From: "Bruce O. Benson" <benson@sparta.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 2:01am

Subject: Comments on Enhancement of .us domain space

Ms. Rose,

Please accept my following comments on enhancement of the .us domain

space.

My responses are organized numerically in correlation with the Questions

for Public Comment.

1. The geographic structure of .us is sufficient. All my suggestions

would expand the .us domain while remaining fully compatible with the .us

TLD in place.

2. I propose to expand .us to include commercial subdomains for .com.us

(or a .co.us) as well as the states as .com.va.us (for example). The cost

will be borne by the registrants and administered by InterNIC for .com.us

and for an authority set up by each state for .com.state.us. Each state

could then decide how costs should be borne.

Additionally, I strongly suggest a subdomain for U.S. Citizens, .per.us or

something similar. This would allow a simplified redirection of IP

requests to the user and follow him/her during relocations. A similar

convention could be allowed for at the state level for state residents.

Costs would be minimal and borne

by the personal user, delegation could be performed by any number of

existing non-profit authorities, but my personal favorite would be the

U.S. Postal

Service. This would allow a single change-of-address form to be used as

well as encouraging the USPS to commence a no-frills email service. If

changing your surface is free, shouldn't changing your Internet Address be

free (or nearly free) as well?

3. I do not suggest any other subdomains be created other than .per.us,

.per.state.us, .com.us, and .com.state.us.

Further subdomains are unneccesary branches from these and create

additional delegating authorities which would heavily complicate the

existing DNS. Imagine someone typing URL://703-448-0120.us to get to my

voicemail. The named daemon would have a huge parser to differentiate

this from URL://78.80234+37.890.us and all the other types of urls. It

would be better to let software engineers craft special daemons to serve

the needs of telephonic or geocoordiated URLs.

Just going through the exercise of simulating a telephonic or

geocoordinated URL reveals the lack of orthogonality of appending .us

afterwards. This begs the question of whether telephonic or geocoodinated

URLs should be TLDs. That is not a question that should be discussed

here.

4. .us should not be unrestricted, as suggested by aforementioned

comments. Delegation is mentioned in previous comments as well.

5. The top level .us domain should be administered by the United States

Government. This would ensure proper maintenance of subdomains for states

and citizens. This requires minimal registry database, as all the heavy

work for .com.us is borne by InterNIC. And all the .per.us would be borne

by a separate delegating authority as well.

I believe this would be the FCC's job to administer this TLD.

6. .com.us domains are issued first-come, first served. It is very hard

to make domain holders give reference to a different trademark holder of

the same name and should not be required. The delegating authority should

treat each entity requesting a name as if it were requesting a street name

(in the case of a .com.us domain) or a personal legal name change (in the

case of a .per.us domain). Can a copier company get a street name 'Xerox

Road'? I don't know, but this is the analogue of precedence.

When applying for a .foo.us domain, Federal laws prevailing over the

analogues are applied. When applying for a .foo.state.us doamin, state

laws will prevail.

7. Each state may administer/delegate it's own sublevel as it sees fit.

This settles the important states-rights issue once and for all. The

presence or absence of any DNS service within a .state.us subdomain would

completely be the responsibility of the state. It would be possible for

some states to have free state-provided URLs for all comers, while others

delegate the assignment to profit-taking corporations.

State government domains would be pointed to by DNS listings maintained by

the U.S. Government delegating authority (i.e. the FCC).

8. I think the current system of delegating third-level locaility domains

to private registrars is poor. It is not possible for an individual to

be assured he/she could receive a low-cost or free domain listing. This

is a simple service that can be performed very inexpensively or freely by

the quasi-government and quasi-states entities (a la USPS, Amtrak, power

companies, etc.). Some states could actually appoint volunteer

authorities for certain locality domain delegation as they see fit.

Conversely, I doubt the United States could issue up to 250M+ .per.us

domains without substantial cost. The gist of my argument is that profit

motive should be removed from non-commercial delegation wherever possible.

