From: Roger Cochetti <email@example.com>
Date: Friday, October 09, 1998 9:41 AM
Subject: IBM COMMENTS ON DOCKET 980212036-8172-03
Ms. Karen Rose
Office of International Affairs
National Telecommunications and Information Administration
U.S. Department of Commerce
RE: Docket No 980212036-8172-03
On behalf of IBM Corporation, I am pleased to comment on the above docket,
labelled "The Enhancement of the .us Domain Space".
Over the past several years, as the Internet has experienced dramatic growth
both in the United States and in other countries, two separate approaches to
the use of top level domains have emerged. In the United States, most
commercial and non-commercial users have tended to use the generic, top-level
domains (gTLD's such as ".com", ".org", ".net", etc), while in most other
countries, most commercial and non-commercial users have tended to use the
country code top-level domain for their country (ccTLD's such as ".uk", ".de",
".jp", etc). Thus, many Internet users in the United States have come to
assume that these gTLD's are all that is available for their use in the
medium. It is now clear that the wider use in the United Sates of the ".us"
ccTLD can open up new opportunities for a wide range of Internet users.
Thus, IBM supports the Department's efforts to explore this matter with the
goal of the greater of the ".us" ccTLD.
There are several steps that we believe need to be taken to ensure the wider
use of ".us". Principal among them is the designation of some entity with a
mission to encourage the use of the ".us" domain by Americans. Second is the
establishment by that entity of a variety of second-level domains (SLD's)
within the ".us" ccTLD that will attract the interest of commercial and
non-commercial users. This need not, and should not, in any way interfere with
the current structure employed in the ".us" TLD, which provides a breakdown by
State. For example, new SLD's for commercial and non-commercial sectors would
attract the interest and support of those sectors. Similarly, SLD's on broad
topics could attract the interest of those whose content reflects that topic.
A key issue raised in the Notice is who should be the designated entity and how
should such an entity be governed. A variety of suggestions have been made for
the entity, including the designation of the United States Postal Service
(USPS), or some body affiliated with USPS, and the creation of an altogether
new management corporation. We believe that the designation of an organisation
affiliated with the USPS, if done with appropriate safeguards to ensure private
sector control and no cross subsidy with the USPS's regulated postal services,
offers a viable structure.
At a time when the Internet community is already devoting quite significant
resources to the creation of a new management organisation for the central
administrative functions of the Internet and given the risks associated with
investing in an effort to further develop the ".us" ccTLD in competition with
the existing and any new gTLD's, a USPS-affiliated organisation, or something
similar to it, could offer stability and experience. It is essential, however,
that any such designated entity be governed entirely by a body selected by, and
accountable to, the private sector. Such a body could be selected through a
process that involves both those with a direct stake in t he ".us" TLD and the
public at large.
Roger J. Cochetti
Internet Address: RogerC@US.IBM.COM
Program Director-Policy & Business Planning, IBM Internet Division