07-01-97 Electronic Filings on Internet Domain Names

Number: 1
From:      Brian Kitchen mr_b@cyberdude.com
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/1/97 1:06am
Subject:   internet domain registration

In my Humble opinion, we( internet users) as a group must somehow solve
this dilemma. I would like to see ALL x-rated stuff in it's own domain,
thank you very much. The internet does now and should reflect real
society. We know where the "red light districts" are and we can choose
to go or not. Thanks to the first amendment, we are free to speak our
minds. But lets do something about the domains and access. Would it not
seem easy to somehow classify areas without restricting free speech. As
the internet grows, more domains are needed so why not have .xxx ? There
has to be a way to control this. I don't mind xxx when I WANT xxx. I
really mind searching on hotbot for free and getting a xxx reference in
the 31st position. This is bullshit. Regulation of one sort is
inevitable. Let's hope for the sake of us all that for the first time in
history we the people...on a global scale...can regulate ourselves
without a governing body screwing it up. Some independent organization
should be set-up, voted on over the internet, (digital certificates)to
deal with domains and new domains. This will be a very powerful
organization and I.M.H.O. the best way to protect the public would be a
democratic body based on the American Bill of Rights, accountable to
internet users and the general public.
Thanks for the soapbox  Brian Kitchen a.k.a. mr_b@cyberdude
mr_b's CyberWorld

Number: 2
From:     christopher post cp15@cornell.edu
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 1:07am
Subject:  Internet Domains


I am resonding to the request for comment on the internet naming
debate.  I feel that the adhoc committee has done an excellent job of
designing a system to increase the number of top level domains
available.  Although the new naming system was not developed by a
government entity, it was developed with the future of the internet in


Christopher Post
Graduate Student, Cornell Unversity, 503 Bradfield Hall, Ithaca NY 14853

Number: 3
From:     Victor Gavin Victor.Gavin@unilever.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 8:12am
Subject:  My suggestions for resolving the DNS issues.


Comment #1

I believe that there should be no special Top Level Domains (as there
are at the moment e.g. .com or .uk) handled by a special agency.

Instead, I suggest is that anybody should be able to register a Top
Level Domain and that the registration process should be handled
similarly to patents.

The registration would be handled by an international committee with
national sub-committes who would vet applications before authorising
their creation. There should be a legal obligation on registree's to
research ownership of a name before it can be used.

Once registered, the owner would/should not be held liable for trademark
infringements within the domain. What I mean by that is that sub-domains
should be able to incorporate trademarks (accidental or deliberately)
without fear of legal proceedings. The rationale behind this is that a
domain name is to all intents and purpose an address, and corporations
can't sue for damages just because their trademark is used in a street
address in another country - e.g. 128 McDonalds Drive, Kirkintillock,


Number:  4
From:     STriker RedWolf/Kelly Price kprice@physics.umd.edu>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:07am
Subject:  Input on new domain names

At this time, the use of domain names is proliferating wildly, becoming
a kaos into itself.  I propose the logical organization of those domain

To illustrate my point, I will theoretically "create" a few names in
this mail alone:

strlabs.com  - a standard company
amazonpark.org - for Amazon International Park (saving the Amazon.  "We
     breath for the world")
amongus.com  - ISP
umd.edu      - yes, University of Maryland, College Park.

Now for the organization of .edu, .org, .com, .net, et al.

.edu will always be for educational associations.  (umd.edu stays)

.net will be reserved to, and should be exlusive for, ISPs.  No ISP
should have a .com unless it provides another function (strlabs.com
would still be stlabs.com, as it's a standard company, but amongus.com
would have to be named amongus.net)

.org will be for non-profit organizations.  amazonpark.org stays the
same.  Companies would be moved out.  In the event that this continues
to be "a mess," the below organization may be enacted (so amazonpark.org
would become amazon.park.org)

.com will be reorganized:

  News organizations would be moved from .com to .news.com.   Therefore,
  abcnews.com and msnbc.com would become abcnews.news.com (or maybe
  abc.news.com) while msnbc.com would be stuck with msnbc.news.com.  
  C|Net's news.com would have to be renamed cnet.news.com.

