From: Thomas & Donna Adams <imcelt2@gte.net>

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

Date: 8/11/98 6:07pm

Subject: Universal e-mail proposal

Butt out! Do anything you want to with the government's e-mail system -

that's Uncle Sam's prerogative - but leave the public alone. We're fine

just as we are.

"If it ain't broke, Don't fix it!"

###

From: "Michaelson, Jason D" <Jason.D.Michaelson@cdc.com>

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

Date: 8/11/98 11:11am

Subject: .us Request for Comments

Thank you for allowing the public to comment on potential changes to the

.us DNS space. As someone who plans to register a personal name in the

.us space, I feel that is important to maintain the current heirarchy of

the space. The .us name space provides a way for individuals to acquire

and use their own domain name which, when compared to registration in

one of the main top-level domains (e.g., .com, .net, and .org), is quite

inexpensive, if there is a cost at all. Therefore, let me proceed with

my comments.

I believe that the current geographic structure should be maintained, at

least to the .(state).us level. However, the names under .com, .net, and

.org are being depleted at a rapid rate. The majority of these names are

taken by organizations within the United States. The .us domain space

could easily be extended to support such second-level domain names. How

this is done needs to be carefully examined. If .com.us is used as a

second level domain, it would be easily confused with names under the

current .com domain. This would be similar to the frequent mistake made

by people who mistype www.whitehouse.gov as www.whitehouse.com (which is

a well-known adult-content site). If .co.us is chosen (as is done in the

.uk and .kr domains), it would conflict with the space for entities

within the state of Colorado. In order to make the .us domain attractive

to commercial organizations, such second-level names need to be added.

Another issue surrounded by this is cost. Currently, registrants are

charged $50 per year for a domain under .com, .net, or .org. Because of

this, many entities (particularly personal entities such as myself) have

investigated registering under their respective .(state).us domain.

Under a revised system, I would leave the fees for a name to be set by

the registrars of that second-level domain or delegated lower if the

registrar for that domain so chooses. However, orgainzations wishing to

have the convenience of foobar.corp.us, rather than the somewhat cryptic

foobar.saint-paul.mn.us, could be asked to pay for such convenience.

The authority for names under .(state).us should be delegated to that

state, which may further delegate authority if it so chooses. As for the

unrestricted second-level domains, any method of authority delegation

would be acceptable.

In summary:

1) Maintain the current locality-based structure of the .us domain

2) Add unrestricted second-level domains such as .corp.us, etc.

3) Maintain the fees structure of the current systems under the .us

domain:

a) For names under .(state).us, fees are "inexpensve"

b) For names under the other second-level domains, as much

as $50 per year.

4) Maintain similar registration structures as above.

If the .us domain is modified in this fashion, I think that it will

still be acceptable to those who have found it to be an alternative to

one of the other top-level domains. In addition, the ability to register

under a .corp.us domain would make it significantly more attractive to

commercial entities who can't fit into the .com domain.

Thank you,

Jason D. Michaelson

Jason.D.Michaelson@cdc.com

750 Magnolia Avenue East

Saint Paul, MN 55106-3129

CC: "'ares0@gecities.com'" <ares0@gecities.com>

###

From: "John Public" <johnzpublic@hotmail.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/11/98 9:34am

Subject: Universal email plan -- negative response

CNN reports: "The Clinton administration wants all Americans to have an

e-mail address to go along with their street address and is asking the

U.S. Postal Service to deliver the project's backbone."

Please cancel all such plans. There is no way that I and most of the

rest of the internet users want Big Brother to assign email addresses to

every resident. Of course, if the USPS handles it, it won't work anyway,

but please don't spend my tax money on this huge boondoggle. This is not

a desirable function of government. PLEASE! Stay out of our lives. Less

government is better government.

John Z. Public

###

From: <mib@io.com>

To: NTIADC40.SMTP40("cypherpunks@cyberpass.net")

Date: 8/11/98 11:27pm

Subject: Re: FWD: NTIA Proceeding on ".US"

On Mon, Aug 10, 1998 at 06:12:19PM -0700, Bill Stewart forwarded:

> The Request for Comment poses specific questions related to the future

> of .us administration. These include how domain names should be assigned

> under .us, the type of entity that should administer .us, and the role

> of the states and localities in domain name registration, among others.

> In addition, the public is invited to comment on other aspects of .us

> management.

The map is not the territory.