9. Because of the sparcity of top level .us doamins (one pointer for each

of the states,

territories, and a single pointer to the .per delegating authority, and

pointers to U.S. Government departments) this

would be a low-cost administration of the FCC.

10. This issue should be left to the United Nations.

11. To summarize:

.us--FCC

.co.us--InterNIC or someone like them.

.per.us--quasi-governmental/non-profit.

.co.state.us--a state-appointed authority as they see fit.

.per.state.us--a state-appointed authority, non-profit, or free.

.gov.state.us--state government.

Feel free to contact me for further comment or explanation.

My opinions may or may not reflect those of my employer, who provides my

email service. My comments are offered in a professional but onofficial

capacity as a practicing electrical and formet network and wireless

engineer.

Thanks for the opportunity to comment.

All the Best,

Bruce O. Benson, Electrical Engineer,

SPARTA, Inc. CPD

7926 Jones Branch Drive, Ste. 900

McLean, VA 22102-3303

703-448-0210 x. 211

benson@sparta.com

http://www.mclean.sparta.com

###

Date: Mon, 10 Aug 1998 11:28:50 -0600

From: Brad Pierson <bpier@cfer.com>

To: usdomain@ntia.doc.gov

Subject: Comments on the Enhancement of the .us Domain Space

Brad Pierson
9051 Holland St
Westminster, CO 80021
piersonfamily@uswest.net

Simply put, the Federal should not be involved in this issue. There is no legitimate reason stated in the US Constitution for the executive branch to control or define this function. This merely gives the Federal government another avenue to pry into the private activities of citizens.

###

From: Chuck Clemens <eo11@mychoice.net>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 9:51am

Subject: universal e-mail

Pursuant to an article on cnn.com this am I believe assigning an e-mail

address to every US citizen would be impossible and foolhardy. I furter

would be adamantly against using said addresses to send mass information or

personal information to individuals expecting that they would have or gain

access to the means to respond to same.

Charles Clemens

Student Health Program

Southern Illinois University Carbondale

Carbondale, Illinois

62901

eo11@mychoice.net

###

From: "Fabio M. Zambelli" <fmz@usa.net>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 2:59pm

Subject: Enhancement of the .us Domain Space

Hello Karen,

I cannot say anything about the proposal 'cause I'm italian and I'm not

involved in the discussion, but I would like only to say that open to

everybody a public discussion about these kind of things is a great proof

of your democracy.

Have a nice day.

> ============================================ <

> F A B I O M. Z A M B E L L I <

> ============================================ <

> vicolo San Martino # 6 <

> Pero, Milano - 20016 <

> ITALY - EUROPE <

> ============================================ <

> PHONE (international +39): 02.3810.2645 <

> FAX (international +39): 02.3810.2645 <

> [fax: dalle 14,00 alle 16,00 giorni feriali] <

> [fax: from 2 pm to 4 pm C.E.T. working days] <

> ============================================ <

> E-MAIL: <mailto:fmz@usa.net> <

> ============================================ <

###

From: <frburton@scif.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 1:15pm

Subject: Universal email

I favor the added .us domain if it means universal email for all and more

efficient use of the Internet.

Frank Burton

Phone number: (213)954-5609

Fax number: (213)954-5692

###

Date: Mon, 10 Aug 1998 08:55:07 -0400

From: LARRY FRIDAY <friday.l@nypa.gov>

To: usdomain@ntia.doc.gov

Subject: USPS Proposal Viewpoint

While the idea of a USPS email backbone linking my physical address to and electronic one is a nice idea ... however, I can see some of the following happening if this backbone was approved.

I will make a broad assumption that electronic mail would be an option that could be exercised - not a mandatory change-over.

First, laws regarding electronic mailing would need to be reviewed at all judiciary levels to verify the usability of electronic data in court. How long would this take? This should be done *before* any enactment of an email system country-wide. Let's not be revamping laws after the fact ... think ahead.

Secondly, what costs for upgrading software and hardware to generate electronic billing records are going to be passed on to the consumer? Myself, I really would not like my phone bill or electric bill to take an increase for something like this. They are bad enough as it is. Will credit card interest rates go up a point to offset the same changes? While I realize a return on investment would be preferred, I for one would not wish to see this happen to me.