  Television stations, networks, and shows would be moved to .tv.com.
  Therefore, cbs.com and local wjz.com would be moved to cbs.tv.com and
  wjz.tv.com (or wjz.md.tv.com, since it is local).

  Movies should be moved to .movies.com in similar fashion. 
batman.com   would be batman.movies.com.

  Similar organizations can be made, like that of the popular web page
  index "Yahoo".


strlabs.com may become strlabs.sci.com, depending on it's goals.
amazonpark.org may stay the same or use amazon.park.org
amongus.com would be forced to become amongus.net
umd.edu will always be umd.edu

Hopefully, some logical, sensible reorganization of names would only be
required for to fix, or delay, this problem.

p   |\      _,,,---,,_      Kelly "STriker" Price -Spiritual Polymorph
u   /,`.-'`'    -.  ;-;;,_  http://www.furnation.com/striker
r  |,4-  ) )-,_..;\ (  `'-' Not offical word of AITS/UMCP.  Junk Mail
r '---''(_/--'  `-'\_)  fL  fined.  Never wake sleeping physics majors.

Number: 5
From:     Edwin Hayward info@igoldrush.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:08am
Subject:  Response to Request for Comments on new gTLDs


Please find attached my response to your RFC on the proposal to extend
the current gTLD administration system. The response is in Word 97

Edwin Hayward

Response to Request for Comments on the
Registration and Administration of Internet Domain

Basis for response: Owner and operator of Internet
Gold-Rush [www.igoldrush.com], the Internetfs #1
collection of domain name news and information.

Author: Edwin Hayward

Date: July 1st, 1997

A. Appropriate Principles

The Government seeks comment on the principles by
which it should evaluate proposals for the
registration and administration of Internet domain
names. Are the following principles appropriate?
Are they complete? If not, how should they be
revised? How might such principles best be

a. Competition in and expansion of the domain name
registration system should be encouraged.
Conflicting domains, systems, and registries
should not be permitted to jeopardize the
interoperation of the Internet, however. The
addressing scheme should not prevent any user from
connecting to any other site.

It is important to define what exactly the term
gcompetitionh refers to in this context.
gCompetitionh could be considered as market forces
that combine to bring about conditions in which
the cost of administering domain names decreases.
gCompetitionh could also be considered in terms of
groups and individuals competing for a limited
number of domain names.

It is essential that the proposal that is adopted
is accepted by 100% of the Internet community
worldwide. In essence, the .com, .net and .org
domains are excellent examples of such acceptance.

b. The private sector, with input from
governments, should develop stable, consensus-
based self-governing mechanisms for domain name
registration and management that adequately
defines responsibilities and maintains

The problem here is that different elements of the
private sector have conflicting interests. For
instance, companies that have invested heavily in
their domain name [such as Mecklermediafs recent
purchase of internet.com for a sum reported to be
in excess of $100,000] and companies that have
invested a lot of time and money in promoting
their domain name [such as the major search
engines and companies such as Microsoft and
Netscape] have no interest in expanding the domain
name system, as this would dilute the value and
perception of their domain names.

Similarly, companies that make a living from
domain names, such as domain name registries
[several hundred companies], vanity mail services
and domain name brokers have no interest in
changing the existing status quo.

Individuals and organizations who have invested in
domain names, either for current use or future
deployment, will not wish the existing domain name
system to be expanded.

For all the above reasons, reaching a full
consensus may prove impossible.

c. These self-governance mechanisms should
recognize the inherently global nature of the
Internet and be able to evolve as necessary over

Correct. I am concerned about the repeated mention
of the role of the US Government in this process
of revising the domain name system. The US
represents an ever-shrinking portion of the global
Internet, and any agreement reached in defiance of
the will of the international community will be
bitterly opposed at best and unenforcible at

d. The overall framework for accommodating
competition should be open, robust, efficient, and

These four conditions are irreconcilable. Any
truly fair proposal that takes full account of the
intellectual rights of trademark holders will not
be efficient. Any proposal that does not take full
account of such rights will not be fair. This
should be redrafted to reflect a best case balance
between the four conditions outlined above.

e. The overall policy framework as well as name
allocation and management mechanisms should
promote prompt, fair, and efficient resolution of
conflicts, including conflicts over proprietary

Yes. Such conflicts must be resolved on a global,
rather than national scale.

f. A framework should be adopted as quickly as
prudent consideration of these issues permits.