--

http://www.io.com/~mib/ | "Say what you know, do what you must, come what may."

41.035437 N 73.567253 W | 3490 FE89 45E8 27B8 234A 153E 5FA5 F587 4243 FE81

CC: NTIA.NTIAHQ(usdomain)

###

From: Rajiv Shah <r-shah4@uiuc.edu>

To: NTIA.NTIAHQ(usdomain)

Date: 8/11/98 6:45pm

Subject: Comments on .us Domain Space

Attached are my comments in Word 97

Thank you,

Rajiv Shah

University of Illinois

Institute of Communications Research

r-shah4@uiuc.edu

309-662-2908

3507 Wegeng Dr.

Bloomington, IL 61704

Comments on the Enhancement of the .us Domain Space

General Comments:

The .us domain space should go beyond the textual representations of IP addresses, such as .us, and also encompass numerical IP address space. The combinations of both the numerical and textual address space will allow the creations of "zones" or "neighborhoods". Such zones could exist through the use of either numerical or textual address space. Examples of these zones include the creation of an "adult" zone or zones on the basis of geography. The advantage of zones based on numerical IP addressees is that do not force people to use a certain domain name. This is an area that I have begun to write on, so please contact me for more information on this topic.

1. How should the present geographic structure of .us be extended or modified? What changes should generally be made in RFC 1480 or the posted policies for .us?

The naming structure may also add support for zip codes. This would allow addresses such as acme.61704.us.

3. Should special-purpose second-level domains be created under .us?

Yes, second level domains would add definition to cyberspace. They would allow people to better find relevant sites, organizations, and companies. Special purpose domains, for example, would allow "adult" material to be zoned to a particular area of the Internet. I would also recommend zip codes to be added as a second level domain. This would allow universal service in cyberspace. As for latitude and longitude, I believe these are better incorporated into the numerical internet addresses. I believe earlier versions of IP Version 6 or IP Next Generation considered adding a location to every IP address.

There is an urgent need for businesses to know exactly where their customer is located. Location based domain names or numerical addresses could allow businesses to have some certainty as to where a customer is located in with regard to legal jurisdictions. This could be helpful in determining whether the "adult" material meets local community standards or what states law applies to a particular situation.

4. Should the .us be treated as unrestricted?

No, simply because if the concept behind .us is to administer special-purpose domains and add universal service cannot be done in an unrestricted manner. An organization will need to administer and be held accountable for such a service.

Who should administer?

There simple isn't enough information available to make a good decision. The type of administrating that is required to manage such a domain name system suggests some type of governmental or quasi-governmental organization. This is simply because this is a one of a kind business, there is a need for stability and reliability (can't be switching companies), and decisions that are made must be fair and subject to public review. Through fees it is quite possible that such an organization could support itself. This would allow the people of the United States to have an self-supporting agency in which they could trust.

###

From: <sully@votiv.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/11/98 11:59am

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

Comments on the Enhancement of the .us Domain Space

Submitted by: VoTiV Systems LLC, 8/11/98

Alan Sullivan,

Managing Director,

VoTiV Systems, LLC

Engineering Facility

20140 Scholar Drive

Suite 210

Hagerstown, MD 21742

US Voice: 301 766-7150

US FAX: 301 766-7151

Headquarters

PO BOX 705

983 Tiffany Rd.

Harpers Ferry, WV 25425

e-mail: sully@votiv.com

web: http://www.votiv.com

Comments on the Enhancement of the .us Domain Space

Submitted by: VoTiV Systems LLC

Submitted to: usdomain@ntia.doc.gov.

To be posted at: http://www.ntia.doc.gov

Introduction:

US is the ISO-3166 2-letter country code for the United States and therefore the US domain is established as a top-level domain and registered with the InterNIC in the same way as are other country domains. We propose that new affinity domains under the US domain should function under the auspices of a new organization called the US Affinity Domain Name Association (USADNA).

This proposal recommends putting the United States top-level Internet domain (.us) on a more stable financial, legal, and structural footing by creating new second-level "affinity" domains under .us which correspond to recommended usage.

Comments are numbered and organized in response to the questions set forth in the Request For Comments on the Enhancement of the .us Domain Space.

Answers to Questions for Public Comment

1. 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?

The current geographic structure should remain unchanged. This domain name space is in use, and has proven to be very useful for local governments, municipalities, and other organizations associated with particular geographic entities.