Last is a concern about 'spam' - electronic mass-mailings. What happens if the USPS has an electronic version of my physical address? Will my inbox get flooded with all this 'chaff' as well? Right now, my electronic inbox is quiet and I'd really like it to stay that way, please. My physical mailbox is also reasonably peaceful with the exception of the "Resident at ..." type of mailing. I like it that way!

I appreciate what the Postal Service is trying to do and while laudable, it would need quite a bit of before-hand planning and preparation to enact in an equitable manner that would be suitable for all.

Many thanks for the opportunity of voicing my views.

Sincerely,

Lawrence B. Friday

###

From: Gary Williams <gary@gvltec.edu>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 11:00am

Subject: Government email envolvement

I see this more of an issue of lost revue by the post office. The Postal

Services' desire to provide an email for everyone does not appear to be for

the best interest of the consumer but rather an attempt to find some way to

recover the lost income related to email. I believe the responsibility of

government under the constitution is very limited and should be so to

protect the population from too much government intervention. Greed by

private or public institutions is destructive in any form. I say, let the

post office stick to the letter caring, package delivery (that is if they

can compete with the UPS, FedEx, and the other carriers in a cost effect

way) and help keep the government out of the Internet and email arena.

###

From: Justin Denney <jdenney@cse.ogi.edu>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 1:33pm

Subject: questions

3.Specifically, should special-purpose second-level domains be created

under .us? What are the benefits and costs of creating particular

special-purpose domains (e.g., industry-specific, credentialing, zoning)?

How should such domains be created and administered? Are there reasons to

map names and other addressing and identification systems (e.g., postal

addresses, telephone numbers, longitude and latitude, uniform resource

numbers or others) into .us?

They should not be created according to physical location. One of the

benefits of networking is that it allows for physical independence.

People/companies shouldn't have to change their email address or web

address just because they change their physical location.

5.How should conflicting proposals and claims to manage or use .us

subdomains be resolved? Who should have responsibility for coordinating

policy for .us over the long term? What public oversight, if any, should

be provided?

.us should be the only top level domain managed by the US government.

(Other than .gov which is primarily for internal government purposes.)

6.What rules and procedures should be used to minimize conflicts

between trademarks and domain names under .us? Should this problem be

treated differently at international, national, state, and local levels?

Should special privileges be accorded to famous trademarks, such as a

right to register directly under .us or a procedure to preempt the use of

the trademark in a range of subdomains?

Don't issue multiple high-level names to the same company. Limit resale

of the domain name. It is terrible that in .com, some companies snatched

up common family names so that they could sell them to people from that

family. e.g. my personal example is that M@il Bank (http://MailBank.com/)

should not be allowed to own www.denney.com, as they do.

7.What role should states play in the allocation and registration of

their respective subdomains? Should commercial names be permitted under

states as third-level domains? Or should such third-level domains be

limited to special categories such as domestic corporations or other

state-licensed entities? Should states and localities operate registries

and accept registrations directly? To what extent should state policies be

coordinated and through what mechanisms and procedures?

If states are given subdomains, then they should be given full,

unregulated control over the allocation of the subdomains. But there

should first be a suggested standard for several common third-level

domains. States should accept registration directly.

9.How should the operation of the .us registry be supported? Should

uniform registration (and renewal) fees be instituted? Should registrars

contribute to the operation of the registry?

There should be a one-time registration fee. Operation should be

primarily registration, not regulatory activities, so that it remains

inexpensive.

11. By what type of entity should .us be administered? Private,

governmental, or quasi-governmental? For profit or not-for-profit? What

are the advantages and disadvantages of using one type of entity (private,

public, for profit, not-for-profit) over the others?

Top level should be government, second levels should be private for profit

with required "watch dog" groups. Since the current proposal has been made

by the U.S.P.S., I imagine that they might be considered for some level of

administration. I think that would be a bad idea.

