Date: Thu, 01 Oct 1998 20:46:20 -0400

From: Michael Sondow <msondow@iciiu.org>

To: usdomain@ntia.doc.gov

Subject: Comment to (63 Fed. Reg. 41547 (1998))

Dear NTIA,

This is a second comment in response to the NTIA's Request For Comments on the Enhancement of the .us Domain Space (63 Fed. Reg. 41547 (1998)). It is divided into two parts: 1)Comment on administration of .us domain names by the United States Postal Service, and 2)Comment on the delegation of .us domain space.

1) The administration of domain names, whether within the .us domain space or any other domain space, by a postal service is antithetic to the spirit and the historical trajectory of Internet development, which have created a new non-geographic and extra-territorial location, commonly referred to as "cyberspace", in which communications flow between individuals and entities without regard to their geographical location. The Postal Service, being a service for geographical distribution of communications, cannot, by its nature, it history, and its function, provide a useful extension of communication in the new cyberspace, and should not be allowed to associate domain names and/or Internet addresses with geographic addresses, which would be a grave restriction upon the freedom of communication on the Internet.

2) Delegation of address space within the .us domain has not been done with due regard to the principles defined by the IANA (ISI/USC) for use of the .us space. Nowhere is this more clearly demonstrated than in the delegation of the third-level generic domains .CC, .COG, .GEN, .K12, .LIB, .MUS, .STATE, .TEC, and others, with the NY state second-level domain, to a commercial, big business-oriented network named PSI Net:

.............................................................

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-Q

COMMISSION FILE NUMBER 0-25812

PSINET INC.

(EXACT NAME OF REGISTRANT AS SPECIFIED IN ITS CHARTER)

510 HUNTMAR PARK DRIVE, HERNDON, VA 20170

(ADDRESS OF PRINCIPAL EXECUTIVE OFFICE) (ZIP CODE)

(703) 904-4100

(REGISTRANT'S TELEPHONE NUMBER, INCLUDING AREA CODE)

.............................................................

(http://www.isi.edu/in-notes/us-domain-delegated.txt)

DELEGATED SUBDOMAINS

NY CC.NY.US. hostinfo@ns.psi.net

NY COG.NY.US. hostinfo@ns.psi.net

NY GEN.NY.US. hostinfo@ns.psi.net

NY K12.NY.US. hostinfo@ns.psi.net

NY LIB.NY.US. hostinfo@ns.psi.net

NY MUS.NY.US. hostinfo@ns.psi.net

NY STATE.NY.US. hostinfo@ns.psi.net

NY TEC.NY.US. hostinfo@ns.psi.net

.............................................................

Because PSI Net cannot profit from the distribution of these name spaces, whose commercialization is prohibited by their charter, it has done nothing to publicize and distribute them. This phenomenon of disinterest on the part of commercial networks to whom components of the .us name space have been delegated, quite as much as any general lack of interest on the part of public and non-profit organizations in the use of those domain names because of their length or other criteria, has resulted in the present conjuncture and should not be repeated in a future redistribution of the .us name space.

These comments are submitted in a spirit of constructive support for an enhancement of the .us domain space for public use.

Michael Sondow

====================================================================

International Congress of Independent Internet Users (ICIIU)

http://www.iciiu.org iciiu@iciiu.org


###

From: <mheltzer@inta.org>

To: NTIA.NTIAHQ(usdomain)

Date: 10/1/98 11:15am

Subject: INTA Response

Dear Ms. Rose:

The International Trademark Association (INTA) is pleased to provide you with

its response to NTIA's request for public comment concerning the "Enhancement of

the .us Domain Space" (Docket No. 980212036-8172-03). INTA has elected to

answer questions 1,4,5,6,7,10, and 11. The attached document containing our

responses is in Word Perfect.