From: Roger Cochetti <rogerc@us.ibm.com>
To: NTIA.NTIAHQ(usdomain)
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
Washington, DC

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