION: Notice; request for public comment.
>
>SUMMARY: The Department of Commerce requests comments on the
>current and future system(s) for the registration of Internet
>domain names. The Department invites the public to submit
>written comments in paper or electronic form.(1)
>
>DATES: Comments must be received by August 18, 1997.
>
>ADDRESSES: Mail written comments to Patrice Washington, Office
>of Public Affairs, National Telecommunications and Information
>Administration (NTIA), Room 4898, 14th St. and Constitution
>Ave., NW, Washington, DC 20230. See SUPPLEMENTARY INFORMATION
>for electronic access and filing addresses and further
>information on submitting comments.
>
>FOR FURTHER INFORMATION CONTACT: Paula Bruening, NTIA, (202) 482-1816.
>
>SUPPLEMENTARY INFORMATION:
>
>Electronic Access and Filing Addresses
>
>The address for comments submitted in electronic form is
>dns@ntia.doc.gov. Comments submitted in electronic form should
>be in WordPerfect, Microsoft Word, or ASCII format. Detailed
>information about electronic filing is available on the NTIA
>website, http://www.ntia.doc.gov.
>
>Further Information on Submitting Comments
>
>Submit written comments in paper or electronic form at the
>above addresses. Paper submissions should include three paper
>copies and a version on diskette in the formats specified
>above. To assist reviewers, comments should be numbered and
>organized in response to questions in accordance with the five
>sections of this notice (Appropriate Principles,
>General/Organizational Framework Issues, Creation of New gTLDs,
>Policies for Registries, and Trademark Issues). Commenters
>should address each section on a separate page and should
>indicate at the beginning of their submission to which
>questions they are responding.
>
>Background
>
>The rapid growth in the use of the Internet has led to
>increasing public concern about the current Internet domain
>name registration systems. According to Internet Monthly
>Report, registration of domain names within a few top-level
>domains (.com, .net, .org) has increased from approximately 400
>per month in 1993 to as many as 70,000 per month in 1996, the
>overwhelming majority in the .com category. The enormous growth
>and commercialization of the Internet has raised numerous
>questions about current domain name registration systems. In
>addition, the present system will likely undergo modification
>when the National Science Foundation's cooperative agreement
>(NSF agreement) with Network Solutions Inc. to register and
>administer second-level domains for three top-level domains
>expires in 1998. Resolution of these issues will also affect
>the future operation of the National Information Infrastructure
>(NII) and the Global Information Infrastructure (GII).
>
>The United States Government played a central role in the
>initial development, deployment, and operation of domain name
>registration systems, and through the NSF agreement as well as
>Defense Advanced Research Projects Agency (DARPA) agreement(s)
>continues to play a role. In recent years, however, Internet
>expansion has been driven primarily by the private sector. The
>Internet has operated by consensus rather than by government
>regulation. Many believe that the Internet's decentralized
>structure accounts at least in part for its rapid growth.
>
>The Government has supported the privatization and
>commercialization of the Internet through actions such as the
>transition from the NSFNET backbone to commercial backbones.
>The Government supports continued private sector leadership for
>the Internet and believes that the transition to private sector
>control should continue. The stability of the Internet depends
>on a fully interconnected and interoperable domain name system
>that must be preserved during any transition.
>
>Various private sector groups have proposed systems for
>allocating and managing generic top level domains (gTLDs). The
>Government is studying the proposals and the underlying issues
>to determine what role, if any, it should play. The Government
>has not endorsed any plan at this time but believes that it is
>very important to reach consensus on these policy issues as
>soon as possible.
>
>The United States Government seeks the views of the public
>regarding these proposals and broader policy issues as well.
>Specifically, the Government seeks information on the following
>issues:
BACKGROUND
British Telecommunications plc, trading as BT is the UK's major
telecommunications operator. BT is a world leader in the provision of
international communications networks and services. BT has numerous
operating alliances across the globe, including its principal
collaboration with MCI Communications in the Concert Communications
joint venture providing internet infrastructure (e.g. Concert Internet
Plus) and services. This business will expand in future through the
imminent merger of BT and MCI's businesses.
BT is also a major trade mark owner, and as a consequence has been the
target in several cases where its trade marks have been misappropriated
in domain names by unprincipled speculators with no rights to such
marks. BT has also experienced the situation where another entity has
acquired a domain name incorporating a mark to which it and BT both have
legitimate rights in the real world. Such pre-emptive legitimate
registration of a domain name under the present systems, however,
excludes any other party from using the same name in cyberspace
regardless of the fact that both can happily co-exist in the ordinary
course of business.
BT has been actively involved in commenting and in discussion
particularly with interested parties in the UK and Europe during the
evolution of the IAHC/iPOC proposals.
These experiences highlight the two issues which, in our view, it is
essential to resolve in order to allow the internet to fulfil its
optimum potential and provide an efficient and effective medium to meet
the needs of consumers and business for reliable and secure services in
the 21st century information age. These are:
1. That the DNS should be structured to allow businesses which have
legitimate rights to use names and marks in the real world without
conflict to be able to use the same names in cyberspace also without
conflict and without discrimination. Businesses use marks and names for
identification and to give customers assurance about whom they are
dealing with. Domain names, therefore, certainly can and do perform a
trade mark function on the internet.
Fundamentally, a more equitable and formal structure for the allocation
of names and a move away from the inappropriate first-come, first-served
model - FCFS - (which is really first-come, ONLY-served) would seem to
be desirable. The current essential uniqueness of domain names coupled
with a simplistic FCFS system only encourages a "land rush" approach to
grabbing of names to prevent others getting them or to hold potential
users with legitimate rights to ransom for their preferred names. What
is needed is a more sensible, orderly system which gives businesses and
consumers confidence that the interests and rights of all (not just the
fastest to register) will be properly considered and balanced. Domain
names need to be as available for use as trade marks are in the real
world, whether a business comes early or late to the net.
2. As noted above, it is unsatisfactory that the first to register a
domain name should be able to exclude any other business with legitimate
real world rights from using the same name or mark in a domain name
when it could not maintain such exclusivity in the real world.
Conversely, however, trade mark owners are entitled to prevent those who
have no such legitimate rights from misappropriating their names and
marks in domain names. Owing to the instant international reach of the
internet and the corresponding potential for rogue registrations to
cause significant immediate damage to a trade mark owners rights, it is
essential that any domain name registration system should have an
effective and fast dispute resolution procedure to resolve such
conflicts and to deter such piracy. Network Solutions, Inc. (NSI), of
course, does have a dispute policy (see
http://rs.internic.net/domain-info/internic-domain-6.html ). However,
it has been criticised as inadequate and lacking transparency by trade
mark owners and domain name holders alike (see e.g. Carl Oppedahl's
comments at http://www.patents.com/nsi.sht and the International
Trademark Association's comments at http://www.inta.org/intaprop.htm ).
BT itself has had the unsatisfactory experience whereby NSI's policy has
not been applicable to rogue registrations of domain names such as
british-tele.com and bt-mci.com, for example.
In this respect, BT considers the alternative dispute resolution and
administrative challenge proposals originally produced by the Internet
International Ad-Hoc Committee (IAHC) and which are being refined by the
Interim Policy Oversight Committee (iPOC) offer significant improvements
over NSI's policy and have the potential to be fairer and more
effective.
The merits of alternative proposals for domain name administration will
stand to be judged against these two principal criteria.
>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?
The IAHC in its gTLD-MoU (see http://www.gtld-mou.org/ ) has provided a
clear statement of the basic principles which it believes should apply
to the administration of domain names. BT considers that these basic
principles are sensible and realistic and worthy of support. They are
certainly preferable to some of the principles underlying the
alternative models we have seen proposed by NSI, PGP Media, eDNS,
Alternic and others. Accordingly, and notwithstanding the fact that BT
has serious concerns about other details of the IAHC's proposals, BT
would be prepared to endorse the basic principles in the gTLD-MoU and
would commend the US Government to do likewise. These principles are:
(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.
>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.
BT certainly believes that competition in services for registration is
desirable. The IAHC proposal for shared registries, therefore, which
allows for competition between registrars is preferable to NSI's
monopoly control of registration in the existing gTLDs.
However, "expansion" of the DNS is a different issue and this requires
wider and deeper consideration. The proliferation of non-specific
gTLDs, even to the limited extent presently proposed by the IAHC, will
inevitably result in a diminution of the utility of the DNS generally as
a meaningful alternative to less memorable number strings (IP addresses)
and will pose an increasing problem for trade mark owners in policing
unauthorised use of marks in domain names and consequent infringement or
dilution of established trade mark rights.
There is a case for controlled expansion of the DNS to allow for
properly qualified, and industry specific gTLDs where these can
facilitate identification of businesses and improve usability. There is
also a case for an alternative "shared" gTLD (see below for further
discussion) as an option for resolving the first issue (equitable rights
to use real-world names in cyberspace) identified in the preamble above.
BT believes that an expansion of the DNS by adding the seven new gTLDs
as currently specified by the IAHC, with allocation continuing to be
made by a simplistic FCFS process is inappropriate. The likelihood
is that such expansion will only replicate and multiply the problems
already experienced with existing gTLDs. They are not adequately
structured to allow different businesses with legitimate rights to the
same name to have equitable access without risk of conflict or
confusion. This lack of distinguishing structure and the FCFS
allocation system will mean that, if they can, businesses will be
obliged to try to register their key marks in each new gTLD in order to
strengthen their association with those marks and to exclude others as
far as possible. The addition of new gTLDs has been discussed by BT
with representatives of other major trade mark owners, the UK Trade Mark
Registry, the European Commission, European ISO3166 country code
registrars (e.g. Nominet UK) and others - the overwhelming weight of
considered opinion is against the addition of any more general gTLDs at
this stage. Whilst, as the International Trade Mark Association and
others have observed, the addition of only seven new gTLDs is
potentially less prejudicial than the 150 or more that have been
advocated by some from the "internet community", we firmly believe that
NONE should be added for now.
Accordingly, BT recommends this aspect of the IAHC plan should be
thoroughly reconsidered and that no new gTLDs should be added at least
until the IAHC plan has been proven to work with the existing gTLDs
(.com, .org and .net). Obviously, this implies that steps must be taken
to ensure that NSI's monopoly control over these gTLDs is transferred to
iPOC on expiry of NSI's present contract with NSF in March 1998.
From a business and operational perspective, stability and consistency
in the administration of the DNS are highly desirable. The DNS must be
managed to allow universal access to any valid address. Fragmentation
of the DNS and conflicting alternative systems must be avoided. This is
particularly important in the case of gTLDs. BT supports the IAHC call
for all gTLDs to be administered according to the same principles as
specified in the gTLD-MoU. Ultimately, it would also be desirable to
encourage ISO3166 National Registries to operate according to the same
principles and with consistent procedures. However, this is clearly
likely to be a longer-term objective, which might require the internet
equivalent of the WIPO Trade Mark Law treaty to establish!
>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.
BT strongly supports the implementation of private-sector led
self-regulatory mechanisms for DNS management, with governmental input
where relevant. To this end, the IAHC/iPOC initiative is a commendable
precedent. However, BT considers (and we believe the iPOC itself
recognises) that the appropriate balance of the various stakeholders who
need to be involved in the process is yet to be established. At the
moment, BT's impression is that the process is still substantially being
"technically driven" rather than genuinely "market led" (i.e. those with
technical expertise and those internet-specific businesses with a
specialist technical interest are pushing for more gTLDs, for example,
while the wider business community is unconvinced that they are needed
or that they will resolve the perceived problems with the existing
system.) In these circumstances, BT would suggest that the balance of
representation on iPOC (or any successor private sector management body)
should evolve to have greater mainstream business and ordinary
(non-technical) consumer/user representation and the weight of
representation from the technical side should be reduced. Thus
additional representatives might be drawn from groups like the
International Chamber of Commerce or other business organisations
world-wide as well as from mainstream consumer organisations.
>c. These self-governance mechanisms should recognize the
>inherently global nature of the Internet and be able to evolve
>as necessary over time.
This is an essential. The internet has grown from its original US roots
into a truly international medium. It would be inappropriate and
counterproductive now for any national government or any self-governing
body to treat it as a parochial asset (although ISO3166 national
registries obviously remain free to establish national rules for domain
names under their respective national country codes). More
specifically, it is desirable that the DNS should become more flexible
and less anglo-centric, so that other non-English/American character
sets, for example can validly be used. This is an important issue for
members of the European Union where there are many languages in use
other than English!
>d. The overall framework for accommodating competition should
>be open, robust, efficient, and fair.
Again, BT completely supports these principles. And we reiterate that
the "fairness" must extend to enabling equitable access to domain names
for all with demonstrable rights (not just the most "internet aware" who
happen to be fastest to register under existing systems). However great
are the claims for the growth of the internet, there are more potential
users still to connect (who will legitimately want representative domain
names in due course) than there are connected now.
>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.
As indicated above, BT considers this to be a major issue. It is much
to be preferred that a policy framework should enable and promote
settlement of any conflicts and elimination of disputes BEFORE names are
registered and allowed to go live. It is unsatisfactory and
commercially prejudicial both for domain name registrants and trade
mark owners to have disputes arise after use of a domain name has taken
place for any length of time.
To this end, the IAHC proposal to establish Administrative Challenge
Panels (ACP) for fast track administrative review of challenges together
with options for pre-registration publication and for post-registration
suspension during adjudication of a challenge is a positive step. The
IAHC proposals to require substantive details from a potential
registrant (as would be required from a trade mark applicant) and
submission to a defined jurisdiction are also welcome.
However, the iPOC's present plan to open its proposed new gTLDs to a
free-for-all on day one with no provision for provisional applications
before that is a recipe for provoking conflicts and for encouraging
rip-offs. It may evoke fond memories of the Oklahoma land rush as the
internet-aware scramble to stake their claims, but now just as then,
there will be other groups who consider they would have prior claims to
the "land" (or names in this case) which should not be pre-empted by
such a manifestly crude system of allocation. If the internet is to
evolve seriously as a mainstream business tool then it needs a more
mature approach to administration in a civilised and orderly fashion,
not according to some rough traditions of frontier law dating from the
nineteenth century.
When a new trade mark law is introduced these days (such as the
Community Trade Mark) it is common practice to accept applications prior
to the start date, to accord all such applications the same priority and
to resolve any conflicts equitably. If unqualified new gTLDs are to be
introduced, then BT considers an analogous procedure should apply to
discourage rip-offs and to provide a genuinely equitable opportunity for
all who might have legitimate rights to use any given name.
Similarly, applications for domain names in the new gTLDs could be open
for a reasonable period (say six weeks) before the start of operation of
the new gTLDs. In the event of multiple applications for any given
domain name in the new gTLDs, those domain names would NOT be delegated
immediately, but the claimants would be told to resolve their competing
claims in some mutually acceptable fashion (and subject to some rules to
prevent spurious claims and dilatory behaviour). For example, the
claimants might adopt different names, modified to distinguish the
parties and/or might agree to sharing the primary (contested) domain
name. This would i) reduce the potential for the new CORE Registry to
get involved in disputes; ii) remove the opportunity for FCFS
pre-emptive grabbing of non-exclusive names which simply favours the
net-aware (and the technically adept at flooding the CORE registry with
applications at zero hour); iii) promote resolution of disputes BEFORE
registration; and iv) result in a more equitable allocation of domain
names giving more companies a chance of obtaining at least a share of a
name to which they might have a claim.
>f. A framework should be adopted as quickly as prudent
>consideration of these issues permits.
BT would encourage an early international adoption of a practical
framework for DNS management consistent with the basic principles
expressed in the IAHC gTLD MoU. The only clear deadline which we are
aware of in this respect is the 31 March 1998 expiry of the NSI contract
with the National Science Foundation (NSF). It would obviously be in
the interests of all parties for the future administration of the
existing gTLDs to be specified before then. As we understand it, the
NSF can oblige NSI to hand over the necessary data to enable others to
administer these gTLDs if desired. BT would recommend that NSF should
assert this right and transfer responsibility for administration of the
existing gTLDs to iPOC. NSI's interests as a registrar could be
sufficiently preserved by "grandfathering" NSI as a Registrar under the
gTLD-MoU (provided NSI then agreed to abide by the gTLD-MoU principles).
From: "Gymer, Keith" <GymerK@hlcec1.agw.bt.co.uk>
To: 'NTIA - DNS COMMENTS' <dns@ntia.doc.gov>
Date: 8/14/97 7:55am
Subject: BT Response to US Government RFC - Part 2 - Q1-20
>B. General/Organizational Framework Issues
>1. What are the advantages and disadvantages of current domain
>name registration systems?
ADVANTAGES:
i) IF one is first to register then one gets completely EXCLUSIVE rights
to a domain name even if one would not be able to exert such exclusivity
in the real world. Thus, for example, there is only one apple.com (the
computer company) even though there are several other companies who
could also legitimately use the trade mark "APPLE" in the real world.
ii) A trade mark owner can use NSI's dispute policy to force a
registrant with no demonstrable rights to relinquish a disputed domain
name.
iii) The acquisition of domain names is generally a quick, automated
process which is significantly faster and cheaper than obtaining trade
mark registrations!
DISADVANTAGES
i) If a domain name is already registered to a holder with legitimate
rights then that party has completely EXCLUSIVE rights regardless of
whether any other party might have equivalent rights to use the same
name in the real world (thus what is an advantage for the first to
register is a disadvantage to everyone else who might also have
legitimate real world rights - remember, it's not just FCFS, it's first
come, ONLY served!)
ii) Unscrupulous or covetous trade mark owners can attempt to use NSI's
policy to force legitimate users to relinquish a disputed domain name
(see the PRINCE.COM case).
iii) The existing gTLDs have been over-used by entities which are
parochial and not genuinely international. Thus registrations which
ought more logically to be under national country code domains have been
made in .com, .net and .org as these are seen as more "prestigious".
iv) the original distinction between .com, .org and .net has not been
enforced by NSI and therefore has not been respected by domain name
registrants. Consequently, where a commercial, non-network business
might previously only have had to worry about trade mark infringements
by rogue registrations under .com, now trade mark owners must monitor
and act against registrants in .net and .org as well. This demonstrates
the ineffectiveness of simply adding gTLDs without requiring and
enforcing objective criteria for registration in those domains. Thus
.net was intended to be for organisations with network infrastructure,
but that requirement was not enforced and so the utility of .net as a
separate and distinct name space from .com has been lost. Similarly,
.org was intended for non-commercial organisations, and this distinction
has also been lost because it has not been enforced.
v) The registration details required by registrars like NSI are often
insufficient, although NSI is by no means the worst offender. Most of
the national ISO3166 registries make little or no information available
on domain name registrants. There are numerous instances of false IDs
and email addresses being used to obtain domain names, particularly by
so-called "cybersquatters" or domain name pirates who register
well-known names and then attempt to sell them to the legitimate owners
of rights in those names. The inaccuracy and inadequacy of registrant
information frequently makes it problematic for a legitimate trade mark
owner to track down and take action against an infringer who has
misappropriated a mark in a domain name.
vi) The databases of ISO3166 registered domain names are frequently
unavailable altogether for any checking - i.e. there is no WHOIS
facility at all. (In contrast, NSI provides a rather good WHOIS
service).
vii) Many of the national ISO3166 registries have far too restrictive
policies on who may register what names. Whilst these systems can
almost completely eliminate disputes under the relevant ISO3166 country
code, effectively what happens is that the disputes are transferred
elsewhere (e.g. to .com) as businesses seek to get the names they
originally wanted in a national TLD in one of the gTLDs.
>2. How might current domain name systems be improved?
i) For gTLD administration, adopt the basic principles in the IAHC
gTLD-MoU.
ii) Generally, for all domains, adopt more sophisticated and independent
dispute resolution systems (cf. the ACPs proposed by the IAHC).
iii) Make more use of the national TLDs - national TLDs should be
encouraged to adopt more open registration policies generally (subject
to providing adequate structure under the national country code).
iv) In particular, make .us more attractive for US entities
v) Establish structural requirements for gTLDs and/or other means for
enabling equitable use of real world marks in domain names (cf. Issue 1
in the preamble above).
vi) Add new gTLDs only where these distinguish classes of business and
assist user access and where registration can be subject to objective
tests for qualification (e.g. .air might be established for IATA
airlines with qualification determined by IATA). There is also a strong
case for having a content-specific gTLD (and corresponding SLDs under
nTLDs) such as .xxx or .sex. Sexually explicit services could then be
legally required to operate with domain names in this gTLD (or SLD under
an nTLD) which would make it much simpler and easier to control access
to such sites to protect children for example.
vii) Require sufficient application details (and evidence of
qualification for entry in class-specific gTLDs) from any registrant as
would be required for a trade mark application - the IAHC proposals are
exemplary in this respect. Make registration revocable if the details
are falsified or qualifications shown not to exist.
viii) Reintroduce and enforce the original intended qualifications for
registration in .org and .net (this might need to be phased in over a
period to avoid excessive disruption to existing registrants who do not
meet the relevant criteria but who have been allowed to register because
of the absence of enforcement by NSI).
>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?
i) All gTLDs should be administered by a genuinely international body
with representatives of all potential stakeholder interests. The IAHC
proposal provides a practical basis on which to establish such a body,
although, as noted earlier, we do not believe that iPOC as presently
constituted yet represents all relevant stakeholders. Ultimately, we
feel the representation will probably need to give substantially greater
weight to mainstream business and consumer interests if it is to be
genuinely market-led rather than technology-driven.
Obvious constituencies with a representative interest would include:
Technical:
IANA
IETF
CORE/Registrars
Business:
Mainstream business organisations (e.g. ICC) from all the geographic
regions
Consumers:
ISOC (net-aware bias?)
Mainstream consumer organisations from the geographic regions
Legal:
INTA
International Telecomms/Legal
ITU
WIPO
BT particularly supports the involvement of the ITU and WIPO as
absolutely appropriate given the nature of the subject matter and the
issues concerned. Through their membership of these international
bodies, national governments can provide appropriate input and direction
to the initiative to manage gTLDs and allow the internet to develop as a
genuinely global resource with no individual Government exerting a
proprietary claim to the whole. Although some commentators have
criticised the ITU and WIPO actions, BT believes such criticisms are
misguided and that the ITU and WIPO bring absolutely invaluable
experience at the international level in dealing with the communications
and intellectual property issues which affect the DNS. The active
participation of these bodies brings the benefit of real-world expertise
and credibility to the DNS administration. The informal procedures
which were effective in the initial development of the internet are no
longer appropriate given the scale of the network growth. More formal
organisation and processes are required in which WIPO and ITU are well
qualified.
ii) For the ISO3166 nTLDs, it would seem similarly desirable for all
relevant national stakeholders to have appropriate input into the
administrative decisions for registration of domain names under their
national country code. Thus, for example, for .uk one might reasonably
look to Nominet (the .UK Registry) to extend consultation on
administration policy issues to include parties such as (say) the
Confederation of British Industry/ ICC(UK), the Consumers Association,
the Institute of Trade Mark Agents, and the Department of Trade &
Industry.
>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 DNS certainly needs to be as scaleable as the telephone numbering
plan. This suggests that it also needs to be more formally structured
and organised both at first and second and possibly at the third level
of the domain name if the advantage of having meaningful mnemonic names
is to be preserved.
The proper and essential role of international organisations like WIPO
and ITU has been discussed under 3 above. BT believes that at gTLD
level national Governments should channel their advice and
recommendations via such international organisations and should not seek
to exert any individual control (other than where necessary to establish
effective international administration of gTLD namespace - i.e. in the
US case by assuring the NSF requires NSI to pass administration of the
existing gTLDs to iPOC.)
>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 has been suggested (and it would be technically possible) that all
existing gTLD names should be migrated to be under .US (i.e. .com would
become .com.us etc.). However, this would clearly cause major
inconvenience to existing registrants and is probably not a realistic or
necessary option. If more detailed structure is adopted at gTLD level,
then it may be appropriate to stop further registration under existing
gTLDs if replacement gTLDs with more specific registration requirements
were to be introduced. The same applies to .net and .org.
Presently, there are two gTLDs .edu and .mil which are not genuinely
international and are expressly reserved for US entities. Consistent
with this national restriction, it would be desirable to migrate
registrations under these domains to be under .us. As the number of
registrations affected is many less than under .com, this would appear a
reasonable and practical option.
It would certainly be helpful to encourage more use of ISO3166 nTLDs,
particularly by organisations with only a national presence. However,
it would probably be considered unreasonable to make this mandatory
given the widespread commercial appeal of gTLD registrations.
gTLD management issues are separable from ISO3166 nTLD management
issues, as INTA has observed (see INTA Response
http://www.inta.org/rfcidns2.htm ), for historical and political
reasons. IANA has always been prepared to allocate national authorities
independent control over the administration of their own country code
domains. Universal attachment to National sovereignty is likely to
dictate that countries will want to retain that independence. However,
BT considers that it would be highly desirable to work towards
establishing international agreement (perhaps through an "International
Domain Name Administration Treaty" under the auspices of ITU/WIPO)
setting minimum consistent standards as, for example, the Trade Mark
Law Treaty does for Trade Mark Law. The objective would be for nTLDs to
have consistent standards for such matters as name allocation,
application information and dispute policy.
>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?
It would be possible (at least for websites) for internet browser
software to be adapted to enable more structured domain names to be used
to improve usability and help users access the businesses they require.
Already, browsers can assume elements of a uniform resource locator such
as "http://www." and the concluding ".com" so that a user merely typing
in "microsoft" can immediately be taken to Microsoft's website. Thus,
for example, browsers could provide users with pick-lists of countries
(by country code) and type of business (e.g. by using Yellow Pages
classifications) so that a user might select (say) "Airlines" or "Foods"
and by typing "United" be taken to United Airlines or United Foods as
the case may be. Such a facility would vitiate the present perceived
advantage of obtaining the shortest domain name (there can only be one
united.com, but united-airlines.com and united-foods.com would obviously
be more helpful to a user seeking one or the other). Other
technological options utilising shared domain names, for example, could
also be feasible to alleviate the present problems and reduce conflicts.
The roots servers are critical to the operation of the internet as
recent problems experienced by NSI have demonstrated. It is vital that
they are maintained by a trusted authority independent of any individual
registrar, for reasons of operational security and reliability and to
remove the potential for partisan monopoly control as exercised by NSI
at present. In this respect, BT considers the IAHC proposals for CORE
offer a practical and preferable alternative to the present
NSI-controlled system.
>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?
If the DNS is to be properly scaleable to meet future needs then more
radical solutions for the DNS structure are required than the piecemeal
addition of new gTLDs as presently proposed under the gTLD-MoU. BT
believes the introduction of new gTLDs should be postponed for this
reason.
Co-ordination and interoperation of the rootservers should be assured by
placing them under control of an appropriate single authority such as
CORE which is independent of any individual registrar. For political
reasons and possibly to provide greater international resilience, more
rootservers should be established outside the US (where most presently
reside).
>8. How should the transition to any new systems be accomplished?
BT believes that the transition to any new system should be progressive
and deal with acknowledged existing problems first. Specifically,
therefore, considering the administrative systems proposed by the IAHC
offer an improvement over those presently adopted by NSI, BT recommends
the first step should be to transfer administration of the EXISTING
gTLDs (.com, .org, .net) to the iPOC and to assess how this change works
BEFORE proceeding to introduce any further new gTLDs.
In order to achieve this transition, as noted above, it is understood
that the NSF must instruct NSI accordingly. If so, then obviously this
should be done as soon as possible to allow time to plan a smooth
transition which causes the minimum disruption to the continued
operation of the internet.
>9. Are there any other issues that should be addressed in this area?
These issues cannot be considered in isolation, but impact upon and are
affected by other issues, particularly any policy regarding protection
of trade mark rights in relation to 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?
We are not aware of any technical constraints. However, as indicated
above, BT does not believe it would be desirable either for practical or
policy reasons to expand the number of gTLDs in an unconstrained and
unstructured manner. To do so would diminish the basic utility of the
DNS over a numerical system and would significantly increase the risk of
cyber-piracy for trade mark owners.
>11. Should additional gTLDs be created?
At this stage, NO! See the reasons already given above. Simply adding
new gTLDs without qualification is not an effective solution to the
long-term scaleability which is required. A much more structured system
of industry specific gTLDs (and second level domains under nTLDs) with
strict qualifications for name registration in such specific gTLDs is
more likely to provide a usable solution.
>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. As noted in the response to Question 10 above and elsewhere,
scaleability based on the continued use of more memorable names in place
of numerical addresses will require a formal and logical structure to be
introduced if the utility of the DNS is to be preserved. Otherwise,
the unstructured proliferation of gTLDS would have significant
disadvantages particularly in increasing confusion and making it more
difficult for users to find what they want.
>13. Are gTLD management issues separable from questions about ISO country
code domains?
See the relevant answer to Question 5 above.
>14. Are there any other issues that should be addressed in this area?
See the response to Question 9 above.
>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?
Under the IAHC model, the preference is for shared registries and
potentially unlimited numbers of registrars with no registrar having
exclusive control over any one gTLD. As a system which should enable
competition without necessarily requiring the proliferation of new
gTLDs, BT believes it is a desirable model. However, in the longer term
there must be some doubt about the ability for large numbers of
registrars to survive commercially and ultimately one would anticipate
that the number of registrars active in providing registration in all
shared gTLDs may be small. In such circumstances it will be important
to ensure that quality of service and effective competition is still
maintained.
In certain circumstances it may be appropriate for a registrar to have
sole control over a gTLD, but this would probably only be appropriate in
cases where a gTLD has a very limited number of potential registrants
who must meet special criteria (cf. .int). In such cases a registrar
might conceivably be given a specific charter and be subject to
stricter controls on matters of service and charges, for example.
We are told that it is not intended that there should be any technical
limitations on the use of shared registries for any or all gTLDs.
However, we understand that the development of the necessary software is
likely to take longer and be more complicated than originally predicted.
As shared operation on the scale required is reportedly untried, a
cautious approach to its introduction would seem prudent. This would
also suggest that it might not be wise to expose the software to an
uncontrolled flood of applications on day one, but to roll it out
gradually, perhaps starting with .org and proceeding via .net to .com
and then to any new gTLDs if introduced.
Exclusive and non-exclusive gTLDs should be able to co-exist without
problems provided the rootservers are appropriately managed.
>16. Should there be threshold requirements for domain name
>registrars, and what responsibilities should such registrars
>have? Who will determine these and how?
From a competitive perspective, it is obviously desirable that the
barriers to entry are not set unreasonably high. However, we believe
that the IAHC is right to demand a relatively high level of threshold
requirements from new registrars. It is important that customers should
be able to rely on a registrar being adequately resourced to provide a
consistent, reliable service. A high standard of integrity and probity
is also to be demanded to ensure that a registrar does not abuse its
trust, for example, by encouraging misappropriation of trade marks in
domain names. The IAHC thresholds were developed after considerable
analysis of such issues and therefore should provide a reasonable guide
to what standards ought to be applied.
>17. Are there technical limitations on the possible number of domain name
registrars?
Not so far as we are aware.
>18. Are there technical, business and/or policy issues about
>the name space raised by increasing the number of domain name
>registrars?
Yes. To ensure that the integrity and reliability of the DNS is
maintained it is important that Registrars are subject to strict
standards of conduct. It would be very undesirable to find registrars
abusing their privilege. One important requirement established by the
IAHC is that registrars must be established in a jurisdiction which
applies certain minimum standards of protection for intellectual
property rights. This is of especial concern to trade mark owners who
do not want to find rogue registrars promoting "cybersquatting"
(misappropriation of trade marks in domain names) in jurisdictions with
weak trade mark laws.
Under the IAHC model, BT believes that it will be particularly important
that CORE should enforce its rules and act promptly against any rogue
registrar which fails to adhere to its contractual obligations in this
respect. Discipline must be applied to deter abuse of the system.
>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 reason to limit the number of shared gTLDs that a
registrar might choose to operate in. If the choice of gTLDs it wishes
to register in is left to the registrar, then it will be important to
ensure that sufficient registrars do operate in each shared gTLD to
ensure effective competition.
As noted above, it should be exceptional that a private registrar is
accorded exclusive control over a gTLD.
>20. Are there any other issues that should be addressed in this area?
See the response to Question 9 above.
From: "Gymer, Keith" <GymerK@hlcec1.agw.bt.co.uk>
To: 'NTIA - DNS COMMENTS' <dns@ntia.doc.gov>
Date: 8/14/97 7:55am
Subject: BT Response to US Government RFC - Part 3 - Q21-28
>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 trade mark rights need to be respected, whether registered or common
law. Geographic indications will also merit protection to the extent
legal rights are available. However, achieving the appropriate level of
protection is not a straightforward matter.
Trade marks are inherently subject to national rights which are
generally specifically limited by territory and class of business.
Trade marks are not normally unique. Frequently, several different
businesses may each have rights to use the same mark in the same
jurisdiction but for different goods or services. Trade mark rights are
restricted to distinctive signs (words) which are not descriptive of the
relevant goods or services. Thus generic words are not protectable as
trade marks. Neither, in general, are geographic names.
In contrast, under existing gTLD policies: domain names do not need to
include any territorial or business identification; domain names must be
unique, so only one entity may ever have a particular domain name;
descriptive, generic and geographic names may all be registered.
In these circumstances it is easy to see how conflicts of rights can
arise and not so easy to see how the system might be modified to reduce
or avoid such conflicts.
However, as courts in many jurisdictions have already determined,
trademark law most certainly does apply to domain names and trade mark
rights can be infringed and diluted by use or registration of trade
marks in a domain name.
Consequently, the domain name system needs to be adapted to deal with
the problems this raises. As explained in the introductory pre-amble,
there are principally two issues:
1. That the DNS should be structured to allow businesses which have
legitimate rights to use names and marks in the real world without
conflict to be able to use the same names in cyberspace also without
conflict and without discrimination.
2. That trade mark owners are entitled to prevent those who have no
such legitimate rights from misappropriating their names and marks in
domain names.
To deal with the first of these issues the logical solution is to import
relevant features of trade mark law such as territorial and business
restrictions to the extent required. In the case of territorial
limitation, it would seem appropriate to encourage greater use of the
ISO3166 nTLDs. For business distinctions, it might seem logical to
construct a system using distinctions such as SIC (Standard Industrial
Classification) or existing trade mark classes as a basis for industry
specific gTLDs. However, the former is probably too general and the
latter includes many different businesses in each class. A more
flexible and practical classification may come from consolidation of
Yellow Pages categories. Thus one could envisage introducing an
international system of business-specific gTLDs (and SLDs under ISO3166
nTLDs) familiar to users world-wide and based on Yellow Pages! However,
coupled with intelligent browser software the potential exists to use
plain numeric gTLDs, each associated with a particular business, which
the browser would then convert into the appropriate language for users
in different countries. Thus a gTLD code .1234 might be displayed on a
browser as the category for [automobile] businesses in the US, [cars] in
the UK and [voitures] in France.
To enable effective protection of trade mark rights, as noted in the
preamble, the key is the establishment of an open and independent
fast-track dispute resolution procedure. In this respect the ACP model
developed by the IAHC is promising. However, BT is concerned that it
may be too restricted in its application unless any party with
registrations in more than one country is able to make use of it.
>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?
It would be preferable, as we have previously indicated, for potential
conflicts to be resolved before a domain name registration is allocated
or used.
However, in the case of unstructured gTLDs, it is clearly impractical to
undertake comprehensive world-wide checks for any possible conflicts
internationally. Unfortunately, most trade mark registers are not
accessible on-line and the detailed databases which would be needed to
provide a reasonable degree of confidence in any international checking
procedure simply do not exist at present.
In these circumstances, again, the logical path to reduce the potential
for conflicts is to incorporate more effective territorial and business
distinction in the structure of the DNS, and to provide effective
challenge procedures (similar to conventional opposition procedures in
trade mark law) to allow rights holders to challenge domain name
registrations which may conflict with those rights. The IAHC model
provides a good basis for developing an appropriate challenge procedure.
Additionally, it would help to educate users to consider and respect
trade mark rights when selecting a domain name. It is also essential
that any DNS administration should have policies which actively
discourage "cybersquatting" and trade mark piracy. At its simplest
level this must mean that applicants with no demonstrable rights to a
name will not be able to retain that name in the face of a challenge
from a party which does have such rights. This is not to say that the
policy should then automatically re-allocate the disputed name to the
challenger. Indeed, where more than one party may have demonstrable
rights it is always going to be considered inequitable by one or other
for a policy to attempt to choose between parties who each have a
legitimate claim. This is another reason which again suggests there is
a need to consider a more sophisticated allocation policy than
First-come, Only-served or re-allocation to the first challenger. This
issue needs further review. For example, a policy which mandated that
disputed names would not be delegated and which encouraged parties to
select distinctive variants on the name in dispute might be more
appropriate if the DNS is to be able to cope with the anticipated
problems from the increasing scale of demand. Alternatively, a scheme
which had a resolution procedure whereby any parties with legitimate
claims could share a disputed domain name (subject perhaps to payment of
premium fees to discourage mere hangers-on) might also be practical for
new domains. Again we believe more radical solutions to the allocation
of names are required, beyond merely adding new gTLDs, to maintain the
utility of the DNS.
In ISO3166 nTLDs, where it is logically possible to make a presumption
that the jurisdiction of the relevant nation will prevail, it would seem
potentially practicable to have the applicant (or registrar) carry out a
check of registered trade mark rights in that jurisdiction (assuming the
relevant Trade Mark Register is readily accessible electronically). An
applicant would then be on-notice of potentially conflicting rights and
a registry might set its policies to require sufficient distinctive
structure to distinguish names where conflicts might otherwise arise.
So, for example, GUARDIAN Insurance might be distinguished from GUARDIAN
Newspapers in the UK by business class: GUARDIAN.ins.uk
GUARDIAN.news.uk. Again, the principle is to add logical structure to
remove the potential for conflicts.
>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?
As noted above, preferably, disputes should be resolved voluntarily by
the parties. Domain name policies should be structured to facilitate
and encourage this.
National Courts will always provide the definitive judgments in trade
mark conflicts. Administrative DNS procedures should be directed at
minimising the need for recourse to the Courts, but must ultimately
always leave it open for trade mark disputes to be subject to formal
jurisdiction in a Court of applicable law. In this respect, the IAHC
ACP procedures are properly to be seen as "administrative" in that they
are to be restricted to making decisions on whether or not a disputed
domain name should be registered. BT supports the WIPO role in the
administration of such procedures and considers that it is appropriate
in the international context of gTLD administration that a specialist
body such as WIPO should be involved in setting up a dispute resolution
system which is independent of the registrars. This is a far more
acceptable system than that practised by NSI where decisions are made in
secret by the registrar itself.
>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?
As noted in the responses to previous questions, in order to best
prevent trade mark conflicts we believe a more radical revision of the
DNS structure is required in combination with policies which are
directed at encouraging constructive solutions by agreement between
disputants.
Whilst it would obviously be helpful to have additional database
resources (such as, for example, provided by the Directory Corporation's
initiatives at http://www.trademark.org and http://www.dir.org ). It
would also be helpful for all national trade mark offices to make
available their databases in electronic form for convenient access.
However, the flexibility of the DNS means that the DNS could provide a
very effective directory function itself without the need for separate
services simply by incorporation of appropriate structure into domains,
for example, by adapting the Yellow Pages categories as we have
suggested in the answer to Question 21 above. It has been argued that
the existing "internet community" with its anarchic preferences would
not accept the introduction of the more formal structure required to
achieve such solutions. It is submitted that it is of far greater
interest for the majority of users and businesses yet to come onto the
internet that a logical and stable structure should exist to facilitate
commerce and communication and ease of use. The old simplicity may be
attractive but a more sophisticated system is essential as the internet
matures into a global medium for use by all.
>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?
As previously noted, a significant problem with almost all existing
domain name registries is the inadequacy and inaccuracy of information
available on the applicants for and registrants of domain names. This
severely hampers legitimate rights owners when seeking to track down or
investigate infringements, not just of trade marks in domain names but
also of businesses infringing copyright or otherwise acting illicitly
from a site.
Both for gTLDs and ISO3166 nTLDs it is very important that applicants
should be required to give adequate contact details such as would be
required for a trade mark application to enable the holder of a domain
name to be identified and tracked down.
The template produced for this purpose by the IAHC/iPOC (see
http://www.gtld-mou.org/docs/core-mou.htm at Appendix C) is exemplary in
this respect. BT strongly believes all registries should require such
information from domain name applicants and that domain names should be
subject to cancellation if critical details identifying the domain name
owner and his contact details are falsified. This requirement to
provide such information would act to discourage abuses such as
cybersquatting.
Critical details include:
-Identity and contact details for applicant and basis for claim to
requested name
-Country of establishment
-Name and address of agent for service of legal process
-Warranty of bona fide intention to use and identification of purpose
of use
-Warranty that name requested does not infringe third party rights
-Submission to appropriate jurisdiction.
Registrars should be responsible for ensuring all the required
information is provided and registries should not issue domain names if
any critical information is missing. Provision of false information
must carry the potential penalty of cancellation of the domain name.
>26. How would the number of different gTLDs and the number of
>registrars affect the number and cost of resolving trademark
>disputes?
Simply adding additional gTLDs without qualification will inevitably
multiply the problems and expense for trade mark owners in policing and
in pre-emptively registering their marks in each new gTLD. So long as
there is a lack of adequate distinction between the gTLDs, then each new
gTLD will provide a further opportunity for cyber-pirates to
misappropriate valuable trademarks and businesses will consider it
necessary to prevent dilution by registering their important marks in
the new domains as well as the existing ones. In the case of the new
gTLDs presently proposed by IAHC/iPOC, for example, this will inevitably
mean that businesses who might already have THEIRMARK.com will also feel
obliged to try to register THEIRMARK.web, THEIRMARK.info etc. as these
gTLDs do not adequately allow businesses with the same marks to be
distinguished.