###

From: Kevin M Fox <kmfox@mail.bhi-erc.com>

To: NTIADC40.SMTP40("usdomain@ntia.doc.gov ")

Date: 8/10/98 1:02pm

Subject: email

Having a unique email address per postal address sounds like a good

idea. I think that the email address should be a redirector rather

than an email end. Say, for instance, that I have two houses. I could

have the one houses email redirected to the other house so I only have

one email address to look at. Also, SMime must be in place. This

allows you to confirm who you are over email and makes it unreadable

by everyone but yourself and your recipient.

Kevin

###

From: "Lon Seidman" <lon@safety-zone.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 9:42am

Subject: response

>How should the present geographic structure of .us be extended or modified?

What >changes should be made in RFC 1480 or the posted policies for .us?

I think the universal email addresses should be keyed to their state

associations. For example, I live in Connecticut, where our .us domain is

state.ct.us (something like that). That will at least allow people to

generalize the area of the country their email is going.

>What are the benefits and costs of different options for allocating

second-level >domains under .us? How should the allocation of such

second-level domains be decided >and administered? What should be the terms

of delegation?

That should be decided through the Internic or similar governing body, for

no cost to the US gov't for domain name maintenance.

>Specifically, should special-purpose second-level domains be created under

.us? What >are the benefits and costs of creating particular special-purpose

domains (e.g., >industry-specific, credentialing, zoning)? How should such

domains be created and >administered? Are there reasons to map names and

other addressing and identification >systems (e.g., postal addresses,

telephone numbers, longitude and latitude, uniform >resource numbers or

others) into .us?

As I stated above, state zoning should be used.. Zoning by industry will be

a haven for spammers, and it really won't prove useful. Also keep in mind

that many people already have an email address, and may not take advantage

of one if it's offered by the government.

>Alternatively, should .us be treated as an unrestricted top-level domain

like .com or >should one or more specific second-level domains such as

.co.us or .com.us be used >for unrestricted assignment of domain names (as

in .com)? How should such >unrestricted domains be administered and by whom?

Leave it restricted.. That will at least provide some seperation for people

on the net. I've always considered .us to belong to the nation, and not to

private organizations. com.us and other variations is too complicated.

Leave the .com.. It's already become a part of 'pop' culture.

>How should conflicting proposals and claims to manage or use .us subdomains

be >resolved? Who should have responsibility for coordinating policy for .us

over the >long term? What public oversight, if any, should be provided?

The way it's done now, through the Internic. While there are many

complaints, they seem to be able to resolve many disputes rationally.

>What rules and procedures should be used to minimize conflicts between

trademarks and >domain names under .us? Should this problem be treated

differently at international, >national, state, and local levels? Should

special privileges be accorded to famous >trademarks, such as a right to

register directly under .us or a procedure to preempt >the use of the

trademark in a range of subdomains?

Again, Internic rules should apply.

>What role should states play in the allocation and registration of their

respective >subdomains? Should commercial names be permitted under states as

third-level domains? >Or should such third-level domains be limited to

special categories such as domestic >corporations or other state-licensed

entities? Should states and localities operate >registries and accept

registrations directly? To what extent should state policies be >coordinated

and through what mechanisms and procedures?

Just leave it alone.. Nobody gets a .us domain unless it's a government or

government assigned email address.

>How well has the system of delegating third-level domains (localities) to

private >registrars on an exclusive basis worked? How could it be improved?

Should registrars >be accountable to their delegated localities (just as

country-code registries are >accountable to national governments)? Should

registrars be limited to a single >jurisdiction? Should multiple competing

registrars be able to register under any >local, state, or special-purpose

domain under .us as in the plan proposed for generic >Top-Level Domains?

No, again look above.

>How should the operation of the .us registry be supported? Should uniform

>registration (and renewal) fees be instituted? Should registrars contribute

to the >operation of the registry?

Again, see my previous answers.

>What are best management and allocation practices for country-code domains?

What >practices should be emulated or avoided?

What's in place now seems to work fairly well.

>By what type of entity should .us be administered? Private, governmental,

or quasi->governmental? For profit or not-for-profit? What are the

advantages and disadvantages >of using one type of entity (private, public,

for profit, not-for-profit) over the >others?