We recommend creating a new structure, the US Affinity Domain Name Association (USADNA), to administer these new second-level domains. This structure would operate and exist in parallel with the locality-based domain structure now in use within the .us domain. The affinity domains and the locality-based domains would not inter-operate, but the .us domain administrator - currently the US Domain Registry at the Information Sciences Institute of the University of Southern California (ISI), under the authority of the Internet Assigned Numbers Authority (IANA) - would participate in the operation of the USADNA.

An integral part of the USADNA is a fair and equitable registration system, using a shared-registry model in which Registrars will compete in a free market based on their prices and services. This will provide for the financial health and stability of the Registrars receiving domain name registration requests from prospective domain name holders. Finally, we propose a legally authoritative and robust registration process and dispute resolution policy that will relieve the .us domain of many legal and administrative problems stemming from disputed intellectual property and trademark rights.

The USADNA would hold a physical annual meeting of all Members, at which time elections would be held to fill the currently expiring terms on the Board of Directors. The meeting would also be used to take care of any business the Board of Directors feels requires the attention of the entire membership and for Members to publicly bring up any issues to the Board of Directors.

The USADNA Board of Directors may promulgate formal by-laws based on this proposal and/or other models, such as the by-laws of the Internet Society (ISOC).

The USADNA will consist of four main bodies:

The Members, who join by paying a membership fee, and have the right thereby to register and modify domain names

The Board of Directors, six of eight of whom are elected by the membership

The Council of Advisors, who are appointed by the Board of Directors

The USADNA staff

The USADNA Board of Directors:

The USADNA Board of Directors will consist of eight persons, six of whom will be elected by the Membership of the USADNA. The other two are ex-officio.

The Members of the USADNA will vote elected Directors as follows:

Any Member of the USADNA may nominate a person as a candidate for the Board of Directors.

Elected Directors will serve for a term of two years, except during the initial term, when three of the directors will serve for three years, in order to stagger the terms so that after the first two years, three directors would be elected each year.

All USADNA Members in good standing at the time of elections may vote for three directors from the list of nominees during each election (except during the first election, when six candidates will stand, with the top three vote recipients receiving the initial three year term).

Ex-officio Directors are two: the Managing Director and the Director of the US domain. They will appoint and charged as follows:

The Managing Director will be appointed by the Board of Directors, and will serve at the pleasure of the Board of Directors. The Managing Director will run the day-to-day affairs of the USADNA.

The Board of Directors will hold quarterly meetings, at which the Managing Director will brief the other Board members about USADNA business. Meetings may be held in person or through alternative media if all Board members agree. The Board of Directors will meet physically at least once a year. Any Board member may call an emergency meeting. A quorum consists of two-thirds, or six, members of the Board of Directors.

Each member of the Board of Directors shall have one vote. Decisions will be made when five members of the Board of Directors vote together.

All members of the Board of Directors are unpaid, except the Managing Director, who receives a salary, the amount to be determined by the Board of Directors. Certain administrative expenses incurred by members of the Board of Directors may be reimbursed, according to a policy to be announced publicly by the Managing Director.

The Board of Directors can create committees, composed of qualified individuals, to work on specific areas of interest to the USADNA (e.g., technical or legal issues). The committees report to the Board of Directors, which implements or ignores the suggestions.

The USADNA Council of Advisors:

The USADNA Council of Advisors will consist of twelve (12) members appointed by the Board of Directors for a term of one year.

The members of the Council of Advisors are to be drawn from the ranks of leaders of many different groups, including business (Internet and non-Internet), ISPs, public policy groups, the United States Government, and other groups. Care should be taken by the Board of Directors to select members from a good cross-section of both the public and private sectors.

The purpose of the Council of Advisors is to make recommendations and suggestions to the Board of Directors in the operation of the USADNA and the management of the US Domain.

Members of the Council of Advisors are unpaid. Certain administrative expenses incurred by members of the Council of Advisors may be reimbursed, according to a policy to be announced publicly by the Managing Director.

The USADNA Staff:

USADNA employees, who would number about ten, operate the USADNA. The exact number of employees and skill sets required to manage and run the operations of the USADNA will be determined by the Managing Director in consultation with the Board of Directors, except that the Managing Director shall appoint a Technical Director.

The Managing Director is at once a member of the USADNA staff and a member of the Board of Directors.

Relationship between the USADNA and USADNA Members

Members of the USADNA can act as agents for the USADNA for purposes of registering a new domain name, for modifying a domain name, or for renewing a domain name. Upon joining the USADNA, Members will be issued a PGP key that will verify and authenticate all transactions between Members and the USADNA.