>27. Where there are valid, but conflicting trademark rights for
>a single domain name, are there any technological solutions?
As previously noted, we consider that adding more specific structure to
domain names would significantly relieve the potential for conflict over
a single domain name. Combined with technological solutions in the form
of intelligent browser software, as also suggested above, we believe
such changes in policy need not result in users having to remember
longer names, but could still allow selection by a single mark. e.g.
typing "apple" might then take the user to Apple Computers or Apple
Records depending on the business class selected by the user.
>28. Are there any other issues that should be addressed in this area?
See the response to Question 9 above.
###
Number: 270
From: Sonny Ferguson <sonny@netgrp.net>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 8/14/97 5:47pm
Subject: DOMAIN NAME CONFLICT
Please consider that some corporate attorneys are claiming rights to
domain names because of a single word or common name being similar... i.e.
I registered ferguson.com about 21 months ago. Our company was founded in
1953 as William V. Ferguson Company and changed in early 70's to The
Ferguson Company. We have maintain the ferguson.com site since registering
the name.
Several weeks ago, a Washington law firm demanded that we release the
domain to their client Ferguson Enterprises claiming that we infringed on
their trademark [Ferguson Enterprises]. We obviously do not, and do not
intend, to infringe on their trademark.
But in checking, I found multiple domain names registered to Ferguson
Enterprises - NONE of which were active - STRICTLY accumulating names...
fei-inter.com, the-stockmarket.com, plumbsource.com, ferginc.com
Large corporations with large law firms should not be able to threaten
existing domain name strictly as an attempt to force existing domains into
their holdings.
It is interesting that the single court decided dispute is in UK and the
court ruled in favor of the earliest registered site.
I believe that the internic policy that they remove the domain until the
parties settle the dispute only give strength to those disputing legally
registered domain sites and creates an even larger problem.
Thanks for the opportunity to respond to the public comment period.
Sonny Ferguson
President - Ferguson Company
Knoxville, TN
###
Number: 271
From: Wehbe Roger F. <wehberf@pbac.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 1:44pm
Subject: Domain Names
Drop Internic as sole provider.
Let Courts settle out disputes over domain names.
###
Number: 272
From: Shirley MacPherson <smac@followme.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 7:47pm
Subject: Re: Name Space
I don't really understand the problem of name space on the internet.
I want it to remain out of the hands of governments and vested interest
groups. Everyone should have the right to make his/her opinions known.
Because large corporations own the press and TV, ordinary people are no
longer able to express opinions that do not coincide with corporate
thought. We are censored. Stories are deliberately ignored. Important
stories are not broadcast. Internet is the only public forum that
expresses all opinions.
As long as the net follows the same laws on libel and decency as other,
publications, there should be no problem.
--
Yours truly,
Shirley MacPherson
smac@followme.com
###
Number: 273
From: Jon Postel <postel@isi.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 6:45pm
Subject: Domain Name Comments
TO: dns@ntia.doc.gov
Patrice Washington,
Office of Public Affairs,
National Telecommunications and Information Administration (NTIA),
Room 4898,
14th St. and Constitution Ave., NW,
Washington, DC 20230.
( via Electronic Mail)
FROM: postel@isi.edu
Jon Postel
Internet Assigned Numbers Authority
c/o USC - ISI, Suite 1001
4676 Admiralty Way
Marina del Rey, CA 90292-6695
Talk: +1-310-822-1511
Fax: +1-310-823-6714
EMail: IANA@ISI.EDU
Discussion:
Your request for public comments on the domain name system comes in
the context of the Internet community process to evolve the system to
a more open and competitive model. The key committee work in this
process was done by a group called the IAHC.
The IAHC process was as open and as available for public participation
as the organizers and participants knew how to make it. Perhaps there
were important constituencies that were somehow not aware of the
process or slow to realize the significance of the activity.
I believe the IAHC has provided a tremendous public service under
difficult conditions. I am confident that the members of this
committee do not expect to personally gain from the system they have
proposed.
It may be that the IAHC proposal needs to be evolved and expanded to
address the concerns of additional parties, however i do believe that
the work done so far is quite general.
The particulars of the IAHC plan should be flexible, for example, the
exact membership (and member selection procedures) of the Policy
Oversight Committee (POC) may need to be revised, and the exact
choices (and number) of the new gTLDs may need to be revisited.
I firmly believe that moving forward with the IHAC plan (in the
general sense) is in the best interest of the Internet community,
including the users, business, and the technical operation of the
system.
Comments on the questions:
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?
These principles are good. The role of government should be to foster
a fair system of self governance for the Internet that embraces open
competition where possible on a international scale.
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.
Good. Note that competition should be based on price and service and
not on who has the "best" gTLD. Competition should involved not only
the original choice of registrar, but also the continuing use of a
registrar; thus, names must be portable.
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.
Good. And should be based on careful evolution from the existing
mechanisms, practices, and procedures. Continued stable operation for
the existing users is critical. Evolution not revolution.
c. These self-governance mechanisms should recognize the
inherently global nature of the Internet and be able to evolve
as necessary over time.
Good. The international nature of the Internet is very important to
keep in mind.
d. The overall framework for accommodating competition should
be open, robust, efficient, and fair.
Good.
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.
Good. Of course it would help if the system of recognizing
proprietary rights on an international basis were more coherent.
f. A framework should be adopted as quickly as prudent
consideration of these issues permits.
Good. Rapid action is need to eliminate the current temporary
unusual situation of a monopoly operation.
B. General/Organizational Framework Issues
1. What are the advantages and disadvantages of current domain
name registration systems?
The current system is fairly simple to use and provides fast service
entirely through electronic communications (in the vast majority of
cases). The big disadvantage is that there is a single company in a
dominant role (in essence a monopoly), such that there is no market
driven check on service quality or price competition.
2. How might current domain name systems be improved?
By adding a competitive element to the business of registration.
There should be multiple companies in the business of handling
customer requests for registration. These companies should all have
access to the full set of gTLDs, so that the competition is based on
service performance and price, rather than any "ownership" of the more
desirable gTLD.
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 current management by the IANA should be evolved so that the IANA
is a free standing independent entity funded by the community,
particularly those other entities that use its services. This free
standing IANA should be an institution in the sense that in is managed
by a committee or board with procedures for refreshing the membership
of the board as needed and with the responsibility of selecting the
executive an staff to perform the IANA task. Thus this future IANA
should not depend on any particular individuals.
It is possible that an intermediate step would be to change the IANA
from its current position as a task at a research institute at a
university to a separate corporate entity managed by the university
with a council of advisors drawn for key Internet constituencies.
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 are two distinct ideas here: the domain names, and the Internet
addresses (32-bit numbers).
The domain names are a structured set of names but not limited in
principle. These are not a scarce resource.
The Internet addresses (32-bit numbers) are by definition a limited
and increasingly scarce resource. The management of these addresses
in somewhat similar to the allocation of telephone area codes or radio
frequency spectrum.
These are both international in scope and generally speaking (except
for the country code TLDs) not generally amenable to management at
the national level. Procedures that work on the international scale
are required.
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 completely impractical to have names that are in wide spread use
stop working. The existing gTLDs must continue in service, to do
otherwise would have great impact on the existing users of the
Internet and seriously impact the stability of the Internet as view by
the business community.
The gTLD management issues can be separated from the management of the
country code domains. Of course, any good ideas, procedures, or
practices should be shared both ways, but they can be treated as
different classes of TLDs and can develop in different ways.
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 problem is not technical in nature but rather a social, political,
business issue. The solution is to change the business model to
provide competition. There are no technical roadblocks to
accomplishing this.
There is one technical aspect that needs to be tested - the operation
of a central database to be shared among the multiple companies
providing registration services. This is not a new concept but it
should be proven out before existing service are required to convert
to this model.
There are no technical problem with the relationship of the root
servers and the gTLD servers. Additional gTLD servers can be
introduced with no changes to the existing software.
The operation of the root servers must be separated from the operation
of the gTLD servers. This means the management control should be
separated to eliminate any real or perceived conflict of interest, and
the set of actual machines should be separated for robustness of
operation.
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 scalability of the DNS depends on structure. The more structure -
that is hierarchy - that can be used in the system the more it can
scale. My opinion is that there should be at most about 200 gTLDs
(and there are about 200 country code domains). Thus the root servers
would handle about 400 TLDs total. This is quite reasonable
technically.
The address space (that is the IP 32-bit numeric addresses) must be
allocated in a very conservative manner since it is a fixed resource.
The best scaling (for routing) is to use CIDR blocks effectively.
8. How should the transition to any new systems be
accomplished?
Carefully. Some new gTLDS should be created and some new companies
should start registering users with names in these new gTLDs using a
shared database. This new system should begin operation as soon as
possible to provide a period of proven service before the end of the
current agreement with Network Solutions. Once the new model of
operation is proven successful, then the existing gTLDs should be
added to the shared database and all the registration companies should
be able to register customers under any of the gTLDs (new and old).
NSI certainly is welcome to participate in both phases of this plan.
9. Are there any other issues that should be addressed in this
area?
Not at this time.
C. Creation of New gTLDs
New gTLDs should be created, initially a limited number (say 20) and a
few (say 5) added each year until the total reaches about 200.
10. Are there technical, practical, and/or policy
considerations that constrain the total number of different
gTLDs that can be created?
There are no technical issues that limit the number of gTLDs to less
than a million. There may be practical and policy reasons to strongly
limit the number of gTLDs to provide stability and minimize user confusion.
11. Should additional gTLDs be created?
Yes, to provide diversity, and access to simple domain names by the
holders of not-so-strong trademarks.
12. Are there technical, business, and/or policy issues about
guaranteeing the scalability of the name space associated with
increasing the number of gTLDs?
There are no technical problems with increasing the number of gTLDs,
the scalability of the DNS system in technical terms is not an issue.
There may be good business and policy reasons to limit the number of
gTLDs and the number of new gTLDs introduced per year. One of the key
concerns is stability of the system. It may be difficult for
businesses and end users of the Internet to cope with an explosion in
the number of gTLDs.
13. Are gTLD management issues separable from questions about
ISO country code domains?
Yes. There need be no technical or policy connection between the ways
in which these are managed. A country code domain may be managed
in was that are responsive to the culture of the country and this may
vary substantially from country to country. Of course, good ideas
about procedures and technology to provide robust and reliable service
should be shared between the gTLDs and the country code domains.
14. Are there any other issues that should be addressed in
this area?
Not at this time.
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 key issue is portability. If the customer has registers a domain
name with one registration service and subsequently decides that he
would rather use a different registration service (for whatever
reason, for example, billing problems, service choices) the customer
wants to keep the same domain name. This can be done under the IAHC
shared registries model. It can not be done if a registrar has
exclusive control over a particular gTLD. Technical there could be
some d exclusive gTLDs and some non-exclusive gTLDs simultaneously.
However, i can not see any social, political, or business reason to
have such a situation except during a brief transition period, and it
could be very confusing to the customers.
16. Should there be threshold requirements for domain name
registrars, and what responsibilities should such registrars
have? Who will determine these and how?
There should be some minimum business and technical requirements to
enter the registration service business. This should be determined by
a reasonably representative body with business and technical
experience. The applications should be evaluated against the criteria
by an independent third party such as an auditing company.
17. Are there technical limitations on the possible number of
domain name registrars?
There may ultimately be technical limitation of the access to the
shared database, but this type of technology limit changes as the
underlying technology improves. There are not likely to be any
practical limits with this.
18. Are there technical, business and/or policy issues about
the name space raised by increasing the number of domain name
registrars?
There are no technical problems to increasing the number of 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
The trademark situation is very complicated with respect to domain
names since the trademark situation itself is very complicated. The
basic facts are that trademarks are not unique, and that domain names
must be unique. The reason there is so much trouble about using
trademarks in domain names is that the trademark system is a mess.
Trademarks are not unique: There is no place to register a universal
world wide trademark. There are no globally unique trademarks. There
are "strong" trademarks, these are trademarks that companies that own
them defend very vigorously in all venues and for all usages (example:
"Coca-Cola").
However, there are many more not-so-strong trademarks that are used in
one or only a few counties (or within the United States in one or only
a few states), or used in a particular industry sector (such as
hardware or food). For example, ACME might be the trademark of a
hardware company, and at the same time be the trademark of a coffee
producer. This is allowed because the consumer is unlikely to confuse
the ACME hammers and saws with a beverage. However, there can only be
one ACME.COM since domain names must be unique. If the hardware
company registers ACME.COM first then the coffee company can't have
that name and may feel it has been prevented from using its properly
trademarked name as its Internet identity.
Introducing more generic top level domains may allow more of the
companies with not-so-strong trademarks to have access to using their
"obvious" name as a domain name under one generic top level domain or
another. There are many more small companies with not-so-strong
trademarks than there are big companies with strong trademarks.
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 up to the trademark lawyers and the courts to decide.
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?
And how long should it take? The domain name registration process has
been designed so that it could be completely automated and in
principle be completed in minutes. How much of the "preliminary
review", and "determination of conflicts" can be done in a few
minutes?
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?
This looks like a role for the World Intellectual Property
Organization (WIPO).
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?
If there were a single agreed on list of unique trademarks
and their owners, such checking could be easily performed by an
automated process. So far, no such list exists, it is the
responsibility of the trademark world (not the Internet) to create
such a list. The closest approach to such a list is managed by the
World Intellectual Property Organization (WIPO) under an agreement
called the "Madrid Convention". However, to date several economically
important countries (including the United States and Japan) have not
signed this agreement.
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?
How would such a process be automated? How would cheating be detected?
26. How would the number of different gTLDs and the number of
registrars affect the number and cost of resolving trademark
disputes?
It depends on how it is handled. If there is a common dispute
resolution procedure and organization, the number of registrars should
not have any significant impact on the cost of resolving disputes. If
there is a common list of strong trademarks that are not to be
registers except by their owners then even the number of gTLDs should
not be a significant factor in the cost of resolving disputes.
27. Where there are valid, but conflicting trademark rights
for a single domain name, are there any technological
solutions?
No. Two different people can't use the same domain name.
28. Are there any other issues that should be addressed in
this area?
The key is to sort out and rationalize international trademark law,
which is not an easy or short term task, however, these problems will
not go away until it is done.
If the holders of strong trademarks want to have an easy way to
protect the use of their marks in the context of domain names they
need to give the domain name technologist the necessary information.
This necessary information is a list of the strong marks to be
protected world wide. It is up to the trademark users to establish
this list.
---------------------------------------------------------------------
###
Number: 274
From: "Goldstein, Mitchell P." <mpgoldst@mwbb.com>
To: 'Commerce' <dns@ntia.doc.gov>
Date: 8/14/97 6:37pm
Subject: Comments on Internet Domain Names
Hope this helps.
QUESTIONS/ANSWERS
B. General/Organizational Framework Issues
1. What are the advantages and disadvantages of current domain name
registration systems?
Advantages:
single registry easier to administer
avoids conflicting domain names
allows for networks to interconnect with a uniform system
Disadvantages:
less competition means no reason to innovate
more expensive than it needs to be
2. How might current domain name systems be improved?
more organizations requesting domain names under a uniform
system administered
by an international, non-governmental organization
more competition will yield faster registration and more
innovation
agreements and treaties will insure that the system still allows
users to connect to
any system and any site
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?
A nongovernmental organization (NGO) which includes all interests -
government,
research, corporate, family, educational, etc. - should adminster the
domain name
registration system. It should be made up of representatives from
various organizations
(e.g., the UN, educational institutions, industry). It should not
have any official
government representatives on it so that it does not become a
political entity.
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?
It should be administed on a first come, first served basis. An NGO
can ensure that
Internet remains private and still efficient. Governments will only
make it political and
then political and national fights will spill onto the Web.
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?
Generic top level domains should be expanded
.com
.fam (for family and personal domain names)
.mil
.gov
.edu
.org
.net (for networks like Internet service providers and registries)
The .com gTLD should further be expanded by industry:
.tec - technology
.man - manufacturing
.fin - finance
.con - consumer related
.med - health care
.ind - industrial
.bus - business services
.tel - telecommunications
The result would be (domain name).(industry).com
Countries should use mandatory geographic codes or .int
(international - reserved for
organization. like multinational corporations and international
organizations).
.int will be more expensive because it will block out all similar
domain names with only
country code (e.g., McDonalds.com.int would block out
McDonalds.com.us)
8. How should the transition to any new systems be accomplished?
give domain name owners one year to switch to new system.
during that year, the old name and the new expanded domain name
will work
after that year, the old name will no longer exist
C. Creation of New gTLDs
11. Should additional gTLDs be created?
See #5.
13. Are gTLD management issues separable from questions about ISO country
code domains?
Mandatory country codes will expand the availability of domain name
worldwide.
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?
All registrars should have Joint control over gTLDs. If a domain
name is available, any
registry should be able to register it.
16. Should there be threshold requirements for domain name registrars,
and what
responsibilities should such registrars have? Who will determine
these and how?
Domain name registrars would be required to maintain a database that
all can access to
determine domain name availability and maintain interconnectivity.
The requirements will
be determined by NGO through global meetings open to everyone
17. Are there technical limitations on the possible number of domain name
registrars?
The number will be limited by what the market can bear.
18. Are there technical, business and/or policy issues about the name
space raised by
increasing the number of domain name registrars?
Limitations - mil. gov. will be reserved
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?
Common law and registered trademarks and trade names should be
protected on the Net.
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?
Trademark owners should be responsible for seeking redress;
registrars should not make a
determination. Registrars would publish new domain names for a
30-day period before
granting a domain name thereby giving others notice; then they can
decide whether to take
action. Also, any registry must agree to accept jurisdiction of all
national courts (e.g.,
should accept injunctions issued).
Registries are not full of trademark lawyers and experts. They
should leave
determinations up to the current legal system.
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?
National courts should resolve trademark disputes on the Net like
they resolve trademark
disputes in real space. We could add provisions to (or create) an
international treaty.
24. How can conflicts over trademarks best be prevented? What
information resources could
help reduce potential conflicts? If there should be a database, who
should create the
database? How should such a database be used?
There should be a database paid for by all registries and maintained
by an NGO. All
registrars would have to open their registers to the NGO's database
to allow for
preclearance searches and backup their registers on the large
database.
This would involve little or no government interference.
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?
Applicants should not have to prove that they have a basis for
registering name; impedes
freedom and growth of Internet.
26 How would the number of different gTLDs and the number of registrars
affect the number
and cost of resolving trademark disputes?
Increasing the number of gTLDs would increase cost of trademark
disputes and the
number of suits; however the Net will be able to expand.
27. Where there are valid, but conflicting trademark rights for a single
domain name, are there
any technological solutions?
Valid but conflicting trademark rights will be resolved by using
geographic or country
codes. Longer domain names and letting market place handle
conflicting rights will
resolve the problems. Expanded domain name levels should decrease
the problems.
28. Are there any other issues that should be addressed in this area?
The main point to remember is to have as little government
involvement as possible and
little opportuniry for a large company or a small company to hold up
development of Web
sites through frivolous actions.
Mitchell P. Goldstein
Staff Attorney
CC: "Goldstein, Mitchell P." <mpgoldst@mwbb.com>
###
Number: 275
From: "mare@hrc.wmin.ac.uk" <Mare.Tralla@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 12:38pm
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 Mare Tralla 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 14, 1997 12:36:25 EDT
Mare Tralla
31 Jackman House
Watts Street
Wapping
London E1 9PU
###
Number: 276
From: "incontinence@hotmail.com" <Leann.Wieand@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 3:44pm
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 Leann Wieand 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 14, 1997 15:42:42 EDT
Leann Wieand
###
Number: 277
From: "mylikoski@hotmail.com" <Maria.Ylikoski@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 9:22am
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 Maria Ylikoski 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 14, 1997 09:13:37 EDT
Maria Ylikoski
###
Number: 278
From: bob@ct1.nai.net <Matt Anderson@zero.tolerance.org>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/14/97 12:07am
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 Matt Anderson 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 14, 1997 00:05:46 EDT
Matt Anderson
###
Number: 279
From: steve <usdh@mail.ccnet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 7:50pm
Subject: BRIEF: DNS, Language, and the Constitution, by Dr. S.J. Page
Before the
National Telecommunications and Information Administration
In Re: Constitutional, Economic, and Social Relevance of a )
Scalable, Open Free Market Approach to Implementing )
Internet's Domain Name System (DNS) )
for Maximum Value to Present and Future Internet Users )
Brief of Stephen J. Page
1. This brief is submitted for information purposes to accompany actionable
matters before the U.S. Department of Commerce' National Telecommunications
and Information Administration (NTIA), which is evaluating the impact of
changing the Domain Name System (DNS) of the Internet from a controlled
monopoly to other forms of governance. The purpose is to further the
momentum behind the movement to let the market decide what is useful,
therefore valued when pertaining to Domain Name System (DNS) Top Level
Domains (TLDs).
2. This brief indirectly relates to and any or all of the following
agencies: U.S. Department of State, Federal Communications Commission,
Register of Copyrights, and the U.S. Patent and Trademark Office, where the
agencies individually or collectively are being requested to bar the IAHC's
gTLD-MOU instrument from becoming a self-enacting international
intergovernmental agreement by virtue of its submission to and circulation
by the International Telecommunication Union.
3. Qualifications of the Petitioner. He possesses Bachelor of Science
degrees in Combined Sciences (physical, biological, and social sciences),
and Physiological Optics (the study of how human beings' brains process
light energy), Doctorate in Optometry, and a Masters degree in Business
Administration. He was a Distinguished Military Graduate and George C.
Marshall (citizen/soldier) Award Winner prior to serving as a Commissioned
Officer in the Regular Army of the United States. He served as Assistant
Chief, Optometry Section, Landstuhl Army Medical Center, Landstuhl,
Germany. In 1992 he submitted a Proposal for an Intelligent Health
Delivery System to the National Institutes of Standards and Technology
Advanced Technology Program. In 1993 he submitted a Proposal for Network
Architecture to the Department of Defense' Advanced Research Projects
Agency, (DARPA), which was funded at the time of funding project for
initial commercialization of the Internet, CommerceNet. (referenced below).
His specific focus has been on network architecture and design of
telecommunications data networks, with an emphasis on the role of human
(biological) network architectures and their resulting impacts on the
future of telecommunications and economics, the subject of electronic
commerce. Below, he includes elements of a Scientific Proof in Support of
the Constitution of the United States and the Bill of Rights to support the
concepts of an open, free market for Domain Name Services (DNS) which will,
in turn, flexibly support various economic models for the emerging
electronic commercial Internet activity.
I. The Constitution of the United States is the fundamental document which
places protecting the inalienable rights of individuals as the highest
value which its governing bodies can achieve.
4. Historically, benevolent governmental institutions have been
developed which place at the center of their existence, a recognition of
certain inalienable rights of individuals. Fundamentally, the right to
pursue happiness is one such right, that is recognized to be "above all
meddling" by any governmental structure created by mankind. Another such
right is the right to congregate freely. Another such right is the right
to inform others, or freedom of the press. The most important right, upon
which happiness is based, is the fundamental right to speak freely. It is
these principles of rights and freedoms which form the core of the
Constitution of the United States, through the formal Bill of Rights, as
well as the core of most other benevolent, democratic governments in the
world.
5. The essence of these governments is the focus on the protection of
individual rights. Without understanding the cognitive science or
knowledge of biological networks, the Framers of the Constitution
understood the essence of human beings is their desire to be free and to
puruse happiness. As creatures with an physical energy-core, freedom means
being free to exchange energy with others. This energy exchange can take
many forms, emotional energy (anger, fear...), sexual energy (kissing,
intercourse...), physical energy (heat, movement...), intellectual energy,
(ideas, thoughts, and language...). The framers recognized that there was
no place for government meddling in the personal affairs and exchange of
energy between individuals, especially when it related to language, a
freedom formally protected under the First Amendment.
5. With respect to the Internet, the absence of an easy method for
locating others, built upon the structured use of language as a program for
organizing information, has been the primary impediment to the development
of an electronic transaction-based economy. Presently, Internet
information is popularly exchanged via the World Wide Web using a
visually-oriented browser, typically organized in a uni-directional manner
where the user 'pulls' the information toward them by 'clicking' on icons
which represent information organized at a particular 'site' called a 'web
page'.
II. DNS is Structured Like a Tree Root (with unlimited ability to extend
from the central root into smaller and smaller branches, over time.)
6. Today's DNS problem is fundamentally due to the absence of a
scalable, common vocabulary (or lexicon of meaningful words) which can be
useful to persons who choose to exchange energy electronically with others
across the free and open commercial Internet medium. Since the DNS was a
contolled and monopolized service for many years, this was not a problem
then. However, as the Internet has gained commercial value, its control or
governance is an issue.
7. Without a rich and meaningful grouping of words with which people
can organize their internal energy, and interact with others who may want
to organize themselves in a manner where seekers can find them, topically,
categorically, or by activity, significant commerce will not happen. So,
without the programming 'tools' to make 'electronic' commerce happen, which
allow individuals to organize themselves, the promise of electronic
commerce remains unfulfilled.
8. Contrast the situation of an individual who owns a rich vocabulary
which organizes how he/she thinks, acts, and interacts (exchanges energy)
with a situation where a new broadly applicable medium (Internet) is
created with a very narrow purpose (defense-contractor-government
communications) for exchanging energy electronically. This Internet
(called DARPANET) is organized structurally around an unlimited,
multi-level naming system (analogous to the structure of language), but
limited in vocabulary (lexicon) to seven abbreviated words (COM, ORG, NET,
GOV, MIL, INT, ARPA). Such a limited implementation of a vocabulary
applied to this limitless language program, has been a bottleneck to the
mass adoption of this new medium by people worldwide, and therefore a
bottleneck to Internet Commerce.
9. Commerce functions because meaning is exchanged when individuals
speak using the same language program, and have the same general vocabulary
(word lexicon). Without language, there is a bottleneck to commercial
communications, especially when viewed from the medium of the Internet,
where facial expressions and body language are not viewable. If commercial
communications cannot occur, commercial transactions cannot occur.
10. The shift in the Internet's defense-focus to commercial focus
occurred in 1993/94, and paradoxically where the present struggle to define
and control useful language in the Internet-medium began. Although the
technology for enabling commerce has been rapidly evolving, an
understanding of the importance of a subsequent shift from a limited
vocabulary to an "open vocabulary" has not been achieved by the
historically technically-focused leadership of the "Internet community".
III. Language is, like DNS, Structured Like a Tree Root, with the Alphabet
at the Root.
11. The Root elements of language are sounds and symbols (letters).
Both elements are the building blocks of language. As visual
representations of language, letters form the root elements or common
denominator of any text-based electronic communications which are
transmitted across Internet. As the building blocks, they are simpler in
form and structure than any other language element, and more flexible than
any other language element.
12. Principles of Language Ownership
1) Language is owned by the individual speaker(s), and is protected in law
2) The right to create language exists with the individual, and is
protected in law
3) The right to decide how to use language resides with the individual, and
is protected in law
4) Language is not a public resource, it is a private energy channel, whose
expressed output (words and ideas), chosen or created by the
creator/sender/speaker, can be used in either a generic (free) form, or in
an ownable form. The right to create either form should be protected and
safeguarded by law, as it is in Nature.
13. This issue of Domain Names is a "use-of-language" issue, and
therefore an individual rights issue, and as such, related Constitutionally
to the U.S. Government which stimulated the development of this medium of
communications, for the benefit of individual users assigned to the Defense
Department, commissioned to Protect and Defend the Constitution.
14. Therefore, the present move, to stimulate the creation of an
intergovernmental organization to control the allocation of vocabulary,
ensuring only a limited use of by individuals, suddenly required to be
subservient to this body, is Unconstitutional, and furthermore, it will
unnecessarily impede the development of user acceptance of commercial
activity on the 'net, and therefore damage the opportunity for return on
investment by those individuals who have invested in preparation for the
acceptance of electronic commerce by individual users.
15. The key question in the Domain Name issue is, "Who owns language?"
The answer is fundamental and simple, "The two individuals who agree to
exchange energy via speaking, own it." The U.S. Constitution has been
created to protect individual rights, not only to be free, but to ownership
of the products of their use of language. Free individuals are not
required to ask permission from an intergovernmental body to speak, nor
should they be required. History is full of examples of unelected,
unrepresentative, authoritarian (top-down control) regimes which have
attempted to impose controls upon people, and those controls have included
attempts to control the use of language by indigenous people. However,
all have basically failed in their attempt to control language because the
ownership lies at the speaker level.
16. The historical study of language bears the truth of individual
ownership of language, and this explains why languages evolve over time.
New individuals, with new experiences, will add elements to existing words
which become roots for other words over time. If we go back in time, the
evolution of human language resembles the roots of a tree. So, it is no
accident that the Domain Name system is designed in a manner which
resembles the roots of a tree, either. In fact, the computer backbone of
the Domain Name System is a set of computers called "Root Servers" whose
purpose is to enable the energy to flow from one user to another user in a
manner which supports the user control of language. The useful language
at the Root Servers are the Top Level Domains (TLDs), which can be viewed
historically, as the modern equivalent of the ancient Root Words of the
future language family of a globally reaching, electronically-enabled
socio-economic system.
17. Language is as alive as the people who use it, regardless of the
medium in which they choose. When the people who speak a language die,
new people are born who add new elements, keeping it dynamic and alive,
ever-changing. This has occurred since the beginning of mankind's
recognition of the value of sounds and symbols. One very recent example
can vividly provide a case study to support these truths.
18. One year ago, the word 'ebonics' did not exist. Focusing on the
process of creation, it was created by one person, unknown to me, who
recognized the need to describe a simple term for the style of speech which
inner city African Americans have used at times when speaking. That person
combined the root word 'ebony', (meaning 'shade of brown') with the suffix
of the word 'phonics' (meaning 'sounds'), mathematically into: eb- +
-onics = ebonics.
19. In this example, the owner of the unique idea chose to express the
term generically, enabling free and open use by anyone who wants to use the
word, thereby giving up the right to ownership of the word. However, the
owner could have chosen to express the ownership of the term by applying
copyright or by using the term exclusively for private benefit in commerce,
by applying for registration. The key issue here is that the ownership
rights to use, and decide, reside with the speaker or creator of the
language. To summarize, there appear to be some clear truths recognized in
Law (although I am not a lawyer),
20. Language represents a 'handshake' forming a bi-directional energy
channel which can exists between any two human beings. As the basis for
communication of energy across this channel, language serves as the product
of an implicit agreement between communicators. When applied to a
bi-directional electronic energy channel like the Internet, the principles
which apply to language above, can be applied to a limited subset of
language applicable to this commercially useful medium.
21. The IAHC, structured as a "top-down" organization, with its
gTLD-MoU instrument, is attempting to gain control of globally applicable
Internet "vocabulary", under the false pretense of international consensus
among intergovernmental bodies. The IANA, historically and legitimately
controlling names and number allocation during the early evolution, is no
longer able to maintain its monopoly, if the Internet is to achieve full
commercial relevance and value. As I have attempted to demonstrate, each
individual owns creative rights to language. Therefore, language can be
viewed as an energy channel owned by each speaker in a cooperative
structure. As owners, we might choose to lawfully exercise our right to
own what we create by protecting the creations using Copyright or Service
Mark/Trademark law.
22. Under the IAHC scheme, the rights of individuals to use language
freely for their own purposes are not recognized, nor are they respected.
Similarly, under IANA, there is no mechanism for expanding DNS top level
domain name usage. By IAHC seeking to control the allocation of
vocabulary, and IANA and InterNIC (Network Solutions) controlling the
allocation of TLDs into the "root servers" both organizations attempt to
monopolize all future language-related activity for this medium. The IAHC,
and to a lesser degree, the IANA/InterNIC has positioned themselves and
their supporters as mandatory editors of human activity, in a style which
is reminiscent of authoritarian regimes from the past.
23. The proposed IAHC solution (the gTLD-MOU) is clearly not aligned
with any laws which exist in nature, or support self-organizing,
democratically created, self-governing bodies, despite the rhetoric from
its supporters. The existing InterNIC exclusion of alternative TLDs from
its root servers is contrary to the stated position of U.S. leadership
which supports free market economic activity.
24. The present monopolization and control of language by Network
Solutions in its management of the InterNIC function, does not serve the
individual user, who values choices and competition in commerce.
IV. Scientific Knowledge Supports What the Framers Instinctively Knew: That
Individual Freedoms and Rights to Use and Own God's Gifts, Further the
Pursuit of Happiness.
25. All people interact with physical electromagnetic frequency energy
by absorbing it (photons, heat, etc.), by storing it (calories, heat,
photons, etc.), and by producing it for our personal benefit and ultimate
survival (heat, photochemical processes, electrochemical processes,
biochemical processes...)
26. As energy life-forms, we obey the laws of physics, internally and
externally because we exist in a universe governed by these laws.
Therefore, all of our internal and external individual actions,
interactions, and experiences, as well as our collective actions,
interactions, and experiences, are influenced by these laws. As both
individual and collective actors in this energy environment, we, therefore,
can be studied and analyzed scientifically, using the laws of physics and
the tools of mathematics to aid in our understanding.
27. We exist within a framework called a Universal Set of energy which
is expanding in space and time. The Universal Set of energy can flow in
various ways: radiading, broadcasting, channeling, or randomly. There
are a myriad of subsets of the overall energy superset, which we can call
the Universe. The subset of visible energy we can call the outerNET(c),
because it is outer relative to ourselves. The subset of all invisible,
but internalized understandable energy we can call the innerNET(c). In
this same manner, the term Internet (interNET) can achieve its true
potential as a communications 'channel' between individual human beings,
used to help them in their creation and absorption of energy. The ultimate
goal of these activities for each individual is the pursuit of happiness.
V. The process by which subject instruments (gTLD MOU and InterNIC root
server monopoly) was prepared is intended to be executed, and the
associated transfer of existing Federal authority and responsibility are
unlawful.
28. Any proposed structure for determining which names will be used by
millions of Internet users worldwide in the future undermines the
inalienable rights of individuals to choose how they will use their
language...for speaking, for organizing their thoughts, for organizing
their economic activities.
29. As a researcher who recognized the need for a broader perspective
on the Committee, I submitted a proposal on January 17, 1997,
Draft-IAHC-SJPAGE-001, under the Call for Proposals calling for 1)
broadening of IAHC representation to include experts in Cognitive
Perception (language and vision experts), since both language and sensory
capabilities represent THE two most critical skills required by users for
successful interaction and navigation of Internet-accessible equipment.
30. Until that point, I had been an active participant in what had been
said to be an 'inclusive' process of obtaining feedback from the
'community' (bottom up preferences). However, I quickly learned that the
IAHC was not interested in responding to the comments of highly educated,
committed researchers in the field of user-focused network architectures,
which had been the focus of our ARPA grant. All comments were ignored by
IAHC. It was apparent to one with intimate knowledge of user perceptual
processes and visual processes that this Committee was unqualified to
provide the solutions to the two distinct 'problems' which it had set
itself up to solve, 1) oversight of the process of populating the
Internet's Root Name Servers with a language vocabulary which would be
valuable in commerce, and 2) governing the business of registering domain
names. Going hand-in-hand, the IANA/InterNIC supported the process, which
is clearly not Constitutional.
31. Since ignorance of the basic human and scientific issues which
relate to the DNS has been apparent, I've offered to share the efforts of
twenty-one years of education and training, focused squarely on
understanding exactly what both IAHC and IANA have been trying to do, while
doing it with a Constitutional-supporter's perspective. I became an active
participant in the process to replace their solution with a user-focused
solution.
VI. Several Federal agencies have explicit delegated Constitutional
responsibilities to act in this matter.
32. In the Bill of Rights, the right to freedom of speech is evidence
that the Founding Fathers recognized that the owners of language are
individual speakers, and that no governing body has the right to control
it. The result of the MoU of the IAHC would be a situation where an
international reaching, self-appointed, intergovernmental body would
assume the uninvited role as 'managing censor' of language used at the Root
level of commercial activity on the Internet. The thought is repugnant to
anyone who cherishes the inalienable rights of human beings, as protected
in the Constitution of the U.S.
33. As the owners of a system of government created by thoughtful
people, the American people are the custodians of individual rights as they
pertain to the sovereign territory called the United States. As direct
descendants of the Framers of the Constitution who recognized that specific
protections of individual freedoms would be forever necessary if people
were ever to have the opportunity to pursue happiness, the responsibility
for maintaining the torch of liberty rests with us, individually and
collectively.
34. Americans who have had the opportunity to travel the world in
leisure or in defense of the Constitution, expose themselves to forms of
government which do not recognize the rights and freedoms of individuals.
We understand that the U.S., especially the Statue of Liberty, are
worldwide symbols of hope for people whose circumstances leave little for
which to be hopeful. Protecting our freedoms requires constant vigilence.
Powerful forces, directly opposed to individual rights, are constantly
manifesting themselves in different geographic spheres around the world, as
well as within our own borders, because they exist within each individual.
35. When groups of individuals possessing such opposing ambitions hide
them from trusting individuals who might be naive to the danger,
opportunities for either entrenching themselves within organizational
structures or creating new structures should be fought with all resources.
The seeds of destruction of liberties are planted very quietly and sprout
very quickly when backed by powerful forces.
36. As a cancer which begins with one cell, the idea for controlling
language usage in the medium of Internet begins. This idea, masked under
rhetoric of 'inclusiveness' and 'community' and 'competition', when
uncloaked is really about one thing...control of the Root program of
personal thinking and interaction of the individual, language, and its use,
through the control of the Root Server network of vocabulary tables
maintained presumably for the benefit of individual users. If one is able
to control language, one is able to control user activity. If one is able
to control individuals, then it is impossible for the individual to ever
hope to pursue happiness, because true happiness is predicated upon freedom
and liberty.
37. Anything which serves to impede the ability of people to be free to
use language, and pursue happiness, is inconsistent with the intent of the
Constitution of the United States, and should not be permitted to move
forward. Furthermore, the signing of the IAHC's MoU by representatives of
the United States Government or its contractors is an abomination and a
direct insult to the People of the United States, and the people of the
world.
38. Conclusions Pertaining to Domain Name System
1) Domain Name System is a subset of language, and as such be protect under
the laws which protect the rights of individuals to own, create, and use
language freely.
2) Domain Name System should not represent only the 'generic' form of
protected speech, especially if used in an open and inclusive commercial
purposes.
3) No governmental or intergovernmental has the right to supercede the laws
of physics and biology which govern the individual's right to own and
control language.
VII. Pursuing a Balanced Course Which Supports the Principle of
Self-Determination, Openness, and Self-Organization, Makes Sense at this
Point in Time
39. Such a service would seem to be an appropriate consideration for a
free market alternative to the IAHC process, which would serve as an
example of a self-organizing system might be created from the bottom-up
level, by market participation of those interested in doing business as
registries.
40. If it were deemed important to stability of this emerging industry,
this system could be partially funded by a contract with the National
Science Foundation to assist in the building of Intellectual
Infrastructure, as envisioned by the existing arrangement which exists
between NSF and InterNIC. Since the NSF contract with InterNIC is
apparently expiring in 1998, such a transition strategy for building a free
market might be an appropriate, Constitutionally supported alternative to
the IAHC process.
41. The Department of Defense, as the Constitutional arm of our
benevolent government tasked with defending the Constitution, created the
'chain of events' which led to what we presently know as the Internet.
Presumably, in this process of events, there was an unbreakable chain of
Constitutional intent which has flowed with the events. At each link in
the chain, from the initial DARPANET to the NSFNET, and now the Internet
whose Root Name Servers are managed under contract by either Defense
Information Systems Agency (DISA) or National Science Foundation (NSF) by
the Internet Assigned Numbers Authority (IANA), it is presumed by the
People of the United States that there is no dilution of the protections of
individual rights which are guaranteed by the Constitution.
42. If IANA is indeed a signatory to the IAHC MoU, with a presumption
of Constitutional intent and authority, answering to the People of the
United States, how is the Constitutional responsibility to protect the
rights of the People of the United States specifically ensured by the IAHC
process? Where are individual rights prevented from being diluted? Where
is the accountability the People of the United States? How is the
democratic process of ensured?
43. The NTIA, or another governing body should be responsible to the
people to oversee (not control) the process of transition of the Internet
from a limited-use, defense-focused medium, with limited usage of
vocabulary (COM, GOV, ORG, NET, INT, ARPA, MIL) to a truly free market
economic medium. This responsibility should not be handed off to any
unelected governing body. Such a process would constitute an illegal
transfer. The Laws of Science, especially physics, have been specifically
applied above in order to better understand the inherent truths in the
Constitution, and the continued need for vigilance in the defense of
individual rights and freedoms.
VIII. A Suggested Course of Action: a Non-Profit Service for Maintaining
TLDs from a Variety of Open, Free Market-supporting Root Server Consortia
44. The NSF has been contracted to place thirty percent (30%) of all
Domain Name address revenue into a fund for building Intellectual
Infrastructure. The present amount of the fund is presumably $15 million.
Using a portion of that amount to build intellectual awareness through
education of the interNET, innerNET(c), and outerNET(c), and could be very
useful to assisting all individuals in the attempts to grasp the essence of
the importance of words, vocabulary, and language, in human life.
Language, as an agreement between people, is a fundamental compromise
between sovereign beings. All activity flows from that point forward.
45. If the U.S. government and its people support the creation of a
truly free market for (interNET) domain names, as it did when it supported
the creation of CommerceNet in 1994 (funded by DARPA), one way to support
such a system is to use a portion of the 30% to fund a self-sustaining,
non-profit, self-organizing association of free market name registries
which all agree to participate in the open-market populating of generic AND
non-generic words in a manner in which vocabulary will be open and useful
for individuals worldwide. This process has already begun, and would
require little except for 1) formal support for the concept, and 2) limited
financial support, 3) participation by IANA/Network Solutions as InterNIC.