There is no hurry to modify the current system.
Domain names are only running out because of a
combination of two things: market forces in the
secondary market for domain names, and a failure
of the imagination on the part of companies and
individuals involved. As I recently explained to
Inter@ctive Week, there are an astonishing number
of domain names still available in the .net and
.org hierarchies. The rules surrounding these
domains have recently been relaxed and effectively
anyone can register domain names under .org and

A further tightening of the rules surrounding
speculative domain name purchases, together with a
more robust system for looking up domain names
will prove perfectly adequate to meet the current
demand for domain names.

B. General/Organizational Framework Issues

1. What are the advantages and disadvantages of
current domain name registration systems?

The advantage of the current system of domain name
registration is that it is relatively inexpensive
and open to anyone at an individual or corporate

The disadvantage of the current system of domain
name registration is that it is shrouded in too
much mystique for the average Internet user to
fully understand the process behind such a
registration. This enables unscrupulous companies
to charge usurious fees [$250 to $1000+] for very
limited services provided when registering domain
names on behalf of clients.

2. How might current domain name systems be

The process of domain name registration should be
fully documented in less technical terms. The
central domain name registry should provide name
server services for all domain names it issues.
This removes the onus on domain name registries
and web hosting companies to provide DNS services,
and protects the rights of the domain name holder
[There have been numerous cases of DNS abuse;
either the company providing the DNS services has
refused to change the IP address that a domain
name points to, or it has pointed the domain name
at its own site]

Ideally, the central registry or registries should
provide the following minimum services:-

A) Simple form-based registration process
B) DNS services for the domain name included in
the maintenance price for the name
C) A mechanism for automating or partially
automating the process of submitting intellectual
property information in support of a domain name

The way to solve the shortage of domain names is
very simple. Implementation of the following
procedures will free up needed domain names and
ensure that an adequate supply will be available
for the future:-

A) Increase the fee for retaining domain names
from $50 to $100 per year, effective from the
renewal date for current domain names. This serves
to discourage speculators.
B) Implement a system in which money is demanded
up front, rather than the current system in which
a grace period of up to 90 days makes it easy for
speculation to take place. This has a number of
advantages: a guaranteed cash-flow in exchange for
the provision of domain names; reduced
administration costs [no longer any requirement to
send out reminders for individuals and
organizations that have failed to meet the
deadline for invoice payment]; reduction in domain
name speculation [speculation is less attractive
when the money must be paid up front]
C) Rolling renewal system in which a reminder is
sent 8 weeks before the current term of domain
name ownership expires. If payment has not been
received by the expiry date [a second reminder is
issued at 4 weeks] then the domain name
immediately defaults and is put back into the pool
of available names.
D) A more comprehensive method of dealing with
domain name disputes, and one which does not
penalize the owner of the name from the start, but
only removes the right to the given name at the
end of the process.
E) A clearer explanation of where funds raised by
the domain name process will be distributed and
used. Mechanisms to ensure that this money is
actually used in practice for the stated purpose
[more public accountability]
F) Open up the .org and .net domain names fully,
so that they have the same status as .com
G) In conjunction with F), give control of .org
and .net to two separate organizations, forming a
triumvirate of registrars with the organization
chosen to continue the administration of the .com
domain name.

The above 7 steps will be adequate to solve the
problem of the shortage of domain names. They will
also be less costly and less difficult to
administer than any proposal that involves
expanding the number of top level domains.

5. Should generic top level domains (gTLDs),
(e.g., .com), be retired from circulation? Should
geographic or country codes (e.g., .US) be
required? If so, what should happen to the .com
registry? Are gTLD management issues separable
from questions about International Standards
Organization (ISO) country code domains?

