From: Chris Steele <email@example.com>
Date: 8/19/98 7:07pm
Subject: Re: ACTION: Notice, Request 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?
You already have a system that works, why break it? The whole purpose of the
US Domain was to get geographical diversity. What you are implying is opening
.us TLD so that every company that has registered a .com will also register
a .us. Is this really desireable?
You repeatedly state that you are looking to open the US Domain up for
commercial use, however you fail to miss, that it already is. A company can
register their name as 'MyCompany.gen.XX.US' as you can read in RFC 1480.
By opening up the US Domain, you are suddenly creating a need for every
entity on the internet to have TWO registered domains, the one that is
registered in .COM and now the one in .US as well, whatever the structure
you may come up with.
Is this really what you are striving for? Name diversity in .com should not
be a problem unless companies have the same name, at which point they should
consider registering in something more geographical and local to their area.
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?
As the US Domain stands now, in assigning a state agency the state code they
represent, it would eliminate the need for an entity not familiar with
the state in question to have to control registering within that state.
It would reduce the time/manpower/costs that are needed to keep up with
requests that currently come in to the US Domain registry (ISI). There does
need to be restrictions on who can get a second level domain (under the current
layout) to assure that it does not fall into the wrong hands.
Requirements to consider for delegation of the state to an entity could
include the following:
The state manager must also have the proper authorization by the state
government to perform this role. [We don't want there to be any
fights about who should be the state manager, there must be a
preauthorization step where someone (the state governor ?) designates
who the state manager should be.]
Set up and operation of the primary name server for the state code.
Set up and operate a "rwhois" server for all third level delegations
under the state code
Set up and operate an email mailbox to receive and process requests
for registrations under the state code. This includes provisions
for forwarding requests for fourth level names to the delegated
third level managers.
Set up and maintain a web page with information about the state code
and registration procedures, policies, and processes.
Now, if you are going to totally restructure the US Domain, as your request
implies you are trying to do, you will only need another entity like Network
Solutions to maintain the new domains you create, just as the .com, .org,
and .edu domains are maintained. But like I said, is that what you really
want to happen? I don't think so.
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?
No, they should not. If they are, they should be created carefully and with
discretion, you don't want to overpopulate the US Domain. The current structure
serves its purpose well. You can easily tell where an entity is by its name.
If you are unable to type 'YourCompanyName.<locality>.<State>.US' then register
in the already existing .COM. DNS was created so humans could enter in a
unique _name_ to reach any given machine. Now, people are realizing somewhat
of a limit to the names available, but are not willing to accept longer names,
which alleviates the problem immediately in the first place.
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?
Well, you can NOT use .co.us as that would be the domain used by the state of
Colorado in the current structure, unless you were going to completely dismantle
the current structure of the domain. Opening up .us to anyone and everyone
will only lead to the same results you have right now with .com, except every
domain registered will now have a '.us' on the end of it. This makes that
decision pretty pointless. As for how they should be administered, efficiently
and timely? A request should not take more than a day or two. By who? Not
Network Solutions, but presumably some company with a very similar role.
Again, all you will have accomplished is creating another place for every
company registered in .com to need to register.
For example, Microsoft.com would now also be Microsoft.com.us. Would this
change accomplish additional name diversity? Not really, just double the
amount of in-use domains.
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?
The IANA is the authority over all top level domains. Once a domain is assigned
to an entity, it would seem to belong to them. If beyond that, it goes to
court over who has the rights for it, that is the lawyer's problems, not the
administrators of the domain(s) in question. Long term, it should probably
remain with ISI unless IANA has another entity that it feels should be
responsible for the US Domain.
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?
No 'special' privledges should be granted. No favorites should be played.
All rules should be fair and apply to everyone at all levels. If you really
feel it necessary to assign someone the task of checking every domain that
gets registered with the trademarks registered throughout the world, then
you can check them when registered. Seems a bit extensive and tedious.
Most conflicts would be resolved rather easily, as they are now, with the
few exceptions that go to court. If an entity begins to register a series
of domains that do not get used, (mostly for the purpose of /selling/ them
to the company that is trademarked with that name) then the top level
authority should have the right to remove delegation of those domains
at their discretion.
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?
A state agency should be granted the ability to administer their own state's
domain. Commercial names should still register under the appropriate
third-level domains as they do now. Perhaps the addition of a .com.XX.US
would be an added option? But then again, that is what .gen.XX.US is for.
All state agencies that maintain a second level US Domain should have to
agree to meet certain requirements and adhear to certain rules before they
are delegated their domain. Furthermore, any violation of these rules and
requirements could lead to removal of delegation. But each state, as available,
should be allowed to get the appropriate state level domain registered to
its own government for purpose of maintaining it locally.
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
The current method works fairly well, however the restrictions of 50 domains
per state is a bit tight. Some states have entities that could/should be
permitted to register more domains than 50 (for example, a state agency).
A very good improvement would be the delegation of the entire state domain
to the appropriate agency, which would reduce the need to remove the
restriction of the 50 domains. Registrars should be restricted to where
they can register based on their localtion. A company in Maine should really
have no reason to register a domain in California, especially at the third
level for jursdictional domains.
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?
A fee should be instituted for registry to aide in the funding, but it should
be a one time fee, as once the entry is there, it does rarely requires further
intervention. If a yearly fee were instituted, some billing arrangements would
need to be made, especially in the case of state delegations. Registrars
would already be contributing to the operation of the registry simply by
registering to administer a second or third level domain and paying any fees
that were instilled upon them.
10.What are best management and allocation practices for country-code domains?
What practices should be emulated or avoided?
Human intervention. Do not automate the process. If you have a staff reading
all registrations, you can pretty much ensure that no entity will horde any
series of domains that may have some future monetary value for that entity.
Most disputes in the US Domain seem to happen because people don't take the
time to explain things. If you delegate the second/third level domains to
parties who are responsible and understand how to maintain DNS properly,
you can avoid most disputes.
Also, lay down some governing policies and requirements for a registering
entity to follow, so there is some sort of guidelines to start 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?
Preferabbly, by a not-for-profit, government funded agency, since this is
.US we are talking about. Giving it to a for-profit, non-government agency
will only lead to conflict, complaint, and unfairness. By holding it under
government agencies, you can have a better control on the policies that
are in place for the domain.
CC: Chris Steele <firstname.lastname@example.org>