46. By way of example, such an association could be folded into an
"intellectual infrastructure fund" which is educational. In 1996, the word
"dot" was chosen as the Word of the Year (by an organization which does
this each year), because of the fact that the world "dot" is the common
element of each and every internet domain name and address. In
approximately 18 months ending December 31, 1996, about 1 million domain
names were registered and being used in Commerce, through advertising and
marketing programs. The meteoric awareness of the word transmitted in
auditory fashion generically, as well as generically as a punctuation
separator, ".", had created an immense opportunity to leverage this
awareness into understanding. To further the cause, dot Registry, Inc.,
was incorporated in California earlier this year, for this specific
purpose, and is looking to participate in the education process, which
could be sponsored by either NSF or NTIA, with initial memberships from
Network Solutions, Alternic, Name.space, eDNS, uDNS, and the growing number
of other root server operators.
August 15, 1997
(Signed)
Stephen J. Page, President,
Internet .A*-.Z* Name Registry, Member, dot Registry Inc, Root Server
Operator Association
1113 Hopkins Way
Pleasanton, CA 94566
Tel: +1 510.484.4557
Fax:+1 510.484.0448
(c) Copyright, 1997. Stephen J. Page. All Rights Reserved. This
copyright serves only to establish the creative source of the material.
Users are free to duplicate in order to further their own knowledge. This
Brief was designed to support the position of the Brief(s) of Anthony
Rutkowski before the U.S. Department of State, Federal Communications
Commission, National Telecommunications and Information Administration,
Register of Copyrights, and the U.S. Patent and Trademark Office, as well
as to support the creation of a governance structure which allows for an
unlimited number of Top Level Domains, for sale to the consumers of
emerging Internet Registry Industry products and services. Let the market
decide what is useful, therefore valued.
This Brief is excerpted from a forthcoming book entitled, The innerNET(tm).
CC: NTIADC40.SMTP40("casrokcomm@aol.com","hongd@slip.n...
###
Number: 280
From: "joseph j. kim" <jokim@ipcom.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 8:45pm
Subject: dns tld proposal based on trademark
Internet Draft Joseph J. Kim
Expiration Date: Feb 1998 Ipcom
August 1997
DNS Top Level Domain Name Classification and Structure
draft-kim-tld-class-00.txt
Status of this Memo
This document is an Internet-Draft. Internet-Drafts are working
documents of the Internet Engineering Task Force (IETF), its
areas, and its working groups. Note that other groups may also
distribute working documents as Internet-Drafts.
Internet-Drafts are draft documents valid for a maximum of six
months and may be updated, replaced, or made obsolete by other
documents at any time. It is inappropriate to use Internet-
Drafts as reference material or to cite them other than as
``work in progress.''
To learn the current status of any Internet-Draft, please check
the ``1id-abstracts.txt'' listing contained in the Internet-
Drafts Shadow Directories on ftp.is.co.za (Africa),
nic.nordu.net (Europe), munnari.oz.au (Pacific Rim),
ds.internic.net (US East Coast), or ftp.isi.edu (US West Coast).
Abstract
This document specifies a structural organization of Internet top
level domain names based on the International Schedule of Classes
of Goods and Services. This structure intends to provide a
framework for classification such that web content providers can
differentiate their goods and services and minimize the probability
of name confusion and collision. Under each class, as specified by
the International Schedule of Classes of Goods and Services, single
or multiple top level domain names should be specified each
appropriately partitioning the class of goods or service into an
appropriate sub-categorization. A method will further be described
to incorporate additions/modifications as becomes necessary by as
of yet unforseen future developments.
This document does not address the delegation or the administration
of top level domain names which the author feels should be
considered separately. However, the author does acknowledge that
some form of centralized authority should be in place to properly
control the structure to be described.
Joseph Kim [Page 1]
Internet Draft draft-kim-tld-class-00.txt August 1996
1. Introduction
Many new TLDs will soon be created, however, a framework for
classification which appropriately limits the scope of TLD names is
not yet formally specified. Instances of name space collision in ".com"
illustrate the potential of future conflict by TLD names which are
not appropriately limited in their scope of application. In other
words, TLDs with names which are too general in nature will be a
cause of conflict since multiple entities may have an interest in
registering similar names under a particular TLD.
A TLD naming system based on the trademark system is in no way
novel. In fact, many have independently realized and suggested
variations of this approach before. However, a flexible system
which 1. maintains a fairly flat structure allowing for short and
easily remembered names (the whole purpose behind DNS in the first
place), 2. allows for flexibility in the definition of
sub-categories and names under goods and service classes as needed,
and 3. considers future revisions and modifications, has not been
specified to date. The definition of sub-categories is especially
important in light of the fact that most Internet related
businesses would likely fall under one of the 8 service classes
especially class 42: "...services that cannot be placed in other
classes [Int-sched]".
2. The Current System
In the current system, the majority of domain names fall under the
TLDs administered by Network Solutions, Inc. of:
.com
.net
.org
These TLDs have been in use for some time. However, conflict from
name collision and trademark issues continue as companies desire
the same names under a particular TLD. Current TLDs simply do not
provide enough granularity in terms of partitioning specific names
with categories of goods and services.
Joseph Kim [Page 2]
Internet Draft draft-kim-tld-class-00.txt August 1996
A recent proposal by the "IAHC" [Final-report 97] suggests
implementation of 7 new top level domain names including:
.arts
.rec
.per
.store
.info
.firm
.web
However, the generic nature of some of these domain names and the
lack of guidelines for names to appropriately limit scope
[suffers
from the same problems encountered by the generality of ".com".
Future conflict is thus inevitable and a more robust and scalable
solution preferred.
3. Proposed Structure
The International Schedule of Classes of Goods and Services is the
international standard for trademark. The proposal in this document
assumes the right of the trademark holder as a priority in
determining the rights to a particular domain name under a
particular TLD name space.
Top level domain names should be specified and categorized based on
the International Schedule. Each class as defined by the
International Schedule should have associated with it a single or
multiple top level domain names. Thus multiple TLDs may exist under
a single class, unlike in the trademark system. This allows for
finer levels of granularity where needed and easily remembered TLD
names associated with particular products or services.
Again, each top level domain name would specify a particular subset
of goods or service for it's associated class. Thus, for example,
class 25 according to the International Schedule covers "Clothing,
footwear, headgear". Possible top level domain names under this
class could include:
.cloth - for clothing in general
.shoe - for footwear
.caps - for athletic caps
Actually, a more elaborate and formal description of the scope of
each top level domain name should be given. However, for the
purposes of illustration, the above should be sufficient.
Joseph Kim [Page 3]
Internet Draft draft-kim-tld-class-00.txt August 1996
In a like manner all 34 classes of goods and 8 classes of services
should be appropriately partitioned and given appropriately
associated TLDs. Further each TLD should have a specific and
clearly defined scope of coverage. In other words, ambiguity and
overlapping of what goods and services are covered by a TLD should
be minimized as much as possible.
In the above example, if it is not clear whether socks fit into
".cloth" or ".shoe" then this should be made concrete by the
governing body controlling the definition of these TLDs (more on
this governing body in the next section).
A single and complete description of all TLD names under their
appropriate class of goods or service should be provided. The
author currently keeps a proposed description at
"http://www.idns.net" (will be updated regularly). The initial
suggestion of TLDs in each class is also included in Appendix A.
Again what is provided is a suggestion and even after a formal
categorization is constructed future modifications as needed should
always be possible.
4. Coordination and Management of TLD Names and Name Scope
The question now arises how to determine names for each class and
how to incorporate new names as the need arises in the future?
Ideally some international, governing body consisting of various
members of Internet and trademark bodies could be created and this
body could reach a consensus on the categorization and scope of
each TLD. This governing body could also deal with disputes.
However, the reality in creating such an organization may be
difficult. Also, the current power struggle between various
factions vying for control of the TLD name space makes this an
issue which will ultimately be decided by the victors of this power
struggle.
5. Future Modifications in TLD Name Space
When modifications need to be made in the classification of a TLD
or it's scope, it may become necessary for some domain name holders
to move from one particular TLD to another.
Joseph Kim [Page 4]
Internet Draft draft-kim-tld-class-00.txt August 1996
TLD name changes will probably take the following form:
1. the addition of an entirely new TLD which does not conflict with
pre-existing TLD names and does not conflict with the scope of
coverage of other TLD names within the same class, 2. the change of
a particular TLD name to that of another, 3. the creation of a new
TLD with some scope "stolen" from other TLDs, 4. the aggregation of
2 or more old TLD names into 1 TLD name, and 5. the splitting of a
single TLD name into 2 or more TLDs.
Case 1 should not not produce any difficulties.
Case 2 and 3 would require that old TLD name holders will need to
change to use the new TLD name. For this case, some kind of a
standard grace period should be provided (preferably for at least a
year) in which the old TLD remains active. No new registrations
would be allowed in the old TLD but eventually after the grace
period expires old users would be forced out of the old TLD name
space and into the new TLD name space.
Case 3 presents an interesting issue in that if a new TLD name
space is created, whether domain name holders under the old TLD be
given priority for "generic" names under the new TLD name space. In
other words, if someone has a generic name (which implies no
trademark protection) such as "cat" or "house" or "sex" does that
person have rights to that same name in the new TLD name space?
The author's tentative suggestion is to allow old domain name
holders rights in the new name space as well.
In Case 4, which seems fairly pathological, there is a contentious
point of issue for domain name holders with "generic" domain names.
Assuming, this event were to occur (which most likely would never
happen) some form of prioritization needs to be established (i.e.
whoever registered first, etc.).
Finally case 5, should be similar to case 2 and have the same kind
of associated action.
6. Incorporating the IAHC Proposal and NSI TLDs
There are obvious problems with the current IAHC assigned TLD names
as well as the current NSI governed TLD names. For example
".store" and ".firm" are too similar and their scope becomes
ambiguous in relation to each other and ".web" and ".info" are too
general. This is not to mention NSI's ".com" which conveniently
covers the entire realm of commercial enterprise. However, if the
"IAHC Proposal" is successful with their 7 new TLD names then it
would be useful to consider how to incorporate that possible
outcome with the suggestions outlined in this document.
Joseph Kim [Page 5]
Internet Draft draft-kim-tld-class-00.txt August 1996
The first step would be to place the 7 new tlds in a particular
class as specified by the International Schedule and the second
step would be to appropriately limit the scope of the current
names. Priority should be given to those who have priority for a
certain name given the associated scope of a given TLD as
specified.
A tentative suggestion is as follows and is by no means definitive:
class 41. "Education; providing of training; entertainment; sporting
and cultural activities [Int-sched]."
.arts - libraries; museums; clubs centering around an artistic
focus;
.rec - recreational centers; health clubs; sporting centers;
sporting events; other recreational events;
.nom - "for those wishing individual or personal nomenclature
[Final-report 97]"
class 42. "Providing of food and drink; temporary accomodation;
medical, hygienic and beauty care; veterinary and agricultural
services; legal services; scientific and industrial research;
computer programming; services that cannot be placed in other
classes [Int-sched]."
.info - directory services; Internet searching; white and yellow
pages; whois;
.web - web related advertising firms;
.store- see below
.firm- see below
Eventually, .store and .firm should be obsoleted and registrants
should be moved (as specified by this document) into appropriate
TLDs to be created in the future.
Joseph Kim [Page 6]
Internet Draft draft-kim-tld-class-00.txt August 1996
Similar to incorporating IAHC TLDs, the TLDs currently administered
by NSI of .com, .org, and .net could also be handled.
class 42
.org- non-profit organizations;
.net- network consultants; isps; web design firms;
.com- should be obsoleted as .store and .firm
As future TLDs are created some of the above listed TLD names can
be changed or moved or deleted as per the specification of this
document.
7. Acknowledgements
Many people have expressed various ideas about incorporating
trademark into the DNS, however, the first real codification of
those ideas, and similar to those ideas expressed in this document,
came from a now expired IETF draft document by Simon Higgs of Higgs
America.
The problems associated with the "IAHC proposal" (as well as a
stimulus for writing this document) and their 7 new top level
domain names was best described by Donna Hoffman in her article
"IAHC'S Seven New Top Level Domains Will Confuse Customers"
[Hoffman 97].
Joseph Kim [Page 7]
Internet Draft draft-kim-tld-class-00.txt August 1996
8. References
[Int-sched] International Schedule of Classes of Goods and
Services
[Final-report 97] Final Report of the International Ad Hoc
Committee: Recommendations for Administration and Management of
gTLDs
[Hoffman 97] Hoffman, D., "IAHC's Seven New Top Level Domain Names
Will Confuse Customers", The COOK Report on Internet, Vol. 6, No.
4/5, 1997.
9. Author Information
Joseph Kim
ipcom
811 Haverhill Dr.
Sunnyvale, CA 94087
Phone: (408) 527-2579
email: jokim@ipcom.com
Appendix A. Initial Recommendation of TLD Names and Scope
All TLDs should be 3-7 characters in length.
Goods:
=====
Sub-categorizations for classes is listed with examples listed to
the right. Manufacturers of the associated goods described should
apply for domain names under the appropriately designated TLD.
Class 1-
.CHEM chemicals used in industry, science, and photography, as
well as in agriculture, horticulture and forestry;
.PLAS unprocessed plastics
.MANURE manures
.PRSRV chemical substances for preserving foodstuffs
.ADHSV adhesives used in industry
Joseph Kim [Page 8]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 2-
.PAINT paints, varnishes, lacquers; colorants;
Class 3-
.LNDRY bleaching preparations and other substances for laundry
use.
.SOAP soaps, perfumery, essential oils, cosmetics, hair
lotions.
.CLEAN cleaning, polishing, scouring and abrasive preparations
Class 4-
.OILS industrial oils and greases; lubricants; dust absorbing,
wetting and binding compositions; candles, wicks.
.FUEL fuels.
Class 5-
.PHARM pharmaceutical, veterinary and sanitary preparations.
Class 6-
.METAL common metals and their alloys, pipes and tubes of
metal; ironmongery, small items of metal hardware; safes;
goods of common metal not included in other classes.
.ORE ores.
.WIRE non-electric wires of common metal.
.CABLE non-electric cables of common metal.
Class 7-
.MCHN machines and machine tools; motors and engines
Class 8-
.RAZOR razors
.CUTLRY cutlery; knives
.TOOLS hand tools and implements (hand operated)
Joseph Kim [Page 9]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 9-
.INSTR scientific, nautical, surveying, electric, photographic,
cinematographic, optical, weighing, measuring,
signalling, checking (supervision), life-saving and
teaching apparatus and instruments;
.RECORD apparatus for recording, transmission or reproduction
of sound or images; magnetic data carriers, recording
discs.
.VEND automatic vending machines and mechanisms for coin
operated apparatus;
.CASHREG cash registers.
.CALC calculating machines.
.COMP data processing equipment and computers.
.FIREX fire-extinguishing apparatus.
.NTWK routers, switches and hubs; modems and other network
related machinery.
Class 10-
.SURGI surgical, medical, dental and veterinary apparatus and instruments
artificial limbs, eyes and teeth; orthopedic articles; suture
materials
Class 11-
.LTNG apparatus for lighting.
.HEATER apparatus for heating.
.STEAMG apparatus for steam generating.
.KITCHEN apparatus for cooking, refrigerating, water supply and
sanitary purposes.
.WTRSPLY apparatus for water supply.
.VENT apparatus for ventilating.
.DRYER apparatus for drying.
Class 12-
.VEHI apparatus for locomotion by land, air, or water
Class 13-
.ARMS firearms; ammunition and projectiles; explosives; fireworks
Joseph Kim [Page 10]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 14-
.JEWEL jewellry, precious stones;
.WATCH horological and chronometric instruments (wrist based)
.CLOCK horological and chronometric instruments (non wrist based)
Class 15-
.MUSICI musical instruments
Class 16-
.PRINT printed matter; bookbinding materials; printers' type;
printing blocks.
.BRUSH painters brushes.
.PAPER paper, cardboard and goods made from these materials.
.CARD greeting cards; playing cards.
.STNRY stationery.
.TAPE adhesives for stationery or household purposes.
.PHOTO photographs.
Class 17-
.RUBBER rubber, gutta-percha, gum asbestos, mica and goods made
from these materials.
.PIPE flexible pipes, not of metal.
.PACK packing, stopping and insulating materials.
.PLSTC plastics in extruded form for use in manufacture.
Class 18-
.LTHR leather and imitations of leather, and goods made of these
materials and not included in other classes; animal skins ...
.HIDE animal skins, hides.
.SADDLE harness and saddlery
.UMBRLA umbrellas, parasols and walking sticks.
.WHIPS whips.
Class 19-
.BUILD building materials (non-metallic); rigid pipes for
building; asphalt, pitch and bitumen; non-metallic
transportable buildings; monumetns, not of metal.
Joseph Kim [Page 11]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 20-
.FURN furniture, mirrors, picture frames; goods (not included
in other classes) of wood, cork, reed, cane, wicker,
horn, bone, ivory, whalebone, shell, amber,
mother-of-pearl, meeschaum and substitutes for all these
materials, or of plastics.
Class 21-
.HSHLD household or kitchen utensils and containers (not of
precious metal or coated therewith); combs and sponges;
brushes (except paint brushes); brush-making materials;
articles for cleaning purposes; steelwool; unworked or
semiworked glass (except glass used in building);
glassware, porcelain and earthenware not included in
other classes.
Class 22-
.ROPE Ropes, string, nets, tents, awnings, tarpaulins, sails,
sacks and bags (not included in other classes); padding
and stuffing materials (except of rubber or plastics);
raw fibrous textile materials.
Class 23-
.YARN yarns and threads, for textile use.
Class 24-
.TEXTILE textiles and textile goods, not included in other
classes; bed and table covers.
Class 25-
.CLOTH clothing in general; socks; caps.
.SHOE shoes; boots; thongs; other types of footwear.
Joseph Kim [Page 12]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 26-
.LACE Lace and embroidery, ribbons and braid;
Class 27-
.CARPET Carpets, rugs, mats and matting, linoleum and other
materials for covering existing floors;
.POSTER wall hangings (non-textile)
Class 28-
.GAMES Games and playthings; gymnastic and sporting articles
not included in other classes.
.XTREE decorations for Christmas trees.
Class 29-
.MEAT Meat, fish, poultry and game; meat extracts; edible oils
and fats.
.????? preserved, dried and cooked fruits and vegetables.
.JELLY jellies, jams, and fruit sauces.
.DAIRY milk and milk products.
Class 30-
.COFFEE Coffee and artificial coffee.
.TEA Tea.
.SUGAR sugar.
.SALT salt.
.RICE rice.
.FLOUR flour.
.BREAD bread.
.PASTRY pastries.
.HONEY honey.
.SPICE spices.
.CONDMNT condiments, sauces, mustard, and ketchup.
.ICE ice
Joseph Kim [Page 13]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 31-
.AGRI agricultural products not included in other classes
.HORTI horticultural products not included in other classes;
plants and flowers.
.FRSTRY forestry products not included in other classes
.ANIMAL live animals
.FRUIT fresh fruits
.VEGE vegetables.
.FEED foodstuffs for animals
.MALT malt
Class 32
.BEER beers
.BEV mineral and aerated waters and other non-alcoholic
drinks; fruit drinks and fruit juices; syrups and other
preparations for making beverages.
Class 33
.ALCO Alcoholic beverages (except beers).
Class 34
.TBCO Tobacco; smokers articles; matches.
Services:
========
Class 35
.ADS Advertising;
.BUSI Business management; business administration; office
functions.
Class 36
.INSU Insurance.
.FINA Financial affairs; monetary affairs.
.REAL Real estate affairs.
Class 37
.CONST Building construction.
.REPAIR Repair services
.INSTALL installation services.
Joseph Kim [Page 14]
Internet Draft draft-kim-tld-class-00.txt August 1996
Class 38
.TELCO Telecommunications.
Class 39
.TRANS Transport
.SHIP Shipping of goods.
.TRAVEL travel arrangements
.STRAGE Packaging and storage of goods.
Class 40
.MTRLS Treatment of materials.
Class 41
.EDU Education.
.TRAIN providing of training.
.SPORTS Sporting activities.
.CLTRE Cultural activities.
Class 42
.ADLT web sites containing adult/mature material.
.BAR bars.
.MOVIE movie information.
.RESTNT restaurants
.HOTEL hotels.
.MOTEL motels.
.MED medical care.
.COSM hygienic and beauty care.
.VET veterinary services.
.AGRIS agricultural services.
.LEGAL legal services.
.RSRCH scientific and industrial research.
.PROG comoputer programming.
.NET network consultants; isps; web design firms.
.ORG non-profit organizations
.NEWS newspapers; news related web sites
.INFO directory services; Internet searching; white and yellow
pages; whois/rwhois.
Joseph Kim [Page 15]
###
Number: 281
From: "Gregory B. Bulkley, M.D." <gbulkley@welchlink.welch.jhu.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 3:26pm
Subject: Government interference in the Internet
As has been clearly exemplified in the past several years, especially
by the present administration, attempts by the government to increase
its power to further interfere in our lives are always justified by
intellectually dishonest arguments which exaggerate a real or imagined
problem, (a problem often created by prior, misguided attempts at
government regulation,) and the (usually short-term) benefits purported
to be obtained, while ignoring or minimizing the long term loss of our
freedom created by yet another ceding of the control of our lives to the
statist-collectivist sociopaths who fight indefatiguably and ruthlessly
for the power provided by that very control. In the past decade, two
phenomena have emerged that threaten this widespread, pathologuic world
view to a greater degree than anything since lassaiz-faire capitalsim:
The first is a global economy that has proven virtually impossible to
regulate, and has therefore been freed to produce an immeasurable
increase in the standards of living of rich and poor alike, all over the
world, except in a few closed societies (North Korea, Viet Nam, Cuba,
Iraq and perhaps Iran) that are strangulating themselves by their
isolation therefrom. The second is the Internet, the enormous growth
and utility of which is due almost entirely to the fact that its content
is virtually unregulated. As access to and control of information
itself continues to increase exponentially in value relative to other
commodities, especially traditional goods and services, it poses an even
greater threat to the statist-collectivist world view. This has been
clearly illustrated by the current administration's pathologic fervor in
pursuing control of the encryption of electronic communication, which
has beeen rationalized on the basis of better control of drug
trafficking, an arguemnt so patently riciculous that it should be
laughable. This is indeed ironic, as it draws attention to the
collossal failure of the "War on Drugs," an outcome which has been
purchased at enormous cost to our financial resources and personal
freedom, and therefore a perfect example of the logical, indeed
inevitable outcome of this same line of reasoning. Make no mistake
about it: the attempts to control the content of the Internet represent
a blatant attempt to control communication itself, and by clear
implication, our thought processes. Moreover, this fact is clearly
understood by those who seek such control. Their arguments for this
interference are so patently ridiculous that they can only be advocated
by the truly stupid or the intellectually dishonest, and these actual
and aspiring bureauocrats are not that stupid, at least in the usual
sense of the word. Fortunately, I think that the Internet, even more
that the international trafficking in narcotics, will probably prove to
be unregulatable anyway. Nevertheless, as is clearly illustrated by the
"War on Drugs," attempts at such regulation by the government may well
generate untold human misery, loss of personal fredom for persecuted
individuals, and enormous economic cost.
(Hopefully, this document will be posted before it is read by the
mindless bureauocrats who undoubtedly administer this forum.)
Gregory B. Bulkley, M.D.
Ravitch Professor of Surgery
The Johns Hopkins University
gbulkley@welchlink.welch.jhu.edu
(These opinions are my own, and are almost certainly not representative
of the University.)
###
Number: 282
From: Michael Loftis <mjl@tcbbs.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 1:30pm
Subject: InterNet Domain Regulation
I feel that Internet Domain regulation should not be that of the courts,
nor the Department of Commerce to decide. The "first come first serve"
law has allways held up until a few stupid lawers changed that. Now I
have to worry about some person sueing me for my domain name!
This is ridiculous. I also feel that the creation of TLDs (Top Level
Domains, such as .com .net and .org and others) should be regulated in
the same way it is now, by an International committee.
By and large the court system has *no idea* what the heck a DNS server
is much less what it does. If they do know the knowledge is only
rudimentary. If we let everyone create a TLD either through committee
review or not there would be too many lawsuits and it wouldn't be long
before the root DNS servers simply died, or became too overloaded to
handle all the requests.
We have this problem starting to appear with the .COM domain because of
peoples reluctance to move to a nation-centric approach. I would have
used a .US domain had there been any way for me to get in contact with
the registration authorities for it.
MAny people suggested adhering to the set-forth hierarchy (.NET for
ISPs, .COM for COMPANIES (no more of you movie idiots there) etc etc)
this is by and large an excellent idea. It is just stupid the way
everyone wants to use .COM domains. These are for COMPANIEs or
COMMERCIAL sites. InterNIC has *NOT* handled its contract properly and
I hope that a committee will remove it from its contract and find
another agency that will do its job and not allow movies in the .COM
domain and instead push for a .MOVIE domain for movies only.
OK, I feel better now. LEts just hope something is done about it. The
US DoC has no business in meddling with anything Internet related until
they can show that the majority of them have working technical knowledge
of DNS, NIS, and WHOIS also. Without some knowledge of these protocols
it is impossible to judge accurately as to the fate of the current DNS
system. They must also understand the impact that a major change in the
naming system would incur.
<soapbox mode off>
###
Number: 283
From: "Timothy K. Timlin" <timothy_usa@mindspring.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 6:47pm
Subject: Domain names and governmental involvement
Let the computer / communications [internet] industry resolve this
matter themselves. If not, then create a quasi-governmental responsible
to Congress/Senate to resolve the matter.
_______________________
Timothy K. Timlin
timothy_usa@mindspring.com
###
Number: 284
From: Johanna Byrne <infopros@mhtc.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 7:41pm
Subject: Domains
I believe that the InterNIC has done a good job sofar in its handling of
web site name registration and that there is no reason to take this
"authority" to a different organizaiton. Since it makes no difference
where InterNIC is located in respect to the registering company, it
should be no issue at all that InterNIC happens to be physcially located
in the U.S. Starting up an international governmental agency sounds
too Orwellian to me...
I can see the need for further domain segmentation, but surely hope that
the companies that already have a .com designation do not have to pay
again to get a new designation in a .com subcategory!! And maybe even
would have to battle someone else for a name they have been using with
.com for a couple of years.
Johanna Byrne
Website under construction
www.tranquiltime.com
###
Number: 285
From: Dallas Jones <djones1@san.rr.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 8/15/97 8:53pm
Subject: DNS
Simply put. Keep it as un-obtrusive as possible. I will gladly take the hit.
Keep the Gov't out as much as possible.
###
Number: 286
From: "David H. Klein" <davidhk@cint.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 3:55am
Subject: RFC on Internet Domain Name Administration
Dear DOC,
Attached to this e-mail is a Word 7.0 file that have my full comments. The
same file is being sent in print form, on disk, and will also be available
later this week at: http://www.cint.com/dns.htm
Sincerely,
David H Klein
This is a Response to:
Request for Comments on the
Registration and Administration of Internet
Domain Names
DEPARTMENT OF COMMERCE - Docket No. 970613137-7137-01
DATE: August 14, 1997
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: David H Klein - Cambridge Internet
9123 E Mississippi Ave #19-301
Denver, CO 80231
(303) 696-9098
davidhk@cint.com
http://www.cint.com
The best
way to allow for competition in domain name registration and
protect organizations and trademarks legally is in the choice of
the TLD names.
I. A New Model
Introduction
The New DNS Administrative Model
Principles
Operation of the Root Servers
Choosing the TLD names
Creation of new TLD’s
Code of DNS Dispute Resolution
Advantages of this model
II. Answers to the DOC Questions
A. Appropriate Principles
Comment on the Appropriate Principles
B. General/Organizational Framework Issues
1. What are the advantages and
disadvantages of current domain name registration systems?
2. How might current domain name systems be
improved?
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?
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?
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?
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?
12. Are there technical, business, and/or
policy issues about guaranteeing the scalability of the name
space associated with increasing the number of gTLDs?
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?
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?
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?
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?
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?
The purpose of this response to the DOC’s request for
comments is to both provide a potential new model for the
administration of the Domain Name Service and answer all
questions that I am qualified to. The answers to the questions
will come from the perspective of the state of DNS today and the
new model listed in this document.
As you go through Section II, the answers to the questions, I
have put a title page in front of each grouping of questions that
lists the ones that I have chosen to answer.
The New DNS
Administrative Model
The organization of DNS should be supported legally by
either the United States of America and/or the United
Nations.
The rules for organization of DNS legally describe a GTLD,
the root servers, and registration companies that manage,
maintain, and operate the distribution for each GTLD.
The control of the root servers is government regulated at
a minimum. A contract to a third party for the maintenance of
the GTLD database is acceptable, but the company that
maintains it can not also be a distribution registry for any
individual GTLD.
There are multiple TLDs and registries.
The TLDs should be created so that certain named TLDs
afford legal protection to corporations, trademarks, and
copyrights.
A uniform code of DNS resolution will regulate name
disputes. The first part of the resolution would require
arbitration. Extensive disputes would be handled by the court
system.
The root servers of DNS control who has the table for each Top
Level Domain. Due to the organization of DNS it is appropriate
for there to be exactly one root server database. There are great
difficuties in a DNS system that does not have one root database.
The coordination of multiple databases is extremely complicated.
In addition, multiple root server databases could potentially
bring chaos to the entire addressing system for e-mail addresses
and websites. By having exactly one root server database, we can
have a consistent organization for Domain Names and TLDs.
The root servers should be operated by a company or multiple
companies who agree to keep the computers operational 24 hours a
day, 7 day a week for the length of their contract. They will
also agree not to operate the database for any individual TLD.
One of the greatest advantages of multiple companies with
multiple computers with a single database that they all have the
same copy of is for the protection of the root server database
from hackers. If a company has more than one computer and it is
determined that their database has been corrupted, intentionally
or not, that computer can be immediately turned off without
affecting DNS world-wide. The company can then have a spare
computer available with a copy of the accurate database.
Even in the situation that a company suffered from a large
disaster, the outage of an individual company will not effect
world-wide DNS. The secondary DNS servers will just move on to
the next set of servers at another root server company.
In order to keep the root databases coordinated, all of the
servers can be set up to receive the database information from
one computer controlled directly by one governmental
organization.
The best way to allow for
competition in domain name registration and protect organizations
and trademarks legally is in the choice of the TLD names.
New recommended names:
.TM1 Trademark Registry #1
.TM2 Trademark Registry #2
.TM3 Trademark Registry #3
.INC1 Corporation Registry #1
.INC2 Corporation Registry #2
.INC3 Corporation Registry #3
.NOM1 Surname Registry #1
.NOM2 Surname Registry #2
.NOM3 Surname Registry #3
.ORGx Non-profit Registries
.NETx Network Entity Registries
The new TLDs should all have two parts. The first part
identifies the type of organizations or domain name. This must
always consist of two to four letters. The second part would
follow immediately and always be a number that identifies a TLD
registry. Because a TLD type would always have a number following
the name that identifies a company, a consumer could always go to
a different company to get a domain of the same type.
So from the Registry comanys’ perspective, upon deciding
to become a registry, they would be assigned a number. That
company would then be responsible for any GTLD they wished to
administer by adding a number to the end of the registry name.
For example, if I registered my company, Cambridge Internet, as a
registry, the governmental organization would assign a number to
my company, let’s say 4. From that point forward I could
register domain names under my registries for: .TM4, .INC4,
.ORG4, etc.
From the perspective of a domani name holder, they would
always have a choice of multiple companies to register their
domain name. For example, let’s assume that my company,
Cambridge Internet, chose the domain name CINT.INC. I could then
have it fully assigned as CINT.INC1, CINT.INC2, or CINT.INC3,
etc. If I were not happy with the service I was receiving from
registry #1, I could always switch it to #2 or #3 as long as that
domain were not previously assigned.
In this system, there would not be a TLD that did not have a
registry number. This way, no individual registry could have an
advantage over another by having the shorter and potentially more
desirable name. For example, there could not be a TLD called .INC
instead of .INC1, .INC2, .INC3, etc. A name without the number
would likely be more desirable to consumers because shorter names
are preferred for domain names on the Internet.
The best advantage of this system would be to afford legal
protection to some of the names and allows others to be
unrestricted. For the companies that have trademarks they wish to
protect on the Internet, we can require that the only domain
names that go into a .TMx registry must have proof of a Federally
Registered Trademark. All companies or organizations registering
in the .INCx registries must have documents of Incorporation as
proof.
Other domains such as .NOMx for surnames and .FUNx for
entertainment, would not have to prove anything. Anyone could
register within these names. The only requirement for an
unregulated TLD would be that an individual or organization could
not have the same domain in multiple unregulated registries. For
example, I could sign up KLEIN.NOM1, but would not be allowed to
own KLEIN.NOM2 and KLEIN.NOM3 in order to corner the market on
all .NOMx domains that began with KLEIN.
The only rule that would be needed for trademark or corporate
protection at this point would be that the use of an unregulated
TLD domain could not represent one that is regulated in any
manner. For example, in this model I could not sign up
MICROSOFT.ORG1 and attempt to represent myself as Microsoft. This
would clearly be a trademark infringement. On the other hand,
this would allow me to make a website dedicated to discussing
snakes called SLINKY.FUN1 without infringing on the product which
would be registered under SLINKY.TM1.
In order to accommodate people who are currently in domains
without registry numbers, a one-year period would be allowed for
both unnumbered and numbered registries to co-exist. During that
period, all individuals and organizations must update to the new
numbered system. After that period, unnumbered TLDs would cease
to exist.
The only reason that a new TLD should be created is in order
to provide groups different set of protection based on their
product, service, or affiliation. The new TLDs would be best kept
at a minimum for efficiency, but should go through the vote of a
committee if there is a legitimate reason for a regrouping.
Probably the best example of a new TLD that might or might not
need legal protection would be .MOVx for movie title websites.
A new TLD should be created when there is a potential conflict
in two types of domains within one existing one. The purpose of
the creation would be to minimize any potential conflicts within
one TLD.
NOTE: Please see question 7 in Section IIB of this document.
Code of DNS Dispute
Resolution
As long as the extensively distributed naming system above is
used, there should be few conflicts altogether. The only cases
that should bring a dispute to arise is when either one company
attempts to corner a domain name within many different registries
or a company or individual infringes upon the legal corporate or
trademarks of another by misrepresenting their domain.
If either of these cases do occur, the current method of
arbitration or prosecution should be sufficient to deal with
these cases.
There would be redundancy of the root DNS database.
No single organization, company, registry, or domain name
holder would have the monopoly rights to the root DNS
database, a TLD, or complete domain name.
There would be competition for the registration of domain
names, thereby improving the service to domain name holders.
Due to the allowance for market competition, domain name
holders would likely face a fair market price for the
registration and service of their name.
With registration laws afforded to certain TLDs,
trademarks and corporations would be protected from
infringement of their product, service, or good name.
Due to the equal use of all registries for any TLD, a
domain name holder would not have to worry about being
blocked out of the domain name of their choice.
II.
Answers to the DOC Questions
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.
Comment on
the Appropriate Principles
The most important change to the principles listed above is
the elimination of self-governing mechanisms. If the new model
listed in the first document is implemented, there is little need
for regulation or governing the operation of the registries.
However, it is necessary and imperative that the government
step in with a set of rules and regulations so that the root DNS
database has legal protection. Without it, an individual or
organization can destroy Internet commerce completely by taking
over or destroying the access to the root DNS servers.
The foundation of DNS today is now and should be a public
service. Governments are necessary where the common good is
enhanced by a service that would fail under the self-interests of
individuals or companies. This is the same reason that Interstate
Freeways are funded by the Federal Government.
B.
General/Organizational Framework Issues
1. What are the advantages and disadvantages of current domain
name registration systems?
2. How might current domain name systems be improved?
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?
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?
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?
1. What are
the advantages and disadvantages of current domain name
registration systems?
Disadvantages:
Because there is no competition for the registration of
domain names, it is in the economic interest of Network
Solutions, Inc. to provide as little and/or no support for
the registration of a domain name. Once they have the $100
registration fee, the less support of the domain name they
operate, the greater percentage of the registration fee is
kept as profit. Therefore, it is in their self-interest to
not help or serve their customers.
Network Solutions, Inc. has the ability to cut off a
domain name and substantially damage a company that does
business over the internet. The domain name customer has
little to no recourse.
Because they can have a monopoly over a domain name and
the root servers, they can prevent others from becoming
registries.
Due to the limited number of GTLDs that companies can
register domain names within, an individual or organization
can prevent others from access to a domain name. For example,
if I wanted to start a consulting company called "Klein
Networks" and use a domain named called KLEIN.NET, I
could not because the company that currently holds it will
not let me use or rent it.
Because an individual or organization can block others
from use, many domain names have been purchased in order to
charge significant sums of money to those who could have a
use of it for any purpose besides real-estate holding value.
2. How might
current domain name systems be improved?
Allow for multiple registries of domain names that each
individually do not have a monopoly of any TLD.
Require that certain TLDs have proof in order to get a
domain name under them. (i.e. In order to get a .TMx domain,
you must show proof of a Federal Trademark. In order to get a
.INCx domain, you must show proof of incorporation.)
A company that runs a Root Server should not be allowed to
have any interest in a Registry.
GTLD
TLD
Root-Server Company
Registry
Domain Holder
What should the
makeup of such an entity be?
GTLD - a Global Top Level Domain that either has or does
not have regulations on its usage. For example, a GTLD under
the system in Section 1 would be .INCx, .TMx, .NETx, etc.
TLD - the complete Top Level Domain that an individual
registry could give out complete domain names from. For
example, a TLD under the system in Section 1 would be .INC2,
.TM8, .NET5, etc.
A Root Server Company - is a company that lists the IP
addresses of the servers for each TLD in its root DNS
database.
A Registry - is a company with a specific registry number
that can
5. Should
generic top level domains (gTLDs), (e.g., .com), be retired from
circulation?
No.
Should geographic
or country codes (e.g., .US) be required?
No, but there is also no reason to eliminate them either.
If so, what should
happen to the .com registry?
If the new suggested model listed in Section I of this
document is implemented, the following transitions should occur:
A one year period should be allowed for current holders of
domains within the .COM registry to migrate to new gTLDs.
Once at least two new registries have been formed with the
new system, there should not be any new registrations within
the .COM registry.
A domain name representing a trademarked product or
service should migrate to a .TMx registry.
A domain name for an incorporated company should migrate
to a .INCx, .LTDx, .LLCx, or .GmbHx domain
6. Are there
any technological solutions to current domain name registration
issues?
Not that I am aware of.
Are there any
issues concerning the relationship of registrars and gTLDs with
root servers?
A registrar should not at the same time be allowed to maintain
operate or have any interest in a root server or the database
contained on any. The common control of both allows undue power
to be given to an individual. The registry would then have the
ability to use the monopolistic power made illegal by our Sherman
Anti-Trust act.
This exact type of incident has already occurred with Network
Solution’s operation of the root servers. The Department of
Justice has already started looking into Network Solution’s
use of this monopolistic power. This action is also publicly
listed within Network Solution’s S-1 form to the SEC in its
filing for an Initial Public Offering of stock.
As long as TLDs are created for domain names that can be
grouped under new TLDs, the DNS database structure should grow
evenly between all the new TLDs.
Probably the best model for adding a new TLD is to ask:
If this TLD existed, would more than 1000 domains be
registered under it?
If the answer is yes, then it should be created. If no, then
it should not be created.
In order to keep any individual TLD from becoming too big, the
following question should be asked:
If this TLD has more than 1,000,000 domains, can it be broken
into one or more groups that contain at least 100,000 domains?
If the answer is yes, then a committee should recommend one or
more TLDs. If not, then the TLD should be allowed to grow.
8. How should
the transition to any new systems be accomplished?
See question 5.
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?
12. Are there technical, business, and/or policy issues about
guaranteeing the scalability of the name space associated with
increasing the number of gTLDs?
If the model in this paper is used, the potential number of
gTLDs will be TLD x # of registries. Due to the cost of
maintaining a registry, it is unlikely that there will be more
than 1,000 registry companies.
11. Should
additional gTLDs be created?
Yes. The current system allows for no differentiation of
domain names since the vast majority of domain names currently
reside in .COM. There are also a significant number of advantages
that support the existence of multiple gTLDs including:
The prevention of one individual or organization from
blocking another from the legitimate use of a domain name.
Greater differentiation of domain names to reduce the size
of any individual registries’ database.
By creating special purpose, regulated domain names, we
can give corporations trademark protection.
In general, No. The current system has more than 1,000,000
.COM domain names. DNS software has scaled well for the quantity.
However, it would be wise to limit the creation of a gTLD for
a registry only. Otherwise this system will probably run into the
same problem of multiple people fighting over the names that
would represent companies or trademarks. For example, we would go
through the same headache again when multiple organizations begin
fighting over .IBM or .MICROSOFT. As long as we follow the rules
suggested in the answer to question 7 in this document, there
shouldn’t be any trouble in the expansion of gTLDs.
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?
15. Should a
gTLD registrar have exclusive control over a particular gTLD?
No.
Are there any
technical limitations on using shared registries for some or all
gTLDs?
If the system does not allow for multiple registries to use
the TLD numbering system as described in Section 1 of this
document, then we must assume that there can only be one
descriptive TLD (i.e. there would only be one .TM or .INC). In
this case it would be, for all practical and technical purposes,
impossible for multiple organizations to control and manage a
single TLD database. The regulation and cooperation required
would not be worth the headaches involved.
Can exclusive and
non-exclusive gTLDs coexist?