Relationship between domain name holders and USADNA

Persons or organizations holding a domain name in the US Domain have a contractual relationship with the USADNA with regard only to the registration and modification of their domain name(s), and certain matters relating to intellectual property disputes. The USADNA is not responsible, nor does it have any say, in the relationship between a domain name holder and a USADNA member. Specifically, the USADNA is not responsible for billing, technical services, or customer service issues.

Modifying a domain name

A Member of the USADNA must process modifications. The USADNA staff will not modify a domain name directly. Modifications can include changes of contact information, or re-delegation of name servers. Transferring a domain name from one holder to another is considered a transfer, not a modification, and is subject to a separate process.

(1) The domain name holder notifies a Member that he or she wishes to make a modification to his or her domain name. The Member may be either the original applying Member or a different Member.

(2) The domain name holder may choose to supply, or may already have supplied, his or her digital key to the Member.

(3) If the Member is in possession of the domain name holder's digital key, the Member requests a modification of the domain name from the USADNA and signs the request with both the Member's digital key and the domain name holder's digital key. If the request is valid, the USADNA makes the change to the US Domain database.

(4) If the Member is not in possession of the domain name holder's digital key, the Member requests a modification of the domain name from the USADNA and signs the request with the Member's key only. The USADNA then notifies the domain name holder that a request for modification has been made, and the domain name holder must acknowledge and affirm that he or she desires that the modification be made, and must sign the acknowledgment with his or her digital key. If the USADNA receives the proper acknowledgment, it makes the change to the US Domain database.

Renewing a domain name

Renewal of a domain name is an essential activity. The renewal process ensures that the domain objects stored in the US domain database are current. Domains must be renewed every twelve months. Renewals must be completed through a Member.

Two months before a renewal for a domain name is required, the USADNA will send out a notification to both the domain name holder and to the Member who made the latest modification to the domain name, stating that the domain must be renewed. The USADNA will send out a second notification one month before the renewal is due.

The domain name holder who wishes to renew his or her domain name must contact any Member. Domain name holders who do not wish to renew are not required to do anything.

The Member processes the renewal by sending in a renewal request and paying the required fee to the USADNA. The Member is responsible for billing the domain name holder for its services.

If the renewal request is received on time, the USADNA updates the US Domain database and sets the subsequent renewal date at a year from the current renewal date.

If no renewal request is received from a Member before the expiration date for renewal, the domain name holder and the Member who made the latest modification to the domain name receive a final notice. This final notice should be made by postal mail as well as by electronic mail. If a renewal request is not received from a Member within thirty days of this final notice, the domain name is deleted from the US Domain database.

Transferring a domain name

Transferring a domain means changing the domain name holder. In another sense, it means changing the power to make modifications to the domain name. The transfer of a domain is the only transaction where the domain name holder communicates directly with the USADNA.

To transfer a domain, the domain name holder signs the reverse side of the security certificate issued when the domain name was first registered, after filling in the information about the new domain name holder.

The domain name holder sends the signed security certificate to the USADNA (traceable courier is advised).

Upon receipt of the certificate, the USADNA checks the signature on the certificate against that on the certificate the domain names holder signed when the domain name was last assigned.

If the signatures match, the USADNA sends out a new contract to the prospective new domain name holder, and upon receipt of the new contract sends a new certificate to the new domain holder, along with a new digital key. If no contract is received from the prospective new domain name holder, the domain name is not transferred.

If the signatures do not match, the USADNA returns the certificate to the domain name holder, along with instructions on how to obtain a new certificate. In this case, the domain name is not transferred.

Location and Maintenance of the US Domain repository

The DNS database name servers which are the repository of information that make up the domain database will operated and maintained as part of the USADNA registry by USADNA staff under the supervision of the Technical Director.

Determination and implementation of technical policy

The Board of Directors shall determine technical policy, with input from the Board of Advisors. Technical policy shall be implemented the Technical Director, who shall have day-to-day responsibility for technical administration. Committees appointed by the Board of Directors will consider technical policy issues, and their recommendations will be implemented at the will of the Board of Directors.

Construction of USADNA repository

The construction of the USADNA repository shall be contracted out to vendors through tenders offered by USADNA. Vendors can be paid either by a per-transaction percentage over a pre-determined period or on a fixed-cost basis. There are few organizations that can provide such a service. The USPS has offered to provide such services, and may well be positioned to provide these services.