Quite frankly, that is the most preposterous
suggestion I have read for a very long time. There
are over 1,000,000 .com domain names in
circulation, most of them paid for. This means
that there are as many as 1,000,000 potential
lawsuits over the loss of .com names. In addition,
.com has become firmly ingrained in the publicfs
consciousness as the gconventionalh form of an
Internet site address. Domain names appear as part
of site addresses in a wide range of situations,
from advertisements in trade magazines to
indications at the foot of posters and even in
television advertisements.

.us is a good idea. The US is one of the few
countries that does not fully regulate its domain
name system.

The .com registry can remain in its present form,
a completely global registry not subject to
localized rules and regulations. The .net and .org
domains should be further promoted and opened up,
potentially nearly tripling the number of domain
names available.

In addition, a process should be instigated to
regulate the .us domain, or a new alternative to
the .us domain, along the lines of the .uk domain
in the UK. There, the central registry demands
various forms of proof that the registrar is a
genuine company, including the companyfs
deposition at Companies House in London. A similar
system for the .us top domain would ensure that
its use be limited to companies. This will easily
solve much of the congestion around existing
domain names, which are mainly being bought up by
speculators and investors.

6. Are there any technological solutions to
current domain name registration issues? Are there
any issues concerning the relationship of
registrars and gTLDs with root servers?

Yes. They should be one and the same. The
registrars should be sub-contracted by the
organization running the root servers. Only one
set of root servers should be sanctioned at the
international level, and the money to pay for the
upkeep of these root servers should come from part
of the funds collected to pay for the domain

This prevents the ludicrous farce that has been
perpetrated recently around the attempts of the
eDNS coalition and AlterNIC to form their own
alternate domain name system. AlterNIC pulled its
support for eDNS, and its name servers, meaning
that the eDNS domain names were effectively
rendered worthless. No company or organization
should be allowed to exert that kind of control
over another.

8. How should the transition to any new systems be

In two stages. First, disseminate clear, simple
details about the new system after it has been
finalized. Ensure that members of the Internet
public have a chance to consider and understand
the implications of the new system before it is
put into practice. Second, refuse all applications
for new domain names until a random interval of
several days or weeks has elapsed. This eliminates
much of the stress that would be put on the new
system by domain registration companies queuing up
gpre-registrationsh ready to fire at the central
registryfs computers as soon as the new domain
names become available. Also, implement a system
to restrict the number of domain name purchases
through any one organization to a low number, say
100 a week, for an initial gteethingh period of a
few weeks or months to effectively curb any
potential for a wave of speculation in the new
domain names.

C. Creation of New gTLDs

10. Are there technical, practical, and/or policy
considerations that constrain the total number of
different gTLDs that can be created?

Yes. The intellectual property disputes
surrounding a case such as parallel registration
of gibm.comh and gibm.neth by two different
organizations pale into insignificance next to the
problems that might arise if a single company can
purchase a g.ibmh address. Thus, any proposals
that effectively allow an unlimited number of top
domains, such as PGPMediafs name.space plan,
should be blocked immediately.

There is also the problem of perception. Domain
names are only useful as long as they are
memorable. They serve as mnemonics in place of IP
addresses. If the domain naming system is unduly
complicated to the point of having several dozen
possible top domains, it will be extremely
difficult for individuals to easily remember
internet addresses. Some people already get
confused between XYZ.com and XYZ.org; the
situation becomes unimaginably worse if they also
have to choose between XYZ.ABC, XYZ.CDE, XYZ.EFG

11. Should additional gTLDs be created?

No. There is absolutely no need for any new gTLDs.
All that needs to happen is a gradual but firm
tightening of the rules surrounding the existing
gTLDs, coupled with a better exploitation of a
country domain for the US.

D. Policies for Registries

15. Should a gTLD registrar have exclusive control
over a particular gTLD? Are there any technical
limitations on using shared registries for some or
all gTLDs? Can exclusive and non-exclusive gTLDs

Yes, but the costs and profit level should be
regulated by an international body. A good example
of such a system in the offline world is the
running of the UK National Lottery. The lottery is
run by a private organization, Camelot, but with
government-specified levels of profit.

By exercising this type of partial control over
the domain name registrar, any possible abuse of
the monopoly over a given gTLD can be avoided.

16. Should there be threshold requirements for
domain name registrars, and what responsibilities
should such registrars have? Who will determine
these and how?