If we allow all registries access to a TLD via the registry
numbering system listed in Section 1, then the answer is yes.
Yes. The responsibilities should fall into two categories:
technical operation of the service and customer service. In
technical operations, a registry needs to guarantee redundant 24
x 7 operation of the servers on circuits directly connected to a
backbone of the Internet. For customer service responsibilities,
the registry should be able to respond accurately to the requests
of a customer within one business week.
Who will determine
these and how?
A board that regulates the DNS structure as a whole.
17. Are there
technical limitations on the possible number of domain name
registrars?
There shouldn’t be more than 1,000 for ease of regulation
and technical scalability if all registries are allowed to manage
all TLD’s as described earlier in this document.
If we do not allow for multiple registries to give out TLDs as
defined in question 3, they will continue to fight and sue each
other for the ability to monopolize a GTLD.
19. Should
there be a limit on the number of different gTLDs a given
registrar can administer?
As long as a registry can have any GTLD they wish to register
via the TLD numbering system, no.
Does this depend on
whether the registrar has exclusive or non-exclusive rights to
the gTLD?
Yes.
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.?
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?
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?
No. Due to the fact that there can be legitimate use of a
domain if it does not fall within a .TMx domain, there should not
be any pre-checking of an unregulated domain name. It is possible
for the use of a domain called SLINKY.EDU1 to discuss snakes
without infringing on the product that would reside under the
domain name SLINKY.TM1.
In general, it is not required that a small company,
individual or organization attempt to seek permission for any
potential use of the word "slinky in their advertising or
documentation". It is the responsibility of the company that
holds the SLINKY trademark to protect itself against
infringement. This should hold true if we give a GTLD that will
clearly identify them.
In the case of regulated GTLDs, yes. In unregulated ones, no.
If so, what
information should be supplied?
For a domain .TMx, a Federal Trademark registration should be
supplied. In the case of .INCx domains, articles of incorporation
should be.
Who should evaluate
the information?
The registry should require it in their application process.
On the basis of
what criteria?
Legal documentation.
As long as the new GTLD system prevents an organization from
blocking access to a legitimate trademark, product, service, or
company representation, then the only rules that need to apply
are the normal ones of trademark protection.
The key issue that has caused disputes in domain name usage
has been the sole representation of one domain for the name of a
product or service.
Yes, a domain name can be split up. If the only uses of the
domain are e-mail and a website, both parties should be given the
choice of one of the following two solutions:
The domain name in question should be put under the
control of a third, uninvolved party. This party will replace
the website at the domain name that lists the new websites
for the disputing parties. Both companies will have only one
e-mail address in the disputed domain.
They resolve their dispute.
If the new system described in Section 1 is used, then the
disputing parties could have WIDGET.TM1 and WIDGET.TM2.
###
Number: 287
From: "David R. Johnson" <david.johnson@Counsel.COM>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 12:12pm
Subject: DNS NOI
David R. Johnson hereby submits comments in electronic form, in
Microsoft Word format, in response to the Department of Commerce's
Request for Comments on the Registration and Administration of Internet
Domain Names.
Acknowledgement of receipt (to david.johnson@counsel.com) would be
appreciated.
/s/
David R. Johnson
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 David R. Johnson
___/s/________________
David R. Johnson
3650 Appleton Street, N.W.
Washington, D.C. 20008
August 15, 1997
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
SUMMARY
1. The basic principles articulated by the government are sound. The
U.S. Government should foster those and related principles by using its
role as an early operator and subsidizer of key net resources to
facilitate the growth of a sound private sector-driven system of
self-governance for the Internet.
2. Any system for Internet self-governance must be based on a web of
contracts entered into between users, ISPs, registrants for
net-identifiers, registrars, and various parties (such as the operators of
root servers) who implement those contracts. In general, the marketplace
can and should decide what contracts will be entered into.
3. The government should encourage and allow the development of
contracts that provide coordination among all registrars regarding the
terms and conditions under which net identifiers will be issued, used and
revoked. Such contracts ought not to be found to violate antitrust laws or
other public policies. Those engaged in constructing such self-regulatory
regimes should be provided with appropriate immunity from liability,
provided that they act to improve the Internet rather than for private
financial gain or special competitive advantage.
4. Disputes regarding registration and uses of domain names should be
resolved by a global arbitration process, resort to which is made a
condition of registration of any domain name. Such a process will produce
efficient and expert decisions that are easier to enforce globally than
are judgments by local courts.
5. The domain name system involves many policy issues and potential
disputes that have no relationship to traditional trademark law. Trademark
concerns should be fully taken into account but should not drive the
engineering decisions nor determine the overall shape of the system likely
to be used, more generally, for Internet governance.
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 David R. Johnson
1. I, David R. Johnson, respectfully submit comments in this proceeding.
I am Chairman of Counsel Connect, an online system for lawyers, and
Co-Director of the Cyberspace Law Institute. I have written various
articles on domain name system administration and on related Internet
governance issues (See, generally, www.cli.org). These comments are
submitted in my individual capacity.
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. Competition should be analyzed at various different levels. For
any given domain, there may be a natural monopoly with respect to the
single database used to make sure that second level domain name
registrations are unique. In contrast, the provision of registration
services may benefit from competition. Certainly, the provision of lower
level identifiers (e.g., email accounts and web addresses within a
particular domain) ought to be provided on a competitive basis.
2. Insofar as certain types of domain names may provide a useful
"signaling" function by being associated with particular terms and
conditions (e.g., a requirement that users of ".edu" be educational
institutions), competition among registrars to provide registration
services might create confusion if the registrars were free to attach any
given terms and conditions, or to use differing levels of zeal in
enforcing standard terms. For example, certain domains might come to be
understood to include only registrations from certain types of persons
(corporations) or from persons who can be identified and found at
particular geographic addresses. If competition among registrars were to
reduce the certainty that particular terms and conditions are being
applied consistently within a particular domain, then a loss in signaling
efficiency (and an increase in information costs and transaction costs
incurred by users) would result. The remedy for this would be for all
registrars for a particular domain to enter into and clearly disclose
concrete agreements regarding any minimum set of terms and conditions that
will be applied by all registrars to applicants for registration in that
domain.
3. The U.S. Government (and other governments) should make clear that
collaboration and agreements designed to produce a responsive and
responsible domain name governance system are not violations of antitrust
laws. Governments should also take all available steps to protect those
engaged in creation and administration of domain name governance systems
from risks of litigation and liability that would otherwise chill this
important activity that serves the public interest.
4. While there is merit in any proposal that preserves universal
addressability, some addressing schemes may reasonably require certain
actions and/or agreements on the part of the user before they provide
access to the addressed sites. For example, web sites may require
registration and agreement to particular terms as a condition of access.
Certain subdomains, such as those used by software agents, might operate
in a similar fashion. Rather than seeking to eliminate such barriers, the
government should support the general principle that fully disclosed terms
and conditions for access to online spaces should be enforced, as a matter
of contract law, unless they violate commonly accepted trade practice
applicable to electronic commerce. New technologies and experimental
addressing schemes should also be encouraged so long as they do not cause
undue confusion or interfere with the functionality of established and
widely relied-upon systems.
5. Any domain name governance system should be designed to work
generally with all functional domain names, including those associated
with country codes. Insofar as the government of a particular country
asserts a desire and obtains the means to set policy with regard to its
country code domain, the degree of competition allowed or required for
provision of registration services with respect to such country code
domain should be determined by the public policy of that country, subject
only to a requirement that all registrars, including those operating with
respect to country code domains, should comply with generally applicable
trade practices as established by contracts among such registrars. Insofar
as a particular registrar sets policies that conflict with those agreed to
by most other registrars, the majority group should have the right to
cease cooperation and interconnection with those implementing conflicting
policies. Delegation of responsibility for registration for top- level
domains, including country code domains, should take account of the
desirability of preserving a consistent and widely agreed upon policy
regime for all domains.
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. Private sector self-governance for the domain name system,
including policies applicable to the issuance, registration, revocation
and use of domain names at all levels, must take the form of a
multi-tiered contract regime. The accountability of such a system comes
from the fact that each actor at each level -- end user, domain name
registrant, registrar, and collaborating registrar groups and their agents
-- must voluntarily agree to specific contract terms and conditions that
define the rights of various parties with respect to the domain name in
question. Governments may, of course, become parties to such contracts in
their capacities as users of certain portions of the domain name system.
The resulting contracts will provide a flexible regime informed by those
who know most about and care most about the growth of global electronic
commerce. Such contracts should be enforced under local law unless they
violate commonly accepted trade practice or are found, by appropriate
dispute resolution mechanisms, to violate rules the parties are
contractually bound to obey.
2. While consensus is a laudable objective, there will always be
disagreements among some parties regarding what rules ought to apply to
the domain name system. It is not feasible to resolve such disputes by
means of electing representative legislative fora or writing mandatory
rules that could be imposed "from the top down," whether by local law or
international treaty. To the contrary, the best means of developing
commonly accepted and workable rules for administration of the domain name
system is to enter into multiple contracts that, collectively, "from the
bottom up," define the rights and responsibilities of the parties.
Registrants can and will decide what terms and conditions to accept in
connection with their use of particular second-level domains. Registrars
will need to attract registrants by offering acceptable terms -- and to
avoid serious risks of liability by avoiding practices that unreasonably
and unjustifiably impose harm on third parties. It is critical for the
development of this private contract-based system that governments make
clear that they will not intervene to impose rules on the participants and
that they will seek to provide a shield against antitrust and tort
liability for those engaged in good faith in the development of such an
open, responsible, and responsive self-regulatory regime.
c. These self-governance mechanisms should recognize the inherently
global nature
of the Internet and be able to evolve as necessary over time.
1. No one country can assuredly establish jurisdiction over, or set
rules for, all participants in any given Internet domain. Even country
code domains are used in many instances by parties that are not physically
within the jurisdiction of the particular country in question, nor bound
by its laws. Moreover, the pervasive availability of materials sent over,
or located on, the net means that non-territorially based addressing can
be very useful and most appropriate in many circumstances. Insofar as the
terms and conditions applicable to use of such addresses is based on
contracts, such rules may be easier to enforce on a global basis than
would be the rules or decisions of any particular country.
2. The Net is still evolving rapidly and it is reasonable to expect
that the demands placed on Internet identifiers will change quickly.
Necessary flexibility is most likely to come from decisions made by
private sector participants.
d. The overall framework for accommodating competition should be open,
robust,
efficient, and fair.
1. Openness to competition should be assessed not just with respect
to the potential role of competing registrars but also with respect to the
question whether those seeking to register and use a Net identifier have a
maximum degree of freedom of choice with respect to the nature of such
identifiers and the terms and conditions under which they are obtained and
used.
2. Reliability of domain name resolution, including assured
uniqueness of such resolutions and the continuous availability of needed
root servers and databases, can best be assured by means of inclusion in
contracts among registrars and between registrars and root servers of
appropriate terms limiting participation in the mainstream system by those
who do not avoid duplicative addresses or do not meet applicable technical
reliability standards.
3. Any particular role, including provision of root servers,
registration of domain names, and operation of centralized registry
databases, should be open to those who meet reasonable qualifications.
Where there is a limitation on the number of parties who can play a role
at any given time (such as the need to operate one centralized database
for any particular domain), the selection of the party to play that role
-- and the terms and conditions under which the selected party performs
such services -- should be set by means of a contract entered into between
that party and the beneficiaries of such services. Thus, the registrars
for any particular domain should contract with the provider of the central
database services and should reserve in that contract the right to replace
such central database administrator for cause or on other specified
conditions. Similarly, the registrars for all interconnecting domains
should contract with those who provide the root servers that make it
possible for end users to find applicable domain databases, and may agree
among themselves on the terms on which new qualified registrars will be
admitted to the group.
4. In order to be "fair," the contractual agreements entered into
among participants in a particular domain name administration system need
not have been subject to individualized negotiation. The fairness of such
systems of contracts will stem from the facts that (1) to be bound by the
rules, the participants must have voluntarily entered into the agreements
that implement such systems, and (2) those who are not willing to accept
the terms and conditions available from any particular set of participants
remain free to deal with other groups or to set up their own system of
interrelated contracts. The robustness and efficiency of the system will
come from competition among private parties to build reliable and
cost-effective systems that attract end users. Such competition and
overall "fairness" can only be preserved if the system remains "open" in
the sense that anyone who thinks they can develop a better system, without
breaking or otherwise interfering with the operation of the existing
system, remains free to do so. Preserving this openness requires that no
centralized body be given the power to prohibit the creation of sets of
contracts and operational procedures that might otherwise create
responsible competing regimes.
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. Conflicts are sure to arise regarding the use of Net
identifiers. These conflicts will involve application and interpretation
of particular contract terms, claims regarding rights to continue to use
(or to revoke or transfer) particular identifiers, and some concerns
regarding confusion, dilution or infringement of trademarks and trade
names registered under various local legal regimes. Resolution of such
conflicts will be most efficient and prompt if alternative dispute
resolution (ADR) methods are used. If resort to, and compliance with, such
ADR procedures were required under contracts among the participants, the
resulting decisions could be enforced efficiently on a global basis.
2. There will always be some risk that a conflict will involve a
party who has not contractually agreed to use efficient ADR methods or to
abide by the results of a fair process widely accepted by participants in
electronic commerce. Such a risk of "end runs" should be minimized by
requiring all participants in electronic commerce expressly to agree that
all disputes primarily relating to such participation should be resolved
by means of ADR. Governments should expressly support such ADR procedures
and should take the view that it is fair and permissible to require all
participants in global electronic process to be required to resolve their
disputes in this manner. Reservation of the rights of all parties to seek
separate remedies in local courts will merely prolong and complicate
disputes, often to the detriment of all involved. Any parties who have not
entered into such agreements to use ADR may reasonably be identified as
such, so as to allow those who do not wish to deal with such "holdouts"
to avoid doing so.
3. The mechanism provided for ADR should maximize the ability of the
parties to a particular dispute to choose among a wide range of neutral
and expert mediators, arbitrators, or other decisionmakers. In light of
the global character of the Net, and the presence online of most likely
parties to disputes, such ADR mechanisms should make maximum use of online
means of presenting the parties' arguments and reaching and publishing the
needed decisions.
f. A framework should be adopted as quickly as prudent consideration
of these
issues permits.
1. Insofar as a robust and open framework will evolve from the
bottom up, as a result of contracts entered into among participants in
global electronic commerce, there is no need or occasion for any rush
towards promulgation by any "authoritative" body of any "top down" set of
rules. But it would be helpful for all governments promptly to make clear
that they will enforce the contracts entered into by the parties and that
they will shield those engaged in creation of a responsible and responsive
governance mechanism from risks of antitrust and tort liability.
2. Insofar as the U.S. Government subsidizes or provides particular
elements of the domain name system, it should promptly make clear the
specific terms and conditions on which it will continue to do so. Insofar
as the U.S. Government uses the domain name infrastructure, it should
enter into agreements consistent with those acceptable to most private
participants.
Other principles
1. No government should reserve the right to pass laws or make
policies applicable to persons or resources not within its physical
territory. In particular, the mere fact that practices engaged in by
those administering the Internet identifier systems might have an impact
in any particular country, based on the accessibility of the Net from
within that country, is not sufficient to support a claimed right of any
such country to regulate the terms and conditions under which Net
identifiers are issued or used.
2. No single group of private (or even "public interest") actors may
legitimately claim the right to set rules or establish mandatory practices
applicable to the issuance and use of Net identifiers, regardless of the
relationship of such group to historical means by which such rules and
practices have evolved. Instead, the claim to legitimacy of any set of
rules must stem from the entry by appropriate participants into binding
contracts that embody those rules.
B. General/Organizational
Framework Issues
1. What are the advantages and disadvantages of current domain name
registration
systems?
1. The mnemonic character of domain names is very valuable, not so
much for its "guessability" but rather for the aid it provides for
preserving relevant addresses in short term human memory.
2. The variety of terms and conditions under which Net identifiers of
all types can be issued to end users is very valuable.
3. The current relative speed and relatively low costs associated
with issuance of domain name registrations should be preserved.
4. There is now an unfortunate level of uncertainty regarding the
extent of rights to prolonged use and enjoyment of registered domain names
and concerning the specific terms and conditions under which such use
occurs (including questions regarding the procedures by which such terms
and conditions may be established and changed).
2. How might current domain name systems be improved?
1. Domain names could provide substantially more meaningful
information regarding the character of the party using a particular
address, or the nature of the material or service found at a particular
address, or the terms and conditions under which a particular identifier
is used, could be improved substantially, insofar as applicable sets of
terms and conditions were more clearly established and reliably enforced.
2. Uncertainties regarding the extent to which continued use of
domain names is assured to registrants (and regarding who sets the terms
and conditions under which registration under particular domains is
offered) should be reduced.
3. Costs associated with resolution of disputes between domain name
holders and owners of trademarks should be reduced.
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. The party accepting an application to register a domain name
should have a clear and assured right to provide the registrant with
accurate information regarding the availability of the name, with reliable
entry of the registration, and with stable and secure enjoyment of the
rights to use such name in accordance with applicable contract terms.
2. The party operating a central database of registrations for any
particular domain should be able to provide reliable service to the
registrars and, indirectly, to registrants.
3. A party providing root server services should be contractually
obligated to participating registrars to provide reliable and responsive
service.
4. There need not be, and should not be, any single central entity
whose agreement or permission is required as a condition to establishment
of what would otherwise be a domain name system that does not break or
interfere with established systems, cause undue confusion, or infringe
third parties' proprietary rights.
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 core decisionmaking process that ought to underlie any
domain name system is the entry by participants into binding contractual
agreements.
2. The proper role of governments is to enforce such agreements,
unless they violate antitrust laws or other public policies. As long as
the agreements provide for open processes, they should be found not to
violate antitrust policies. In assessing the limitations provided by
"public policy," governments should look to the "trade practices"
established by participants in global electronic commerce. Governments
should also provide immunity from tort liability for those engaged in
creation of responsible and responsive self-governance mechanisms for 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?
1. Many private parties have made major investments based on
assumptions regarding the continued availability of the .com registry and
other top level domains. Little is to be gained, and much would be lost,
by elimination of such domains.
2. Because the Net is accessible on a global basis, use of
nonterritorial domains is appropriate and useful in many contexts. Any
required use of country code identifiers would be most unlikely to
eliminate or substantially reduce uncertainties or conflicts regarding
application of local laws. In particular, there is no necessarily valid
inference that those operating within a country code domain are bound by,
or found within, the jurisdiction of that country's laws. Efforts to
require contractual agreements that condition operation within a country
code domain upon submission to that legal jurisdiction would create
increased confusion and conflicts of laws: the enforcement of such
contracts would still be contested in other jurisdictions, persons from
different domains would still need to interact, and the cost of locating
and applying local laws to particular cross-boundary transactions and
disputes would still be substantial.
3. While it may be possible in theory to separate gTLD management
issues from questions about country code domains, there are many reasons
to adopt a single policy paradigm for all top level domains. Sound
operation of a core root server function probably requires that the root
server operators have the same contractual relationships with all the
cooperating registrars they serve. Confusion and operating costs will be
reduced, if as many top level domain registrars as feasible enter into a
cooperative agreement. The potential for confusion, abuse and infringement
exist in all top-level domains -- so any applicable policies and
dispute-resolution procedures designed to deal with trademark issues will
operate most effectively if applicable to all top-level domains. This is
not to say that all top level domains must have the same sets of policies,
procedures, rules, and terms and conditions for registration. To the
contrary, any standardization should be adopted only to the extent this is
voluntarily agreed to among participants, based on what appears necessary
to achieve the most reliable and flexible and valuable system.
Nevertheless, the policy paradigm should allow for the possibility that
all types of top-level domain registrars may want to agree upon some core
(i.e., standardized) rules or practices.
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?
1. There does not appear to be any technological means of
eliminating the possibility that a domain name or other Net identifier may
be used in a fashion that creates confusion regarding the source of
information or services. Some set of rules and dispute-resolution
procedures is needed to deal with this problem on a global basis.
2. There are many other issues relating to domain name registrations
as to which there is no purely technological solution. Questions regarding
how to set applicable fees, whether and when registrations must be renewed
or may be revoked, and issues regarding any terms and conditions imposed
as a prerequisite to issuance and use of a Net identifier all raise
"policy" questions. Such questions must be dealt with by means of (1)
unilateral choices made by participants on the net, (2) agreements reached
among such participants (and their agents and service providers), and, as
a last resort, (3) laws imposed by local sovereigns (via application to
particular actors within their jurisdictions or, in concert with other
nations, by treaty).
3. Insofar as operators of root servers provide a service that is
needed to allow decentralized name server software to locate the databases
containing definitive information regarding particular top-level domains,
both domain name holders and registrars have a vital stake in the reliable
operation of such root servers (under policies that serve the interests of
ISPs and end users). Accordingly, it may be advisable to transition to
operation of root servers by actors who serve as contractually obligated
agents of groups of 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?
1. Root servers can continue to interoperate and coordinate, either
by means of reaching agreements among themselves or by means of agreeing
to operate on behalf of, and under directions from, a set of registrars
that have agreed to coordinate their own actions. It may not be feasible
or necessary to attempt to require that the operator of any computer that
resolves inquiries regarding the location of domain name databases must
operate under one uniform set of operational terms. As long as separate
operation of supplemental root servers does not "break" the generally
acceptable system, the worst impact of such "supplemental" root servers
may be simply that the Net will have failed to that extent to achieve
consensus around a single, universal standard. Some experimentation
around the edges of any given system seems highly desirable. If
experimental systems "break the Net" or interfere with the reliable
operation of existing domain name systems, then the operators of the
mainstream domain name (and IP address) allocation systems could take
effective action to disable the "interfering" source (or those knowingly
hosting it). 8. How should the transition to any new systems be
accomplished?
1. Assuming general agreement among participants upon a standardized
set of interlocked contracts, the U.S. government could greatly facilitate
an orderly transition by: (1) directing the root servers under its control
to point to domains that are operated in conformance with such mainstream
standard agreements; (2) directing any agencies or contractors that it
controls or subsidizes (IANA, InterNIC) to transfer any assets or
prerogatives under their control to those operating the new system (in
conformance with the generally agreed upon contractual terms); and (3)
entering into such standard contracts, in its capacities as a regular user
of the net, as a holder of various second-level and top-level domain
names, as an operator of a registry/registrar (e.g., .mil), and as an
operator of root servers.
9. Are there any other issues that should be addressed in this area?
1. Most people want a system in which each node on the network can
locate and address every other public node, by means of mnemonic domain
name lookup. Local domain name server software must have a way to locate
the databases associated with every commonly recognized domain name. This
implies pointing to a "root" server, and a set of multiple root servers
that are kept "in sync" by common agreement. Only those domains that are
recognized by the central, synchronized, mainstream root servers will
appear to most users of the net. Accordingly, the key question may be for
whose benefit the mainstream root servers agree to operate.
2. No one government has complete control over the establishment and
regulation of root servers. While the U.S. Government subsidizes many root
servers, others could be cheaply established. Ultimately, ISPs who run
domain name servers have control over which root servers their server
software targets. Therefore, large ISPs, who could subsidize the creation
of root servers, and the updating of name server software, will select the
root server operators and control the agreements among root servers
regarding what domain names to recognize.
3. Large ISPs must compete for customers. Insofar as large numbers of
customers, particularly those who seek to register second-level domains,
insist on some specific practices by ISPs with regard to relationships
with the domain name registration and lookup system, such practices will
likely prevail.
4. Anyone seeking to establish a new top-level domain must obtain the
agreement of the dominant root servers to point to the database that
represents the domain. Anyone seeking to establish a second-level domain
name must find some way to register it in a database that allocates unique
second-level domains to particular parties.
5. There are thus four distinct and important types of contracts that
must be entered into (explicitly or implicitly) to make the domain name
system work: (1) an agreement among root servers to point to particular
sets of domains and to update data consistently, (2) an agreement among
registrars/registries not to take actions that cause conflicts and to take
actions to protect the integrity of the domain name system, (3) an
agreement between the party registering a second level domain to abide by
the terms and conditions made applicable to such registration by the
registrar/registry, and (4) an agreement between an end user and an ISP
with regard to the terms and conditions for use of a net identifier (such
as an email address or subsidiary web page address), which carries with it
some terms regarding access to domain name lookup software and stability
of the higher level domain registrations.
6. There is no necessary relationship between the system used to
allocate domain names and the system used to allocate IP numbers. But many
of the same questions regarding fairness, open systems for formulating
policy, protection of reliance interests, and relationships to national
laws are similar for both systems.
7. Any given registrar (or group of registrars, or, derivatively,
group of root servers or ISPs with an interest in the subject matter) may
have reasons to want to preclude or revoke registrations of particular
domain names (on the ground that they infringe third party rights, offend
others, have been used to facilitate violation of some core net "public
policy" or local law, etc.). Registrants of particular second level domain
names may have reasons (such as substantial investments in reliance upon
such registrations) to want to be sure that their registrations cannot be
revoked without just cause and due process.
8. Local courts and local laws must be relied upon to force the
parties to contracts relating to the use, registration and revocation of
domain names, and the operation of the domain name system, to abide by
such contracts. But local laws need not be the source of any special rules
applicable to the domain name system. Insofar as submission to
international specialized online arbitration is made a mandatory condition
of participation in the domain name system, that arbitration process can
become the sole source of decisions regarding interpretation of the
contracts.
9. Insofar as third parties (who have not entered into the relevant
contracts) advance claims in local courts regarding alleged harms from the
operation of the domain name system, and insofar as some parties who have
entered into such contracts seek to avoid their obligations by claiming
that such contracts are unconscionable or violate "public policy," local
courts and local laws can and should defer to "trade practice" among those
participating in electronic commerce to determine what is reasonable.
Accordingly, the domain name system can and should be supplemented with a
mechanism for determining what contract terms participants on the Net
consider to be unenforceable. Local laws should override such Net-based
"public policy" determinations only when local authorities have clear
jurisdiction over all the parties and when the interests of the local
jurisdiction in the resolution of the matter clearly exceed the interests
of participants in global electronic commerce.
10. The mechanism for development of "Net public policy" can take the
form of (1) decisions in the course of the arbitration process, if these
are published; and (2) deliberations online among parties with appropriate
levels of interest and expertise. There is no need for codification of
such deliberations into a "statutory" code -- and any effort to reduce
such policies to authoritative texts would risk rapid obsolescence. To the
contrary, the substance of online discussions of such questions should be
made available to decisionmakers (both the arbitrators with jurisdiction
over Net participants and the local courts hearing claims from those who
do not participate on the net and who are therefore not bound to engage in
arbitration of their claims) who are faced with concrete questions
regarding how to interpret and whether to enforce particular contract
terms.
11. Various domains and subdomains should be free to adopt differing
terms and conditions for registration, use and revocation of net
identifiers, subject to the public policy override and the terms of
particular contracts into which they have entered voluntarily.
12. Local governments should decide that the system of contracts
governing the domain name system is not a violation of any antitrust laws,
provided that the contracts (1) do not exclude participation by would-be
entrants other than on substantively reasonable grounds (involving a valid
business purpose) and (2) do not leverage any claim to intellectual
property rights (or any monopoly over any resource required for
participation in the domain name system) into a special competitive
advantage for one party (or closed group) with respect to any aspect of
the domain name system that would otherwise be open to competition.
13. It will be useful for all participants in the domain name system
to have ample notice of the likely terms and conditions under which
additional top-level domains may be added and administered. The root
servers, and the existing registries, and key ISPs, should, therefore
promptly enter into an agreement setting forth the mechanisms to be used
to create new domains and the key terms and conditions all agree should be
applicable to all registrars/registries.
14. It is unclear whether particular local laws will be found to
apply to the registration and use of country code domains. Each registrar
for each country code domain should promptly make clear its policies with
regard to the application of local laws, the required submission of claims
to particular local or international arbitral dispute resolution, and any
other terms and conditions applicable to registration and use of country
code domains. Insofar as any such terms and conditions are inconsistent
with general "Net public policy," and not justified by vital local
interests that outweigh the general interest of all participants in global
electronic commerce in establishing the contrary rule, then the contracts
among registrars and root servers may provide for cancellation of the
delegations of responsibility for registration under such country code
domains.
15. The contracts among root servers and registrars may provide for
rules of various types designed to prevent or punish (1) failure to pay
reasonable fees supporting operation of the domain name system and
particular registrars/registries; (2) creation of confusion regarding the
identity or nature of particular parties or online addresses; (3) failure
to provide appropriate operational security and reliability; (4) actions,
such as fraud, theft or vandalism, that inflict unjustifiable harm on
third parties; or (5) failure to abide by the terms of applicable
contracts, including obligations imposed as a fully disclosed condition of
entry into a particular online space (unless such contracts violate Net
public policy).
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?
1. Insofar as gTLDs serve as mnemonic devices, which help people
remember locations on the net (and, to a much lesser extent, to "guess"
locations corresponding to existing commercial and noncommercial
institutions), expansion of the number of gTLDs could somewhat impair that
function. On the other hand, a finite number of new gTLDs with easy to
recognize and meaningfully distinct names might enhance that function.
2. The root server system probably cannot deal with an arbitrarily
large number of gTLDs, because it represents a centralized resource that
must address and update multiple copies of a single database.
11. Should additional gTLDs be created?
1. There is no clearly right or wrong answer to this question. The
best way to evaluate it is to allow the creation of new gTLDs by
responsible actors, in the context of an overall governance system that
responds to the needs of those participating in global electronic
commerce, and then see whether potential registrants sign up. If users
demand the new gTLD registrations and other registrars can coordinate
successfully with the new entrants, the answer is "Yes." If no one signs
up, or the new gTLDs cannot be successfully integrated operationally (and
by contract) with the existing system, the answer is "No."
12. Are there technical, business, and/or policy issues about
guaranteeing the
scalability of the name space associated with increasing the number of
gTLDs?
1. It is increasingly difficult for particular registrants who want
a non-country-code domain name to find satisfying second-level domain
names in the most popular ".com" top level domain. Creation of some
alternative gTLDs could help to alleviate these problems and, helpfully,
enhance the growth of global domain names that can operate under diverse
rules responsive to various constituencies.
13. Are gTLD management issues separable from questions about ISO
country code
domains?
1. Insofar as gTLDs use distinct registrars and establish separate
policies, their administration is separable. But the same root servers are
used for looking up both gTLDs and ISO country code domain databases -- so
any set of agreements or systematic means for administration of the most
widely used root servers must deal with both types of domains. Moreover,
insofar as trademark protection or other policy questions potentially
relate to all domain names, it is impossible to resolve such policy
questions by means of management structures or agreements that relate only
to one portion of the domain space.
14. Are there any other issues that should be addressed in this area?
1. One key issue in this area is whether only one person or entitye
will have the power to decide as to whether or not to create new gTLDs.
If so, then numerous subsidiary questions arise concerning how to make
that person or entity accountable to the full range of participants in
online commerce, all of whom are impacted by such decisions. If not (i.e.,
if it is possible that the decision to create new gTLDs might be made by
multiple parties, in a decentralized fashion), then the question is
instead how the decisions of such parties might be coordinated or
constrained to avoid unnecessary and counterproductive conflicts (or other
vices). It appears that decisions to create new gTLDs might be made by
many people, in a decentralized fashion, and yet still result in a
responsible and responsive system, insofar as the widespread use of a
particular new gTLD would require willingness on the part of mainstream
root servers, acting as agents of mainstream registrars, to point to the
new gTLD. A community of responsible actors, coordinating their activities
by contract, can serve as a mechanism that tests and accepts new proposed
operating procedures that originate from decentralized sources. This is
the standard mechanism of open standards processes. Its feasibility
suggests that there is no need to centralize power in any one "political"
body in order to preserve the reliability of the mainstream Net.
2. Insofar as an important determinant of the value of a new gTLD is
its presence in the database used by the predominant root servers, and
insofar as the U.S. Government administers or supports many if not all of
the root servers at present, another issue is what constituencies the U.S.
Government should seek to serve in the course of deciding whether and how
to open up such root servers to point to new gTLDs or to transfer its
prerogatives in that regard to private parties. A related, perhaps
subsidiary, question is who will make and implement those decisions on
behalf of the government. Having helped to launch the Internet, the U.S.
Government should now serve the long-term health and growth of Net
self-regulation by acting through a single policy arm to empower (and
contract with) the parties who appear to be engaged in constructing the
most responsible and responsive web of contracts dealing with these
issues.
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?
1. While shared gTLDs have not been widely demonstrated in
practice, with some limited exceptions (such as the delegation of
registration role by Nominet to third parties), there does not appear to
be any theoretical limit on the use of a single domain name registration
database by multiple parties, each of whom offers to enter into a
registration agreement.
2. On the other hand, there is no reason why some gTLDs might not be
served by a single registrar on an exclusive basis while other gTLDs were
administered on a shared basis. An exclusive registrar may make it more
difficult to transfer a registration to another registrar, within the same
domain, for purposes, for example, of seeking the lowest registration fee.
But an exclusive registrar might also be able more effectively to promote
the value of a particular gTLD and might, therefore, be able create more
value for consumers. The market ought to be able to choose effectively
between the two models.
3. One problem with shared registries could arise if the registries
are allowed or encouraged to established widely varying terms and
conditions. Insofar as domain names serve as concise means of signaling
that a particular registrant has entered into a specific contract
applicable to that domain (and required as a condition of registration by
the registry), the sharing of registry duties among unrelated third
parties could operate to make it less clear whether the holder of any
given domain name has agreed to any particular set of obligations
(including, e.g., the obligation to provide accurate name and address
information, or to comply with requirements that only certain types of
entities use particular domains, etc.)
4. If domain names cannot really be made portable, in the sense that
the full terms and conditions initially agreed to by a registrant cannot
be transferred by that registrant at will to assure continued operation of
the domain name under such terms and conditions, regardless who performs
the registration function, then there will be more pressure to assure that
registries are substantial, responsible parties and that such registries
are not subject to arbitrary revocation or alteration of their rights by
means of actions of other groups (such as a council of other registrars).
This will lead thoughtful and careful registrants to insist on the
creation of a web of contracts that establishes, in effect, enforceable
property rights with regard to domain name registrations.
16. Should there be threshold requirements for domain name registrars,
and what
responsibilities should such registrars have? Who will determine these
and how?
1. The marketplace should determine this, insofar as registrants
can decide unilaterally whether to deal with a particular registry and
insofar as other registrars can decide whether and on what terms to agree
to work together to create a shared domain registration database, or to
coordinate their activities as a council of registries. The mainstream
group of registrars need not reserve the right to prohibit formation of a
new registrar -- because they can simply decide not to allow an
irresponsible registrar (or one not otherwise willing to adopt generally
agreed upon standards for operations or policy) to join the core group
(and they can direct root servers operating as their agents not to point
to an irresponsible domain).
2. A more serious question is posed by the likely decision of any
would-be registrar to challenge in court or before some local authority
the decision of a mainstream group (which by its actions is defining and
enforcing generally accepted standards) to exclude it. A decision by a
local authority that the mainstream group must admit a member that the
group does not deem qualified would be tantamount to a finding that the
mainstream group may not develop and apply such a standard. If the
private group applies criteria that have a valid purpose connected with
the improvement of the Net, rather than being designed solely to place the
interests of a small identifiable group of participants ahead of those of
their competitors, then the decisions of the private group should receive
deference. If the private group conducts its affairs in the open, and
regularly welcomes input from third parties, and appears genuinely willing
to enter into applicable contractual agreements with anyone meeting its
publicly articulated criteria, and applies its criteria to concrete cases
by means of processes that afford notice and a reasonable opportunity to
be heard by a neutral decision-maker, then its decisions also deserve
deference on that account. Governments should support these principles in
applying their antitrust laws and in ruling on (and precluding) tort
claims made by those who challenge self-regulatory systems.
17. Are there technical limitations on the possible number of domain
name
registrars?
1. Insofar as a registrar can serve merely as an agent for purposes
of finding registrants and entering into agreements with such registrants
on terms and conditions specified in advance, and subject to confirmation
by a central database that the domain name for which registration is
sought is available, there do not appear to be any such limits.
2. Insofar as each registrar might have exclusive duties with regard
to a particular domain, then the limitations on the number of registrars
would stem from limitations on the ability of root servers to store and
update information about multiple domains.
18. Are there technical, business and/or policy issues about the name
space raised by
increasing the number of domain name registrars?
1. There are already approximately 200 distinct top-level domains
and even more registrars. As their numbers increased substantially, there
might be some added expense or difficulty in coordinating their
activities. But, in general, there are substantial reasons to want to
have a large number of registrars, with various diverse policies regarding
registration and with a presence in and responsiveness to a very large
number of differing communities of potential registrants.
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?
1. The marketplace can provide an answer to this question. Insofar
as operation of registries for multiple domains makes a registrar more
efficient and effective, then domains under the control of such a
multi-domain registrar should prosper. Insofar as such operations detract
from the registrar's ability to serve each separate community of
registrants, potential registrants will seek out alternatives.
20. Are there any other issues that should be addressed in this area?
1. One major question that has not been fully enough explored is
the extent to which registrars are or should be constrained in terms of
their right to revoke registrations on particular grounds. Any widely
accepted system will need to provide, by means of enforceable contracts or
other means, adequate protection against "hold up" fees and security
sufficient to allow registrants to invest in reliance on the continued
availability of the domain names they have registered.
2. Another key question that has not yet been fully discussed is the
extent, if any, to which a domain name registrar may claim intellectual
property rights in the database(s) resulting from registrations, or,
indeed, may make any use of such information other than as required to
further the goals of the registration system. Such rights might
appropriately be established and defined by means of contracts between
registries and registrants -- and constrained overall by the standards to
which registries must agree as a condition for entry into a mainstream
coalition that prevents conflicts and oversees the operation of root
servers. But it appears that most registrants and registries have not yet
paid adequate attention to these issues.
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. Uses of domain names on the Internet to indicate a source of
goods or services can be infringing or diluting of traditional marks. But
trademark law now relies heavily on the geographic separation of
marketplaces (most marks are valid only within particular geographic
territories) and on the applicability of marks to particular lines of
business (often facilitated by the attachment of marks to physical goods).
Insofar as domain names are global and do not necessarily and clearly
relate to any particular line of business, they present a new set of
problems. Moreover, insofar as they may include generic terms (e.g.,
"sneakers.com") and are widely used for noncommercial purposes, domain
names present certain distinct questions relating to confusion, dilution,
and fraud that are not solved by any existing trademark laws.
2. If we were addressing these questions ab initio, we would want to
create a system that (1) provides unique, reliable resolution of domain
names to particular IP numbers, (2) prohibits the use of confusingly
similar or identical domain names under circumstances in which such uses
will lead to confusion on the part of users (or fraud, passing off, or
other well-recognized forms of unfair competition), (3) provides clear and
prompt notice to all concerned regarding which domain names are already
"taken" and which proposed new names will create unjustified harms to
users of existing names, (4) allows full use of the domain name space for
noncommercial as well as commercial purposes, (5) avoids unnecessarily
destroying any values associated with substantial investments in brand
names, (6) avoids rewarding those who reserve names for the purpose of
"hold ups" or otherwise take opportunistic actions without substantial
economic or social justifications, and (7) applies and is enforceable,
with prompt and efficient dispute resolution, on a global basis.
3. The best way to serve these goals is to recognize that, while
domain names can infringe trademarks, they represent a distinct form of
identifier that differs in material respects from traditional marks. We
should develop, by contract, a global regime that is based on and respects
the unique characteristics of these identifiers. That regime can and
should respect the interests of parties with established, globally famous
marks -- as it respects the interests of established, globally accessible
domain names that may or may not be used for commercial purposes. Insofar
as most of the owners of globally famous marks will want to participate in
the Internet, and will therefore want to become signatories of the
registration contracts that form a key component of the domain name
system, it should be possible to resolve the conflicts between domain name
holders and trademark owners, pursuant to such contracts, whether these
conflicts relate to substantive rules regarding rights or to procedures
used to resolve particular cases. Any trademark owner who did not agree to
reasonable and commonly accepted terms applicable to protection of both
domain names and trademarks could be denied a registration. Any domain
name at risk of infringement liability claims from such a rare hold-out
could be reserved or perhaps issued only at the risk of the registrant. In
most cases, both trademark owners and domain name registrants will
recognize the novel character of these new identifiers and will agree to
be bound by rules and dispute resolution procedures that give all
concerned adequate notice of both their rights and any limitations on
those 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. Because many trademark rights are established by use, rather
than registration, it will be very difficult to be sure in advance (or
even shortly after registration) that any particular domain name does not
conflict with any and all marks in use on tangible products.
2. Preliminary review processes run the risk of imposing substantial
and costly delays on many parties, while providing meaningful guidance or
conflict prevention for very few.
3. The private sector will likely provide databases and lookup
services that do help potential registrants evaluate the likelihood of
conflicts.
4. As discussed below, a mandatory alternative dispute resolution
process, reference to which is required as a condition for registration of
a domain name, would be most likely to produce efficient, informed
decisions and to yield results that are enforceable on a global basis.
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. While many owners of strong marks may prefer to turn to national
and local courts to protect their marks, that preference is
inappropriately based on their ability to expend far greater resources on
litigation than can their typical adversaries. A better informed view of
their own self-interest would suggest that it will be easier for owners of
strong, globally famous marks to protect their legitimate interests if
their disputes are resolved by means of an arbitration process. Accepted
as part of the registration contract, arbitration would produce fair and
expert results and the resulting decisions would be easier to enforce on a
global basis than the judgments of local courts. Insofar as such awards
deal only with the issuance or revocation of domain names (as distinct
from injunctions against persons or the award of damages), such "in rem"
decisions should not be seen to raise serious questions regarding the
jurisdiction of local courts or governments. In contrast, remitting
decisions regarding domain names to local courts could well lead to many
conflicting decisions and, while unfairly favoring the interests of
parties with superior resources, would also impose substantial costs on
all participants in global electronic commerce.
