From: "Al Costanzo" <al@akc.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 5:41am

Subject: NTIA-OIA Us doamin extensions

Dear Karen,

In regard to you're your solicitation for comments, I would like to make some general observations as well. I have been delegated a region in the US domain.

1. The present structure could be enhanced in many ways without breaking the existing structure. One such way would be the allowance of abbreviations in city names.

Currently "Los Angeles" could not be defined as "la.ca.us" for example causing many NOT to use the US domain....

Special care needs to be taken or modifications to this domain will cause existing entities to feel the need to leave the us domain and be placed in another.

I have already been faced with this dilemma. Municipal governments for one, are currently excluded from the top-level ".gov" domain. Modification to the US domain in any form other than what I have just mention above will generate new interest in requests to modify the .gov domain to allow state and municipal government entries into it. Furthermore, I would be in favor of such a modification if the US domain structure is modified in any way.

The .gov domain could be enhanced for state governments as well as municipal ones. This change should be made BEFORE decisions are made to modify the us domain.

Furthermore, certain unscrupulous entities have gobbled up large regions of the US domain and will not allow you to registered in there delegated zone without also 'using' some of their services.

For the most part, they normally force someone to host a web site with them to be registered in their delegated area. This surely will need to be addressed as well. Currently, this causes many to register outside the .us domain. I have examples but for brevity, I have omitted them.

The next portion of my proposed extension to this domain are outlined in response to the second question.

2. Second level domains should not be extended in ANY FASHION. They should ALWAYS remain the state abbreviation. Good reasoning for this is explained in response to your questions

four and seven.

4. The second level domains must not be altered in any way. The United States is composed

separate states who have the authority to regulate commerce within their own

jurisdiction.

With this jurisdiction they are allowed to authorize Certificates of Incorporation and statewide

trademark certificates. Please note, that a state registered trademark is only valid within the

registered state that it was issued, unlike a federal trademark which covers the entire country.

To alleviate naming conflicts for state corporations, corporations that do business in only in one

state, it would be extremely wise to extend the us domain in the following fashion.

SomeCompanyName.COM.SomeState.US. This would alleviate trademark as well as name

conflicts. A large amount of companies only do business in their residing state.

6. This issue is extremely important to us as a company. We have a registered trademark. It is the lettering AKC. We feel that Federally or State registered or trademarks that are intended to be registered (it is a 13 month process) should not be allowed to be registered as a domain name by anyone except the holder of the right.

If you do not implement this rule, we for example would have to register "akc" in every domain

that will open to protect our trademark's exclusivity. We find this burdensome. A mechanism will need to be introduced to protect trademarks from being introduced as domain names.

7. We have previously addressed this but to summarize again we feel that the third level should be ".com" example: "com.nj.us". A complete example of how we would register our

web site using this example: "www.akc.com.nj.us" I would strongly be opposed to modifying

the structure in any other way.

In effect, what I am suggesting is three new third level domains (.com .net & .org) which will match the current top level structure.

The top level domains would now be for those that do business in more than one state, on a national or international basis. This would relieve the name space pressure greatly.

9. Any cost involved would need to be phased in over a period of time, furthermore existing

domains should be grandfathered in to their current cost structure for an extended period of time.

Thank You for the opportunity to comment.

al@akc.com

Al Costanzo

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From: "Al Costanzo" <al@akc.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 9:31am

Subject: Re: NTIA-OIA Us domain extensions

Dear Karen,

In regard to you're your solicitation for comments, I would like to make one additional comment taht I negleted to mention.

1. I attended an Internet Engineering Task Force meeting in 1993 in which one of the topics of discussions was the US domain. If memory servers me, the RFC on the topic of the US domain was either to be released or just released.

The issue is individuals registering in the US domain. One of the main features of this domain space was the ability for an individual user who had no ties to an organization or company, who wanted to register a domain could, for their individual use, and their computer systems, furthermore there was to be NO charge for this service.

This seemed like an excellent idea then and it remains an excellent idea now. Since there were no ties to organizations, a geo structure was used.

I would strongly oppose an attempt to change this process for individuals in any form. I am sure the authors of the original RFC put great thought and diligence into the formulation of the process involved.

I would also oppose a formal registration fee for individuals.

I would hate to see the process damaged when in all actuality a new top level domain could be created.

-Al

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From: Felix Finch <flx@uniplex.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 3:45pm

Subject: What a silly idea!

One of the benefits of email is that it is geographically independent. Now you propose to tie these email addresses to a geographic location. So I move. Then what? Forwarding forms to fill out? I think not. You could go ahead and assign it to me, but I will never read it.

Who thought up this nonsense? Fire the losers. Save me some tax money.

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Date: Fri, 21 Aug 1998 15:42:03 -0400

From: Larry Smith <lcs@zk3.dec.com>

To: usdomain@ntia.doc.gov

Subject: Response to .us domain plan

Dear Sirs,

I do not believe the United States Postal Service has so distinguished itself as to deserve to be handed yet another monopoly. Nor do I feel it is necessary that every US citizen must have an "official" email address. Nor do I believe that this plan sufficiently addressed the problem of spam - that is, unsolicited commercial email. Nor do I believe that this plan can do so until commercial spam is made illegal. In short, this plan is a typical government boondoggle, a waste of taxpayer funds, and a naked power grab by an agency with a miserable track record in customer service. It is completely unacceptable.