Yes. They should have sizeable assets and the
technical know-how to guarantee that they can
maintain their systems in full working order at
all times. They should be responsible for
providing DNS services for domain names under
their control. They should be able to INSTANTLY
issue domain names [even though the update could
be reflected periodically in the central DNS
databases, such as once a day as per the current
InterNIC system]

17. Are there technical limitations on the
possible number of domain name registrars?

Yes. The InterNIC database is already extremely
slow due to the number of queries being sent to
it. If registrars need to query the databases held
by all other registrars, or alternatively need to
all share a centralized domain name registry
database, the system will slow to a crawl. One
domain name, one registrar, one database.

18. Are there technical, business and/or policy
issues about the name space raised by increasing
the number of domain name registrars?

Yes. Increasing the number of registrars increases
the possibility of conflicts between different
groups seeking to register a single domain name.

19. Should there be a limit on the number of
different gTLDs a given registrar can administer?
Does this depend on whether the registrar has
exclusive or non-exclusive rights to the gTLD?

Yes. 1. All rights should always be exclusive.

20. Are there any other issues that should be
addressed in this area?


E. Trademark Issues

21. What trademark rights (e.g., registered
trademarks, common law trademarks, geographic
indications, etc.), if any, should be protected on
the Internet vis-a-vis domain names?

All trademarks should be given weighting when
considering domain name disputes, IRRESPECTIVE of
the country of origin of the domain name. This is
vitally important: US trademarks should not be
given any kind of precedence over trademarks
issued by other countries.

22. Should some process of preliminary review of
an application for registration of a domain name
be required, before allocation, to determine if it
conflicts with a trademark, a trade name, a
geographic indication, etc.? If so, what standards
should be used? Who should conduct the preliminary
review? If a conflict is found, what should be
done, e.g., domain name applicant and/or trademark
owner notified of the conflict? Automatic referral
to dispute settlement?

Yes, for the new .us or similar country domain
that I outlined earlier. In this case, the
trademark should be a US trademark only. An
independent body should be set up to monitor such
disputes. A cost could be levied on the disputee
and on the disputer; the successful party in the
dispute would have the cost refunded, and the
losing partyfs cost would pay for the review

NO ACTION should be taken until the process has
completed and a decision is reached. The current
system that DNS services are suspended to the
domain name holder UNTIL a settlement is reached
is completely unacceptable, and is not conducive
to promoting the use of the Internet as a tool for
global business.

.com, .org and .net names should be allocated on a
first come, first served basis. Any resultant
disputes should be handled by a similar,
independent body. Because of their global nature,
any pre-review process would be unsuitable for
such domain names.

23. Aside from a preliminary review process, how
should trademark rights be protected on the
Internet vis-a-vis domain names? What entity(ies),
if any, should resolve disputes? Are national
courts the only appropriate forum for such
disputes? Specifically, is there a role for
governmental/nongovernmental organizations?

An international organization should be formed
with the specific aim of resolving such disputes.
A framework of rules should be laid down to make
all but the most complicated of cases a mere

24. How can conflicts over trademarks best be
prevented? What information resources (e.g.
databases of registered domain names, registered
trademarks, trade names) could help reduce
potential conflicts? If there should be a
database(s), who should create the database(s)?
How should such a database(s) be used?

Trademark databases already exist. Patent
databases can also be considered when resolving
such disputes. An organization could be set up to
integrate these databases in some form, possibly
via a unified query mechanism to provide a front-
end interface to these various databases.

25. Should domain name applicants be required to
demonstrate that they have a basis for requesting
a particular domain name? If so, what information
should be supplied? Who should evaluate the
information? On the basis of what criteria?

Yes, for the new .us domain name reserved for
companies. Proof of company ownership should be
required. Small businesses and self-employed
people, and individual domain name applicants
should content themselves with other domain names
such as .com, .net and .org.

If this new top domain becomes widely used as THE
domain for US companies, then problems such as
conflicts between IBM.com and IBM.org [for
example] will be of much lesser significance.

26. How would the number of different gTLDs and
the number of registrars affect the number and
cost of resolving trademark disputes?