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 domain name system is itself a distributed database that
contains extensive information regarding the use of such identifiers.
2. The private sector already does supply products and services
designed to assist those who want to spot and avoid conflicts and
disputes. It can be expected to develop new offerings. Any attempt to
develop a definitive central database would artificially constrain the
growth and flexibility of the domain name system itself -- and probably
fail in attempting to prevent disputes.
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. The requirements imposed as a condition of registering a domain
name should be established as a matter of contract between the registrant
and the registrar. Insofar as a number of registrars agree among
themselves to require a particular item of information, or a particular
contractual undertaking on the part of the registrant, that requirement
should stem from an agreement among registrars who must at least
potentially compete with other registrars who might not agree to impose
such terms and conditions.
2. It seems reasonable to require a registrant to warrant that it
does not know that its use of a domain name will infringe the rights of
third parties. It seems much less reasonable to demand a demonstration
that there cannot be any such disputes -- much less that the registrant
establish some affirmative right or "basis" on which to claim the use of a
particular second level domain name. If the name is not in use, and is not
known to be likely to infringe a third party's rights, then it should be
available to be issued. The number and diversity of theoretically possible
infringement claims is such that no one could reasonably certify that
their use will not create any difficulties. Moreover, the many
noncommercial and personal uses of domain names makes it highly
inappropriate and unjustified to require that all registrations be
conditioned on demonstrated possession of any specified forms of
intellectual property rights. Indeed, because of the many legitimate uses
of anonymity and pseudonymity, and the rapidity of change in the uses to
which domain names are put, it might well be unreasonable to ask for
specific real world identifying information as a condition to
registration, where this is not needed to assure payment of registration
fees, and it may also be unreasonable to require statement of any fixed or
specific purpose for use of a particular domain name. As noted, the
market, in the form of registrants deciding where to register, and
registrars deciding what terms to impose (on registrants and on
cooperating registrars), will best decide these types of questions.
26. How would the number of different gTLDs and the number of
registrars affect
the number and cost of resolving trademark disputes?
1. Some large companies apparently fear that proliferation of
numerous gTLDs will make it harder and more costly for them to protect
their marks. This concern seems overstated, in light of the fact that the
Internet provides many opportunities to automate the process of searching
for infringements. Insofar as the concern represents a view that it will
be hard to protect non-globally-famous marks in many gTLDs, because
holders of conflicting marks that are now used in other territories or
lines of business will be able to establish prior registrations of
particular domain names, the objections prove too much. Non-famous marks
should not be made easier to protect, as against other non-famous marks,
just because the owner of such marks is a large company that wants to
establish its brand globally. To the contrary, one reason to expand the
number of gTLDs is to create more space in which non-globally-famous marks
can co-exist.
27. Where there are valid, but conflicting trademark rights for a
single domain
name, are there any technological solutions?
1. By agreement, the owners of conflicting marks could establish an
intermediate page, at the domain name in question, pointing in multiple
directions. Such agreements are unlikely, however, unless the trademark
owners have roughly equally valuable (and otherwise "compatible") brands
and neither one of them establishes a prior right to the domain name.
2. In the vast majority of cases, this is simply not a problem that
is so serious that it ought to drive the design of the domain name system.
There are many alternative satisfactory domain names that might be
associated with any given trademark. Seriously and intentionally confusing
or infringing uses can be prevented or punished. Expansion of the gTLD
name space can also relieve this problem, insofar as it stems from
scarcity.
28. Are there any other issues that should be addressed in this area?
1. The challenge to the trademark system posed by the net does not
relate only to top-level domains. Confusing or infringing uses of marks
may be made in the context of any Net identifier, including third and
fourth level domains and even email addresses (and, indeed, direct use of
marks on web pages). Thus, any effort to deal with trademark protection
must take into account the fact that all Net identifiers, generally, can
be used to cause confusion and can be accessed globally. It may be that
the best way to deal with this problem is to encourage the adoption by
mainstream registrars and system administrators of contracts that include
among their provisions agreements to prohibit the use of Net identifiers
to cause unjustified harm to important property interests of third parties
and to revoke the registration or issuance of such identifiers by those
found by fair processes to have committed such wrongs.
2. Net identifiers may be used in various ways that create confusion
or mislead users but that have no connection to trademarks. We should
encourage the development of clear rules against such wrongful actions --
and foster private institutions that can apply such rules in a fair and
efficient manner.
###
Number: 288
From: "bobb@es.co.nz" <Bob.Berryman@panix.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 6:49am
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 Bob Berryman 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 15, 1997 06:48:06 EDT
Bob Berryman
------------------------
http://zero.tolerance.org
at@zero.tolerance.org
###
Number: 289
From: "editec@agate.net" <Guy.Chocensky@panix.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 2:21pm
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 Guy Chocensky 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 15, 1997 14:19:51 EDT
Guy Chocensky
------------------------
http://zero.tolerance.org
at@zero.tolerance.org
###
Number: 290
From: "cvision@leroy.cc.uregina.ca" <Ahasiw.Maskegon-Iskwew@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 4:25pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Ahasiw Maskegon-Iskwew 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 15, 1997 16:24:02 EDT
Ahasiw Maskegon-Iskwew
###
Number: 291
From: "janis@kkh.se" <Jaanis.Garancs@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 6:21pm
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 Jaanis Garancs 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 15, 1997 18:20:05 EDT
Jaanis Garancs
###
Number: 292
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 00:47:46 EDT
George Morris
###
Number: 293
From: "pit@icf.de" <Pit.Schultz@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 9:14pm
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 Pit Schultz 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 15, 1997 21:13:27 EDT
Pit Schultz
Berlin, Germany
###
Number: 294
From: "DRPRODS@AOL.COM" <Louise.Diamond@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/15/97 10:03pm
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 Louise Diamond 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 15, 1997 22:02:23 EDT
Louise Diamond
###
Number: 295
From: David Diano <dave@diano.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 12:39am
Subject: Comments:Trademark and TLD
To the weary people reading all of these suggestions:
I believe that part of the Trademark issue can be handled by a Top
Level Domain dedicated to that purpose.
I propose a .TM (or .TMK ) top level domain. This domain would be
restricted to only those companies with registered trademarks. The
"first-use" rule would still apply to .com, but the new .TM would be
controlled by legal registration of trademarks. (At least it would be no
worst than the problems that already exist in trademark law.)
In general, the top level domains should be broadened and should
reflect the current model used by the USENET newsgroups. The .COM name
is so overloaded that it no longer carries any useful information as a
category.
I basically agree with the following recommended tld's:
.web for entities emphasizing activities related to the World Wide
Web
.arts for entities emphasizing cultural and entertainment
activities
(although, should be .ART)
.rec for entities emphasizing recreation/entertainment activities
.info for entities providing information services
I suggest adding the following:
.law for legal services
.med for medical (hospitals, doctors, drug companies, etc)
.mag for current print magazines
.xxx or .sex for sexually oriented material
.kid or .k12 for child oriented material
.per for personal domains
.cty for local City governments
.env for environmental and conservational efforts (a global
problem)
.tm or .tmk for registered trademarks
I hope my comments have been helpful and will contribute to a general
consensus.
Sincerely,
David Diano
###
Number: 296
From: "Dan S. Tong" <drdancm@concentric.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 2:01am
Subject: Comments
It's quite clear to me, but apparently not clear to some of the authors
of the publicly listed comments, that the domain naming/administration
task is very complicated and requires a lot of background knowledge.
Since I am by no means even adequately knowledgable on this subject I
will confine my comments to general suggestions.
1. Whatever solutions are proposed and seriously considered they must
allow for the nearly unlimited expansion of domain names (3-5x the
population of our planet projected for the next 50-100 years, may be
adequate).
2. It would also be extremely useful at the same time to create a
universal unique ID/E-MAIL address system so that mailing addresses
would become portable for life and not be hostage to one's current ISP.
3. Domain names should be affordable (less costly than they are now)
and should be inexpensive to maintain (a small fraction of the initial
registration fee).
4. The administration should be efficient and cost effective-either
private (non-profit) or government run -but TOTALLY APOLITICAL. I am not
sure which would work best. I think the current administration has
worked reasonably well (except for recent big errors) and the overly
hight cost of registration and maintenance.
Sincerely,
Dan S. Tong, Ph.D.
Computer Consultant
###
Number: 297
From: "Thomas Thompson" <tomrt@muscanet.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 10:47am
Subject: Domains
Dear Sirs,
I believe that no private company should control the distribution of
domains. If the internet is going to be a true information media, no
private interprise should control the distribution. Right now the price
to obtain a domain is price inhibiting to some individuals.
Thomas Thompson
tomrt@mucscanet.com
###
Number: 298
From: "rev@starnetinc.com" <Ron.Vikara@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/11/97 8:31pm
Subject: Comments on Domain Names
My idea is to give all adult sites a .xxx so all filters
will work right. I think this must be the only way we the
people can let our kids and teens use the web.
A law should be writen to enforce it so no links can be
to any adult site that is not one itself. A good ext. can
be .ADT or .21 or some form. We can't stop the sex but we
can keep it hidden away. No jail time but to be kicked off
the net is a good way. and to setup a page to report crime
on the net. It a new world and the goverment has got to do
its part in it. Already child porn and drugs are being sold
over the net, whats next?
I have lots of ideas and I wish I had some say in what
would be the new police dept. (World-U.S. Net Police)
I would police the net.
Thanks for reading,
Ron Vikara
-------------------------------
Monday, August 11, 1997 20:29:51 EDT
Ron Vikara
Lets just say:
DuPage Co.
Illinois.
###
Number: 299
From: "J Johnson" <jjohnson@inneroffice.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 8:32am
Subject: domain names
After spending the better part of a month trying to come up with a new name
for my web site design business, only to find, each time, that the desired
domain name was already taken, it becomes obvious to me that assigning
addresses in the customary fashion simply won't work. I think that
addresses in the cyberworld should be handled the same way they are in the
tactile world - alpha-numeric designations given out systematically.
Search engines and "yellow pages" would then assist the traveler in
reaching their designation. We don't need any more reasons to feed
lawyers. This should not be an issue left to litigation.
The concepts of trademark infringement and plagiarism need to be examined
more closely. As the population of the world increases, ideas, especially
original ones, become harder and harder to generate. We still have only 26
letters in our alphabet. The combination makes a finite number of
acceptable words. As populations soar every one of those words gets used
more and more often. The only real hope for originality is to make up new
words that then become indicative of a product or service. Kleenex is the
best example I can think of - and that, boys and girls, ain't easy. Our
standards of originality must go up and we must begin to rely on the old
adage, "it's not what you have but how you use it" that becomes the
deciding factor. I occasionally supply answers for an advice column in
this area's primary newspaper. My answers are carefully researched and
even more carefully worded. On more than one occasion, I've later found
that entire phrases match, almost word for word, comments made on the topic
by others. This was not plagiarism on either my part or theirs. It simply
demonstrates that there are a finite number of combinations of words to
describe a particular idea. If many people describe the same concept
changes are very good that the answers will be similar. People don't read
anyway - "gotta have pictures" - and they are a whole lot easier to
regulate since Mr. Kodak has provided us with an endless supply.
Joy M. Johnson
jjohnson@inneroffice.com
jjohnosn@gamma4.com
###
Number: 300
From: "Henry Teutsch" <hbteutsch@msn.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 11:52pm
Subject: Proposed Domain Names
Hello I would like to add my comments to the public record regarding the
proposed domain names.
First I feel that these other organizations, other than the one which is
currently in charge of registering domain names, are criticizing the current
system because they are locked out of any profit involved with controlling and
registering domains. Also I believe these seven new domain names are an
attempt to by pass the current parties involved who seemingly have control
over domains and there registration. There would almost certainly be an
attempt to reregister such high profile names of the most popular name brands
by parties hoping to draw attention to their site or sell these names to the
perspective companies or it would force some companies to register there
current domains seven times over incurring seven times the current cost. This
could make a nominal fee available only to those with deeper pockets. If there
is any regulation where current domains such as coke or Pepsi could not be
registered by other parties under the proposed domain system then there is no
point in adding more domain name suffixes. If I own a domain under .com, that
may or may not be trademarked, could someone else register it under .web? If
not then the new proposal would not free up names like the backers claim just
add to the confusion. Domain names should be similar to a broadcast license.
Once used its unavailable to anyone else. There are millions of names still
available. The proposal is designed to make other people and companies money
and to give them part control over a system which is now generally free of
restraints and not controlled by any company. If the registration process were
run by American Online, Microsoft, or IBM it would be extremely difficult for
small companies to acquire names or buy into the Internet for commerce. While
these companies to my knowledge have been quite concerning these issues. The
smaller groups and organizations pushing these changes are hoping that they
will be catapulted into the realms of these big three corporations.
Finally the registration process in my opinion is not flawed. The nominal fee
is easily justified. But if critics prevail why not let the FCC register names
or create a semi-private company similar to the US postoffice which just
registers names and manages the main DNS database. I think there is
approximately 2 million domains registered. At $100 dollars per year per
domain name it is clear why people wish to add more possible names. The
registration business could be a billion dollar industry where it shouldn't
cost more than a postage stamp.
###
Number: 301
From: Daniel Dawes <ddawes@gj.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 8:20pm
Subject: Comments on Domain Name Registration-OCMUG
Attached are the responses of the Orange County Multimedia
Users Group, a group of 3000 multimedia professionals in
Orange County, So.Calif.
OCMUG Response to Domain Name Questions
Comments of Orange County Multimedia Users Group
August 12, 1997
A. Appropriate Principles
Responses to Questions a-f
a. appropriate - yes
complete - no. This principle provides no guidance to
conflict resolution or avoidance. Conflicts over domain
names should be removed from the system and placed into
mandatory alternative dispute resolution (ADR) by statute.
De novo trial in a court of competent jurisdiction may be
made available after ADR or preferably an opposition
procedure similar to that used before the Trademark Trial
and Appeals Board, TTAB, but using private judges instead.
During resolution both parties should operate under
appropriate suspense names. For example, if there were a
conflict on the name ibm.com, the two contending parties
during pendency of ADR would be assigned temp1ibm.com to
the senior party and the temp2ibm.com for the junior
party.
b. appropriate - yes
complete - no. While the private sector is more
likely to more efficiently administer name registration,
responsibility and accountability of registrants can only
be guided by statute and private agency regulation
empowered by law. Only the force of law has the power to
regulate name usage between registrant users of names on
the internet and nonregistrant users of names.
c. appropriate - yes
complete - no. The principle provides for no
direction for global evolution over time. National
organizations should join in an international congress to
deal with world level issues only, leaving national issues
to the national organization and providing for
proportional representation based on a periodic census of
the number of domain registrants.
d. appropriate - yes
complete - no. The principle provides for no clue to
what would be *fair* or how fairness can be determined in
any given instance.
e. appropriate - yes
complete - no. The principle provides for no clue to
what would be *fair* or how fairness can be determined in
any given instance.
f. appropriate - yes
complete - yes.
B. General/Organizational Framework Issues
Questions 1 - 4 and 6 - 8 are answered.
1. advantages: low price, quickness, public searchability
disadvantages: inability to meaningfully deal with
name conflicts or to provide a name structure where name
conflicts can be avoided.
2. The current domain name system can be improved by:
a. Removing name conflict from the net when it occurs by
issuing temporary suspense names and putting the disputing
parties into mandatory alternative dispute resolution.
b. The name structure can be improved by providing hidden
levels in the secondary name rather than splintering
primary domain names. For example, an address
columbia.com would return to the browser a selection tree
of Columbia(broadcasting).com; columbia(river
rafting).com; columbia(records).com; columbia(coffee).com;
etc. This would allow the many legitimate columbias which
operate without conflict in the market, but which come
into conflict on the net to distinguish themselves on the
net by the same means that they use in the market and
still all be accessible as columbia.com. Conflicts in
hidden names, presented only in a selection tree on
addressing, could be arbitrated in a written arbitration
similar to written trademark prosecution in the Trademark
Office, but before the registering body or ADR authority.
3. Private corporations operating under renewable
government contract works very well.
4. Domain name registration could follow the model of
film/television title registration as administered by the
Motion Picture Association of America for net registrants
having no prior commercial use of the name. This
contemplates reserve positions and use obligations. As to
name conflict resolution between registrants basing a
claim on prior use, the procedures of the Trademark Trial
and Appeals Board, U.S. Trademark Office, in opposition
proceedings offer an attractive alternative to court
litigation.
5. Top level generic domain names have no particular
utility unless part of the internationally agreed natural
language scaleable naming system.
6. No comment
7. Natural language hierarchy systems should be used
which are proven as inherently scaleable naming systems.
For example, when a new company incorporates it can be
found by conventional addressed mail using its company
name, at a street, city, country location. A simple four
level tree structure can quickly lead to an addressed
location e.g. United States, to Washington DC, to 14th and
Constitution, to NTIA. Entry at any level of the tree
known to the user can display the next level down or up to
allow user selection based on other known or guessed level
names.
8. Transitions should occur in the same manner as
transitions in area telephone codes are handled.
9. No comment.
C. Creation of New gTLDs
Questions 10 - 13 are answered.
10. No.
11. Yes, if part of a natural language scaleable naming
system.
12. No.
13. Yes, depending on the natural language scaleable
naming system employed.
14. No comment.
D. Policies for Registries
Questions 15 - 19 are answered.
15. These issues are irrelevant in a natural language
scaleable naming system. No one level of the name has any
unique role in the scaleable naming system as compared to
other levels.
16. Registrars should have the same requirements as postal
address naming authorities.
17. Not necessarily as long as there is adherence to a
single natural language scaleable naming system.
18. Not necessarily as long as there is adherence to a
single natural language scaleable naming system.
19. These issues are irrelevant in a natural language
scaleable naming system.
20. No comment.
E. Trademark Issues
Questions 21 - 27 are answered.
21. Domain names can function as service marks, trade
names and trademarks as well as simply a domain name
without other commercial significance. The manner and
what it is used for on the net determines this function.
Customers ask for services, products and companies by
name, whether on a label or in a domain address. When
used as a protectable mark, then the rights of the mark as
provided by law must be enforceable.
22. Screening of domain names by an authority will
unacceptably slow the process and create unnecessary
beaurocracy and costs similar to current trademark
registration, where costs are several hundreds of dollars
and delays of 12 months typical. Free registration of
nonidentical names with quick and low cost opposition
resolution in cases of conflict is preferred as a
self-screening system.
23. Internet trademark conflicts should be submitted to
mandatory mediation or arbitration with recourse to an
trademark opposition style trial on written records before
private judges, whose judgments are entered as judgments
of courts of competent jurisdiction over the parties as
determined by current federal practice (Title 28).
24. Domain name and trademark databases currently exist,
are affordable, are easily accessed and are available to
those who seek to avoid conflict. Trademark attorneys
capable of assisting users in making private judgments of
availability are available everywhere.
25. No. The registrar should not be burdened or tasked
with making entitlement judgments of any kind.
26. No effect as long as a single natural language
scaleable naming system is used. Trademarks, service
marks, and trade names can be used as the lowest level of
the scaleable naming system. Higher level names can
distinguish similar lowest level names on the internet in
the same way that other market factors currently
distinguish the lowest level names in the market. For
example, the likelihood of confusion between tradenames,
trademarks and service marks are currently adjudicated
based on the standard of the law as set forth in In re E.
I. DU PONT DE NEMOURS & CO., 177 USPQ 563 (CCPA 1973)
where the factors are listed as:(1) The similarity or
dissimilarity of the marks in their entireties as to
appearance, sound, connotation and commercial impression.
(2) The similarity or dissimilarity and nature of the
goods or services as described in an application or
registration or in connection with which a prior mark is
in use. (3) The similarity or dissimilarity of
established, likely-to-continue trade channels. (4) The
conditions under which and buyers to whom sales are made,
i.e. "impulse" vs. careful, sophisticated purchasing. (5)
The fame of the prior mark (sales, advertising, length of
use). (6) The number and nature of similar marks in use on
similar goods. (7) The nature and extent of any actual
confusion. (8) The length of time during and conditions
under which there has been concurrent use without evidence
of actual confusion. (9) The variety of goods on which a
mark is or is not used (house mark, "family" mark, product
mark). (10) The market interface between applicant and the
owner of a prior mark: (a) a mere "consent" to register or
use. (b) agreement provisions designed to preclude
confusion, i.e. limitations on continued use of the marks
by each party. (c) assignment of mark, application,
registration and good will of the related business. (d)
laches and estoppel attributable to owner of prior mark
and indicative of lack of confusion. (11) The extent to
which applicant has a right to exclude others from use of
its mark on its goods. (12) The extent of potential
confusion, i.e., whether de minimis or substantial. (13)
Any other established fact probative of the effect of use.
Therefore, a natural language scaleable naming system
would have level names such as (1) The name which gives
the commercial impression, i.e. Cola;(2) The nature of
the business, goods or services associated with the name,
i.e. manufacture and distribution of beverages; (3) The
established, likely-to-continue trade channels, i.e.
wholesale and retail consumer trade; (4) The variety of
goods on which a mark is or is not used (house mark,
"family" mark, product mark), i.e. a listing of Cola
branded products and services. The browser would simply
ask for *Cola* (dot nothing). The browser would get back
a listing of all names including *Cola* at level 1 and a
tree or table showing levels 2 - 4. Existing search
engines such as used by Thomson & Thomson and others can
make immediate spelling and natural form variations from
the root search word.
The correct Cola would be the one that met the correct
criteria. Other Colas would be distinguished by the
relevant market factors as they are in the market place.
Yahoo currently returns 243 sites for *cola* with much
less specificity. The current domain naming structure
does not provide an unique dictionary selection according
to meaning, but promotes a nonunique random word
association. Those desiring to directly address a site
could simply use the address, Coca
cola.beverage.consumer.house mark, or King
Cola.beverage.consumer.trademark. If there were only one
Coca Cola site, then only the unique portion of the name
would be needed in the address. (Yahoo returns 86 sites
for Coca Cola). The specific names used would be chosen
by the domain owners and only compared by the registrars
to a single database for identical conflict at all levels.
Domain owners wishing to be found will chose optimal
names for themselves. The computer works equally as well
with fixed ISO standards as with user selected codes. If
desired two or more levels for geographic location could
be added, e.g. Coca cola.beverage.consumer.house mark.
AltlantaGeorgia.U.S.
Coca Cola could establish a level 1 monopoly for *Coca
Cola* if it could establish its fame regardless of: (1)
the nature of the business, goods or services associated
with the name; (2) the established, likely-to-continue
trade channels; and (3) the variety of goods on which the
name is or is not used. This is more than famous mark
owners can now achieve with the present naming structure,
since many others return a hit on *Coca Cola* than the
Real Thing, Coke. Browsers thus could search on domain
name only using the natural language naming system and/or
search headers for subject relation as they presently do.
There is currently no usable domain name directory or
dictionary. Anyone can list themselves under any name
regardless of any unique identity, whether it be fictional
or actual. This would not be a tolerable practice in a
telephone directory (everyone lists themselves as
BillClinton1.com through BillClinton250,000,000.com as
opposed to BillClinton.president.UScitizen.human) and it
is not a tolerable practice in domain name listings.
27. Yes. The same or similar trademarks may not create a
likelihood of confusion and hence an infringement based on
other commercial factors as provided by law. The same
factors can be used to establish a single natural language
scaleable naming system, which realistically reflects how
consumers distinguish the marks in the market.
28. No comment.
###
Number: 302
From: "mikel@codamc.com" <Mike.Lile@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 1:30am
Subject: Comments on Domain Names
In addition to my comment made through the pgMedia site, I would add
the following:
As an Internet Administrator for the last two years, I have
always been skeptical of the centralized, government controlled
nature of DNS on the Internet. I would very much like to see
this system moved in to the private sector (perhaps with
minimal subsidies) and decentralized.
Thank you for your time and attention.
-------------------------------
Saturday, August 16, 1997 01:29:18 EDT
Mike Lile
4956 Gem Dr
High Ridge, MO 63049
###
Number: 303
From: Roger Jones <activeink@home.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 3:41am
Subject: junk email
Sirs:
There is little problem with socalled junk email or spam, since I can
delete it at a stroke.
What you ought to stop is sending of junk mail to US residents' physical
mail boxes by the US postal system. It has more than once caused me to
lose important mail amongst pages of useless offensive advertisements,
it destroys trees, and it annoys the heck out of me.
If you allow the US government connive in filling people's mailboxes
with this offensive junk 6 days a week you must by the same token allow
sending of unsolicited email.
Personally, I block, with ease, all unsolicted email except maybe once
or two every two weeks, when I allow myself receive a few merely to
learn what's new and hot and what's not.
Anyone who complains about receiving junk mail is an idiot. It isn't
difficult to prevent receipt. The fact is that many people are putting
enormous misdirected energy into attacking this perfectly normal
American business practice. The anti-brigade display unhealthy
fanaticism. Not to mention ignorance and lack of logic.
Yours truly
Roger Jones
author
###
Number: 304
From: NatCom <natcom@dnet.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 8:56pm
Subject: US Dept. of Commerce: Domain Names
Dear Sirs/Madams:
There is no need to add additonal Domain Names to the internet. This will
just add to the confusion and make things even harder to find.
What is being overlooked is the already available use of the "." (the
DOT). By using dots (.s), you can have a number of DNs just as it is now
set up. For example, if I wanted a DN that somehow reflected Western North
Carolina, most names with WNC,westernnorthcarolina, etc are taken! BUT-
when you start using dots (.s), this is a different story. You can now have
www.homes.wnc.com or www.realestate.wnc.net etc. An almost unlimited number
of DNs can be created using this system.
This eliminates the need for all the other ludicrus DN extensions that add
to the problem, rather than make it better.
Also, there should not be a single entity that gives out DNs for profit.
If there is, is should be an agency of the US Federal Government, and any
excess monies should be use for the NSF.
The current fees are excessive, in my opinion. $100 up front is high.
Also, all the large corporations that obtained DNs for FREE, should have to
pay the $50 yearly renewal fee, just as I do for my six DNs- and I have a
very small company, which may never actually make a profit after expenses.
I hope this input will be considered.
Respectfully,
Merlin Gagle
Gagle Communications
Gagle Communications
"Let us be your billboard on the Information Superhighway"
The All Cities Network: http://www.allcities.net
The US Cities Network: http://uscities.net http://www.uscities.com
Azine For WebNovices: http://www.webnovice.com http://webnovice.net
CC: NTIADC40.SMTP40("Paul.Chavez@MSNBC.COM")
###
Number: 305
From: Lloyd Manley <defaultuser@domain.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 8:19pm
Subject: comments on dns
Dear sir/mam,
I am furious about what I am reading in the popular press about the
designs being placed on the dns situation by corporate interests and
copyright fanatics. First of all, IT IS NOT the governments place, or
any other bodies place, to interfere with the development of new
technologies to protect some special interest such as the copyright
supporters and others who have a lot to profit from the internet.
If the internet spells the end of copyright as we know it (which I
believe it will, no matter what anyone does), then it is the
responsibility and headache of those who would profit from copyrights to
find another means by which to generate profit. If this, AT SOME FUTURE
TIME, results in an objectively measurable inhibition of those producing
quality, academic or artistic material for public consumption, THEN, and
only then, should minimal interventions be considered.
With that in mind, I believe that all matters regarding domain
registration and the handling thereof should be mediated by parties who
have NO INTEREST in copyright concerns.
Though you may find this to sound somewhat revolutionary in tone, I
write it because I want to convey what is at stake here if we don't stop
copyright fanaticism. The very power of the internet, the very things we
appreciate about this medium, will be entirely lost if we give in to
copyright concerns and we will be thrown back to '50's in terms of
communications technologies. The possible benefits of the internet are
so enormous (especially to the average and poor individuals that make up
the 'masses' of our societies-the power of information will truly
liberate them) that it would literally be a crime against humanity for
anyone to stand in support of copyright demands.
The honor of a reply would be greatly appreciated.
Sincerely,
Lloyd Manley, dept. of physics and astronomy, University of Georgia
###
Number: 306
From: "mikel@codamc.com" <Mike.Lile@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 1:25am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Mike Lile do hereby support the design of the expanded toplevel Internet
namespace which is currently operated by pgMedia, Inc.'s name.space(tm)
service, located on the internet at http://namespace.pgmedia.net (or
http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 01:23:42 EDT
Mike Lile
4956 Gem Dr
High Ridge, MO 63049
###
Number: 307
From: "marxx@ljudmila.org" <Marko.Peljhan@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 3:48am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Marko Peljhan do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 03:46:45 EDT
Marko Peljhan
Ane Ziherlove 2
1000 LJUBLJANA
SLOVENIA
###
Number: 308
From: "106401.1503@compuserve.com" <Schels,Michael@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 6:16am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Schels, Michael do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 06:15:07 EDT
Schels, Michael
Dr.-Carlo-Schmid-Str. 48
90491 N rnberg
Germany
###
Number: 309
From: "tristan@www.victor.com.au" <Tristan.Gulyas@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 6:21am
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Tristan Gulyas do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 06:20:24 EDT
Tristan Gulyas
###
Number: 310
From: "henkka@l16.fi" <Henrik.Huhtinen@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 1:25pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Henrik Huhtinen do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 13:24:09 EDT
Henrik Huhtinen
###
Number: 311
From: "vgranger@imaginet.fr" <valery.grancher@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 3:41pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I valery grancher do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 15:39:31 EDT
valery grancher
53 rue de seine 75006 paris
france
###
Number: 312
From: "hartnett@btigadoon.com" <Daniel.Hartnett@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 4:33pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Daniel Hartnett do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 16:31:52 EDT
Daniel Hartnett
D.E. 303 East 8th Street
NYC, NY 10009
###
Number: 313
From: "sakurako@sprynet.com" <Noriko.Fukuyama@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/16/97 7:46pm
Subject: Comments on Domain Names
PETITION TO THE US DEPARTMENT OF COMMERCE
IN SUPPORT OF THE
NAME.SPACE(tm) SYSTEM OF GLOBAL DIRECTORY SERVICES
(The New Paradigm for the Old DNS)
I Noriko Fukuyama do hereby support the design of the expanded toplevel
Internet namespace which is currently operated by pgMedia, Inc.'s
name.space(tm) service, located on the internet at
http://namespace.pgmedia.net (or http://name.space).
The paradigm implemented by name.space(tm) is the most pro-competitive,
democratic and open system proposed so far with respect to opening up the
administration and operation of the Domain-Name-System ("DNS"). The
structure advocated by name.space(tm) removes the artificial barriers to
entry that exist today as a result of the monopolistic control over the
domain name registration market exerted by Network Solutions, Inc. ("NSI").
The name.space(tm) paradigm incorporates a fair, competitive structure
which encourages investment and innovation by companies wishing to compete
in the provision of this service which is essential to the operation and
continued growth of the Internet.
pgMedia, Inc. has created, through substantial private investment in
research and development, its name.space(tm) registry administered by
thirteen toplevel root-directory servers located in five countries. The
name.space(tm) registry uses innovative and creative techniques which bring
the old DNS out of the Cold War and into The 90'S.
The name.space(tm) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace without
regulation by any governments or quasi-governmental authority, nor does it
require the enactment of new laws or regulations.
Description of the name.space(tm) service:
On the name.space(tm) system, name registrations are taken by registrars
who administer client accounts under the given toplevel name categories
(publicly shared toplevel namespace). All registrars must register their
digital ID with a trusted third party/parties which authenticates and
authorizes them to function as registries. The application process is
administered by an independent company, similar to the process used by
banks when authorizing merchant credit-card accounts, and the operation of
secure servers used in commercial transactions on the Internet today.
Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at http://namespace.xs2.net/IDSD). IDSD makes
it technically feasible for ALL registries to share the toplevel namespace
equally, eliminating any technical justification for "exclusive" control
over any given toplevel name by a single registry, such as NSI currently
enjoys with ".com".
Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment options via
a secure server. During the registration process, a registrant establishes
an account, a contact "handle" and, of course its "name". The registrant
has the option to choose whether or not its personal contact information
will be publicly listed. All other account information, of course, remains
confidential. The registrant may then establish a Portable Address Record,
over which it has full administrative access on the name.space nameservers.
This service allows a registrant to change service providers and easily
take its "name" to a new host without delay or complications. Upon
completion of the registration process by the registrant, the
name.space(tm) system immediately processes the information and creates the
second level entry into the toplevel database, which is then distributed to
all other root-servers via the IDSD protocol. The registration process and
the creation of Portable Address Records are instantaneous, and function on
the Internet within minutes, not days or weeks as in the current system.
Issues and Answers
Under the name.space(tm) paradigm, the toplevel namespace functions as a
Global Directory Service and would be managed within the competitive
marketplace in the general interest of the Internet public through the
various independent registrars. Each generic TLD ("gTLD") is administered
by all registrars who wish to offer services thereunder with no exclusive
claim of ownership of any toplevel name by any individual, corporation or
government, subject to existing intellectual property law.
These gTLDs may be added or removed based on public demand. Also, gTLDs
may include languages other than English, limited only to the US ASCII
character set, the English alphabet plus 10 digits and the hyphen for a
total of 37 characters.
All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number of
root directories under the UNIX file system. As NSI admits:
"DNS is highly scaleable. There is no technical limit to the number of new
top-level names that could be introduced. The original designer of DNS,
Paul Mockapetris, has verified the scalability of DNS."
(http://rs.internic.net/nic-support/nicnews/jun97/MYTHS4.html)
Thus, any claim that expanding the toplevel namespace is technically not
feasible is simply unfounded. The proponents of such claims seem to be
guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.
The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the full
implementation of the name.space(tm) paradigm. Thus, for example,
Acme.computers and Acme.plumbing could both have a presence on the Internet
without having to artificially pervert their names. The "byte-counter
mentality," which has plagued us with the dreaded "Millennium Bug," was
responsible for the initial constraints on the toplevel domain name
nomenclature. The name.space(tm) system simply recognizes that such
limitations have long since been eliminated and are wholly artificial.
With respect to intellectual property issues, no regulatory framework can
assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as a
basis to limit the free speech rights of the vast majority of law abiding
users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.
Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational and
non-profit organizations, as well as a selection of totally free categories
(such as the Free.Zone provided currently by name.space*).
In conclusion, name.space(tm) has developed and implemented a new paradigm
for the Global Directory Services on the Internet by bringing the function
of the old DNS, a legacy of the Cold War, into sync with the current
dynamic of the public, global, civilian and commercial Internet.
The name.space(tm) system is a reality today. The name.space(tm)
automated registry has been fully functional for nearly one year now and
has proven its reliability and desirability as evidenced by the thousands
of users who have been using the name.space(tm) servers to resolve their
DNS and those who have registered their names in name.space(tm) .
I fully endorse and support the endeavors of pgMedia, Inc. and the
name.space(tm) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the Internet.
-------------------------------
Saturday, August 16, 1997 19:44:33 EDT
Noriko Fukuyama
###
Number: 314
From: "Phillip M. Hallam-Baker" <hallam@ai.mit.edu>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 5:44pm
Subject: DNS
I write as a former member of the CERN Web development team. I am currently
active both in the IETF and the World Wide Web Consortium.
Comments:
A. Appropriate Principles
1. While accepting the general desirability of avoiding unnecessary
government involvement it should be noted that there is in fact a set of
national domains. Should the US government wish to take an interest in
domain name issues beyond the orderly withdrawal from its current
involvement it should confine its interest to the .us domain and the .gov
and .mil domains.
2. For historical reasons the US government currently has a privileged role
in DNS administration. During the period in which the NSF subsidized much
of the Internet infrastructure it funded the registration of domain names.
2a) The manner in which this funding was withdrawn was extremely
unsatisfactory. Insufficient notice of the change meant that there was no
opportunity to consider any solution other than administration by a single
registrar. The only party in a position to undertake the contract on that
basis was the existing contractor. In effect the contractor was awarded an
undeserved license to print money.
2b) The actions of the NSF in relation to this contract were and are
unacceptable to the Internet community. At a meeting of the IETF
immediately after the contract was announced there was not a single speaker
that defended the NSF actions. The NSF actions in this regard were in
effect Force Majeure, there being no opportunity to propose an alternative
approach.
2c) Further involvement by the US government in the administration of the
.com and .org domains is not acceptable to the Internet developer
community. The IAHC was charged with the task of proposing an alternative
means of administering DNS registration and has reported to the appropriate
Internet authorities. The IAHC proposal contains no role for the US
government.
3) The logical interpretation of the existence of .com and .org domains in
addition to the national domains is that these are international in scope.
B1:
4) The logistics of domain name registration are demanding requiring
considerable technical expertise, clerical and legal resources. The current
charge of $50 made by Network Solutions Inc. is unrealistically high
however for what is a mature market in which a majority of registrations
may be performed entirely automatically. The anticipated cost of litigation
in connection with disputed domain names have not in fact arisen. Indeed
the majority of Network Solutions costs in this area appear to be directed
at finding ways to cause the gravy train to continue.
B3
5) The appropriate entity to administer the Internet are the IAB, the IETF
and IANA. IANA is the entity specifically charged with the allocation of
reserved names and numbers and is recognized by the Internet community as
the root DNS registrar. The decision to delegate this registration is
entirely for IANA to decide.
B5
6) Asking whether the .com and other gtlds be retired says much about the
questioner. It is absolutely impossible to retire these domains. US firms
have invested over a billion dollars in 1996 promoting websites using .com
domains. The US government is not recognized as the owner of the 'dot',
root domain under which the .com domain falls.
7) Any attempt to retire the domains would result in an endless series of
litigation. The US government is not recognized as the owner of the .com
domain.
B7
8) The question of achieving scalability in future DNS implementations is
not a question the US government is qualified to decide. The technical
specification of the Internet is set by the IAB and IETF and not the US
government.
9) The current DNS protocol is adequate for anticipated needs for at least
the next five years. A transition to a new, authenticated version of the
protocol is currently in progress. The total volume of data is not large by
the standards of the Internet, A hundred thousand DNS entries can be
recorded on a standard floppy disk. The total number of domain
registrations remains of the order of a million. The task of exchanging ten
disks worth of information is not insurmountable.
B8
10)The IAHC has already discussed these issues in depth at the request of
the Internet Society and the IETF. The scheme proposed is not perfect but
no US government agency is in a position to propose a more satisfactory
one. The time constraints alone mean that any US proposal could not be
finalized until long after the current NSI contract had expired.
C10
12) The current DNS architecture assumes a limited number of gtlds. The
protocols could be adapted to permit an unlimited number of domains if this
was desirable.
13) The proliferation of top level domains is undesirable however. If
registration of top level domains was unrestricted the administration of
the top level domain would immediately become as problematic as that of the
.com domain. Any non-punitive charge would be considered reasonable by
large numbers of corporations. Disney would not think long before paying
$10,000 to become disney in place of disney.com.
C11
14) Additional top level domains are required for a number of purposes.
First there are many uses of the Web which do not fit within the
traditional groups. In addition to the seven new domains proposed by the
IAHC current usage suggests a demand for .film and .book categories since
goldeneye.com is not appropriate. It may be appropriate to establish
additional criteria for registration in certain domains. Registration in
.film might reasonably require that a film be in production for example.
15) The pornography industry would welcome the creation of an xxx toplevel
domain. But a separate namespace for pornographic material should not be
seen as a solution to the pornography issue. The administrations previous
attempts to regulate pornography having been found unconstitutional the
administration now has very little influence in this area in the Internet
community. Very few part of the world share the US view of sexual morality.
Indeed it is doubtful such a view could be defined since there is great
variation within the US as to what constitutes "unsuitable" material for
minors. Should the Christian Coalitions message of hatred of gays be
similarly identified? Many find their material offensive and regard it as
damaging to children. It was considerations such as these that gave rise to
the PICS scheme.
C13
16) The use of ISO country codes are reserved for use by the countries
concerned. In addition the UK uses the .uk domain instead of the ISO
designated .gb.
D15
17) No, registrars should not have complete control over any domain. For
registrants to have confidence in their ownership of their brand they must
know that it is not subject to arbitrary revocation by the registrar. A
party that invests $10million promoting a brand must know that they will
not be subject to extortionate renewal fees in the future.
D16
18) Registrars must have sufficient financial and technical resources to
ensure that they do not prove to be a menace to the Internet
infrastructure. These should be determined by the existing Internet
Architecture Board in consultation with the directors of the IETF.
Phillip M Hallam-Baker
Visiting Scientist
MIT AI Lab
###
Number: 315
From: "Stephen T. Kean Jr." <skean@halcyon.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 8/17/97 4:22pm
Subject: Management of Domain Name Server Names
To whom it may concern,
Here are some concerns and possible solutions to the numbering system and
other ancillary problems.
1. At one point in the Unix business, the design was for trading
information. As the networking infrastructure became more popular and
grew, the advent of visual enhancements passed the size of our ability to
pipe it to the user efficiently. Unfortunately, the visual enhancement is
not data. We have conned ourselves into believing that pictures are more
relevant than the data we are seeking. Unfortunately, and like most
people, I like a pleasing background and driving visual effects. Thus it
is here to stay. To combat this problem, We should standardize graphics as
much as possible and place as much of the graphic (gif or whatever) at the
user machine.
2. One of the most popular features from a business perspective is the
ability to knock down the traditional demographic/proximity barriers to
marketing. A small businessman can now market a flower box in just about
any country. If I do a search for flower boxes, I may very well end up
with 10,000 relevant returns. This means I will spend more time looking
through the returns to find exactly what I want. If I look through 200
items before I find what I want, the ratio of RETURNS:SITES VIEWED:TO
ACTUAL FIND is 10,000:200:1. This curve represents a very bad investment
of time spent; either mine or the equipment used to get what I want. My
suggestions below may allow for a more discriminate search.
