October 15, 1998
Brian G. Kahin
Executive Office of the President
SUBJECT: .US Domain Registration
Dear Mr. Kahin,
I was referred to you by Robert Shaw of the International Telecommunications Union (ITU) concerning my recent experiences in attempting to register domains in the .us system. I am also sending this to Karen Rose of NTIA as ex parte comments in response to the request for comment on the .us domain registration comments or just for general information.
At my main web site I offer information to small businesses about setting up an Internet domain at little or no cost. This includes a page on how to register in the .us system. I believe the .us system has a much greater potential than is generally discussed. While the domain names are long, they convey a large amount of information. I believe this advantage can outweigh the domain name size issue in some cases. For instance, if the domain is accessed primarily from other web pages as a link it does not matter how long the domain is. If a user is looking for hotels in New York a search engine could yield sites such as: "hotels.com", "hotels.philadelphia.pa.us", and "hotels.new-york.ny.us." In this case a user is very likely to investigate the NY entry. I also believe some local businesses would see the city URL as an advantage but they just don't know about it. Also, if you review the new domains being registered (a daily report is athttp://www.domaingames.com/) you will find many lengthy and awkward names.
I recently tried to register domains within .us and ran into significant difficulty. The registrar handling domains in san-francisco.ca.us is refusing to activate a number of domains I registered. As I am sure you are aware many city/town domains have been delegated to private companies (usually ISP's). The rules covering these delegations are vague and outdated and many issues are not covered at all. The system works essentially like AAA road service. The ISP registers the domains at little or no cost with the hopes of gaining addition business such as domain configuration, web hosting, etc. The comments at the NTIA web site indicate that this process has led to mixed results depending on which company actually registers the domain. Often, the ISP is not physically located in the city referenced in the domain (I recently registered "santa.north-pole.ak.us" but I had to go through an ISP in Tennessee).
My current business plan requires several domains within a single locality (at this time, San Francisco, CA and Washington, DC). I already have a similar business using ".com" domains. At Happy-Holiday.com I have registered approximately 40 holiday related domains (at a cost of over $2,500). I offer users, at a cost of $5/year, to have a web page under all 40 domains at once. This allows the user to set up holiday related pages, party announcements, etc. and use the domain that fits the holiday. So for Halloween they could use Trick-or-Treat.com/user, Easter-Bunny.com/user for Easter and so forth. An individual user is able to use all of these domains even though they do not have a domain registered themselves. In fact, all the users signed up so far use free homepage services available elsewhere in the Internet and may register a domain for themselves. I also plan to offer e-mail similar to service offered bywww.iname.com (they offer addresses such as engineer.com, lawyer.com, etc). It is not possible to start such a business with a single domain name and an even longer name (with 5 parts) would compound the length problem.
During the planning I reviewed all the rules of registering .us domains, including the relevant RFC and the information available at the US domain registration web site. I also verified that I could register more than one domain by calling the US domain registrar's office. I was told there was no restriction unless the delegated registrar had additional restrictions. I then contacted the delegated registrar for San Francisco. Their web site had information about web hosting and registering domains for ".com," etc. but there was no reference to the .us system whatsoever. I contacted the company via e-mail to get the information but I was referred back to the .us site. At that point I went ahead with my plans to register 37 domains (I don't believe any of the domains would involve any trademark issues). This included a considerable effort in configuring my system to use these domains. After I registered the domains the company did not respond at all. I contacted them again about a week later and I received a response that said: "Your list of registration requests is contrary to the stated purpose and overall spirit of the *.us domain name space."
At this point I called the company. The person accused me of "domain abuse" and suggested that I register one domain. I asked them to point out what .us registration guidelines I violated but he was unable to identify any. Several hours later, after I stated that I was filing a complaint with the main .us registrar, the company claimed that they had a long-standing policy of one domain per "organization." The company has since refused to activate all but one domain and I had to file the complaint. At this point, the domains remain unused, there is apparently little or no demand for them by anyone else, and I am unable to use my updated system configuration. I already have an ongoing business providing reservations for tours and hotels in San Francisco at my web site and I am being prevented from using the associated domains. It is also interesting to note that this registrar has registered unused domains in the ".com" namespace, apparently to prevent others from registering names similar to their business.
The registrar is also trying to deny registration of some of the domains based on other reasons. My registration of "airport" was rejected because "the San Francisco Airport is operated by a city/county agency and this application does not have the authority to represent that agency." However, according to the July report on the .us system developed by IANA, an "airport.washington.dc.us" domain was registered that month. There actually is no airport in San Francisco or Washington, DC. Washington National Airport is in Arlington, VA and the San Francisco International Airport is in Burlingame, CA. As a side note, this domain, along with several others registered that month (apartments.washington.dc.us, antiques.washington.dc.us, etc.) appear not to be configured at all. The rules require that configuration be complete before a domain registration can even be initiated.
The San Francisco registrar also rejected another domain "museums.san-francisco.ca.us" claiming "Museums are located in the .mus.ca.us namespace." Of course, I am not a museum and for all the registrar knows "Museums" might be the name of a new nightclub.
The registrar also wrote to the US domain registrar. They claimed that if they were required to register all these domains for me that it would cause them a hardship because the service is free (of course, they tried to sell me others services when I asked about .us registration). Other delegated registrars have solved this problem by offering the first domain at no charge and additional registrations at $10 each. I would not object to such a fee. Also, I would not object to a requirement that the domains actually be used rather than just reserved ("parked").
To summarize, I do not believe the registrars should be making such decisions unless it affects the functionality of the system. Certainly, they should not be in the business of preventing registrations for unused domain or making business decisions for companies registering domains. Being a registrar should also at least require the companies provide information about this service at their respective web sites.
I would be grateful if your office could open up this registration process. Nobody will know how useful the .us domain space is unless the domains can actually be used. At this point I don't who registers the domains as long as I can get them operational!
Cc: Robert Shaw, ITU;
Karen Rose, NTIA;
US Domain Registrar