Every time you add a gTLD, you add another
potential battleground for companies to fight over
the rights to a domain name, and another potential
domain name that can be hijacked away from its
rightful owner.

27. Where there are valid, but conflicting
trademark rights for a single domain name, are
there any technological solutions?

No. First come first served is the fairest system
if both claims are valid.

One additional partial solution would be to have a
standardized glinking systemh that sites would be
required to display on their top page to dispel
confusion. So for example, IBM.com would be
required to display the information: gIf you are
looking for International Bowling Members, please
go to IBM.net. If you are looking for Interior
Bazaar Malls, please go to IBM.org.h at the foot
of its main page [standardized font size and a
high-contrast colour]

In the above example, the site belonging to
IBM.net would have to display the following: gIf
you are looking for International Business
Machines, please go to IBM.com. If you are looking
for Interior Bazaar Malls, please go to IBM.org.h

Finally, in the same example, the site belonging
to IBM.org would have to display: gIf you are
looking for International Business Machines,
please go to IBM.com. If you are looking for
International Bowling Members, please go to

28. Are there any other issues that should be
addressed in this area?


Edwin Hayward, Tokyo, Japan info@igoldrush.com
Internet Gold-Rush [ http://www.igoldrush.com ]
The premier source of free domain name news and info
Number: 6 
From:     Christopher Quinn 
To:  "Paula Bruening, NTIA" 
Date:     7/1/97 11:20am
Subject:  gTLD:  UTI - no!  NSF - yes!

          I utterly mistrust and object to Secretary General Pekka 
Tarjanne's and the International Telecommunication Union's (UTI's) 
attempt to hijack the Internet. 
          The proposed plan to transfer control of the Internet from the 
U.S. government to an intergovernmental organization in Switzerland is 
not in the best interests of Americans (like me) or the Internet. 
          The ITU,  the United Nations agency responsible for 
coordinating telecommunications policies of governments, not the U.S. 
government's National Science Foundation  (NSF), would become the 
worldwide central depository for new Internet domain names, and the World 
Intellectual Property Organization (WIPO) would administer the 
arbitration and appeals mechanisms. Utter folly! Americans paid for and 
developed the Internet; and only Americans, due to our Constitution, our 
economic and military strength, are in a position to safeguard the 
privacy of American citizens and free flow of information and commerce on 
the Internet.  Not some selfordained United Nations bureacracy and a 
fragile balkanized coalition of vested international interests. 
          You don't see Apple, IBM, Microsoft and Netscape Communications 
rushing to endorse the Geneva plan; and even if those major players got 
stupid, an increasing number of smaller organizations are actively 
campaigning against the proposals, afraid that the UTI takeover could 
lead to the splintering of the Internet into rival domain-name groupings. 
The proposal has, in fact, already provoked legal action from Internet 
services companies in the United States. These companies are justifiably 
angry at what they see as the hijacking of the Internet by an unelected 
international body; Richard Beaird, the U.S. government representative, 
would thus be best advised to make sure the absurd proposal is vetoed.
          A protest meeting on the domain-name issue organized by the 
Association for Interactive Media will take place in  Washington, D.C. on 
July 9; so the American protest against the Geneva plan should be in full 
roar by August.
          Having Vint Cerf, known as the "father of the Internet", MCI 
and 80 other organizations with less than sterling motives endorsing such 
a anti-American plot will not sway the majority of Americans, once they 
find out what is really being proposed. Not so much the idea of adding 
seven new generic top-level domains to the five established domains, 
which include .com, .edu and. gov, or even the complex registration, 
payment and appeal process, but the idea of the world dictating what 
Americans can and cannot do with an American technology and architecture 
is galling. 
          Pekka Tarjanne's defense of rushing this through, by saying his 
organization had to act quickly so as not to miss the opportunity to 
reform the Internet, is specious at best. The UTI is secretly salivating 
over future tariffs (taxes) on American Internet commerce and being able 
to acquire covert data on American interests. 
          Americans will no longer stand for our own government 
overtaxing us and methodically diminishing our freedoms; so we sure as 
heck aren't going to take it from beyond our borders. I know I won't! 
Tarjanne and Cerf can stuff it; and so can any American administration 
that plays into their hands.
Christopher Quinn

Number: 7
From:     Tommy Lakofski 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 12:35pm
Subject:  Possible solutions to gTLD clutter.


