From: Alex Kamantauskas <alexk@tugger.net>

To: NTIA.NTIAHQ(usdomain)

Date: 9/30/98 12:56pm

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

A few thoughts about the .US domain:

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?

It is my belief that the present geographic system (ie. STATE.MD.US, NY.US, etc) should remain the same. I also feel that certain SLD's should be introduced into the .US domain.

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?

I believe that the primary benefit of allowing US companies and organizations to register domain name under the .US domain is that the companies would have to abide by US trademark legislation.

I have no opinion at this time about the allocation and delegation of these SLD's.

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?

I feel that the .US domain should be divided into two segments: the first segment is its traditional geographic hierarchy, to be used by local governments and educational institutions, as well as the others who currently use it. The second segment would be a mirror of the gTLD's,

currently offered by NSI, Inc., but only available to citizens, corporations and organizations of the United States. Thus, I would personally like to see ".COM.US" for companies (and only 'for-profit' companies), ".ORG.US" (for only 'non-profit' organizations), ".NET.US" (to be only used by entities providing network connectivity), and ".EDU.US" (to be used by *any* educational institute in the US). I feel that the current government hierarchy handled by .US and .GOV are sufficient, thus no creation of the ".GOV.US" would be necessary.

There should also be a fair process to create new gSLD's in the .US zone (such as .WEB.US, .NIC.US, .HOME.US). I have no opinion at this time as to the creation of this process.

As to the creation and administration of the gSLD's, it would be nice to see competition amongst registrars, operating under the principles of free enterprise. I do not have any qualms about there being a single Registry to handle the .US zone - multiple registries will be okay as well, if they can manage to sync all the registries.

I don't feel that there is any reason to map postal addresses, telephone numbers, geographical information, or the like into the domain name. These functions are covered by the DNS, not the domain name. It is possible to create new Resource Records that will handle these details. The domain names should *only* be used to map a name to an IP address.

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?

Under a fair process to be developed by someone other than myself. As long as *all* users of .US domains have a say in the process, I will be satisfied.

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?

One process would be to create the ".TM.US" gSLD. Everything within this subdomain is a trademarked entity. The other gSLD would not be allowed to use "trademarks". The trademark owner would be given rights to the ".TM.US", and would also be given rights to have "right of first refusal" if someone attempts to register that trademark within another gSLD in the .US domain.

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 be given direct control of their SLD. Each state will then create policy concerning their SLD.

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 delegate 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?

Competing registrars should be allowed to register under any .US domain name, pertaining to any restrictions established by the individual states (concerning <STATE>.US domains), and whatever entity or entities are acting as registries for <gSLD>.US 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?

I would like to see a single organization act as registry for the .US domain. Registrars who apply for more than a certain number of domain names should contribute to the operation of the registry - this will allow individuals to act as registrars.

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?

I believe a not-for-profit quasi-governmental entity would be the best.