2. 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?

We believe that the addition of new domains, administered in an equitable and accessible fashion, will encourage domain users within the United States to register domain names within the .us name space. This will increase the popularity and viability of the .us domain by creating affinity second-level domains in parallel to the existing structure. Affinity domains have domain names that correspond to the intended use of the domain or the activity of the registrant. Familiar affinity domains now in use would include .com (intended for commercial entities) and .net (intended for Internet networks). The affinity domains would provide financial stability for both registrars and the .us domain administrator by generating a solid revenue stream to support the entire .us domain infrastructure.

The USADNA would create a competitive registrar infrastructure, which will foster the survival of registrars who provide the highest level of customer service at the lowest cost. The USADNA would create an administrative structure for the new affinity domains so that it functions as a representative membership organization such that registrars, administrators and outside advisors can work together as a collective entity to make modifications and corrections to keep the .us domain secure and viable. The USADNA would allow for a large number of registrars, and thereby a greater revenue stream and consumer choice, by establishing low membership fees and by providing guidelines and operating procedures that require only limited technical knowledge on the part of registrars. The USADNA would allow customers to provide name servers of their choice instead of having to rely on registrars for these services. Registrars should not be required to administer name servers.

Domain names should be assigned on a strict first-come, first-served basis. There should be no limitation on the number of domain names assigned to a person or organization.

Any person, organization, company, or group can hold a domain name. There shall be no restriction on the geographical provenance of a domain name applicant. The domain name applicant must provide an U.S. address for US Courts' Jurisdiction.

All domain name holders shall have at least two functioning name servers prior to applying for the registration of a domain name. All applications shall have the name servers verified for functionality prior to acceptance of the applications. Any non-functioning name servers shall result in a denial of application.

All information in the US Domain database will be publicly and freely accessible, both through a searching tool such as whois, and possibly as one file, available via ftp or other transfer protocol.

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?

We recommend the creation of new functional second-level domains, under which domain name holders can register directly, as follows.

.TRADE.US (or .MARKET.US) for entities providing goods or services

.ISP.US (or .TECH.US) for organizations providing technical services

.NEWS.US, for organizations disseminating information

.ASSOC.US for not-for-profit organizations and unincorporated entities

.NAME.US for individuals

.EVENT.US for short-lived events (for example, movies and conferences)

Registration applications should not be checked for their suitability for a given second-level domain. Because of the complexity and lack of standards upon which to determine a registrant's suitability to register a name in any particular category, as well as the bureaucracy and legal liability such an attempted predetermination would engender, we believe that a first-come, first-served policy should be applied to all domain name registration applications. Any attempt to check or otherwise police applications would hamstring efficient operation of the USADNA and lead to delays and discontent among domain name holders.

It would also be a mistake to try to encumber the .us domain space by specific applications. The domain name system is not a directory service application or a catalog service application. It's only purpose is to provide a convenient human readable and memorable description for IP addresses.

4. 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?

There should be a restriction of names to second-level domains. .co.us is already a designation for the state of Colorado, and .com.us would be too confusing. The .us affinity domains should avoid the use of common top-level domain names when possible. Other second-level domains may also be added as the need occurs, at the discretion of the managers and members of the US domain. We recommend that all new domains be four or five letters to eliminate confusion with current top-level domains. It is not recommended that existing top-level domains be "folded in" to the new second-level domains.

While some countries allow registration of names at the second level, because of the size of the US market, this would not be prudent for the US domain. By limiting registration under the second level affinity domains, the risk of running out of "good and useful" names can be avoided as additional second level affinity domains can be added as necessary.

The unrestricted second level domain names should be administered by USADNA.

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?

Where parties disagree about who has the "right" to use a domain name, the USADNA should offer mediation and arbitration services, but should not unilaterally decide on who should get the domain. The USADNA would be well served to steer clear of direct involvement in disputes. Nonetheless, the USADNA cannot expect to escape disputes entirely. A well-explained and swift online arbitration procedure can help solve the majority of disputes; where an agreement between the parties is not possible; the courts will have to decide.

The USADNA, as a first step in any dispute, should offer the parties the service of professional mediators. Mediation is not mandatory, nor is it binding. The cost of mediation will be borne by the challenger to discourage frivolous claims.