3. The issue of how to name all of these sites is actually very small by
itself. For a long time, we have allowed a computer to assign names. The
fundamental concept of developing a program for Unix was to create small
programs which had but a single purpose. Because we wanted to keep up with
growth, our programs became larger and encompassed a bigger pool of
requirements. To mow a lawn, a traditional Unix programmer would cut each
blade of grass, whereby a business man would use a lawn mower. Sorry for
the gibberish. My point is to ensure you get the programmers in on this
name problem. Not to slow you down with their "we can't do that's, but to
ensure we don't kill the present system or outdate what we already have.
4. One way to set up a system of naming is to build a system similar to a
Balanced Heap. At the Top of the heap is the center mass of a categories
of use. In present terms, the category of use is .gov, .edu, .com,...
Instead of the traditional .com, catagorize the type of business. For
instance, the business which makes the flower pot would be under the
category of GARDENING. As we convert, to this system, the first number
could represent a category, the second number a server which contains the
data, The third number an actual business number, and the last number
could be anything you want it to be.
5. One of the biggest problems we have in numbering is the static nature of
its system. An example is 255.255.255.1. It is pretty apparent we will run
out of numbers. We cannot use this in what I propose. With each present
set of numbers, we can only discus 256 possibilities. That is a bound we
have to break right now. Consider my numbering system above. It would
look something like this: 43.61743.987.4.
6. My Heap is dynamic in nature. The length of the number in each segment
of the whole number is immaterial. As technology grows or changes, new
categories may be entered without regard to the limiting factors of our
present numbering system. Because the numbers are entered into the heap
based on categories and a parent child relationship (Don't confuse this
with my machine is bigger than yours. It's only a number) , searches can be
made across boundaries, without going to through the top of the heap to get
to the other side.
I realize the Heap is not something we all know about. A truly schooled
programmer should be consulted prior to jumping into this. A mathematician
should be consulted so we do not place static restrictions on the possible
number of names which could be used (so we don't get stuck on 256 again.
Last of all, an open mind is what is required here. Heaping-up,
Heaping-down, Binary Search Trees and the like are not that difficult.
Setting up a system whereby the changes can be affected are, however, very
difficult
Stephen T. Kean Jr.
skean@halcyon.com
###
Number: 316
From: Herb Weiner <herbw@wiskit.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 11:19am
Subject: Comments on Registration and Administration of Internet Domain Names
Response to Question D 20 (Policies for Registries: Are there any other issues
that should be addressed in this area?)
PROPOSED REQUIREMENT:
The Registrar MUST provide a mechanism for handling written (postal mail,
electronic mail, or FAX) disputes and inquiries regarding domain name
registration and billing, and MUST respond in writing to such disputes and
inquiries in a timely fashion. The Registrar must NOT cancel any Domain
Name Registration while such disputes and/or inquiries are pending.
(This is similar to the protection provided by the Fair Credit Reporting
Act.)
BACKGROUND INFORMATION:
I FAXed my credit card payment for my wiskit.com domain name registration
(dated 19-February-1997) on February 22, 1997, and have PROOF of payment
in the form of my MasterCard statement showing that $50.00 was charged to
my account on February 26, 1997.
On April 7, 1997, I received an email message indicating that payment had
not yet been received. On April 8, I phoned Network Solutions, and after
waiting on hold for over 15 minutes, I finally spoke to Darryl, who promised
to relay the information to the billing department. He promised that the
billing department would investigate, and call me back with with the status
of my account.
Since I still had received no response by April 10, I sent a followup email
message reporting the error, and requesting a response. We received no
response to this email message.
On April 18, the president of the company received an invoice postmarked
April 11, warning him that our domain name service would be terminated
if payment was not received by April 19 (15 days after the April 4 invoice
date, and one day following the receipt of the invoice). We FAXed our
response that same day, and followed up by postal mail the following day.
In each case, we requested a written response confirming that the error
had been corrected.
To date, although we have made four requests (one each by phone, email,
FAX, and postal mail) we have received no response indicating that the
error has been corrected. Although our domain name service has fortunately
not been cancelled, we have been unable to determine whether this is
because the error has been corrected, or whether Network Solutions still
has us on a list of domain names to be removed.
Such poor customer service is simply unacceptable. In any non-monopoly
situation, we would take our business elsewhere.
Herb Weiner
Kitchen Wisdom Publishing
10032 SE Linwood Avenue
Portland, Oregon 97222
(503) 771-1402
FAX: 771-1401
email:herbw@wiskit.com
CC: NTIADC40.SMTP40("chrisc@netsol.com")
###
Number: 317
From: Lou Poppler <lwp@mail.msen.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 7:23pm
Subject: Internet Domain Names
There is no role for the US government in the administration of internet
domain names. The current monopoly created by the USG in the
administration of certain TLDs is harmful. The pending revisions to this
system, developed by the network community, represent the correct approach
for future enhancement -- both in the specific measures already nearing
adoption and in the philosophical model of administration of the
borderless internet by our own knowledgable and trustworthy constituents.
I will respond briefly to the following individual points in your outline:
A.b, A.c, B.6.
A.b & A.c: I strongly agree with these statements. Experience has shown
that the best response to virtually any network issue arises through the
consensus of the thousands of individual network administrators. This
mechanism is nimble, knowledgable, and fair.
B.6: I would expect the root servers to become somewhat more numerous,
and for their relationships with both TLD registries and with client
resolvers to become predicated on issues of reliability and reputation.
This should more closely resemble a free-market selection system as
opposed to the current top-down approach.
CC: Lou Poppler <lwp@mail.msen.com>
###
Number: 318
From: Bob Crispen <crispen@hiwaay.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 11:32am
Subject: Re: Request for Comments on the Registration and Administration
of Internet Domain Names
The current movement toward domain name expansion has been
polluted by a number of leaders whose basic motivation seems
to be to force some authority to take money away from NSI
and give it to them.
What evidence do we have that they will manage this
resource responsibly should they get their desires? Their
track record is so short that it contains but one item:
the recent hacking of DNS, which is the strongest possible
evidence that they will *not* exercise responsible
management.
I don't know whether the mechanism set up by NSI is the
best for the long term. I suspect a technological solution
will emerge which will satisfy all the critics of NSI who
are not merely seeking to line their own pockets. But that
solution has not been demonstrated yet. I do know that
doing business with the IAHC is akin to surrendering our
wallets to muggers.
###
Number: 319
From: <lemmon@NOSPAMpanix.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 9:40pm
Subject: Comments on Domain Names
I believe the issues of domain names for the Internet is an important one.
Far too important to allow one entity - Network Solutions - to monopolize.
I believe what is needed is a system whereby those registered domains in
.com, .net & .org domains will get transferred to whatever entity the NSF
decides upon. I also believe that new top-level domain names should be
introduced, such as those proposed by IAHC, including additional categories
such as .rel for religious organizations, etc.
Thanks for soliciting comments.
Marcia H. Lemmon
marcia@cybersynergy.com
###
Number: 320
From: Simon Higgs <simon@higgs.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 8:59pm
Subject: REGISTRATION AND ADMINISTRATION OF INTERNET DOMAIN
NAMES
Filing Instructions
Mail comments in paper form to Patrice Washington, Office of Public
Affairs, National Telecommunications and Information Administration
(NTIA), Room 4898, 14th St. and Constitution Ave., NW, Washington,
DC 20230,
or
Mail comments in electronic form is dns@ntia.doc.gov. Comments
submitted in electronic form should be in WordPerfect, Microsoft Word,
or ASCII format. Detailed information about electronic filing is
available on the NTIA website, http://www.ntia.doc.gov.
Paper submissions should include three paper copies and a version on
diskette in the formats specified above. To assist reviewers, comments
should be numbered and organized in response to questions in
accordance with the five sections of this notice (Appropriate Principles,
General/Organizational Framework Issues, Creation of New gTLDs,
Policies for Registries, and Trademark Issues). Commenters should
address each section on a separate page and should indicate at the
beginning of their submission to which questions they are responding.
Horzontal lines below represent page breaks.
NB. The filing deadline is 1700 hrs EDT (UTC-4), 18 Aug 1997.
------------------------------ 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 Simon Higgs
Simon Higgs
Simon Higgs
P.O. Box 3083
Van Nuys
CA 91407-3083
Self
18 Aug 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
Existing TLD Applications
------------------------------ break ------------------------------
SUMMARY
This document provides some information on the structure of the
names in the Domain Name System (DNS), specifically the top-level
domain names; and on the administration of those domains.
The day-to-day responsibility for the assignment of IP Addresses,
Autonomous System Numbers, and most top and second level Domain
Names are handled by Internet Registries (IR).
The Internet is partly being driven by commercial market forces
using domain names to identify corporate business units which are
known to the public as "brand names"). This document covers some of
the framework necessary to define the purpose, function, delegation,
and use of new top level domains.
Several factors need to be addressed such as why the TLD exists in
the first place, who accepts registrations for the TLD, and what
special purpose (if any) the TLD serves.
------------------------------ 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 Simon Higgs
1. Simon Higgs respectfully submits comments in this proceeding. Simon
Higgs is actively involved in top level domain name issues. Simon
Higgs is the first applicant to request a new international top level
domain from IANA, and has extensively written various internet drafts on
the subject, as well as being a featured speaker at the Internet
Engineering Task Force.
------------------------------ 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.
A.a.1. This is a generally accepted principle.
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.
A.b.1. This is a generally accepted principle.
c. These self-governance mechanisms should recognize the
inherently global nature of the Internet and be able to evolve
as necessary over time.
A.c.1. This is a generally accepted principle.
d. The overall framework for accommodating competition
should be open, robust, efficient, and fair.
A.d.1. This is a generally accepted principle.
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.
A.e.1. This is a generally accepted principle.
f. A framework should be adopted as quickly as prudent
consideration of these issues permits.
A.f.1. No. Consensus is more appropriate than speed.
Other principles
A.Other.1. None of the above principles address the fundamental key
issues as to how the namespace should be administered. They are symptoms
of the consequences of failing to address the most important issues.
A.Other.2. There are two principles that must be regarded higher than
any others:
A.Other.2.a. Use of the the top level domain
Use is generally defined as the purpose or function that
the top level domain serves to the internet community. In the past this
has been to distinguish the coutry of origin of the domain name (using
the ISO3166 classifications), or whether the domain is educational
(.EDU), commercial (.COM), governmental (.GOV) or another
classification. Each new TLD must be created with an identifiable
purpose. A written charter will identify and explain the function and
purpose of each TLD. In the case of the Specialized and Private TLD
classes (described below), the corporation or organization acting as the
registry will be responsible for creating the TLD's charter. This will
be part of the TLD application process. Guidelines for charter creation
will be made publically available by IANA. The following items must be
identified in the charter:
A.Other.2.a.1 Registration procedure, documenting all steps
A.Other.2.a.2 Service guarantees required in the operation of that TLD
A.Other.2.a.3 Error resolution policy (including any refund policy)
A.Other.2.a.4 Dispute policy (including any refund policy)
A.Other.2.a.5 Procedure for dealing with domain name and trademark
conflicts.
A.Other.2.b. Delegation
Once the use and purpose of the TLD is discovered, the appropriateness
of the type of delegation will become apparent. Top level domains can be
divided into three groups. There are those which are Shared
(non-exclusive), and which can be served by multiple competing
registries. There are those that may need to be served by a single
registry that has the necessary expertise to address specific industry
issues, and there are a very small number of private TLDs which are
required to serve single large organizations:
A.Other.2.b.1. Shared TLD Class
The Shared TLD Class contains TLD's in which all second level domain
name registrations are performed by multiple competing registries.
Unless specifically documented otherwise in the TLD's charter, it is
expected that all newly delegated TLDs will be in this class. Existing
TLDs may be delegated by IANA into this class as well.
A.Other.2.b.2. Specialized TLD Class
The Specialized TLD Class describes TLDs that are industry-specific, or
where a high-level of domain name control is needed. These TLD's are
operated by a single registry. Registration is only open to
organizations within the specific areas defined in the TLDs charter.
These TLDs could represent specific industries, other closely defined
market niches, or top level country domains. A registry must beable to
constructively address industry specific issues in the context of
running a TLD registry. An example of an existing TLD in this class is
.INT which is closely controlled and is only open to International
Treaty Organizations. Registry duties are handled by the ITU in
accordance with a policy authorized by IANA.
A.Other.2.b.3. Private TLD
In certain rare instances, it may be possible for a qualifying
internationally known organization to be identified on the Internet by
its own exclusive TLD. All second and third level domain name
registrations are performed within the organization. The organization is
the sole trustee of the TLD, and all disputes arising from domain name
delegation are the organizations responsibility. An example of an
existing TLD in this class is .MIL., which is exclusively operated by,
and for, the United States military.
------------------------------ break ------------------------------
B. GENERAL/ORGANIZATIONAL FRAMEWORK ISSUES
1. What are the advantages and disadvantages of current
domain name registration systems?
B.1.1. In the Domain Name System (DNS) naming of computers there is a
hierarchy of names. The root of system is unnamed. There are a set of
what are called "top-level domain names" (TLDs). These are identified
either by ISO-3166 two letter country codes, or generic TLDs, whose
naming indicates the category of organization that is found there.
B.1.2. Under each TLD may be created a hierarchy of names. Generally,
under the generic TLDs the structure is very flat. That is, many
organizations are registered directly under the TLD, and any further
structure is up to the individual organizations.
B.1.3. The domain name space is a tree structure:
. (un-named root)
|
---------------------------------------------------------
| | | | | | | |
.COM .EDU .NET .ORG .GOV .US .UK [other TLDs]
|
USPTO
|
WWW
B.1.4. The above example describes the internet host <www>.<uspto>.<gov>
where GOV is the US government top level domain, USPTO is the domain
used by the US Patent and Trademark office, and the WWW identifies that
organization's host (computer) that functions as their web server.
B.1.5. In the country TLDs, there is a wide variation in the structure,
in some countries the structure is very flat, in others there is
substantial structural organization. In some country domains the second
levels are generic categories (such as, AC, CO, GO, and RE), in others
they are based on political geography, and in still others, organization
names are listed directly under the country code. The organization for
the US country domain is described in RFC 1480.
B.1.6. As an example of a country domain, the US domain provides for the
registration of all kinds of entities in the United States on the basis
of political geography, that is, a hierarchy of
<entity-name>.<locality>.<state-code>.US. For example,
"IBM.Armonk.NY.US". In addition, branches of the US domain are provided
within each state for schools (K12), community colleges (CC), technical
schools (TEC), state government agencies (STATE), councils of
governments (COG), libraries (LIB), museums (MUS), and several other
generic types of entities (see RFC 1480 for details).
B.1.7. The country code domains (for example, FR, NL, KR, US) are each
organized by an administrator for that country. These administrators may
further delegate the management of portions of the naming tree. These
administrators are performing a public service on behalf of the Internet
community.
2. How might current domain name systems be improved?
B.2.1. By the introduction of TLDs identified by appropriate business
and social categories.
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?
B.3.1. An organization with sufficient network infrastructure, email and
telephone support to fullfill the needs of the delegated TLD.
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?
B.4.1. No.
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?
B.5.1. It may be appropriate to move (not retire) the .COM under the .US
domain. In any case, the .COM or .COM.US domain must be expanded by some
catorgorization scheme (i.e. the introduction of International Schedule
Of Goods And Services-type domains) to relieve the pressure.
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?
B.6.1. No.
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?
B.7.1. The two are independant. Scalability follows Moore's Law.
8. How should the transition to any new systems be
accomplished?
B.8.1. Very carefully.
9. Are there any other issues that should be addressed in this
area?
B.9.1. No.
------------------------------ 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?
C.10.1. No.
11. Should additional gTLDs be created?
C.11.1. No. "Generic" TLDs with overlapping meanings must not be
created. iTLDs with specific non-overlapping meanings can be created.
12. Are there technical, business, and/or policy issues about
guaranteeing the scalability of the name space associated with
increasing the number of gTLDs?
C.12.1. No.
13. Are gTLD management issues separable from questions
about ISO country code domains?
C.13.1. No. The management issues are integral all across the namespace.
There are localized areas of speciality which will varies in how TLDs
are administered but the basic principles are consistant throughout the
name space.
14. Are there any other issues that should be addressed in this
area?
C.14.1. No.
------------------------------ 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?
D.15.1. gTLD registrars may not have exclusive control of a particular
gTLD. iTLDs are similar in that they address an international name
space, but may be exclusively administered.
D.15.2. There are no technical limitations for shared registries.
D.15.3. It is highly recommended that both exclusive iTLDs and
non-exclusive gTLDs coexist together.
16. Should there be threshold requirements for domain name
registrars, and what responsibilities should such registrars
have? Who will determine these and how?
D.16.1. Yes. The function of the registry is to support and maintain the
TLD(s) that it is responsible for, by meeting the TLD's charter. It is
important to understand that the registries serve the TLD's, and not the
other way around. Therefore registries must be selected to meet the
needs of each TLD.
D.16.2. The minimum requirements are determined by the acceptable
response time to delegation requests and other issues. Obviously this is
entirely scalable and is directly determined by the number of domains
within the TLDs delegated to the registry.
17. Are there technical limitations on the possible number of
domain name registrars?
D.17.1. No. There may be more registries/registrars than TLDs if TLDs
are shared. Obviously, there may be many registries/registrars
administering a particular TLD, or a particular registry administering
many TLDs.
18. Are there technical, business and/or policy issues about the
name space raised by increasing the number of domain name
registrars?
D.18.1. Yes. These are mostly business issues. The Central Database will
need one or two million per year to run. Using the InterNIC figures we
can see that 3 TLDs = approximately 1,000,000 domains. If there are 7
TLDs introduced, this is 7/3 x 1,000,000 = 2,333,333 domains. At $10 per
domain per year income is $23,333,333. Assuming a one dollar "royalty"
for each domain name that is registered ($2,333,333) goes to the Central
Database, the net income is $21,000,000. With only 100 registrars the
resulting income will be $21,000,000/100 = $210,000 per registry per
year. No registry could profit from selling domain names with this type
of income, and it's not possible to preset prices between registries
(price fixing is very much illegal). The market must decide what the end
price point is for a domain name - even if it's given away for free.
Look how easy it is for an existing business to absorb that dollar and
give away the domain name as part of a promotion or VAR bundle.
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?
D.19.1. Yes. Limitations must be in-line with natural market forces. If
a TLD is exclusive, then only one registry can administer it. This a
natural limitation. Registries within certain geographic regions may not
wish to administer certain TLDs (such as Muslim registries not wishing
to administer TLDs specializing in pornography). This is another example
of a natural limitation.
20. Are there any other issues that should be addressed in this
area?
D.20.1. No.
------------------------------ 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?
E.21.1. The use of the domain name space has changed since it was first
introduced. This change was not brought about by conscious choice or any
one person, but the change in the demographics of the internet
population as a whole.
E.21.2. As the internet population increases, and the demographic changes
from an academic to a consumer population, more importance is placed on
the identity of the source of goods or services on the internet. There
is no trademark status attached to a domain name when it is issued, but,
through its use, a domain name can aquire secondary meaning in the eyes
of the internet consumer. As such, the legal status of a domain name,
taken on a domain by domain basis, may include the form of a trademark.
E.21.3. Many of the problems regarding domain names as trademarks arise
because they incorporate terms that have already aquired secondary
meaning outside the internet. Certain words or phrases already have
associations with products or services in the minds of consumers. One of
the questions this poses is whether an existing trademark gives any
entitlement to a domain name. The answer is not clear, and probably will
never be entirely clear. New businesses started on the net with a
similar domain name but that do not compete with an existing trademark
holder have already faced litigation. Others in the same position have
not.
E.21.4. The namespace (as a whole - the "root" or ".") exists to serve
the consumer, not to serve the interests of the domain name owner. The
primary operating principle of it is that the consumer is not supposed
to be confused by a plethora of hosts with vastly different content all
bearing what appear to be similar domain names.
E.21.5. The simplest way to understand what a domain name is, is to
regard it as a dba (Doing Business As). The dba is simply a name that
someone is using to do business under with no immediate trademark
implcations. The domain name simply says "Bill Smith is doing business
under bill.com on the internet", and if this is recognized sufficiently
to distinguish Bill Smith's goods and services on the internet from
someone elses it *MAY* become a trademark in the same way Bill Smith's
name *MAY* become a trademark by it's use in trade.
E.21.6. Two points must be kept in mind when understanding trademark
issues on the internet: (a) domain names are and must be unique, and (b)
trademarked names are not necessarily unique (and there are many
examples of non-unique trademarks).
E.21.7. There are no international trademarks. There is no official
international registry of world wide trademarks. Trademarks may be
registered per country or per State/Province/Territory (for example, the
United States offers trademark regisstrations on a per state basis).
The World Intellectual Property Organization offers an international
arbitration service on such matters.
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?
E.22.1. Since a domain name carries the identical weight as a "doing
business as" thereb is no requirement for any review of the application.
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?
E.23.1. Disputes must be resolved in a manner agreeable to both parties
as in any other area of intellectual property. It seems inevitable that
a trademark holder will want a domain name that reflects the name of the
trademark held.
E.23.2. There are "strong" trademarks that are registered in many
countries and are vigorously defended. These may come close to being
unique.
E.23.3. There are many "not so strong" trademarks that may be regional
or business sector specific (for example, United Air Lines and United
Van Lines, or the Acme Brick Company and the Acme Electric Corporation).
E.23.4. There are two conflicting goals of different trademark holders
with respect to domain names: (a) to protect their trademarks against
infringement, and (2) to have access to the domain name system to use
their trademarks in a domain name.
E.23.5. Trademark infringement is the use of a trademarked name in a way
that may confuse the consumer about the source or quality of a product
or service. For strong trademarks there may also be infringement if the
use of a trademarked name dilutes the value of the trademark.
E.23.6. Holders of not so strong trademarks want the ability to use
their trademarked name in a domain name while some other holder of the
same mark for a different purpose also can use their trademarked name in
a domain name. These people would say it is essential to create
additional top-level domains to permit fair access to domain names by
holders of not so strong trademarks.
E.23.7. The number of not so strong trademarks far exceeds the number of
strong trademarks and that the domain name system should provide for the
needs of the many rather than protecting the privileges of the few. It
is because of this need that the top level domain space must be expanded
beyond the currently used TLDs.
E.23.8. It may be prudent, in the case of the Specialized TLD Class,
that they implement a very restrictive TLD charter. For example, it may
be a requirement that the domain applicant is in possesion of an
internationally recognized mark in a particular area (such as
International Treaty Organizations registered under .INT).
E.23.9. It is the responsibility of the applicant to be sure he is not
violating anyone else's trademark. Each IR must include a statement to
this effect in any registration template.
E.23.10. In case of a dispute between domain name registrants as to the
rights to a particular domain name, the registration authority shall
have no role or responsibility other than to provide the contact
information to both parties. In any dispute where the IR is named in any
lawsuit, the IR should file an "Interpleader"** before the appropriate
court, agreeing to abide by the ruling of that court. If the dispute is
between parties in different countries, the World Intellectual Property
Organization international arbitration service should be used to settle
such matters. Until such a time, the IR is obligated to provide
uninterrupted service of the domain in the root database.
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?
E.24.1. The primary solution to preventing conflicts is to ensure that
the name space is divided in a way that distinguishes business and
social categories adequately. Schemes similar to the International
Schedule Of Goods And Services make steps in this direction, though it
may be necessary to create a new set of categories to serve this
purpose.
E.24.2. The top level namespace is already divided up by category. These
categories contain either the geographical location (by country), or a
brief description of the type of entity registering a domain name.
E.24.3. In order to expand the top level, and lighten the load on the
existing TLDs (most notably .COM), a category naming scheme is needed to
avoid, or at the very least, limit the number of potential disputes in
the domain name space. By allowing organizations to obtain and use
domain names within their specific area of business, two companies with
the same business name can operate domain names on the internet without
causing confusion to the consumer in exactly the same way they would
outside the internet. By placing each company under a top level domain
that describes its business category, it will be easier to determine
that <smith>.<meat>, the hamburger company, is not <smith>.<oil>, the
gas station chain. The mapping scheme is primarily designed to protect
the consumer from fraud by describing the area of business and to
establish an identity of the source of goods and services provided over
the internet. It does not provide any trademark recognition or status.
E.25.4. Failure to adequately divide the namespace will guarantee
extensive and complicated beauraucracies, as well as increase conflicts
that will impede the progress and growth of the internet.
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?
E.25.1. The purpose of the TLD determines the necessary qualifications
of the applicant, and also provides a guide as to whether the TLD can be
delegated to the applicant.
26. How would the number of different gTLDs and the number
of registrars affect the number and cost of resolving trademark
disputes?
E.26.1. Increasing the number of parties involved in a dispute increases
the cost of resolution.
27. Where there are valid, but conflicting trademark rights for
a single domain name, are there any technological solutions?
E.27.1. No.
28. Are there any other issues that should be addressed in this
area?
E.28.1. No.
------------------------------ break ------------------------------
F. OTHER ISSUES
Existing New Top Level Domain Applications
The application process is documented in [RFC 1591], which describes
the delegation and use of the existing top level domains COM. EDU, NET,
ORG, INT, GOV, MIL, and the ISO-3166 two letter country code domains.
It also describes the role of the Internet Assigned Numbers Authority
(IANA), which is responsible for the overall coordination and
management of the Domain Name System (DNS), and especially the
delegation of portions of the name space called top-level domains.
[RFC 1591] states "all requests for new top-level domains must be sent
to the Internic (at hostmaster@internic.net)". If approved, these top
level domains are added to the root.zone file which is carried by the
root DNS servers. The latest root.zone can be found at:
[ftp://rs.internic.net/domain/root.zone.gz]
What has caused confusion is the scope in which [RFC 1591] accepts new
top level domain name applications. Some have argued that historically
only new ISO-3166 TLDs have been granted and that is the entire scope
of this RFC. The actual paragraph that is in question is quoted here:
2. The Top Level Structure of the Domain Names
In the Domain Name System (DNS) naming of computers there is a
hierarchy of names. The root of system is unnamed. There are a set
of what are called "top-level domain names" (TLDs). These are the
generic TLDs (EDU, COM, NET, ORG, GOV, MIL, and INT), and the two
letter country codes from ISO-3166. It is extremely unlikely that
any other TLDs will be created.
Expectation and reality aren't always the same thing, just like
financial projections and earnings aren't the same. Does this paragraph
mean that:
a) No new TLDs of any sort will be delegated in the future?
b) Only new ISO-3166 domains will be delegated in the future?
c) There is no perceived need for additonal TLDs at this time?
It is quite apparent that any two letter country codes identified by
ISO-3166 could be added at the request of that country's government at
any time. It does not say other TLDs will not be created, just that it
is unlikely that they will. It was, presumably, left open like this in
case there was a future need for other types of TLDs. It certainly
does not say that new TLD applications outside of ISO-3166 (such as
the majority of new TLD applications currently submitted to IANA), are
not valid applications. [RFC 1591] is quite clear on the issue of
processing applications for new TLDs:
3) The designated manager must be equitable to all groups in the
domain that request domain names.
This means that the same rules are applied to all requests, all
requests must be processed in a non-discriminatory fashion, and
academic and commercial (and other) users are treated on an equal
basis. No bias shall be shown regarding requests that may come
from customers of some other business related to the manager --
e.g., no preferential service for customers of a particular data
network provider. There can be no requirement that a particular
mail system (or other application), protocol, or product be used.
There are no requirements on subdomains of top-level domains
beyond the requirements on higher-level domains themselves. That
is, the requirements in this memo are applied recursively. In
particular, all subdomains shall be allowed to operate their own
domain name servers, providing in them whatever information the
subdomain manager sees fit (as long as it is true and correct).
It quite clearly states that the same rules are applied to all TLD
requests. This means that the assumption by some that only ISO-3166
TLDs should be processed is incorrect.
It also says that all requests must be processed in a
non-discriminatory fashion, and academic and commercial (and other)
users are treated on an equal basis. It is quite clear that every
application received by IANA must be processed, and that this (because
the requirements are applied recursively), includes all the existing
TLD applications received by IANA.
No word has come from IANA as to why these new TLD applications
have not been processed. It has however, in conjunction with the
Internet Society (ISOC), International Telecommunication Union (ITU),
World Intellectual Property Organization (WIPO), International
Trademark Association (INTA), and the Internet Architecture Board
(IAB), created the International Ad Hoc Committee (IAHC) which was
supposed to address the legal, administrative, technical and operational
concerns, with particular attention to the questions of fairness and
functional stability of the domain name space. Unfortunately, the IAHC
have not succeeded in this matter.
------------------------------ break ------------------------------
Best Regards,
Simon
###
Number: 321
From: Scott Persons <golden@uslink.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 2:12pm
Subject: Domain Names
My comments:
There's no question we need more domain names to handle internet
growth. As for who should manage them, I recommend one group be
in charge, but allow many others to offer them in order to foster
competition. We shouldn't have to pay $50/year to a monopoly.
Also, why hasn't anyone thought of adding the domain name ".biz"?
It sounds a lot better than ".firm" or ".store"
Thanks!
Scott Persons
golden@uslink.net
A Golden Opportunity! Scott & Bozena Persons
http://www.uslink.net/~golden golden@uslink.net
---------------------------------------------------------------~
"You can design your own future!"
We'll help you make your dreams come true!
---------------------------------------------------------------~
###
Number: 322
From: "Alex Gigante" <algigan@ix.netcom.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 2:49pm
Subject: DNS
I respectfully submit my comments regarding the domain-name system, annexed
as a document in Word Perfect format. These comments briefly address
issues that I discuss more fully in the following articles:
Blackhole in Cyberspace: the Legal Void in the Internet, 15 John Marshall
Journal of Computer and Information Law 413 (Spring 1997)
Ice Patch on the Information Superhighway: Foreign Liability For
Domestically Created Content, 14 Cardozo Arts and Entertainment Law Journal
523 (1996)
"Domain-ia": The Growing Tension Between the DNS and Trademark Law,
reprinted in Coordinating the Internet (MIT Press 1997)
Alex Gigante
Business Hours:
agigante@putnam.com, and
agigante@penguin.com
All Other Times:
algigan@ix.netcom.com
Comments of Alexander Gigante
The issues surrounding the domain-name system are interrelated with
the organization and structure of the Internet. The so-called Internet
Community is comprised of dozens of organizations and ad hoc groups that
came into existence when the Internet was the province of DARPA and NSF.
So long as these governmental agencies assumed responsibility for the
Internet, no one questioned the authority of the Community acting under
federal auspices
to make decisions regarding the name space. However, the withdrawal
of the governmental agencies from day-to-day Internet activities leaves
the Community without legal basis for its actions.
No statute gives IANA the power it wields. IAHC's authority is
self-proclaimed. And so is the case with every group that currently
participates in Internet governance. Thus, not surprisingly, the
Community's credibility now seems to be slipping away, as exemplified by
the domestic and international opposition to IAHC's proposal to create new
gTLDs accompanied by a Council of IAHC-selected registrars.
The current situation reflects the notion that the Internet should be
allow to evolve in an unregulated environment. This idealistic view is a
mistake. The lack of top-down structure will not mean an unregulated
environment. To the contrary, it will result in an over- regulated and
worse inconsistently regulated Internet. Absent some comprehensive
international agreement regarding the applicable rules, each jurisdiction
will go its separate way to enforce its own laws consistent with its
national policies. A few years ago, a German court enforced German
trademark law against an American Web site. A few months ago, a UK court
assumed jurisdiction over a German company on an unfair-competition
complaint filed by a US corporation. About six months ago, Mattel sued
Hasbro in California federal court, claiming that Hasbro's Scrabble Web
site violated Mattel's rights in the name under a variety of international
and foreign trade laws. (Hasbro, which owns the SCRABBLE name only in the
US and Canada could not, of course, deny access to surfers in Mattel's
exclusive SCRABBLE territory, which encompasses everywhere else in the
world.)
Moreover, even assuming that the Community were permitted to govern
the Internet free of conflict with real-world jurisdictions, its clubby,
elitist approach reflective of the days when the Internet was the
plaything of a select group of engineers has not generated wise
decision-making. IAHC is forging ahead with its gTLD plan, despite
credible evidence that it will not resolve any of the issues plaguing the
current TLD system. Representatives of major intellectual property
interests have already gone on record to state that the conflict between
the domain-name system and real-world trademark law will continue under
the new gTLDs. IAHC's presumptuous division of the world market for
Internet registries does not even pay lip service to possible antitrust
problems under US and foreign law. And what power will IAHC have to wrest
the .com database from NSI if the latter, which asserts a proprietary
right in the database, refuses to make it freely available on expiration
of its cooperative agreement with NSF?
The Internet generally, and the domain-name system in particular,
need the following:
1.
Regulation by a federal agency to establish basic, consistent rules
for the
allocation and registration of domain names;
2.
Amendment of federal trademark law to eliminate conflicts between
trademarks
and domain names (specifically, by providing that one party's use of
a domain
name will not dilute or otherwise affect the goodwill attaching to
another's
trademark in the same name, thereby eliminating the primary reason
for most
domain-name litigation);
3.
Clarify by legislation the legal status (including ownership) of the
name space
(the Internet Community's pious designation of the name space as a
"public trust"
resolves nothing: what are the self-appointed trustees' obligations?
what laws
define the trustees' duties and responsibilities?);
4.
An international agreement addressing points 1, 2 and 3 on an
international scale,
including specifically establishing an international regulatory
organization with
defined, legally based powers, and removing authority from
self-appointed
Internet governors;
5.
In addition, an international agreement to avoid inconsistent,
conflicting
regulation that will result from the application of dozens of laws to
each Internet
transmission (specifically, by applying exclusively the law of the
country of
origin: see my article at 14 Cardozo Arts and Entertainment Law
Journal 523
[1996] for an example of such an approach)
###
Number: 323
From: Michael Schneider <sastre@Anwalt.DE>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 3:33pm
Subject: FYI: Electronic Filing of Comments on Internet Domain Names
Dear Sirs and Madams,
with reference to the above-stated request for public comment, we transmit
the following statement of position by
eco - Electronic Commerce Forum e.V., Germany.
With respect,
- on behalf of eco e.V. -
Michael Schneider
(Chairman)
Comments on the Registration and Administration of Internet Domain Names
Department of Commerce - request for public comment
[Docket No. 970613137-7137-01]
Dear Sirs and Madams, With reference to the above-stated request for
public comment, we transmit the following statement of position by
eco - Electronic Commerce Forum e.V.
As a result of the limited time available to us, we have not been able to
answer all of the questions, or have only been able to provide cursory
answer to some.
With respect,
signed Michael Schneider
- Chairman -
I. Background of
eco The German non-profit association Electronic Commerce Forum e.V. (eco)
was established by Internet service providers and enterprises which use
the Internet and services based on the Internet for commercial purposes at
the beginning of 1995. More than 60 members have now joined Eco - most of
them enterprises.
The association concentrates on two areas:
(1) Services and interest representation for Internet service providers
The association represents the political and economic interests of the
leading German
Internet service providers (ISPs). Eco views itself to be a "lobby"
working on behalf of the
ISPs and in this capacity it communicates with legislators and business
associations; in
addition, Eco is also involved in representing the interests of
providers in numerous national
and international projects. In this context, Eco is - together with
others - preparing, for
example, to found a pan-European ISP-Trade-Association (EuroISPA). Eco
continues to be
member in a worldwide platform of Internet-Trade-Associations which have
recently formed
in order to enable a global exchange of opinion regarding the interests
and needs of the
Internet industry.
On behalf of the German ISPs Eco also performs technical, legal and
content-related
services. These in particular include the German ISP's exchange point
"DE-CIX" and
projects with regard to voluntary self-regulation.
1. Electronic Commerce
The second point of concentration for Eco is the promotion and
propagation of
electronic commerce. Eco views itself in this context to be a platform
for interested business
groups jointly developing markets and solutions for electronic commerce.
In the
international arena Eco promotes the interests of its members within the
framework of the
Electronic-Commerce-Europe-Association (ECE), of which Eco is a founding
member.
II. STATEMENT OF POSITION
A. Appropriate Principles
Eco expressly supports the principles set out in Section A. We are of the
opinion, however, that the following statements should in addition be
considered:
1. The global nature of the Internet" should not only be taken into
account in the
technical respect. Rather, the Internet has in the meantime become a
communications
platform which from an economic point of view has become indispensable
for many
enterprises. For example, the German telecommunications market in
general as well as the
Internet market in particular, is - both with respect to revenues which
are generated here
and with respect to the number of subscribers - one of the biggest in
the world. Internet has
been playing an increasingly more important role here for years.
2. Accordingly, the interests of the German Internet industry must
also be taken into
account in all decisions which are of importance to the continued
development of the
network. This has not been successfully done within the framework of the
IAHC process.
3. The composition of self-regulating bodies in the Internet must
take regional factors
into account. Only then it can be assured that regulations, which are to
have worldwide
effect, meet the requirements of national economies outside the USA: If
this is not provided
for, the development of Internet into a platform for global electronic
commerce will be put
in question. In this respect as well, neither the IAHC or the iPOC have
yet been able to gain
the confidence of business sectors lying outside the USA. Members of the
iPOC moreover
have been making the sustained impression - most recently at a meeting
of various Internet
trade associations (including CIX, CAIP, UK-ISPA, LINX and Eco) - that
no satisfactory
membership for this body can or shall be obtained for the time being.
B. General/Organizational Framework Issues
1. What are the advantages and disadvantages of current domain name
registration systems? One of the most significant disadvantages of the
current domain name registration systems is above all to be found in its
history:
All registries which administer the TLDs traditionally derive
their right to do so from the
IANA. This is not based on written law, but rather on historically
evolved agreements which
continue to be accepted throughout the entire Internet. Such traditions
have increasingly
been criticized, however. The IANA is not a legal person, but rather a
construct which is for
the most part embodied in one single person.
The administration of TLDs is predominantly organized along
monopolistic lines,
thus allowing individual organizations to dictate the conditions and
prices at which they
assign domains - a situation which in part still exists today. The
administrators of the TLDs
are not subject to any effective supervision.
No adequate policies have been developed to extend the domain
name space by
structuring it beyond the top level. Moreover, action against the
improper use of the name
space was taken too late. Both has led to a shortage in the name space
which was avoidable.
2. How might current domain name systems be improved?
The solution to the current problem is not to be found in the further
development of the DNS, but rather in the implementation of a directory
system. As soon as technologies are available which lead Internet
subscribers to find resources in another manner than by using canonical
domain names, the rush for domains - in particular for Com-domains will
decline significantly. As attractive domains are - within the additional
name space which the IAHC as well as Alternic and others want to create -
only available to a limited extent, a further impovement of the DNS by
establishing additional gTLDS would only be helpful as a transitional
solution.
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 DNS should be administered by a non-profit organization which is
subject to the supervision of a self-regulating body, whose membership is
balanced in terms of competencies and regions. In particular, the most
important Internet "stakeholders" - above all the Internet service
providers - should have a seat and vote in the self-regulating body.
Government agencies should not have any role, or only an observational
role, in the self-regulating body.
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?
From our perspective, there is no reason to retire the gTLDs, which are
presently in use, from circulation.
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?
In this context we refer to the proposal made above, according to which a
directory system should be implemented and it should be ensured that the
existing name space can be efficiently used.
8. How should the transition to any new systems be accomplished?
The transition should not be made until worldwide consensus prevails with
respect to the new system. It continues to be absolutely necessary for the
new system to be developed and tested in accordance with recognized
principles of project management. Here those organizations should be
involved which are especially familiar with the technical development of
the Internet (IETF, IAB, ISPs).
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?
From a technical perspective, the number of conceivable gTLDs and country
TLDs is theoretically infinite. The technical expense which must be borne
in order to create a larger number of new TLDs could be significant,
however. Beyond this, the establishment of numerous new TLDs may confuse
enterprises and subscribers which use the Internet as a platform for their
business activities.
11. Should additional gTLDs be created?
The simplest and at the first glance most efficient strategy in order to
prevent a shortage in name domains is to introduce new generic top-level
domains (gTLDs). The technical and administrative efforts involved in
doing this are relatively low and an almost infinite number of additional
name space can be easily created by means of alternative DNS extensions.
It is not surprising, then, that all approaches to revise the DNS which
were discussed in the past few years have also always included the
implementation of new gTLDs. Nevertheless, we are of the view that this
measure is not suitable for avoiding conflicts over name rights. They will
instead cause many enterprises and organizations to see themselves forced
to register their names under several gTLDs - which means in all
categories of relevance to them. Should this prediction turn out to be
true, the extension in the name space at the TLD level will have proven to
be counter-productive.
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?
From a technical point of view there is no reason to make a distinction
between gTLDs and country TLDs. However, the sovereignty over country TLDs
should be assigned to the self- regulating bodies in the respective
countries.
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?
A registrar should only have exclusive control over a particular gTLD if
it is subject to the direct and unrestricted supervision of one of the
above-described self-regulating bodies. The technical implications of
sharing a registry have thus far not been sufficiently examined. Some
experts doubt whether the model developed by the IAHC is technically
feasible. Given this background, we urgently recommend that a technical
analysis and suitable beta test be conducted before the model is
implemented.
Exclusive and non-exclusive gTLDs may easily coexist.
16. Should there be threshold requirements for domain name registrars, and
what responsibilities should such registrars have? Who will determine
these and how?
Threshold requirements for domain name registrars are desirable from our
perspective in order to guarantee a high quality of service, adherence to
minimum standards in the areas of data protection as well as data security
and the economic stability of the registrar. It is scarcely possible,
however, to define requirements for registrars which prevent abuse and
still meet anti- trust requirements.
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?