Internic.

###

From: "Cox, Nancy M." <NANCY.M.COX@cpmx.saic.com>

To: "'usdomain@ntia.doc.gov'" <usdomain@ntia.DOC.GOV>

Date: 8/10/98 12:34pm

Subject: .us Domain Addresses

My concern is not in reference to any of the 11 questions, but one in

general. If our e-mail addresses are linked to our street addresses, IS

THERE ANY POSSIBLE WAY THAT SOMEONE COULD DETERMINE WHERE YOU LIVE??? I

see major security issues at stake here.

Has anyone given any consideration to this EXTREMELY sensitive security

issue??? For your consideration.

Nancy M. Cox

###

From: "Richard A. Putt" <raputt@pod.c3i.saic.com>

To: "'usdomain@ntia.doc.gov'" <usdomain@ntia.doc.gov>

Date: 8/10/98 1:55pm

Subject: Request for Comments on the Enhancement of the .us Domain Space

Dear Karen Rose,

I read the CNN article "Clinton backs universal e-mail plan."

The article gave me the impression that someone in the government is

looking to establish a precedence of control over the Internet. Even

though .us TLD may not be used heavily it looks like the government is

trying to step in again.

The government did a good job starting the Internet evolution.

Also, it seemed that the government made a positive move in proposing to

pass the responsibility of DNS distribution to a private concern. The

government has done a good job at establishing the Internet as it is

today. But, history has shown that continued government involvement, in

anything other than initial development, causes problems and failures.

I see a major issue, a problem, developing if the government

allows the U.S. Postal Service to control any single Internet domain.

Although the USPS is, more or less, a private concern it is present, by

law, as an arm of the government. With this being said I do not believe

the government should continue to intervene in the operation of the

Internet in any way. Private industry has done an outstanding job in

moving the Internet into the future through the use of e-commerce. If we

allow a handful of entities to control the operation of any portion of

the Internet, within the U.S. borders, the door will be open for that

handful to dictate what can and can not be said and done over the

Internet. Trying to resolve a .us domain problem through the USPS would

be equivalent to trying to resolve a tax issue through the IRS. U.S.

citizens should consider the least level of government control in any

issue as being the best.

I read the CNN article and considered 3 different view points.

Then I continued reading about the issue by reading the proposal sent to

the Commerce Department. The prevalent opinion that I developed was one

of concern. It looks like someone is trying to make a grab for their

piece of the pie as well as a piece of controlling interest in the

Internet. If the Internet is to continue to develop at the current rate,

external regulation must be kept to a minimum. Freedom of expression is

what has allowed the Internet to grow. Granted some less than desirable

subjects are discussed over the Internet but we can't let the Chicken

Little view of the world permeate our lives.

Do not let the USPS take control of the .us or any other TLD.

Don't let any single entity, related to the government, have complete

control over a domain. Let the domain(s) evolve through open forum on

the Internet. So far, Internet users have proven to be adequate at using

the resources available over the Intent. We, the average Intent user, do

not need to be spoon fed as the legislative system would seem to lead

most to believe. The Internet is the last free frontier available to

those who need to have a place to roam without a chaperone. Let's not

ruin the Internet by placing a noose around its neck.

Greed seems to be the main impetus to the proposal sent to the

Commerce Department. The USPS wants to take control of the e-mail

industry and a great way to start is though the control of the .us

domain. The USPS and many other groups have been crying about the loss

of revenue caused by people using Internet e-mail rather than the

Shoe-Leather-Express.

Greed has driven the proposal of taxing e-mail and e-commerce.

We are already paying for the Internet in the price of our goods.

Individuals who thrive on control see taxing the use of the Internet as

the next domain to conquer.

Please, do not allow the Internet to be placed into a position

where it would be directly taxed or controlled by any government agency

or affiliate. If that were to happen I believe the Internet would die.

One question would come to mind. "Why use the Internet if it costs the

same to use the Shoe Leather Express?" I see the USPS looking at the

grand old dollar sign with no concern for the end of the free Internet.

