Dear Ms. Rose:

As you know, VeriSign/Network Solutions, Inc. ("Network Solutions") has had more than eight years of experience providing registry, registrar and related services for the .com, .net, and .org domains. In addition, we have had the opportunity to observe the University of California's Information Sciences Institute's administration and management of the .us domain as a subcontractor to Network Solutions. Based upon this background of knowledge and experience, we would like to offer some comments that we hope will be helpful to the Department of Commerce's National Telecommunications and Information Administration ("NTIA") in its preparation of the solicitation for Management and Administration of the .us Domain Space. Please consider the contents of this letter as if you had received it prior to October 2, 2000.

It is Network Solution's belief that its most important contribution to the continuing examination of the evolution of the .us domain can be in the context of supporting the transition of the domain into a viable, widely deployed element of the Internet name space. The .us TLD should fill the unique potential of the .us domain as envisioned by RFC 1480 to provide a locus for registration for political subdivisions and their delegees (the role .us has filled to date), as well as provide a geographically identified top-level domain uniquely identified to the United States, and remain available to a wide range of registrants (the role country code top-level domains play in many other countries).

During the past months, considerable activity has occurred in the Internet Domain Name System that has afforded Network Solutions the opportunity to set out its views on a range of issues posed by significant events in the maturation of the Domain Name System ("DNS"), including:

expansion of the DNS through the Internet Corporation of Assigned Names and Numbers' ("ICANN") introduction of new generic top-level domains

introduction of multilingual registrations in .com, net and .org

Although not repeated in this letter, Network Solutions believes its previously stated views are relevant to the .us domain. (See NSI White Paper on Expansion of gTLD NameSpace at http://www.nsol.com/policy/gTLD-Registry-Best-Practices.pdf).

The foregoing notwithstanding, there is one overriding element that warrants repeating. It is the fact that at the bedrock of this evolving system is the requirement that the entity that has the responsibility to manage and administer the .us domain has the capacity to fulfill its responsibilities in a way that does not impair the domain and consequently adversely affect the stability and security of the Internet. We suggest that there are several obvious components of such structural capacity:

Robust organizational structure capable of sustaining reliable operations in a growth environment

Financial resources sufficient to operate .us in its present scope

Financial resources or income potential adequate to meet requirements of replacement of infrastructure

Financial resources or income potential appropriate to expansion of operating infrastructure of .us

The draft statement of work published by the NTIA is comprehensive and represents a thorough description of the requirements for providing registry, and to the extent required, registrar services for the .us domain.

Network Solutions offers only a few comments for consideration:

Regardless of whether the current structure of the .us domain is preserved or replaced, or some combination of the two, there will be a requirement to provide service to the registry's customers, whether the customer is a delegation or a registrant.

There is potential for disputes regarding, among other issues, trademark infringement and authority for a delegation. Although ICANN's Uniform Domain Name Dispute Resolution Policy may be applicable to the former, the .us registry will need policies and procedures to deal with the latter, or, for that matter, any other dispute that does not involve

The .us registry will need a disaster recovery plan.

It's difficult to comprehend how a registry would operate without a source of income. Contemplating the almost inevitable fees for registration services, the registry should have either an existing invoicing and receivables capability or a comprehensive plan to implement such a capability from the beginning. To wait until the contemplated study is completed and a fee structure is approved is too late. With respect to such a capability, the ability to "scale" should be a factor in the ultimate selection of the registry.

Thank you for your consideration of our comments. If you have any questions, please do not hesitate to contact me.

Roger J. Cochetti
Senior Vice President-Policy
Network Solutions, Inc.
rogerc@netsol.com <mailto:rogerc@netsol.com>
(703) 326-2585

Re: Billing Code: 3510-60-P
DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
Docket Number 980212036-0235-06
RIN 0660-AA11
Management and Administration of the .us Domain Space
AGENCY: National Telecommunications and Information Administration, U.S. Department of Commerce
ACTION: Notice, Request for Public Comment

http://www.ntia.doc.gov/ntiahome/domainname/usrfc2/dotusrfc2.htm

My comments on the use of the .us TLD:
The 50 states of the U. S. currently use web addresses of:
http://www.state.xx.us
for their official state home pages, where xx is the official state 2 letter abbreviation (ca for
California, etc.). This makes it extremely simple to find the home page of any of the 50 states.