The USADNA will offer arbitration through a widely accepted arbitration service, to be offered online via its web site. The arbitration shall not be mandatory, but it shall be binding if accepted. The cost of the arbitration should be borne by the challenger to discourage frivolous claims.

USADNA will take no action to transfer or otherwise modify a disputed domain name, except as requested by the domain name holder, until ordered to do so by a U.S. court or upon agreement by parties involved.

Prospective domain name holders will register a domain through a Member of the USADNA. Members are agents only; the contract governing the use of the domain name is between the USADNA and the domain name holders. Paper certificates, signed by the domain name holder, will constitute a contract between the domain name holder and the USADNA. The paper certificate will complement digital authentication in order to establish the identity of the domain name holder and the authenticity of the request, as well as the authority to perform any modifications to the registration. The domain name holder will be issued a digital key that will be required for any modification or transfer of the domain name.

To register a new domain name, the prospective domain name holder must contact a Member. If a prospective domain name holder contacts the USADNA directly, he or she will be referred to a full list of Members.

Members will explain the registration procedure to prospective domain name holders and process applications on behalf of the domain name holder.

Members will submit registration applications to an automaton operated by the USADNA staff that 'knows' the rules of the USADNA and processes applications.

Applications that generate no errors are registered and delegated immediately. The domain name holder can begin using the domain name right away, but the registration is not complete until a contract is signed and sent to the USADNA and a paper certificate and a digital key are issued to the domain name holder.

Applications that generate known errors (e.g., incomplete applications, or applications for names that are already assigned) are returned to the Member with an appropriate error message.

Applications that generate unknown errors are processed manually by USADNA staff.

Upon receipt of a successful application, the USADNA delegates the domain to its name servers and notifies the applying Member that the application was successful.

The applying Members supplies to the domain name holder the current USADNA contract.

The domain name holder signs the contract and sends it by postal mail or courier to the USADNA staff. The contract can specify whatever the Board of Directors feel is appropriate. Possible provisions might include:

Indemnifying the USADNA and its individual members in case of a dispute concerning intellectual property.

An undertaking to use mediation or arbitration services in the event of a dispute

The power of the USADNA to amend the contract unilaterally upon sufficient notice.

If the contract is received within the time allotted (e.g., two weeks), the USADNA issues to the domain name holder, by postal mail or courier, a security-printed certificate which is constituted as follows:

On one side, the domain name, along with associated information (e.g., listed domain holder, admin and tech contacts, and name servers) is listed.

Also printed on side one of the certificate is a digital key that must be used to complete all further transactions with the USADNA.

On the reverse side is a fill-out form to be used when the domain name holder wishes to transfer the domain to a different party.

The receipt of the signed contract and the subsequent issuance of the security certificate establishes the legal relationship between the domain name holder and the USADNA and ensures that the correct information is entered into the US Domain database

If the contract is not received by the USADNA within the time allotted, the USADNA notifies both the applying Member and the domain name holder. If the contract is not received within an additional time period (e.g., another two weeks), the delegation of the domain name in question is deleted. The applying Member may choose to refund monies to the domain name holder, but the USADNA will not refund any monies or issue a credit to the applying Member.

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?

A benefit to the USADNA of the paper-based contract will be to enable the USADNA to require of domain name holders indemnification of the USADNA and its Members individually against all intellectual property disputes. The contract can require domain name holders to affirm that they are not violating any trademark laws by using a given domain name. (See #5 above for more details)

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?

States should have than the right to register domain names under the appropriate locality subdomains. Commercial names should not be permitted under states as third-level domains. That should be reserved for the cities as currently delegated. No special categories of third level domains in the locality domain should exist. Most municipalities do not have the technical resources to operate registries and accept registrations. State policies should not be imposed upon .us. since coordinating all the different policies that might exist would be costly and difficult.

8. 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?

The .us top-level domain, the national domain of the United States of America, has not gained wide acceptance from Internet users within the U.S., thereby threatening the future of the .us domain as well as putting pressure on generic top-level domains. Under the present system, costs already significantly outpace revenues, resulting in poor and sometimes non-existent service. Erosion of already limited customer base will continue to drive costs up and revenues down.

The proposal outlined in this response aims to put the .us domain on a more stable financial, legal, and structural footing by augmenting and amending both the infrastructure and the registration process. It also offers benefits enjoyed by having US court jurisdiction. The goal is to make the .us domain a viable and sound entity. We propose to accomplish this by establishing the USDNA.