Even the overall U.S. government would have a lot to gain

through the establishment of a whole new government organization

designed to control e-mail and e-commerce. Lots of revenue and taxes for

the government if restraints are established for the Internet. May as

well tax the Internet since everything else is taxed!!! And how would a

common everyday person, who doesn't care to know details about the

Internet, resolve problems with the new government organization? I bet

someone has an immediate answer for this one. But, the answer would not

be simple because of legal issues the everyday person would not be

answered with an expedient reply.

I just don't like the smell of this proposal no matter how it is

colored.

Sincerely,

Richard A. Putt

###

From: <SanityMad@aol.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 2:38am

Subject: Expansion of Domain

The Internet is much appreciated and I find that the investment made by our

government has been well worth the money paid. Now, however, with the

suggestion that email be supplied to everyone in American, I smell a new tax

coming.

The purpose of such a venture would have to be well defined as to it's

benefits. Frankly, I like things just the way they are. Like most people I

desire slow one step changes so that I might evaluate the benefits to my

family, myself and my business. The number of people using online email is

astronomical, it has been of a great service. The amount of electronic junk

mail I receive makes the paper mail coming thru my door slot look puny. I

think we will discover as many draw backs to this method of communication as

pluses. I also think that our government has no business involving itself in

the direction of the personal use of email.

Sandy Madison

Fort Worth, Texas

###

From: <webmaster@polly.mall-net.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/10/98 3:54am

Subject: USPS and internet

I think is pointless to "issue" an internet address to every

household. Who would use it? Most people do not have internet access,

and when they do get it, receive a service provider-specific e-mail

address. A non-service provider related address just means another large

translation table to translate and re-route e-mail messages sent to some

centralized location. As a webmaster and technology consultant, I can

tell you that this would be a stupid waste of computer power, internet

bandwidth, and disk space. It would become yet another franchise, like

the cable TV francise, that someone uses to milk the consumer. With the

current provider structure, they are all competing to give us the lowest

price.

Before doing anything else, extend anti-faxing laws to include

unsolicited commercial e-mail! (UCE, also commonly called SPAM.) The

number one threat to the internet, is saturation caused by unsolicited

commercial e-mail -- Spamming! When a person gets twenty spams a day, he

or she often starts looking to change their e-mail address or service

provider. Spam eats up connection time, people time, and disk space --

things we are PAYING for, not the sender of that crap! They are stealing

our time, our money, (as many still pay by the minute for time spent

downloading e-mail,) and our disk space! Make it a crime!!! The simplest

and cleanest solution is to take existing anti-junk-fax laws and say they

include unsolicited commercial e-mail messages.

Look at the way airlines were encouraged via subsidized air mail.

That is a good model.

1. Subsidize school and library access to the internet in every town.

If they get any Federal subsidies, they need to have their schedule and

card catalog on the web.

2. Requre every Federal Court place all public trial data on the web

using internet service providers in their locations, and allow as much as

possible to be done via the web, including the scheduling of appointments

and the payment of fines. Same for all Federal Law publications, and

eventually, all Federal Publications.

3. Require all Federally subsidized police departments to provide

public services via web pages and e-mail. That includes answering

questions, accepting complaints, and providing "solution" pages for common

local problems on the web. Crime statistics (incident counts by category)

on a per-block basis would be very nice too!

4. Require all subsidized Department of Transportation sites to

provide service access via web pages. That includes non-photo Driver's

license renewals, auto registrations, fine payments, etc.

3. Encourage states to place all their public records on the web;

everything from their laws, to town meetings and real-estate transaction

notices.

These will encourage the creation of local internet service providers

across the country.

The two major players will eventually be the telephone companies and

the cable TV companies. Our major fear is that neither will allow

individuals to serve their own web pages. Freedom of speech should

include the freedom to publish our own web pages from our own computers,

not to rely on extra cost sites elsewhere. When we provide the world with

what we know, we attract people who become friends. Friends help friends,

relieving the burdens of social services departments and other

governmental service departments. The web of information soon becomes a

web of people helping each other.