Cordially,

Lawrence C. Smith

297 Charles Bancroft Hwy

Litchfield, NH 03052

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From: "Craig P. Lewis" <lewiscr@cig.mot.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 3:58pm

Subject: .us domain expansion

I beleive the .us domain should be expanded to include all US address. It will bring a large amount of chaos for a while, and there will be a long transition period, but things will be simpler in the long run.

--

Craig Lewis LewisCR@Cig.Mot.Com

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From: Rob Hagopian <Rob.Hagopian@vuser.vu.union.edu>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 11:32pm

Subject: Comments

The .us domain should NOT be used for anything that is not region specific. Creating a .com.us or .co.us would be a significant detriment to the encouragement of global commerce by segragating US companies. Creating a hierarchy, in addition to or an extension of the existing structure, to allow people to have regional domain names for residential housing would be good though!

-Rob H.

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From: William Aoki <waoki@raven.umnh.utah.edu>

To: NTIA.NTIAHQ(usdomain)

Date: 8/21/98 6:15pm

Subject: comment on .us domain space

1. I belive that the present geographic structure should be retained for entities that are specific to a locality; for example, state government. However, a geographic structure for anything else (e.g. non-location-specific companies and private citizens) defeats the location-independent nature of the internet.

2. As mentioned in RFC1480, any scheme that results in large second-level domains becomes difficult to manage. A single nonprofit entity (with government and public oversight) should delegate administration of second-level domains to sections of itself or external non-profit oganizations.

3. Special-purpose second-level domains make sense; they would cut the namespace into manageble chunks, and would be `nicer' to the end-user; the end-user would know what an entity does simply by looking at its domainname. Mapping physical addressing and identification systems

into .us is an EXTREMELY poor idea except for location-specific entities such as local government or local clubs, and even then the granularity should permit changing location within a single city without a change in domanniame. For anything else, it would mean that whenever the owner of a domanname moved, he/she/it would need to obtain another one and inform everyone of the change. Changing a phone number or mailing address is enough trouble as it is. I belive that private citizens and companies alike would benifit from having the same domainname wherever they move to. With a location-dependent system I would have to inform everyone who knows my previous address of my new address even if I only move down the block; with a location-independent system I would be able to keep the same electronic addresses no matter where in the world I move, as long as I remain a US citizen.

4 An unrestricted second-level domain (such as .com.us or .unr.us) should exist, but use of other, more specific second-level domains should be encouraged. The unrestricted subdomain should be administrated just like any other .us subdomain.

5. A single nonprofit organization should assign the responsibility to manage .us subdomains. Public oversight must be provided; without public oversight there is no way to ensure quality of service.

6. Trademark holders should have the right to prevent registration of their trademark in subdomains that cover the field that their trademark applies to. No special privledges should be granted to famous trademarks. Under no circumstances should a trademark holder be able to remove or take control of a domainname that conflicts with their trademark if the subdomain was registered before the trademark holder moved to prevent registration of their trademark, if it is in a subdomain that does not cover the field the trademark applies to, or if it is in the unrestricted subdomain.

7. Each state should decide if it wishes to allow commercial third-level domains, and establish the apropriate policies and procedures. However, they should honor any existing commercial third-level domains.

8. Competing registrars ensures that quality of service remains high and prices remain affordable.

9. The .us domain should be available to any United States citizen or company based in the United States. Therefore, fees, if instituted, must remain affordable. InterNIC's fees for .com and .org are NOT always affordable to private citizens. If needed, a fee waiver could be offered (similar to that seen in the public schools), but even without a fee waiver the cost of a domainname in .us must remain low.

10. The best management and allocation practices for national TLDs allow any entitiy based in that country to obtain a domainname affordably. Location-based allocation for anything other than local

entities, such as city and state government, should be avoided at all costs. As I recall, the United States is the only country using location-based allocation. That no other country does this should be evidence enough that it is a bad idea.

11. .us should be administered by a governemntal or quasi-governmental non-profit entity. Anything other than a non-profit entity may have motives other than the public good. As .us was assigned to the United States, the agency responsible for assigning domainnames under .us to the public should be governmental or have governmental oversight. Think of it as the highway system; the governement maintains the highway system for anyone to drive on. The highways aren't being maintained for profit, but for the public good; and the .us namespace shouldn't be maintained any differently.

I want to reiterate that .us namespace should not be linked to location, and should be affordable, if not free, to any US citizen or any other entity based in the US. I considered obtaining a domainname under .us, but decided against it because it is linked to physical location, and I considered obtaining a domainname under .com, but rejected it because I can't presently afford InterNIC's fees. I belive that without a location-dependent naming system many more companies would be attracted to registering in .us, and that low or nonexistant fees would enable more private citizens to obtain namespace.

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