We assume that with a large number of competing registrars competition
will be significant and perhaps even more than is being aimed. This could
lead to rapid economic destabilization of those registrars which receive
their main revenues from the domain business. Such a destabilization could
limit the viability of the future DNS strategy as well as confidence in
the stability of the Internet.
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?
In our opinion this question can currently not be answered. It should be
raised again after the first experience has been gained with a limited
number of new gTLDs - to which all registrars should receive equal access.
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?
We are of the opinion that an efficient protection of trademarks and of
trademark owners is not possible vis-a-vis domain names.
In practice, the use of identical trademarks happens again and again, for
example as they are registered for different classes. Furthermore the
registration can - following the principle of territoriality - be applied
for in different countries. Although there were various attempts to
overcome territoriality by supranational treaties in the past - such as
the Madrid Treaty - this has still not been entirely achieved.
In addition, in some legal systems conflicts over names can also arise at
a national level. In many cases, there is provision that although the
holder of a prior right enjoys priority, he must consent to the use of
this mark by a third party. This can, for instance, occur if the
registration of an identical mark is not opposed in good time or if the
earlier mark has not been used over a longer period of time. A legal
solution in such cases of conflict does not exist; the disputed marks must
exist alongside one another and their owners are compelled to compromise.
On the Internet domain names have to be assigned in an unambiguous manner
and therefore it is not conceivable to apply the legal rules dealing with
trademark conflicts to the assignment of domains. In addition, trademark
rights can not completely be protected in the Domain name area.
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?
The following model should be taken into consideration (details in
http://www.anwalt.de/publicat/inet_idx.htm). It is based on the joint use
of a domain in case several applicants raise a claim to the related name:
1. Domains are assigned to the user on a first come, first served
basis (following the
principle of priority).
2. Should a further applicant raise a claim to a domain, this will be
placed under joint
administration ( sequestration").
3. If after examination, the claim of the new user is unjustified,
the domain will be
assigned to the original user. If the original user's claim is invalid,
then the name will be
assigned to the new claimant. If both have a justified right to the use
of a name, then the
domain will be placed under permanent joint administration. In the case
of the name being
assigned to exactly one user, the defeated party will bear the costs of
the examination and
alteration.
4. Should further applicants wish to lay claim in the case of a
permanent joint
administration then the procedure as mentioned in (1) and (2) will be
repeated analogously.
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?
Disputes can only be decided in litigations presided over by national
courts at present as a result of the varying regulations applying to
trademark rights throughout the world. In this context, we have
recommended the following to the German Ministry of Economics and the
Ministry of Justice:
TLD administration by a self-regulating bodies
The administration of TLDs and the assignment of name space at
the SLD level
should continue to be performed by self-regulating bodies. It must be
ensured by means of a
suitable legal framework (by act of law or a public-law agreement
between the government
and the self-regulating body) that this task is performed lawfully, at a
reasonable price and
according to the principle of equal rights.
Integration of the jurisdiction into the federal patent office
The activity of the organization which is administering the name
space should be
closely tied to the tasks of the federal patent office (which in Germany
is also responsible for
the registration of trademarks). However, this should not apply to the
assignment and
technical administration of the name space as such, but rather for the
issue of jurisdiction.
To solve name conflicts, it appears to suggest itself - especially when
taking into account the
proximity of the issue with trademark rights - to set up judicial bodies
at the federal patent
office which have the final word in conflicts relating to domains.
As far as the IAHC intends to solve domain disputes by setting up
so-called "Administrative Challenge Panels" (ACPs) and by mediation and
arbitration, their approach may basically be welcomed, but it does not
ultimately lead to a satisfactory result for the following reasons:
Mediation can only be successful if the parties involved in a
dispute voluntarily adhere to the
ruling of the mediator. Especially in an area of such economic
importance as that
represented by name rights, however, it is to be expected that the
losing party will still act to
initiate litigation even after the conclusion of the mediation.
The establishment of a special jurisdiction and/or arbitration
only makes sense if
these are effectively agreed upon before any cause for legal dispute
arises. This is extremely
difficult, however, in the area of domain name administration. On the
one hand, very
different requirements are placed on arbitration agreements world-wide,
which means that
the effectiveness of this approach can be easily undermined simply by
virtue of formal
mistakes. On the other hand, an arbitration agreement can only lead to
reasonable results if
it must be mandatorily accepted by all parties involved - this is,
however, delicate in an area
in which an authority holds a dominant position in the market and may
accordingly be
subject to anti-trust regulations.
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?
Conflicts over trademarks can be prevented or reduced by either
1. replacing the directory function of the DNS by introducing an
adequate directory
system, or
2. introducing the above-described model of sequestration" to solve
disputes.
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?
Name rights should basically not be reviewed by registrars, as these may
not have the necessary legal knowledge and, beyond this, may be subject to
liability for significant compensation as a result of their rulings.
A pre-review by government agencies - for instance the trademark offices -
does not make sense either, as the review procedure would constrain the
efficient assignment of domains, which is indispensable for electronic
trade in Internet.
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?
An alternative solution which should be taken into consideration is based
on the joint use of a domain in case several applicants raise a claim to a
related name.
28. Are there any other issues that should be addressed in this area?
./.
###
Number: 324
From: "j.poeppelmann@plateaux.com" <Jens@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 5:27pm
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 Jens 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.
-------------------------------
Sunday, August 17, 1997 17:25:56 EDT
Jens
###
Number: 325
From: "rushkoff@interport.net" <Douglas.Rushkoff@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 5:34pm
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 Douglas Rushkoff 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.
-------------------------------
Sunday, August 17, 1997 17:33:22 EDT
Douglas Rushkoff
288 West 12th St.
NY NY 10014
###
Number: 326
From: "may@hiregun.com" <May.S.Young@violet.xs2.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/17/97 10:58pm
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 May S. Young 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.
-------------------------------
Sunday, August 17, 1997 22:57:18 EDT
May S. Young
###
Number: 327
From: "Jeff Griswold" <jgrizzz@msn.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 1:24am
Subject: Domain Name Service
I just wanted to throw my two cents into the hat. I think that we
should seriously consider a regional approach to name resolve. If the
address's took on a regional identifier it might help ease some of the log
jamming the internet experiences. I would look at at least a state level
code for the US.
"www.business.fl.com" or "www.business.ny.com"
Just a thought
J. Griswold
###
Number: 328
From: <Nlordi@aol.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 12:47pm
Subject: Filing of Comments on Internet Domain Names
RECOMMENDATION
The issue of Internet domain name registration and administration is but
a subset of a much broader issue with far reaching consequences, ie.,
the future structure(s) and mechanisms for global Internet governance.
We need to fully appreciate that whatever path we pursue we are not only
addressing management of Internet domain names, but are in fact establishing
a precedent for a private self governance system for the Internet.
Therefore, the US government should work within international circles
to discuss the establishment of a multi-national panel with a compensated,
full time staff with the necessary resources to focus on and
address the issue of global Internet governance. Recommendations should be
provided to the Internet community within 6 to 9 months.
The US government should also consider the upcoming 1 - 3 October 1997
conference (http://www.ispo.cec.be/standards/conf97/welcome.html)
"Building the Global Information Society for the 21st Century"
sponsored by the International Telecommunication Union (ITU), International
Organization for Standards (ISO), and International Electotechnical
Commission (IEC), as a possible venue to initiate discussions
on the topic global Internet governance.
DISCUSSION
Internet domain names is but the first of many issues to surface.
A partial list of other issues which may effect the openness and
universal connectivity of the Internet, and may need to be addressed in
an appropriate forum in the very near future include:
- intellectual property rights regarding the content one posts to
the Internet,
- settlement fees between Internet Service Providers,
- the establishment of rules for peering and exchanging traffic between
Internet Service Providers,
- regulation of gambling over the Internet,
- regulation of pornography over the Internet,
- regulation of taxation,
- the use of "cookies" and ones rights to privacy,
- the establishment of legal jurisdictions and boundaries
regarding the Internet
- management and assignment of IP address space,
- governance and structure of the RIPE, APNIC and ARIN registries,
- ownership of IP address space,
- regulation of email spam,
- intellectual property rights surrounding the use of third party cache
and replication servers,
- governance of Internet telephony, and
- a concern that non-US Internet users pay an inordinate cost for
international connections between the US and other continents.
Any one of these above issues could effect the global stability and
connectivity of the Internet just as easily as the domain names issue.
We must therefore ask ourselves "given the existing set of proposals
regarding Internet domain names, are we establishing a mechanism and
precedent for Internet governance under which new Internet governance
issues will likely be addressed ?"
Our answer to this question is yes, as new Internet governance issues
surface, common sense would dictate to try to address these issues in
an already established framework.
Consequently, we must also ask ourselves, "are the processes and set of
participants in the IAHC / gTLD-MoU sufficient enough to address new
and emerging issues which effect the connectivity of the Internet
and global Internet governance ?".
Our answer to this question is no, the IAHC / gTLD-MoU processes
were not designed to support and are not sufficient to support
global Internet governance.
In fact, in the charter of the IAHC (http://www.iahc.org/iahc-charter.html)
no mention or mechanism is made of how to
address new emerging issues of Internet governance.
Therefore, the US government should consider sponsoring a session to
discuss the establishment of a multi-national panel with a compensated,
full time staff with the necessary resources to address the issue of
Internet governance, with recommendations provided to the
community within 6 months.
The US government should also consider the upcoming 1 - 3 October 1997
conference (http://www.ispo.cec.be/standards/conf97/welcome.html)
"Building the Global Information Society for the 21st Century"
sponsored by the International Telecommunication Union (ITU), International
Organization for Standards (ISO), and International Electotechnical
Commission (IEC), as a possible venue to initiate discussions
on global Internet governance.
ADDITIONAL RECOMMENDATIONS REGARDING THE ISSUE OF DOMAIN NAME
MANAGEMENT
First, the system is stable, and contrary to the popular press there
does not appear, upon examining the Securities and Exchange Commission
Form S-1, filed July 3, 1997 for Network Solutions Inc.,
any exorbitant profits. In fact, it appears after reading the S-1 that
NSI is investing a majority of its fees in hardware, software, and
third party vendors in support of back office operations to deliver
its services.
The US government, specifically the National Science Foundation,
should be commended for actively managing the NSF/NSI cooperative agreement
for the betterment of the entire Internet community.
The real winner of this cooperative agreement is the Internet community.
The initiative of NSF in establishing an Intellectual Infrastructure Fund
with millions of dollars on account will eventually benefit the entire
Internet community.
The system established under NSI has provided a stable system for a fair
price. Where else can one request a service (the issuance of a domain name)
and have it "delivered" without first paying for the service, and without
any prior credit history ? In fact, the net fee of $35, besides supporting
the assignment of an Internet domain name, also supported, without cost to
the end user, the management and assignment of IP address space.
There are still many unanswered questions regarding the IAHC / gTLD-MoU plan.
For example, will the processes defined by the IAHC / gTLD-MoU provide a
comparable level of stability ? What fee(s) will end users have to
pay under the IAHC / gTLD-MoU plan for domain names ? Are 7 iTLDs enough ?
Where is the full time staff to provide a transition to the
processes defined in the gTLD-MoU ?
We are concerned that the IAHC / gTLD-MoU is moving forward
too quickly and fails to address several issues, such as those
outlined in Digital Equipment Corporation's Attachment to the gTLD-MoU
(http://www.itu.int/net-itu/gtld-mou/decadd.htm), ie.,
a concern for consensus building, stability of existing top level domains,
stability of name registration, and preserving intellectual property rights.
Furthermore, we are particularly concerned with the failure to address
the recommendations raised by the IAHC regarding the .US top level domain.
THE .US DOMAIN
The US Domain is an official top-level domain in the DNS of the Internet
community. It is administered by the US Domain Registry at the
Information Sciences Institute of the University of Southern California
(ISI), under the Internet Assigned Numbers Authority (IANA).
(above per http://www.isi.edu/in-notes/usdnr/usdom-overview.html)
The "Final Report of the International Ad Hoc Committee: Recommendations
for Administration and Management of gTLDSs" (available at
http://www.iahc.org/draft-iahc-recommend-00.html) states that:
"Current difficulties with gTLDs are highly exacerbated by inadequate
use of the .us TLD and the IAHC requests that scaleable and functional
Second-Level Domains (SLDs) for .us be defined and used, in the spirit
of those that already exist for many other ISO 3166-based TLDs."
Furthermore, the IAHC report states:
"The IAHC suggests that the domain administrator for .us undertake
further delegations along the lines of the functional SLD structure,
suitably modified to account for large-scale delegation and management,
and suggests this type of functional structure to other ISO 3166
national name space administrators as a widely understood structure."
Why has this issue not been discussed further either by the
US Domain Registry and IANA (both at the Information Sciences Institute
of the University of Southern California) and/or gTLD-MoU Policy
Oversight Committee ?
Would dealing with the .US top level domain provide the community
with additional time to deal with the issues of domain name
management under the broader umbrella of global Internet governance ?
This is but one example that we may be moving too fast without fully
discussing previous recommendations.
###
Number: 329
From: Gordon Irlam <gordoni@base.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 8:24am
Subject: Comments of Gordon Irlam
Document available at:
http://www.base.com/gordoni/thoughts/ntia-dns-comments.html
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 Gordon Irlam.
gordoni@base.com
Gordon Irlam
2310 Rock St. #10
Mountain View, CA 94043
18 August 1997
Gordon Irlam respectfully submits comments in this proceeding. Gordon Irlam
is employed as a software developer. He is a domain name registrant and
operator of a DNS server. He has been using the Internet for 12 years,
participates in the IETF, is a member of the W3C Advisory Council, the
Association for Computing Machinery, and the American Economic Association.
----------------------------------------------------------------------------
Table of Contents
A. Appropriate Principles
* Additional principles
B. General/Organizational Framework Issues
* Questions 1-8
C. Creation of New gTLDs
* Questions 10-13
D. Policies for Registries
* Questions 15, 16, 19, 20
----------------------------------------------------------------------------
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. [...]
The following additional principle is suggested:
Domain name registrants should acrue the wealth they have created.
Domain name registrars should merely be able reap the value of the
registration services they perform.
It is the domain name registrant that performs the vast majority of
investment resulting in the creation of wealth associated with a particular
domain name. It is important that domain name registrants be able to reap
the value of this wealth. Any policy that enables domain name registrars to
reap the wealth associated with investments made by domain name registrants
would create economic inefficiencies. These economic inefficiencies would
manifest themselves as under-investment in the creation of domain name
content, and an over-investment in domain name registration services.
Two implications of this principle are:
* For the duration of use of a particular domain name, the domain name
should essentially be viewed as the property of the domain name
registrant.
* Domain name owners should not be held captive to particular registrars.
Registrants should be able to switch registrars at will. This is
necessary to ensure the registrant and not the registrar can captures
the wealth created by the registrant.
----------------------------------------------------------------------------
B. General/Organizational Framework Issues
1. What are the advantages and disadvantages of current domain
name registration systems?
The registration system for the .COM, .ORG, and .NET domains have the
advantage of being part of a single system, with a single common set of
procedures for the registration of domains, payment of bills, and querying
the status of registrations.
The registration system for the .US domain is highly fragmented rendering it
effectively unusable. Different sub-domains are administered by different
authorities. These different authorities have different policies and
procedures. There is no central database that can be searched to access
information on registrations within the US domain. For many subdomains it is
not even possible to determine which domain names are already allocated. It
is even difficult to determine the appropriate procedures and authority to
contact to register within a particular domain.
The registration systems for most of the other ISO country code domains
besides .US also have various problems. However each of these registration
systems is ultimately under the control of the respective national
governments, and it considered important that national governments are
offered the opportunity to play a role in the provision of domain
registration services.
All the present registration systems have the disadvantage of a lack of
competition in the provision of registration services for the underlying
domain names. This lack of competition results in registration services
being provided inefficiently. A second problem resulting from the lack of
competition is prices need not being set based on the cost of the underlying
services provided. Today this is not as serious problem. Most of the domain
registration systems are under some form of regulations that limit the
prices that can be set. However, were such regulations to be removed,
without provisions for competitive registration within these domains,
serious problems would result. Domain name registrars for particular TLDs
would be able to set almost arbitrary prices for the continuance of
registration within particular TLDs. The structure of the World Wide Web
makes it impossible for a registrant to switch to a different domain name
without loss of almost the entire value built up around a preexisting
domain. Consequently, registrants would have little alternative but to pay
what would essentially be arbitrary monopoly fees set by domain name
registrars. This situation can only be prevented through either the
continued regulation of prices, or the introduction of competition in the
provision of registration services within TLDs.
2. How might current domain name systems be improved?
The provision of registration services could be improved by having multiple
competitive registries for the provision of registration services within
existing domains. This would increase the efficiency of the registration
process. More importantly, it would ensure registrants, rather than
registrars, are able to capture the value of the wealth created by the
registrants investment in a particular domain. This is especially important
if the existing regulatory limits on the fees charged for domain name
registration were to be removed.
The operation of the root name servers could be improved through a
competitive biding process to determine the operators of the root name
servers. An example scenario follows. Registrars could be required to pay an
annual fee based on the number of domains for which they are currently the
registration agent. This fee would be passed on to domain name registrants,
and should be of the order of $1-2 per domain per year. The fees collected
would be used to pay the costs associated with the operation of the root
name servers. Contracts to operate a subset of the root name servers for a
three year period could be competitively bid on a yearly basis. This way,
only a third of the root name servers would undergo operational transitions
each year, ensuring high operational stability of the DNS infrastructure.
For operational reasons, IP addresses associated with the root name servers
need to pass from one contractor to the next, and must not be considered the
property of the incumbent contractor.
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?
We don't feel any existing entity is presently ideally suited. However,
given the overwhelming importance of operational stability, and the urgency
of the present matter, we feel the framework provided by the gTLD MOU that
was created by the IAHC represent by far the best of the available options.
Desirable aspects of the gTLD MOU include the provision of competitive
commercial services acting under a framework of public trust, effective self
governance by bodies including IANA with a proven track record in operating
the Internet infrastructure, and ultimately this governance overseen by
appropriate international bodies.
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 role of the FCC in regulating the provision of long distance phone
service serves as a reasonable model of the necessary role for governmental
or non-governmental organizations in creating the framework for the
provision of DNS services. Desirable features of the regulation of long
distance phone service include:
* Long distance service is provided by commercial organizations within a
competitive framework established by the government and administered by
the FCC. Similarly, DNS registration should be provided competively,
but under a framework established and regulated by appropriate
governmental or non-governmental organizations.
* Phone subscribers have the ability to change long distance providers at
will. Analogously, domain name registrants should have the ability to
change registrars at will.
* Long distance companies do not have monopoly ownership of the right to
provide long distance service to particular blocks of phone numbers.
Similarly, registrars should not have a monopoly on the provision of
registration services to those domains within a particular TLD.
* It is possible to keep the same phone number when changing long
distance providers. Analogously, domain name registrants should be able
to keep the same domain name when changing registrars. A phone numbers
are treated as belonging to the subscriber, not to the long distance
company.
* The competitive provision of long distance phone service is not all
encompassing. It interoperates with the regulated local phone services,
and the phone services regulated by foreign governments. Similarly, the
competitive provision of services for the .COM, .ORG, and .NET domains,
should be able to coexist with regulated provision of the .EDU, and
.GOV domains, and the various different ISO country code 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?
The generic top level domains should be preserved. The regulatory and
administrative issues at hand have nothing to do with whether domain names
exist within a gTLD or an ISO country code domain. The present issues are
most significant for the gTLD domains simply because the gTLD domains are by
far the largest and most heavily commercialized of the TLDs. Therefore, it
is in the gTLD domains that the pressures for transition to competitive
market based registration services, as well as the risks of monopoly
control, are the greatest.
On a long term basis, as ISO country code domains grow, they too would
likely benefit from a competitive management structure. Consequently, it
would be best to develop a general purpose system for the competitive
registration of domain names. Initially this system would only contain the
.COM, .ORG, and .NET domains. However, in the future we should imagine the
possibility of national governments wishing to delegate registrations for
their ISO country codes through this same system. The system should be
designed to allow for this. Doing so does not pose any technical problems.
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?
A clear distinction needs to be made between administrative and operational
activities. The provision of registration services is an administrative
function. The operation of the root name services is an operational
function. There is a serious danger of monopoly control of the Internet when
a single party is free to perform both administrative and operational
activities.
Domain name registrars should be prohibited from operating root name
servers, and vice-versa.
Fundamentally, it is the operators of the root servers that have control of
the Internet name space. To ensure that they don't abuse this power it is
necessary to ensure that the operators of the root name servers treat the
data provided by each registrar equally. If the root name servers only used
data provided by a particular registrar, that registrar would be able to set
monopoly prices for domain name registration services.
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?
To ensure the scalability of DNS, continued investment in the development of
the BIND DNS software should occur. Additional root name servers should also
be deployed. These investments could might be funded from the NSF
Infrastructure Fund established under the cooperative agreement.
Rather than occurring on an ad hoc voluntary basis, operation of the root
name servers could be performed under competitive contract, with contractual
requirement to ensure root name servers continue to interoperate and
coordinate.
8. How should the transition to any new systems be accomplished?
The NSF needs to act in a timely fashion to ensure the complete contents of
the existing domain name databases are publicly available on the expiration
of the cooperative agreement. Article 10(E) of the cooperative agreement
provides the NSF can request the necessary information from Network
Solutions as part of the final report to be submitted by Network Solutions
to the NSF. It is important that the NSF request this information because it
will be required by any successor organization.
The initial registrars for each existing domain name should be allocated
evenly and randomly between the initial set of qualified competitive
registries.
This entire transition process needs to be performed very quickly, in a
period of no more than 5-10 days. Consequently it is vital that operational
planning for the transition be occurring between all relevant parties today.
Under the terms of the existing cooperative agreement Network Solutions is
permitted to collect a fee of $50 per year payable in advance for each
registered domain, with an initial two year payment being required when a
domain is first registered. This fee is intended to cover the cost of
providing registration services for the following year, or two years.
Network Solutions is presently collecting the full amount of this fee
despite the cooperative agreement being scheduled to expire in 6 months
time. The unearned portion of these fees should either be returned to the
domain name registrars, or passed on to the successor registration body.
With over 1 million domains registered, the amount of money at issue is
substantial.
----------------------------------------------------------------------------
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 hard restrictions on the number of gTLDs exist. However, great care and
prudence should be exercised. Once created, it is very difficult to change
or remove a gTLD. Consequently, gTLDs should only be created if there is a
pressing need.
11. Should additional gTLDs be created?
It is our perception that at the present time no new domains need be
created. This is not however a strongly held opinion.
Right now the primary focus should be on the management of the existing
gTLDs, and their transition to a competitive registration system. The
creation of new gTLDs is likely to only serve as a distraction to this
effort.
12. Are there technical, business, and/or policy issues about
guaranteeing the scalability of the name space associated with
increasing the number of gTLDs?
So long as all of the new gTLDs are administered within a single
registration system there are no problems of scalability associated with the
creation of new gTLDs.
If different gTLDs are administered under different administrative regimes,
then the number of different regimes should be kept to a minimum. End users
of the registration system can't be expected to know about and understand
all the different regimes, policies, and procedures. Creating multiple
regimes would likely result in problems similar to the present confusion
that exists regarding registration in the .US domain.
13. Are gTLD management issues separable from questions about ISO
country code domains?
Yes, gTLD management issues can be separated from the management of ISO
country code domains. Similar problems to those facing the gTLDs exist for
the ISO country code domains, but they are presently far less severe, and do
not require solving simultaneously. At a future date, the same mechanisms as
used to solve the problems associated with the registration of gTLD domains,
might be applicable to the ISO country code domains.
----------------------------------------------------------------------------
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?
None of the gTLDs should be under the exclusive control of a single
registrar. Unless subject to government regulation of the fees charged for
registration services, the registrar would be in a position to abuse this
situation by imposing monopoly fees on domain name registrants. Such fees
would result in economic inefficiencies.
There are no technical problems to using shared registries for all gTLDs.
There are minor organizational, managerial, and deployment issues that still
need to be solved, but these issues are readily solvable.
Exclusive and non-exclusive domains could coexist, but the creation of
exclusive domains would be bad public policy. If for some reason exclusive
domains should continue to exist in the future, transition plans for their
eventually maturing and becoming shared should be drawn up, and regulations
should also be imposed to limit fees in the interim.
16. Should there be threshold requirements for domain name
registrars, and what responsibilities should such registrars have?
Who will determine these and how?
There should be a set of requirements on domain name registrars. These
requirements should be focussed on ensuring the stability of the domain name
registration system. Registrants should be contractually required to be able
to guarantee a set of operational requirements, and have appropriate funding
to underwrite this guarantee.
It is reasonable for the bodies established under the gTLD MOU, the PAB,
POC, and CORE, to determine such requirements.
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?
All gTLDs domains should be a part of a single shared database. Registrars
should be able to administer all domains within all of the gTLD domains.
Allowing all registrars to act as registrars for all gTLDs will maximize
competition in the provision of registration services within each gTLD.
Exclusive domains should be phased out.
20. Are there any other issues that should be addressed in this
area?
It is important that appropriate contractual language exist to require
registration information be shareable between registrars. Registrars need to
disclaim all rights to the underlying registration information they have
collected, including all selection and compilation based copyrights, and any
future rights under the recently proposed database treaty. Registrars must
agree to provide the complete registration information for a particular
domain to a competitor in response to an authentic request from the domain
name owner to switch registrars.
----------------------------------------------------------------------------
###
Number: 330
From: "Lawrence W. Hillman" <sofar@compuserve.com>
To: "'Temp'" <dns@ntia.doc.gov>
Date: 8/18/97 7:12am
Subject: Domain Name Changes
I think the number of domain name "extensions" (.com, .gov, etc) should be
kept to a minium. Otherwise, we'll end up with many very similar names and
this will make them difficult to remember and reduce the identity value of
"trademark" names.
Larry Hillman
LHillman@HillcoRealty.Com
###
Number: 331
From: "Dave A" <daveanin@netlabs.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 9:43am
Subject: Keep with Network Solutions
I believe the Internet's naming should stay under one company, for
simplicity's sake...
Think about it, if I had 10 companies to choose from each offering different
services for DNS, such as .games, .home, .biz, .rec, etc... it would get way
out of hand... It should stay with .com, .net, .org, etc... it's easy, it's
established, and it works. Let's face it, other companies are just getting
greedy they can't enjoy profits from this system.. The Internet wasn't
designed for profits in its root structure anyway.
Leave NSI alone... Just because a lot of the good .com's are taken, doesn't
mean new businesses can't think of something creative for a domain name.
Dave Aninowsky
BNL Enterprises Inc.
31 Washington St.
Matawan, NJ , 07747
webmaster@pcwares.com
###
Number: 332
From: <Marktrade@aol.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 12:25pm
Subject: internet issues
FROSS ZELNICK LEHRMAN & ZISSU, P.C.
633 Third Avenue
New York, New York 10017
Telephone: (212) 953-9090
Facsimile: (212) 953-1037
August 18, 1997
VIA E-Mail
dns@ntia.doc.gov.
Office of Public Affairs
National Telecommunications and
Information Administration (NTIA)
Room 4898
14th Street and Constitution Avenue, NW
Washington, D.C. 20230
Attention: Ms. Patrice Washington
Reference: Request for Comments on Internet Issues
Dear Sir:
I am writing on behalf of the Intellectual Property
Law Section of the American Bar Association.
The Section will not be submitting written comments
in response to the request for comments published on July 2,
1997. However, the Section strongly believes that the issues
raised are of the utmost importance for intellectual property
owners and members of the intellectual property bar. Accord-
ingly, and in view of the summer season during which many
interested persons are away for periods of time, the Section
respectfully requests that public hearings be conducted to
insure full public review and analysis of these issues.
Respectfully submitted,
MDE/gf Mark D. Engelmann
Chair - ABA IPL Section
Committee 203
PTO Affairs - Trademarks
###
Number: 333
From: "proteus" <proteus@tpa.net>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 12:25am
Subject: TLD FILTERING SOLVES YOUR DILEMNA
Subject: TLD FILTERING AND WHAT IT DOES FOR ALL OF US
To: The Internet Community and every human on the planet
Cc: vice.president@whitehouse.gov, president@whitehouse.gov,
first.lady@whitehouse.gov
TLD FILTERING AND HOW IT WORKS FOR ALL
OF US TO PROTECT OUR CHILDREN ANDPROTECT OUR RIGHTS.A NEW IDEA
FOR
AMERICA
AND
THE INTERNET COMMUNITY
TLD filtering is a simple and effective answer to a dilemma facing our
society.
The two conflicting issues are:
1. Should parents have the right to determine what content reaches their
children during their formative years.
2. Do adult Americans have the right to freedom of expression and
access
to ideas and content of their choice, as guaranteed by the First
and Fourth
Amendments of the Constitution?
With the unanimous ruling by the Supreme Court that the Communications
Decency
Act was unconstitutional and unenforceable in any event, there have
emerged a number of proposals to deal with this conflict.
These haveincluded rating systems, watchmen organizations, and
possible Federal involvement with some other aspects under their
jurisdiction.
At the same time, the internet community itself has responded to these
concerns with a desire to "police themselves" without Uncle Sam getting
involved
in censorship. Other countries are also not satisfied with recent United
States
gestures toward control of TLD (top level domain) and naming conventions,
that
they feel are questions that should be put to the world community instead of
being pre-empted by us.
The way TLD filtering works is simple.
ISP's can develop methods of offering their customers a menu of TLD's that
they
want to see or that theydo not want to see. Business corporations might want
to
filter out any TLD involved with sexual content. Adults wanting access to
sexual
materials could select FULL TLD * i.e., any and all TLD's that the ISP
might have. The advantages are obvious. Everyone wins. Parents can control
what
their kids see, adults can say and do what they wish.
The BBS community *ancestors of the Internet * always controlled access to
adult content by requiring proof of age. Many *. But not all .. ISP's do
this now.
Certainly one of the leaders in this area is MCS (Macro Computer
Solutions,http://www.mcs.net), lead by Karl Denninger who is
one of the proponents of an extended EDNS (Enhanced Doman Name System) .
Currrently not all ISP's carry the alternate domains, i.e., those presently
carried by the InterNIC. (Those very recognizable TLD's are .COM, .ORG,.EDU,
and
.NET. The other "official" TLD's are MIL and GOV, under Federal
control). But there are other registration authorities and other countries'
telecommunications agencies who oppose the InterNIC and its recently
proposed
expansion plans. The Internet community has largely rejected these
recommendations, and the issue is really up in the air. Two websites that
discuss this are http://www.edns.net andhttp://www.alternic.net and there
are others
as well. There are also a number of well-intentioned public service-oriented
organizations who are trying to address the problem with ratings and even
chip-controlled access. But these are not standardized, and one of the jobs
that
any kid has had has been finding a way to get around parental controls.
With this method, TLD filtering, it is impossible for any child to access
a TLD not on the list provided by his ISP. With this method, an adult could
also
filter out some groups, let in others, based on his ownsense of what is
right
and wrong being on the web.
TLD filtering is a way for us to have our cake and eat it too.
It is a win win for everyone.
Larry BuckmasterPresidentConsulTech of Chicago
Proteus@tpa.net
312/902-2776
As of July 29, 1997, at 3:55 pm CST, the phrase "TLD Filtering" did not
exist
on the AltaVista Search Engine in either the Web or Usenet. This document, I
believe, is the first discussion of it, and I am sending it to various
correspondents
to catalog it as a message with a timestamp.
No claim or credit or the concept is claimed; only a desire to chronicle
what
may be a simple idea with vast consequence to many people.
###
Number: 334
From: Geoffrey Atkin <lmga@millcomm.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 7:08am
Subject: comments on Internet Domain Names
My comments are in answer to section B, questions 1, 2, and 5, section
D, question 15, and section E, questions 22, 24, and 28.
Thank you for the opportunity to voice these opinions.
Geoffrey Atkin
The IAHC memorandum is not perfect, but it is the best solution anyone
has been able to come up with. I agree with its philosophy that generic
top-level domains should be administered by multiple registrars on the
public's behalf. I might quibble with their choices for new top-level
domains, but I understand that there was considerable debate on this
point. I agree that both Internet and international standards bodies
should be involved in the administration of generic top-level domains.
It is vital that the current NSI monopoly be ended, and the expiration
of their contract in March 1998 may be the only opportunity to do so.
Replacement registrars must be in place well in advance to ensure a
smooth transfer of power.
The major problems with the current system are (1) many people are
dissatisfied with the service provided, fees charged, and/or policies
set by NSI, and there is little recourse since NSI has a monopoly on the
most popular top-level domains; and (2) the explosive commercial growth
of the Internet has led to contention for "good names" in .com. The
latter is because domain names are absolutely unique world-wide, while
company names are not, even when trademarked. Also, NSI assigns names
without regard to trademark status; when disputes arise, a common
outcome is for the name to become unavailable to anyone.
I think the IAHC plan can solve the first problem, but it will not solve
the second. The rest of my comments are on the subject of trademarks.
Some have argued that trademark law does not apply to domain names. I'm
no lawyer, but I believe this view is totally without merit.
Domain names are intended to be mnemonic identifiers for a group of
computers owned or administered by a specific entity or organization.
Thus, the main practical use of domain names is to help Internet users
identify to whom they are sending information and from whom they are
receiving it. This is also one of the purposes of trademarks (as
applied to company names) and this is why domain names come into
conflict with trademarks.
I think the .com domain needs to be overhauled. In its place we need a
name space which is strictly for names of corporate entities, available
only to holders of national trademarks for those names, subdivided by
business and by country. For example,
chiquita.ag.us
It is necessary to separate by country because two unrelated companies
in different countries can have the same name, and can hold trademarks
to the name in their respective countries. The existing two-letter
national domains are an obvious starting point. We then need to
subdivide the .us domain by industry or business, because two companies
in the U.S. can hold national trademarks to the same name so long as
they are in different lines of business.
Here is one possible set of replacements for .com, based on Standard
Industrial Classifications (SIC) headings:
.ag.us Agriculture, forestry, and fishing (SIC 0xxx)
.cs.us Mining and construction (SIC 1xxx)
.mf.us Manufacturing (SIC 2xxx and 3xxx)
.tr.us Transportation (SIC 4xxx)
.pu.us Public utilities (SIC 4xxx)
.wh.us Wholesale trade (SIC 50xx and 51xx)
.rt.us Retail trade (SIC 52xx to 59xx)
.fn.us Finance, insurance and real estate (SIC 6xxx)
.sv.us Services (SIC 7xxx and 8xxx)
These subdivisions could also be applied at the state level, for
companies that do not hold a national trademark on their names. For
example, if Chiquita was not a national trademark, but merely a local
banana grower in North Carolina, it might be chiquita.ag.nc.us.
Ideally, the same registrars should be able to assign names in either
ag.nc.us or ag.us.
Whatever second-level names are chosen, I think the list needs to be
short enough to be understandable and long enough that most companies
with the same name wind up in different domains. (And of course, it has
to avoid conflicting with two-letter state abbreviations.)
We don't need to worry about other countries; they have their own
registries. As a point of interest, most have second-level domains such
as .co.uk and .co.jp, which serve as national versions of .com.
If such an overhaul is made, it would be sensible to encourage greater
use of the two-letter national domains, and it might be reasonable to
close .com to new registrations. But there is no reason to eliminate it
altogether, and it would be highly disruptive to do so.
The Department of Commerce could certainly play a helpful role. For
example, it could provide domain registrars with the data necessary to
check for national trademark conflicts before assigning a domain name.
This would help prevent trademark disputes, which would benefit everyone
except possibly the trademark lawyers.
Geoffrey Atkin
###
Number: 335
From: "Christopher Hadden" <webmaster@jasc.com>
To: "'dns@ntia.doc.gov'" <dns@ntia.doc.gov>
Date: 8/18/97 11:12am
Subject: Comments on Domain Names
To whom it may concern:
Inter-network communications is a very open thing by design. I do not believe that Network
Solutions, Inc. should retain it's monopoly as the domain name registrar for top level domains
such as .com and .net.
I welcome some of the ideas contained in the International Ad Hoc Committe's proposal
including
the addition of top level domains. I also believe that problem resolution of domain name disputes
should be handled at an international level.
If I may be of any help in this discussion process, please let me know.
Sincerely,
Christopher Hadden
Webmaster, Jasc Inc.
webmaster@jasc.com
http://www.jasc.com
###
Number: 336
From: <BDarcy@lga.att.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 1:34pm
Subject: AT&T's Response to NOI on Domain Names
Attached is AT&T's response to NOI on Domain Names
CC: NTIADC40.SMTP40("rosenblu@lga.uucp","kleinman@lga....
Before the
DEPARTMENT OF COMMERCE
NATIONAL TELECOMMUNICATIONS
AND INFORMATION ADMINISTRATION
Washington, D.C.
Request for Comments on the )
Registration and Administration ) Docket No. 970613137-7137-01
of Internet Domain Names )
COMMENTS OF AT&T CORP.
Pursuant to the Public Notice released July 2, 1997, AT&T Corp.
("AT&T") respectfully submits its Comments to the National Telecommunications and
Information Administration ("NTIA") on the questions presented concerning the
registration and administration of Internet domain names. AT&T commends NTIA's
leadership on the these issues and welcomes the opportunity to provide its comments.
AT&T also reaffirms its willingness to work actively with the U.S. Government, the
International Ad Hoc Committee("IAHC"), Policy Oversight Committee ("POC"), Network
Solutions, Inc. ("NSI"), and the industry at large to help define an approach that can
achieve broad domestic and international consensus, and be implemented in a
practical and timely way.
AT&T responds below to each of the questions posed in the Public
Notice, as enumerated in that Notice.
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.
AT&T supports this principle.
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.
AT&T supports this principle.
c. These self-governance mechanisms should recognize the inherently
global nature of the Internet and be able to evolve as necessary over
time.
AT&T supports this principle. In addition, any new mechanism must be
scalable and thus be able to grow with the Internet.
d. The overall framework for accommodating competition should be open,
robust, efficient, and fair.
AT&T supports this principle. AT&T recognizes the importance of
clearly
defined transition plans and operations plans in evolving to a new framework.
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.
AT&T supports this principle.
f. A framework should be adopted as quickly as prudent consideration of
these issues permits.
AT&T supports this objective. AT&T urges the U.S. Government to
ensure that appropriate protections for trademark owners are thoroughly considered
and included in the framework.
B. General/Organizational Framework Issues
B.1. What are the advantages and disadvantages of current domain
name registration systems?"
The main advantage is that it works. There have been complaints about
the current registrar, and some of the complaints have merit. On the other hand, the
current registrar has grown the system from a small start to a system that has now
registered well over one million names in ".COM," and it has built up expertise and
support systems to handle the current load of new requests. Any replacement must be
able to handle the current load as well as the expected rapid growth without major
disruption.
The main disadvantage is the monopoly position of the current provider.
Once the current NSF Cooperative Agreement ends, there are no checks on the
registrar. The ".COM" domain is very well known to Internet users and it is thus at this
time the "place to be" for anyone wanting to do business on the net. If the registrar
changed the rules to exclude arbitrarily some businesses or greatly increased the
rates, most name holders would have no alternative but to live with the change.
B.2. How might current domain name systems be improved?
Because of the potential for abuse of NSI's monopoly position to the
detriment of Internet service providers and their customers worldwide, as noted above,
AT&T recommends evolving from the current monopoly system to a structure that
accommodates multiple domain name registrars. However, there are a number of
operational and trademark issues that arise under any new proposal for multiple
domain name registrars distributed throughout the world. AT&T thus recommends
significant further dialogue with key stakeholders prior to the implementation of any
specific proposal.
There are several other improvements that AT&T recommends be
undertaken within the current or any new structure. For instance, one of the major
improvements would be increasing the security of the system. The recent situation
where the AlterNIC redirected requests so that people who wanted to access the
InterNIC were sent to the AlterNIC instead shows the vulnerabilities of the current
system. The IETF has done work on Secure DNS; these features should be
implemented on root servers and other DNS operators should be encouraged to use
them as well. The code exists, is exportable, and is free of restrictions on its use. Use
of this technology is vital to prevent further hijackings.
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?
AT&T believes there is merit in the concept contained in IAHC's proposal
for multiple domain name registrars throughout the world. Any organization effecting its
implementation has to be broadly based. Such organization must include
representatives of the user community including trademark owners, the providers, and
the server sites. Furthermore, it must be international. The current DNS works
because most sites agree that it should. If too many ISPs disagree, there won't be a
single DNS, which would be catastrophic to the Internet. The technology differs in a
major way from the telephone numbering system, where the numbering plan is
implemented in an inherently centralized fashion.
B.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 are lessons to be learned from certain aspects of telephone
number administration process, though we must be conscious of significant differences
as noted above. Examples of processes from which we can gather some insights are
US 800/888 number assignment, assignment of new NPAs in the US, the current local
number portability processes being discussed at NANC (North American Numbering
Council), assignment of telephony country codes and assignment of two- and three-letter country
codes by ISO. Any learning from these processes can not be simply
replicated for the Internet. New processes that benefit from the learning should then be
tailored to the different environment of Internet domain names.
B.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?
While a proposal that all domain names be under a specific country code
has appeal, such a system would pose numerous problems. The main one is that it
may be too late. There are over 1.3 million names in ".COM" already, and
approximately 60,000 more in each of ".NET" and ".ORG." Many of these names are
well known to Internet users, and in many cases businesses have spent significant
amounts of money promoting recognition of their name. To change all these names at
this point would cause massive confusion among users and inhibit the growth of
commerce on the Internet. In all events, eliminating ".COM" is not a practical or
realistic alternative. Even if it were possible, many of the same technical and
administrative issues would arise in the ".US" domain, because ".COM" consists
overwhelmingly of U.S. entities today.