Requiring registrars to be accountable to their delegated localities would create a web of bureaucracy that only a national government could control.

Limiting a registrar to a single jurisdiction would make it economically infeasible for registrars to service small rural communities.

Allowing multiple competing registrars to register under any local, state, or special-purpose domain under .us as in the plan that is proposed for generic Top-Level Domains would introduce healthy competition. But it should be done under the proposed USADNA organization.

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?

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USADNA Members would pay a one-time initiation fee upon joining the USADNA to cover the administrative costs of adding the member to the USADNA. The Board of Directors would determine the fee.

USDNA Members would pay an annual membership fee to the USADNA. The fee would be determined by the USADNA Board of Directors and would be based on a cost-recovery basis.

USADNA Members, and only USDNA Members, would be able to register domain names or make modifications to domain names under the new second-level domains.

USDNA Members would pay a per-transaction fee to the USADNA for adding to or modifying the US Domain database. The fee would be set by the Board of Directors, and would be determined on a cost-recovery basis. (Note: at the discretion of the Board of Directors, some transactions may have a cost of $0 - e.g., updating contact information).

USDNA Members would pay for transactions in advance by purchasing subscription blocks, which would be decrement as the Member makes chargeable transactions. The blocks would be non-refundable, and discounted by volume. The minimum subscription block size would be good for the addition of 20 domains to the database, and each Member must purchase at least one block per year to maintain membership. Members may purchase additional blocks, with larger volume blocks receiving discounts. The size of the discount would be based on reduced administrative overhead when selling a single large block rather than several smaller blocks. Members would be expected to pay for blocks at time of purchase, either via credit card or pre-paid account. The Board of Advisors may decide to allow large volume Members to pay via purchase order on a monthly basis to reduce administrative costs.

The subscription block model assures immediate and steady revenue and would preserve an active membership. The subscription-block model would eliminate the large backlog of unpaid fees that other country domains (.uk, .mx) are now coping with.

10. What are best management and allocation practices for country-code domains? What practices should be emulated or avoided?

Administrators of other top-level country domains have successfully moved to a shared-registry system using second-level domains. Our proposal borrows and expands upon ideas from several of these systems, particularly from Nominet, the administrator of the United Kingdom's domain, and from the NIC-México in Mexico. Since implementing its shared-registry system using second-level domains, both the .uk and .mx domains have seen phenomenal growth in registrations. Falling costs, much-improved service, and wide acclamation have accompanied this growth. These systems provide an excellent indication that the ideas and concepts we are introducing will prove successful when implemented in the .us domain.

However, the practice of allowing registrars to register domain names before the registrations are paid for should be avoided. Thus the subscription-block model would eliminate the large backlog of unpaid fees that other country domains are now coping with.

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?

The USADNA would be created as a not-for-profit membership organization. The USADNA shall operate on a not-for-profit, cost-recovery basis. Any excess funds should be devoted to reducing the cost of domain registration to Members, paying for administrative costs, and to provide funding to cover outstanding obligations of the US domain authority, as determined by the Board of Directors of the USADNA.

The chain of authority goes from the USDNA to the US government. The USDNA can only exist under the authority of the US government. That means that there needs to be some contract between the US government and the USDNA as to what other "outstanding obligations" of the US domain the USDNA will be responsible for.

Here are some possible scenarios:

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- The US government grants the USDNA permission to run a registry and register names under the second level affinity domains specified in a contract with the USG. In return, the USDNA pays either a fixed fee or a cut on registrations (or a combination of both) to support the other US domain activities (such as the locality domains or any of the proposed domain structures being set up by the USPS).

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- In addition to the affinity domains, the USG requires the USDNA to operate the locality domains as a part of its registry. In return the USDNA has to pay less fees to the USG since they are running the locality domains for them.

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- There may be some language in the contract that if the USDNA meets certain performance criteria, the USG will approve the addition of more affinity domains for the USDNA to register domains under.

Basically, this means that the USDNA is not handed the entire US domain on a platter. They are given some the autonomy to control the affinity domains and run them under their charter, but the USG still controls the overall US domain. This provides a way for the USG to let entities such as the USPS to use the US domain as well, but does not tie the USDNA to any one controlling authority other than the USG.

Acknowledgements:

The genesis of most of what is found in these comments can be attributed to:

Proposal to Augment the Administration of the .US Name Space, By Antony Van Couvering and Alan Sullivan, Draft October 6, 1997