I would like to suggest that the federal government of the United States use, as their official government gateway home page, the following address:
http://www.gov.us
which would make it extremely simple to remember where the federal government gateway is.
From this page, one should be able to get to all U.S. federal government web sites. Currently,
the following gateway web sites are used:
http://www.govspot.com
http://www.info.gov
http://www.firstgov.gov
and I could not remember these, and had to look them up from a file in which I had stored them,
in order to list them here.

There are a number of other countries that already do this with their TLD's, and it makes it extremely easy to remember how to find them. For example:
http://www.gov.ai/ ai - Anguilla
http://www.gov.cl/ cl - Chile
http://www.gov.ee/ ee - Estonia
http://www.gov.gg/ gg - Guernsey
http://www.gov.hk/ hk - Hong Kong
http://www.gov.hu/ hu - Hungary
http://www.gov.ie/ ie - Ireland
http://www.gov.im/ im - Isle of Man
http://www.gov.je/ je - Jersey
http://www.gov.kg/ kg - Kyrgyzstan (Kyrgyz Republic)
http://www.gov.lu/ lu - Luxembourg
http://www.gov.mk/ mk - Macedonia
http://www.gov.an/ an - Netherlands Antilles
http://www.gov.nu/ nu - Niue
http://www.gov.ru/ ru - Russian Federation
http://www.gov.sg/ sg - Singapore
http://www.gov.si/ si - Slovenia
http://www.gov.za/ za - South Africa
http://www.gov.ch/ ch - Switzerland
http://www.gov.tt/ tt - Trinidad and Tobago
http://www.gov.uz/ uz - Uzbekistan
http://www.gov.vi/ vi - Virgin Islands (US)
http://www.gov.yu/ yu - Yugoslavia

If the United States adopted this as their "official federal government gateway web site", it would be a big impetus for many other countries to follow suit and do the same. Thus, using:
http://www.gov.us
as the U.S. federal government gateway web site address has two very powerful advantages:

1. It is simple to remember and makes it extremely easy to find the U.S. federal government gateway web site.

2. It would be a powerful example for other countries to do the same, thus making any countries government presence extremely simple to find on the World Wide Web, by anyone, from anywhere in the world (as other countries often follow the lead of the United States).

I would like to suggest that the address:
http://www.gov.us
be implemented immediately, by whoever in the federal government has the power to approve this as policy, so that the citizens of this country can begin find their federal government's gateway web site, easily and quickly, without having to remember some longer and more complicated web address.

Note, I have NOT filed these comments in any of the other formats specified at:
http://www.ntia.doc.gov/ntiahome/domainname/usrfc2/dotusrfc2.htm

Thank you.

----------

Bob Howell, Pensacola, Florida
rahowell@worldnet.att.net or bob@howell.net

Before the
DEPARTMENT OF COMMERCE
NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION

In re                                           )
                                                )
Management and Administration                   )       Dkt No. 980212036-0235-06
of the .us Domain Space                         )
                                                )
                                                )

COMMENTS OF THE WALT DISNEY COMPANY

The Walt Disney Company ("Disney") hereby files these comments in the above captioned proceeding.

Disney supports and signs on to the principles outlined in the attached document, Principles for Management of the .US Namespace. Disney has always agreed that the problems of the Digital Divide must be addressed through partnerships between private industry, non-profit organizations, and the government. Use of the .US domain for this purpose will further the public good, while incurring no cost to the American taxpayer.

Disney has a long history of working with the non-profit community. Disney believes that the .US domain is big enough for both commercial development and non-commercial development.

Disney's affiliated companies are leaders in providing quality content on the Internet, especially for children. This includes not only Disney's well-known and beloved cast of characters, but also educational material as well. In addition, Disney's ABC Television and Radio Networks provide America with the best news, political coverage, educational material, and other non-commercial First Amendment speech on and off the Internet. Disney hopes that the Commerce Department's .US proceeding will allow Disney to use .US' full potential to bring this content to Americans everywhere.

Respectfully submitted,

Richard M. Bates
Vice President
The Walt Disney Company