Furthermore, there are multinational companies that are not easily
associated with any one country code. For example, it is not obvious that Nestle would
be associated with ".CH" (Switzerland), or Shell Oil (Royal Dutch Shell) with ".NL"
(Netherlands). These companies would have to register in almost every country code if
they were permitted to do so by the registrar for that country code domain. Such a
process would be unnecessarily costly and inefficient.
B.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 registration issues are not primarily technical. The root name servers
can handle millions of TLDs if necessary (the ".COM" domain is currently held by the
root name servers and has over a million entries). The technology to support shared
registries exists; many commercial relational database management systems have the
required features. Work would have to be done to implement the system, but it is
technically feasible.
The relationship of registrars and gTLDs is not constrained by technical
limitations. The formal relationship between multiple registrars and multiple root name
server operators would have to be worked out in several dimensions. Significant
substantive work needs to be done on many related legal and organizational issues.
B.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?
There are technical limits to the number of possible servers for any single
domain, including the root and ".COM." These arise from packet size constraints in the
current DNS, and limitations on the bandwidth necessary to download backup copies of
the zone files.
These Comments specifically apply to addresses as well as domain
names. There are some fundamental technical concerns about the current IP address
space. First, it's limited, and will remain limited until IPv6 becomes widespread. This is
already posing problems for many companies. The only long-term solution is
deployment of IPv6.
A second issue is "provider-based addressing." This is more properly
known as "topology-based addressing" -- your IP addresses must be given to you by
your upstream provider. Although there are unfortunate consequences of this scheme -- in
particular, it's hard for a site or ISP to connect to multiple providers, or to change
upstream providers if necessary -- the requirement is due to limits on the memory sizes
of today's routers, and the amount of CPU time necessary to calculate paths through
ever larger routing tables than are used today. The industry requires automatic
renumbering technology.
B.8. How should the transition to any new systems be accomplished?
Any proposed new system should have an associated transition plan that
spells out how the migration from the current system will be carried out. The plan
should include schedules, milestones, contingencies if dates cannot be met, test plans
(including capacity tests), and criteria for meeting the milestones. The plan should
specifically address the scale of the current registry and show how all current domain
name registrations will be handled. The plan must indicate what is expected of the
current registrar during the transition. Because the current registrars have indicated
that they feel they have ownership rights to the current data, the plan must indicate the
terms and conditions pursuant to which the new registrar will be able to obtain and use
the data. As part of the plan an ongoing test system should be maintained to provide
rigorous testing of new registrars and new versions of software that may affect the
central database of TLDs.
The plan should be made available to the Internet community and
substantive comments should be addressed.
B.9. Are there any other issues that should be addressed in this area?
Other issues will certainly arise; this series of questions is adequately
comprehensive at this time.
C. Creation of New gTLDs
C.10. Are there technical, practical, and/or policy considerations that
constrain the total number of different gTLDs that can be created?
There are no significant technical limits; i.e., the technology can probably
handle any number that is operationally feasible. There are clearly trademark-related
implications as new gTLDs are created (for example, ".COM" and ".STORE" for the
same company name).
C.11. Should additional gTLDs be created?
Yes. To support the growth of the Internet and electronic commerce, the
industry must ensure that domain names capacity is increased.
C.12. Are there technical, business, and/or policy issues about
guaranteeing the scalability of the name space associated with increasing
the number of gTLDs?
There is no significant technical limit. The business and policy issues
require further exploration.
C.13. Are gTLD management issues separable from questions about ISO
country code domains?
Yes, and they should be separated.
C. 14. Are there any other issues that should be addressed in this area?
The recent NSI outage shows the dangers of a single point of failure.
Research and engineering should be done to add redundancy to the generation of all
gTLDs, including ".COM," ".NET" and others, and eliminate single points of failure
wherever possible. The planning effort should address both software and operational
processes.
D. Policies for Registries
D.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?
All gTLDs must be served by multiple registrars, to promote competition.
There are no inherent technical limitations on using shared registries, but
implementation options need to be well tested.
D.16. Should there be threshold requirements for domain name
registrars, and what responsibilities should such registrars have? Who
will determine these and how?
AT&T suggests certain threshold requirements applicable to domain
name registrars. For example, all registrars should be bound by a common set of rules,
submit to the jurisdiction of a single, pre-determined court and post a bond to satisfy
judgments. Measures should be taken to ensure the smooth operation and transition to
other registrars, particularly where a registrar has become bankrupt or has ceased to
do business. Underlying these obligations would be full disclosure of the registrar's
credentials and compliance with these requirements, so that the holders of domain
names have the information needed to make a reasonable choice of registrar.
D.17. Are there technical limitations on the possible number of domain
name registrars?
Any reasonable number of registrars can be supported technically,
subject to limitations noted in the answer to B.7. The operational and policy issues will
dictate limits before the technical considerations will.
D.18. Are there technical, business and/or policy issues about the name
space raised by increasing the number of domain name registrars?
Trademark issues are a major concern as the number of registrars
increases. See AT&T's response to the questions in Section E. Operational impacts
of
increasing the number of registrars must be well understood and resolved prior to
implementation.
D.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?
At this time, AT&T does not foresee the need for a limitation on the
number of gTLDs that a given registrar can administer. AT&T does anticipate a need
to revisit and examine the issue based on the registrar qualification process and the
robustness of operational and trademark protection processes that need to be in place
for effective sharing of registration for multiple gTLDs.
D.20. Are there any other issues that should be addressed in this area?
Other issues will certainly arise; this series of questions is adequately
comprehensive at this time.
E. Trademark Issues
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?
All trademark rights, including service and certification mark rights, trade
dress rights and company name rights, should be protected on the Internet vis-a-vis
domain names. Moreover, sufficient measures should be taken to avoid public
confusion.
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?
There should not be a requirement of preliminary review of an application
for registration of a domain name other than review by an entity such as the proposed
Administrative Challenge Panels (ACP).
E.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?
AT&T has developed a continuum of concepts and proposals. AT&T is
prepared to discuss these (and other parties') proposals in future fora before the U.S.
Government and industry groups.
An entity such as the Administrative Challenge Panels would decide
whether the domain name should be registered. The standard which should be applied
by the panels is "identical or confusingly similar to or dilutive of any demonstrable
trademark right". The principles of stare decisis, res judicata
and collateral estoppel
should apply. Moreover, the losing party should be allowed to file a de novo
action
locally. In addition, a reasonably long period of time (five years) should be set aside in
which any party that believed it was being damaged could petition to cancel a domain
name.
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?
It is unrealistic to believe that conflicts over trademarks are preventable.
However, if there is a legitimate conflict, AT&T supports the individual parties being
offered the opportunity to craft a workable solution. For example, if a trademark
registrant of ACME for food services applies to register a domain name of ACME and
another trademark registrant or owner of demonstrable trademark rights of ACME for
toys opposes, the parties could use the Dispute Mediation Procedures so that the first
party registers "ACME-FOOD.COM" and the second party registers "ACME-TOYS.COM."
This is consistent with the current settlement of trademark disputes
parties limit their use of a trademark to their respective goods or services by
agreement. However, where there exists a well-known, strong mark such as AT&T, no
third party other than the trademark owner should be able to use that mark. Principles
of dilution and unfair competition should be used to determine the scope and breadth of
a mark's protection.
It is AT&T's view that the creation and maintenance of trademark
databases would be overly burdensome, costly and difficult to administer.
E.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. Domain name applicants should not be required to have a basis for
requesting a domain name. However, the number and nature of domain name
registrations owned by an individual or entity should be considered and should be a
strong factor in determining the good faith of a potential domain name applicant. If, for
example, an applicant holds scores of other domain names which are identical or
confusingly similar to the names or marks of various third parties, that factor alone
should create a strong presumption, in any litigation or dispute resolution procedure,
that the applicant is attempting to traffic in trademarks, is not acting in good faith and
thus not entitled to domain name registrations.
E.26. How would the number of different gTLDs and the number of
registrars affect the number and cost of resolving trademark disputes?
As the number of different gTLDs increases, so too does the risk of
having to challenge a domain name applicant. The number of disputes and costs will
increase substantially as the number of gTLDs and registrars increase. Moreover,
trademark owners will face the daunting and expensive task of monitoring domain
name registrations for each gTLD. Also, registrars might require that challenges be
conducted in a country across the globe. This will certainly increase costs to a domain
name challenger and will be particularly burdensome to owners of well-known marks
and to small companies that are really primarily national or regional in scope of
business, but to whom their brand is of significant value.
E.27. Where there are valid, but conflicting trademark rights for a single
domain name, are there any technological solutions?
Directory servers can help people find Web sites in ways other than
guessing at "www.company-name.COM." But that solution is not workable for other
uses of domain names, such as e-mail. In other words, the industry can ameliorate the
contentiousness of the trademark battle by deploying directory servers, but the industry
cannot eliminate it -- uses of the DNS by programs (as opposed to humans typing the
names) are not compatible with any sort of vague, interactive lookup process.
Requiring the use of geographic and/or subject area qualifiers in domain
names, to parallel the legal separations, is unworkable. Apart from the fact that most
people can't and won't remember such information, the resulting domain names would
be far too long to be used.
E.28. Are there any other issues that should be addressed in this area?
Yes. AT&T discusses below specific issues with IAHC/MOU proposals:
1. The major problem confronted by trademark owners is "cybersquatting", or the
extortion and piracy of domain names that are identical or confusingly similar or
dilutive of a prior valid trademark right. (For example, a third party other than AT&T
registers "1800CALLATT.COM" and offers to sell the domain name to AT&T.)
Another major problem is the use of domain names that are identical or confusingly
similar or dilutive of a trademark. (For example, a third party other than AT&T
registers "AT-T.COM" or "AT-TWEB.COM." The current IAHC/MOU proposals do
not adequately address these problems. It has been stated that the ACPs have a
limited function. However, litigating in court is extremely expensive, especially with
a proliferation of cybersquatters. This problem needs to be addressed by IPOC and
a compromise solution found that is acceptable to all interested parties.
2. Disputes would be determined by Administrative Challenge Panels
international experts in the field of intellectual property law and Internet domain
names. It is not clear who would serve on these panels, how panelists would be
compensated or what their qualifications would be. There is a need to address this
issue in greater detail.
3. The IPOC Guidelines indicate that to be "internationally known" a mark must be
registered in a least 35 or more countries in at least four geographic regions for the
same goods or services; to be "globally known," the mark must be registered in 75
or more countries for the same goods and services. These are extremely high
thresholds, and will not protect a majority of trademark owners. Enormous amounts
of money are invested in promoting trademarks that do not meet these thresholds.
Such trademarks may have significant commercial appeal, and thus their owners
would enjoy brand equity in such names. However, there is nothing in the current
proposals to protect the interests of these trademark owners. For example, a
medium size business has one trademark in the U.S. that is well-known in its
industry and in the U.S. and all European Community countries. (This business
also owns a U.S. trademark registration that is incontestable and trademark
registrations throughout the European Community.) The current proposals do not
afford protection to this trademark owner.
4. As proposed, the Administrative Challenge Panels will not have jurisdiction to
decide disputes beyond the narrow question of preventing in appropriate
circumstances, the registration of "a second-level domain name in any of the CORE
gTLDs which is identical or closely similar to an alphanumeric string, that for
purposes of this policy is deemed to be internationally known, and for which a
demonstrable intellectual property right exists . . ." (Articles 2 and 3 of the MOU,
emphasis supplied). Industry has revised the question of deciding disputes
respecting all valid trademark rights. There is sentiment that all entities who have
rights should be allowed to challenge, not just the owners of internationally known
marks. Also, significantly, some domain names could be considered an
infringement of a trademark and still not be considered identical or closely similar.
The litmus test should be the internationally accepted standard: likelihood of
confusion.
5. Difficult jurisdictional issues arise. The domain name registrant is located in
Country A, the trademark owner in Country B, the registrar in Country C. The
problem is the domain name registrant may "forum shop." To alleviate this problem,
domain name applicants should agree to be subject to jurisdiction in a specified
choice of venues.
6. The IPOC Guidelines indicate the Administrative Challenge Panel process is
subject to be reopened by any person, and unknown parties may thus have the right
to intervene. If an infringer is dissatisfied with the outcome of the Administrative
Challenge Panel, it would initiate an action in a country whose laws may be
favorably disposed to such party and force trademark owners to engage in exposure
for such litigation. This and other issues related to the finality of arbitration rulings
require further discussion.
7. The 60-day publication period is not mandatory and there is no procedure for
opposing a domain name. There should be a 60-day mandatory publication period
in which any party who believes it would be damaged by the domain name could
oppose. This would also be favorable to the domain name registrant, because
obstacles to use of the domain name would be identified prior to the domain name
holder investing time and money in such domain name and corresponding website.
AT&T recognizes that the mandatory waiting period was removed from the
Memorandum of Understanding due to opposition, but believes the concept has
value.
8. Sui generis protection for domain names, essentially creating a
wholly new form
of intellectual property protection to protect domain names, is unnecessary and will
prejudice existing trademark owners. It has been proposed the use of a domain
name for a two-year period on the Internet will create a right in the domain name.
This is unacceptable. Trademark rights are only created by substantive law.
9. There should not be an opt-out clause in the domain name application that
permits domain name holders to opt-out of binding arbitration. This would effect a
clear and significant prejudice to trademark owners.
10. The Administrative Challenge Panel may, on its own initiative, decide to modify
an TLD in lieu of excluding it. This may weaken a trademark owner rights in a mark
and should not be permitted.
11. It is AT&T's view that the IPOC, which governs policy issues in the domain
name
process, has insufficient representation by trademark owners. While other
organizations (like ISOC, CORE and IAB) are represented by two members, INTA
and WIPO, ostensibly the only representatives of the trademark community, are
allotted one member each. This must be remedied in order to result in balanced
representation.
CONCLUSION
AT&T appreciates the opportunity to provide its views on this important
subject, and looks forward to continuing participation in this and other fora dealing with
the critical issues involving proliferation of new technology-based services in the U.S.
and worldwide.
Respectfully submitted,
AT&T CORP.
By /s/ Ava B. Kleinman
Mark C. Rosenblum
Ava B. Kleinman
Its Attorneys
Mahal Mohan
295 North Maple Avenue
Room 3252J1
Basking Ridge, New Jersey 07920
(908) 221-8312
August 18, 1997
###
Number: 337
From: Glenn B. Manishin <glenn@technologylaw.com>
To: NTIADC40.NTIAHQ40(dns)
Date: 8/18/97 9:17am
Subject: CPSR Comments on Internet Domain Names
On behalf of the Computer Professionals for Social Responsibility,
attached in Microsoft Word 6.0 format is CPSR's electronic submission in
response to NTIA's request for public comment on registration and
administration of Internet domain names. A hard copy of the same is
being delivered today to Patrice Washington of NTIA's Public Affairs
office.
Please contact me at this e-mail address or by telephone at 202.955.6300
if you have any questions in this regard
Sincerely,
Glenn B. Manishin
Counsel for CPSR
+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+
Glenn B. Manishin glenn@technologylaw.com
Tel/Vms 202.955.6300 gbm@clark.net
Fax 202.955.6460 gmanishin@earthlink.net
------------- Washington, DC, USA -------------
Firm: http://www.technologylaw.com/
Personal: http://www.clark.net/pub/gbm/
F1: http://www.clark.net/pub/gbm/F1/f1intro.html
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CC: "Glenn Manishin" <glenn@technologylaw.com>
Before the
UNITED STATE DEPARTMENT OF COMMERCE
NATIONAL TELECOMMUNICATIONS AND
INFORMATION ADMINISTRATION
Washington, D.C. 20230
In the Matter of )
)
Request for Comment on Registration ) Docket No. 970613137-7137-01
and Administration of Internet )
Domain Names )
COMMENTS OF THE
COMPUTER PROFESSIONALS FOR SOCIAL RESPONSIBILITY
Aki Namioka, President Glenn B. Manishin
Harry Hochheiser Michael D. Specht
Andy Oram Christine A. Mailloux
Computer Professionals for Social Blumenfeld & Cohen - Technology Law Group
Responsibility <http://www.technologylaw.com>
<http://www.cpsr.org/home.html> 1615 M Street, N.W., Suite 700
P.O. Box 717 Washington, D.C. 20036
Palo Alto, CA 94302 202.955.6300
415.322.3778
Counsel for CPSR
Dated: August 18, 1997
The Computer Professionals for Social Responsibility (CPSR) <http://www.cpsr.org/
home.html>, by their attorneys, submit these comments in response to the Notice
<http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm> released by the National
Telecommunications and Information Administration (NTIA) <http://www.ntia.doc.gov>
soliciting public input on the present and future systems for registration and administration of
Internet domain names.
SUMMARY
The current controversy over the Internet's Domain Name System (DNS) raises
important questions about how the Internet, as a decentralized, global medium, should be
administered and governed. While much of the Internet was invented and originally funded by the
US Department of Defense and the National Science Foundation (NSF) <http://www.nsf.
gov/>,
and although its governing institutions were initially established and sanctioned by the American
government, the Internet's technical standards and basic policies have in fact been set by a
number of ad hoc, consensus-based consortia comprised of Internet service providers,
engineers
and users. This system worked for a long time because of the shared goals and technical
sophistication of the Internet's original academic-based user community. See And How Shall
the
Net Be Governed?, by David R. Johnson & David G. Post <http://www.cli.org/
emdraft.html>.
But increasing commercialization and explosive growth have begun to strain the
consensus-driven process of Internet administration. The strong and widely publicized reactions
of many providers and users (and foreign governments) against the Memorandum of
Understanding (MOU) developed by the Internet Ad Hoc Committee (IAHC)
<http://www.iahc.org>
for revisions to Internet domain name registration and administration
<http://www.gtld-mou.org/> show that the stakes are high and that more open, considered
and perhaps formal
mechanisms for Internet self-governance -- and for evaluating alternative DNS proposals -- are
called for in the present environment. In these comments, CPSR focuses on proposals for
reforming DNS with a view toward maintaining open Internet self-government,
introducing
competition into Internet domain name administration, separating DNS management from
trademark protection, and supporting the continued growth of the Internet itself.
(CPSR
addresses each section of the NTIA Notice, and as requested our comments in Sections II-VI
follow the organization of the Notice.)
As discussed more fully below, CPSR -- a public interest alliance of information
technology professionals and others concerned about the impact of computer technology on
society, founded in 1981, with over 1,400 members and 22 chapters nationwide -- believes that
DNS is too important to the structure of the Internet for DNS "reform" to proceed in a
hasty or ill-conceived manner, particularly without adequate input from consumers and
other users of the Internet. Whatever its merits, the IAHC process was closed, rushed
and
unbalanced, leading to a proposal that should not be endorsed by the US government. CPSR
commends NTIA for commencing this open, thorough public airing of DNS issues, and
for its
express acknowledgment that DNS reform, like other aspects of Internet governance, should
remain a matter for the Internet community itself, not national or international government
agencies.
CPSR proposes that changes to the current DNS model must reflect the twin goals of
maintaining Internet self-governance, thus minimizing government's substantive role in Internet
administration, while avoiding the continuation of de facto DNS monopolies in the
increasingly
commercialized Internet. We also emphasize, however, that there is no present "crisis"
in
DNS administration that requires hasty implementation of any system for DNS reform,
including those proposed by IAHC, Network Solutions, Inc. (NSI) <http://www.netsol.com/
papers/internet.html> and others. Unlike IAHC or NSI, CPSR believes that the twin aims of
competitive Internet services and non-governmental Internet administration can and should be
applied to the DNS system. A sensible plan for DNS reform combines the better elements of both
the IAHC and NSI proposals, while jettisoning others. In this light, CPSR proposes the following
principles for reform of the Internet DNS system:
A. The Internet domain name registration process should be opened to competition
for all existing and newly created generic top-level domains (gTLDs).
1. Shared gTLDs should be administered by competing registrars, with
restrictions imposed only based on any technical limitations.
2. No registrar (NSI or others) should enjoy a proprietary interest or
commercial "ownership" of any gTLD, including ".com".
B. Domain registration should be separated from trademark issues.
Registrars should not be involved in trademark dispute resolution, but rather
should refer all trademark issues to appropriate national and international judicial
bodies.
C. The Internet's "root" server administration responsibilities should be coordinated
and centralized in order to assure reliability and scaleability of the Internet.
D. The DNS reform process and ongoing DNS administration should be handled in an
open, balanced and non-governmental manner, with full participation by consumers
and small commercial entities, in addition to trademark owners.
1. International quasi-governmental organizations (ITU, WIPO, OECD, etc.)
should have no formal role in Internet governance or domain name
registration. The extensive new bureaucracy for domain name
management and oversight proposed by IAHC, including a Swiss-based
Council of Registrars (CORE), a Policy Advisory Board (PAB)
<http://www.pab.gtld-mou.org> and a higher level interim Policy
Oversight Committee (iPOC), is unnecessary and counterproductive.
2. National governments (Commerce, DOD, etc.) have no necessary role in
DNS administration except for ISO 3166 TLDs (e.g., ".us," ".de," etc.) and
maintaining fair, open and competitively neutral Internet self-governance
organizations.
3. The IAHC process was inconsistent with open Internet self-governance and
biased towards trademark owners. With encouragement from NTIA, the
Internet Society (ISOC) should be required to open up the process to
permit full debate by the global Internet community on DNS practices. The
absence of any "crisis" in domain name resources allows for thoughtful and
deliberate consideration of DNS issues.
4. Hasty implementation of the IAHC approach will continue to splinter the
Internet community and would unnecessarily involve international quasi-governmental
organizations in Internet governance. The DNS reform
process should be slowed in order to permit achievement of a consensus
approach that all interest groups (including Internet users/consumers) can
support. No "rush to reform" is necessary.
5. The US government should not endorse, and should actively oppose,
intervention by ITU and WIPO in the DNS administration process. The
government should not attempt to unilaterally dictate any specific domain
name registration process for gTLDs, which are global Internet resources.
I. INTRODUCTION
A. Background
1. The domain name system (DNS) provides a key service in the global
Internet. In translating Internet 'host' names into Internet Protocol (IP)
numbers needed for transmission of information, DNS shields network
users and administrators from the complexities of using IP numbers to
identify computers, routers and networks on the Internet. Without a
reliable, efficient and robust DNS system -- including registration of
domain names and management of DNS servers -- the Internet as currently
configured could not function in the user-friendly manner available for such
current Internet applications as electronic mail and World Wide Web
(WWW) browsing. DNS administration also plays an important role by
maintaining 'root' servers that operate as the highest-level Internet
databases for translating domain names into IP addresses, without which
domain name-based Internet communications would not be possible.
2. Many governmental, quasi-governmental and private groups, along with
users and Internet service providers, are currently examining the limitations
of the current DNS and domain name registration models, including
questions related to introducing competition to domain registration,
oversight mechanisms for DNS administration, opening of new generic top-level domains
(gTLDs), and the role of registrars in resolving trademark
disputes regarding domains.
3. One of these groups, the so-called Internet Ad Hoc Committee (IAHC),
has proposed and is implementing a plan for establishing new gTLDs, with
significant input from and the endorsement of international multilateral
organizations, such as the World International Property Organization
(WIPO) <http://www.wipo.int/> and the International Telecommunication
Union (ITU) <http://www.itu.ch>, as well as major trademark holders.
After signing of its MOU in Geneva, the IAHC was dissolved on May 1,
1997 and replaced by the iPOC <http://www.gtld-mou.org/docs/ipoc-members.html>.
4. The IAHC proposal has drawn opposition and criticism from parties
ranging from Network Solutions, Inc. (NSI) <http://www.netsol.com>, the
current US government-selected contractor responsible for registrations in
the '.com,' '.gov,' '.org,' and '.edu' domains, to the Domain Name
Rights Coalition <http://www.domain-name.org/dnrc-comments.html>, the
World Internetworking Alliance <http://www.wia.org/pub/dns-brief.html>,
the Organization for Economic Cooperation and Development (OECD)
<http://www.oecd.org/>, Directorate General XIII (telecommunications)
of the European Union <http://europa.eu.int/en/comm/dg13/13home.htm>,
and major US-based Internet service providers. Alternate DNS models
have also been developed by other providers of domain name services, such
as eDNS <http://www.edns.net/> and AlterNIC <http://www.
alternic.net>, and in draft form by the Internet Engineering Task Force
<http://www.iahc.org/contrib/draft-iahc-higgs-tld-cat-03.txt>. At least one
entity has filed suit against the IAHC plan in the United States
<http://www.wia.org/dns-law/pub/stef-io-declaration.html>.
B. CPSR's Concerns
1. CPSR is a public interest alliance of information technology professionals
and others concerned about the impact of computer technology on society,
founded in 1981, with over 1,400 members and 22 chapters nationwide.
CPSR believes that the Internet is a potentially revolutionary medium that
has flourished, and grown exponentially over the past several years, in large
part due to marketplace competition and the absence of restrictive
government involvement. We believe these same objectives should be
applied to efforts to 'reform' DNS administration. Given its central role
in the development of the Internet, the US government has judged well
when to lead the process of Internet management and when to cede
authority to the Internet community and private organizations. In the case
of DNS administration, it is time for more decentralization, competition
and private initiative, although governments can and should serve as
'stewards' of the Internet to ensure open and inclusive processes, prevent
anticompetitive practices, and complete the final step in the transition from
a government-managed to a private sector, community-administered
Internet.
2. While CPSR agrees that monopoly domain registrars are a poor substitute
for a competitive DNS model, we caution that DNS is too important to the
structure of the Internet for DNS 'reform' to proceed in a hasty or ill-conceived manner,
particularly without adequate input from consumers and
other users of the Internet. Whatever its merits, the IAHC process was
inconsistent with consensus-based Internet policymaking and is biased
towards the rights of trademark owners. The IAHC plan should therefore
not be endorsed by the US government. CPSR applauds NTIA for
commencing this open, thorough public airing of DNS issues, and for its
express acknowledgment that DNS reform, like other aspects of Internet
governance, should remain a matter for the Internet community itself, not
national or international government agencies.
3. The current proposals for DNS reform have been advanced by groups with
commercial and institutional objectives that do not necessarily reflect the
broader interest in a competitive, non-governmental Internet structure.
ISOC is a respected organization, with an important role to play in the
Internet community, that to its credit, has correctly recognized that
problems exist with domain name administration. However, the outcry
provoked by IAHC's gTLD-MOU shows that its process was not open
enough. By unilaterally implementing its proposal through quasi-governmental international
organizations (ITU and WIPO), IAHC has
sought to legitimize a role in Internet governance it simply does not enjoy,
at a time when its controversial proposal was still undergoing critical
examination by the Internet community at large. Substantively, although it
proposes competitive provision of domain registration in a series of new
gTLDs, the IAHC plan is geared largely to the creation of international
rules (and mandatory, non-judicial arbitration) for trademark protection of
domain names, including a new bureaucracy within WIPO for the
resolution of domain disputes. The NSI response, in contrast, proposes to
protect its private commercial interests by extending its de facto monopoly
on '.com' registrations into a competitive DNS environment, without
sharing of TLDs, and has advocated that national and/or international
governments should be involved in 'oversight' of certain
'administrative' DNS functions <http://www.netsol.com/papers/
internet.html>.
4. Unlike IAHC or NSI, CPSR believes that the twin goals of competitive
Internet services and non-governmental Internet administration can and
should be applied to the DNS system. To do so, however, requires
recognition that (1) as NSI has explained, there are some functions, known
as 'root' server management, which need to remain centralized and
coordinated in order to promote reliable and scaleable Internet routing, and
(2) 'rationalization' of trademark law (the pursuit of what IAHC terms
'efficient' dispute mechanisms as an alternative to court litigation for
trademark protection) for DNS purposes is inconsistent with the
traditional, and successful, non-governmental approach to Internet
administration. (While the US government for years subsidized certain
Internet facilities and still contracts for DNS and IP-number allocation
functions, Internet policies, standards and operating arrangements have
been set with little if no government involvement since the
'commercialization' of the NSFNet backbone in 1994.)
C. CPSR's Proposal
A sensible plan for DNS reform combines the better elements of both the IAHC
and NSI proposals, while jettisoning others. In this light, CPSR proposes the
following principles for reform of the Internet DNS system:
1. The domain name registration process should be opened to competition for
all existing and newly created gTLDs.
a. Shared TLDs should be administered by competing registrars, with
restrictions imposed only based on any technical limitations.
b. No registrar (NSI or others) should enjoy a proprietary interest or
commercial "ownership" of any gTLD, including ".com".
2. Domain registration should be separated from trademark issues.
Registrars should not be involved in trademark dispute resolution, but
rather should refer all trademark issues to appropriate national and
international judicial bodies.
3. The Internet's "root" server administration responsibilities should be
coordinated and centralized in order to assure reliability and scaleability of
the Internet.
4. The DNS reform process and ongoing DNS administration should be
handled in an open, balanced and non-governmental manner, with full
participation by consumers and small commercial entities, in addition to
trademark owners.
a. International quasi-governmental organizations (ITU, WIPO,
OECD, etc.) should have no formal role in Internet governance or
domain name registration. The extensive new bureaucracy for
domain name management and oversight proposed by IAHC,
including a Swiss-based Council of Registrars (CORE), a Policy
Advisory Board (PAB) <http://www.pab.gtld-mou.org> and a
higher level Interim Policy Oversight Committee (iPOC), is
unnecessary and counterproductive.
b. National governments (Commerce, DOD, etc.) have no necessary
role in DNS administration except for ISO 3166 TLDs (e.g., ".us,"
".de," etc.) and maintaining fair, open and competitively neutral
Internet self-governance organizations.
c. The IAHC process was inconsistent with open Internet self-governance and biased
towards trademark owners. With
encouragement from NTIA, ISOC should be required to open up
the process to permit full debate by the global Internet community
on DNS practices. The absence of any "crisis" in domain name
resources allows for thoughtful and deliberate consideration of
DNS issues.
d. Hasty implementation of the IAHC approach will continue to
splinter the Internet community and would unnecessarily involve
international quasi-governmental organizations in Internet
governance. The DNS reform process should be slowed in order to
permit achievement of consensus approach that all interest groups
(including Internet users/consumers) can support. No "rush to
reform" is necessary.
e. The US government should not endorse, and should actively
oppose, intervention by ITU and WIPO in the DNS administration
process. The government should not attempt to unilaterally dictate
any specific domain name registration process for gTLDs, which
are global Internet resources.
II. PRINCIPLES
NTIA has sought comment on a set of principles by which the Administration can
"evaluate proposals for the registration and administration of Internet domain names." The
proposed NTIA principles are:
"(1) 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 interoperability of the Internet, however. The addressing scheme
should not prevent any user from connecting to any other site.
(2) 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) These self-governance mechanisms should recognize the inherently global nature
of the Internet and be able to evolve as necessary over time.
(4) The overall framework for accommodating competition should be open, robust,
efficient, and fair.
(5) 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.
(6) A framework should be adopted as quickly as prudent consideration of these issues
permits."
CPSR Comments
A. The basic thrust of the NTIA principles are appropriate in light of the needs for
competition in gTLD domain registration and for Internet self-governance.
B. The international role of gTLDs is a crucial aspect of the principles. Neither the
US nor any other national government has authority to dictate unilaterally policies
or rules for gTLD creation or administration. While the vast majority of '.com'
domain registrations certainly remain in the United States, the US government can
best promote the global expansion of Internet access -- to the resulting commercial
benefit of American-based Internet software, hardware and content companies --
by ensuring that it is not viewed internationally as attempting to secure a favored
position for US-centric domain holders in the gTLD scheme.
C. The IAHC and NSI proposals raise administrative, legal, financial and business
issues far beyond the technical focus and scope of the ISOC. ISOC and the other
members of IAHC (such as ITU and IANA), have no clear charter to dictate gTLD
policy and little if any experience in legal procedure or public policy. A need exists,
therefore, for the establishment of new 'consensus-based self-governing
mechanisms' that allow balanced, fair and open participation on these Internet
policy issues by all segments of the Internet community. This includes Internet
users, who have essentially been excluded from the IAHC process. Given the
crucial nature of end-user participation, the Internet community deserves legitimate
public interest, non-profit input into decision making processes. The needs of the
Internet community should not be subordinated to profits or control issues. The
US government can thus act as a catalyst in assisting the creation of the new self-governance
organizations (open and balanced consortia of Internet professionals,
providers and users) that will be necessary to complete the transition to a fully
non-governmentally administered Internet.
D. Although the US government has fostered the growth of the Internet and laid the
framework for its current expansion and commercialization, its future role should
not include oversight of DNS administration or the selection of registrars and other
DNS-related entities (InterNIC, IANA, etc.). Rather, the US and other national
governments should encourage open, consensus-based Internet self-governance,
intervening (as in this proceeding) only to assure public debate and to prevent any
single segment of the Internet community from asserting its special interests above
those of all Internet users. As in its oversight of the North American Numbering
Plan Administrator (NANPA), the US government can also act to guarantee that
vital Internet communications resources are managed impartially by the affected
industries and to prevent disruptive efforts by other governments and inter-governmental
organizations to assert authority over Internet administration.
E. Conflict resolution for domain name registration need not and should not include
resolution of disputes over trademarks or other proprietary rights. DNS policies
should be based on technical efficiency, reliability and competitive considerations,
without regard to the relative legal rights of trademark owners and domain
holders. As discussed in Section VI, 'efficient' trademark dispute resolution is a
code word for supplanting judicial decision-making with DNS registrar-imposed
trademark rules. Particularly in the IAHC proposal -- which provides the basis for
WIPO to establish new international common law of trademarks applicable solely
to DNS and without resort to national courts -- combining DNS administration
and trademark dispute resolution is poor public policy.
III. GENERAL/ORGANIZATIONAL FRAMEWORK ISSUES
In this Section, NTIA asks for comment on a number of issues related to the operational
model for domain name registration and the technical basis for alternatives to the current model,
including retirement of gTLDs from circulation, the relationship between root servers and gTLDs,
and interoperability among registrars.
CPSR believes that the current model for DNS administration -- monopoly registrars for
both gTLDs and ISO (country code) domains -- is anticompetitive and will, in the long run,
present substantial risks to the scaleability of the Internet. We believe that the disadvantages of
the monopoly model clearly warrant a shared registration approach to gTLDs, but that certain
functions, namely root server administration, should remain centralized and coordinated in order
to preserve the basic reliability and 'transparent' functionality of the Internet itself.
A. Existing gTLDs should not be retired. In addition to the transaction costs and
confusion surrounding such an approach, the existence of 'supra-national'
domains is inherent in the global nature of the Internet, helping to maintain the
Internet as a geographical and politically indifferent medium. Instead of
eliminating the .com and other gTLD registries, competition should be introduced
into domain name registration.
B. Shared gTLDs are a workable and efficient approach to introducing competition to
the DNS system. Much as in the US system for administration of '800'
telephone numbers, common standards and technical interfaces can be created --
based on non-governmental industry standards processes -- to allow shared use of
the .com resource. Competing registrars would assign available domains in all
gTLDs on a first-come, first-served basis, with real-time querying of the
appropriate gTLD database. Internet users would in this way be accorded, for the
first time, real choice of domain name registrars, with the consequent competitive
pressures leading to reduced prices, improved service and innovative registration
options.
C. The IAHC proposal for the establishment of new gTLDs is a good approach, in
that it permits use of identical domain names in different gTLDs for different
purposes (e.g., mcdonalds.com and mcdonalds.nom). The specific new gTLDs
selected by IAHC, however, raise questions about global transparency and
potential duplication and user confusion that merit additional study. IAHC's
proposal, now rescinded, to limit the number of registries to 28 (four per WTO
region) is unnecessary, as there should be no limits on the creation and operation
of domain registries except as may be required for technical reasons. Rather than
mandating financial and other registrar qualifications, 'quality control' of domain
registration should be a function of the marketplace. So long as a registrar follows
any technical standards established for assignment of a domain name from a shared
TLD, there appears to be no reason why prior "authorization" from any
governmental or Internet-governance entity should be required for entry into the
domain name registration market.
D. Root server administration (and related "population" of zone server databases) is
a key DNS function that should remain centralized, under the control of a single
entity worldwide, and coordinated through a technically reliable and integrated
process. Root servers must maintain interoperable, updated databases in order to
ensure that all IP networks can communicate across the Internet. As NSI has
correctly noted, the IAHC proposal is deficient because it does not reflect this
need for root server (what NSI terms "the .dot") centralization and "risks the
fragile stability of the Internet" by "increasing the likelihood of failure of the
administrative functions and services of the Internet." Competition in root server
administration would therefore -- absent some new technical approach to Internet
architecture -- appear to represent an exception to the general principle of
competition for DNS. (Of course, competition could still exist as part of the root
server administrator selection process.)
E. The US government has traditionally been the "first-mover" on issues related to
Internet architecture and administration, but in this instance should refrain from
selecting the entity responsible for root server administration. Backbone Internet
carriers and other entities, commercial and governmental, responsible for IP
transport have the technical background to select a responsible root server
administrator and (as in ARIN <http://www.arin.net/>, RIPE <http://www.
ripe.net/>, etc.) establish compensation mechanisms under a non-governmental
structure.
1. End users and domain holders have no substantial interest in root server
administration since root servers are "transparent" to them. NSI's
proposal that the US government assume "interim authority" over root
server administration -- and then transfer such authority to an international
legal entity -- is unnecessary. Absent some fundamental breakdown in the
Internet's technical standards development process, the shared mutual
interest of backbone and major Internet transport providers in maintaining
functional, high-quality root server management (and ensuring their ability
to route domain-based messages to all other IP networks) is sufficient to
guarantee a responsible root server administration.
2. Root server centralization does not guarantee error-free administration or
coordination (synchronization), as the events of the past month (NSI's
snafu) have illustrated. Nonetheless, with the increasing reliance of
individuals and businesses worldwide on the Internet, any benefits from
competitive provisioning of root server management would appear to be
outweighed by the risks of network collapse (and overhead requirements)
arising from multiple root server administrators.
F. Oversight of shared gTLD administration should remain a non-governmental
function. It should not be placed under the auspices of quasi-governmental
organizations like WIPO or the ITU, as IAHC has proposed. So long as registrars
comply with consensus-based technical requirements for domain name registration,
there is no need for the creation of CORE, iPOC and the related new bureaucratic
bodies IAHC has proposed. Thus, as it has already indicated, the US government
should not endorse the IAHC Memorandum of Understanding (MOU) and should
oppose the use of ITU and WIPO as oversight bodies for the DNS system.
G. Administration of gTLDs and ISO country code domains is completely separable.
Although the same principles of competition and self-governance should also apply
to ISO-domain registrations, these resources have traditionally been considered to
be subject to the rules and policies of national governments. There is no technical
reason why competitive, shared gTLD administration cannot co-exist with the
many monopoly ISO-domain registrars. Indeed, the creation of a competitive
system for efficient, worldwide administration of gTLDs would have the
commensurate benefit of creating marketplace pressures that would encourage
national governments to open their own ISO-domain registries to competitive
entry. As the OECD has recommended to EU-member nations for their own
country code domains, the US government should consider opening the ".us"
domain to competing registries and should actively promote similar procompetitive
policies by other national governments for ISO country code domains.
H. The "transition to any new systems" for domain name registration should be
accomplished with the full, open and considered participation of all stakeholders in
the Internet. The IAHC proposal, in contrast, raises serious questions about the
authority of ISOC and the other members of IAHC to impose their chosen solution
for DNS reform and the essential openness of Internet self-governance.
(1) IAHC does not have sufficient input from the Internet community; the
Internet Society is not a member oriented group, and its decisions cannot
legitimately claim to be based on Internet community "consensus."
(2) IAHC's aggressive timelines are unjustified, especially given the lack of
urgent technical problems. As recently as August 1996, it was deemed
unlikely that the growth of the .com domain would pose any technical
problems.
(3) IAHC's comment period was very short (2 weeks), and its extremely rapid
implementation timeline does not allow for sufficient debate and generation
of proposals for registrars.
(4) According to a brief filed by the World Internetworking Alliance
<http://www.wia.org/pub/dns-brief.html>, the participation of international
groups in the IAHC raises concerns regarding the legal nature of the IAHC
proposal as an intergovernmental agreement.
(5) Despite the participation of ISOC, IAHC did not include substantial input
from the community of Internet end-users. Furthermore, the IAHC's
proposed bureaucracy is similarly lacking in community representation.
(6) IAHC is proceeding as if its proposal was thoroughly and completely
accepted, including a Geneva MOU signing ceremony in early May 1997
and the continuation of plans to implement CORE-managed shared gTLDs
in October 1997. However, this purported Internet consensus is not all
clear. For instance, the Commercial Internet Exchange (CiX)
<http://www.cix.org>, a consortium including members such as AT&T,
CompuServe and MCI, has expressed reservations regarding the IAHC
plan, and a new organization known as the Open Internet Congress (OIC)
<http://www.interactivehq./org/oic/> has similarly raised objections to the
closed, hasty and "top-down" nature of the IAHC process.
IV. CREATION OF NEW gTLDs
In this Section, NTIA specifically seeks comment on whether new gTLDs should be
established and whether there are any technical, practical and/or policy considerations that
constrain the number of different gTLDs or the management of gTLDs.
CPSR believes, as discussed in Section III above, that IAHC has developed a reasonable
approach to the creation of new gTLDs, with different gTLDs signifying different uses of
domains. Although this approach was driven more by the demands of existing registrars and
trademark owners for TLD-based alternatives to domain-name disputes in the .com registry, in
order to reduce pressures for litigation over .com domains, the concept of creating
"special-purpose" gTLDs is an attractive one from the perspective of both Internet users and
commercial
businesses. (Whether or not the specific gTLDs developed by IAHC are approp