The document at http://www.ntia.doc.gov/ntiahome/domainname/dn5notic.htm
raises many valid questions. I'm not in a position to comment on most of
them, but it would seem that a fairly obvious solution to the overwhelming
growth of gTLD domains would be to restrict the allocation of such domains
to one per company, organization, body, or individual. This, I believe,
was the original intent of the hierarchical nature of DNS zones -- any
organization could subdivide its namespace as it saw fit in a hierarchical
manner. This indeed is the manner in which most reputable companies on the
Internet manage their DNS -- cf. Digital, IBM, Apple, Microsoft et al. In
my (humble) experience, it is only those less 'worthwhile' companies which
undertake domain registration en masse, for the purposes of speculation,
vanity DNS naming, etc. I believe that these activities must be the chief
factor in the cluttering of the generic namespace, and its eventual
non-operability -- and it would sem that these activities would be the
easiest to eliminate, via a change in the registration process for generic
domains which would require proof of identity -- corporate or individual.

I'd also like to throw in a brief word on the retirement of the gTLDs: 
This would seem to be perfectly justified, and by reducing the 'glamor' of
the gTLDs, would eliminate the registration of gTLDs by organizations
outside the US, further reducing pressure on the namespace. As the
Internet seems to be becoming a more global than exclusively US-centric
domain, the incorporation of the gTLDs into the .us namespace seems
entirely appropriate. It would also make room for the possibility of
global gTLDs for multinational organizations (although this is provided
for currently by .int).

In any reorganization of the DNS, there should be competition between the
registries of names (and with IPv6, numbers) on the Internet, as well as
the continuing minimal interference of governmental organizations, which
will never be able to keep pace with the dynamic evolution of this global

I hope these comments prove useful. Thank you for your time.

Thomas Lakofski.


Number: 8
To:  NTIADC40.NTIAHQ40(dns)
Date:     6/30/97 8:28pm
Subject:  New domain naming system

My main concern on domain naming is that the owners of domain names be
required to submit real contact information, that the registries be
required to verify the contact information and that there be substantial
penalties for providing incorrect or nonfunctional contacts, e.g.,
telephones that are never answered, E-mail routed to /dev/null. 

The reason for this is that currently the major spam domain have bogus
contact information in order to avoid having to listen to complaints. 

 Shmuel (Seymour J.) Metz

Number: 9
From:     Daniel Prather <10ebm3s3ipcm@mci2000.com>
To:  NTIADC40.NTIAHQ40(dns)
Date:     6/30/97 8:44pm
Subject:  Internet Domain Registry Structure

     Hello.  My name is Daniel Prather, and I'd like to share a few of my 
ideas on the future Internet Domain Registry Structure and workings.  
I have tried to structure this in a sense that I feel will best 
benefit you, the reviewer, and answer any questions that you may 
have.  Also, if something in this document is not thoroughly 
explained, and you'd like a more detailed explanation, feel free to 
e-mail me at the address at the end of this letter below.  Thanks!

     Daniel Prather
     Panama City, Florida

The following section of this message contains a file attachment
prepared for transmission using the Internet MIME message format.
If you are using Pegasus Mail, or any another MIME-compliant system,
you should be able to save it or view it from within your mailer.
If you cannot, please ask your system administrator for assistance.

   ---- File information -----------
     File:  internet.txt
     Date:  1 Jul 1997, 0:43
     Size:  4716 bytes.
     Type:  Text

-- Internet Domain Registry Infrastructure and Workings ---

     First hand, I would like to say that this request is not organized in
the way that comments were expected.  Mainly, I feel that the preconceived
format is not adequate to describe the ideas and thoughts which I will
soon depict in this document.  I have organized it in a way that I feel
will make it easy to read, and easy to understand.  If you have any
questions, please refer to the e-mail address towards the end of this


     Due to the sudden growth of the Internet, many of the previously
conceived systems which control Internet traffic have become greatly
overworked.  Not to mention, many things have become disorganized,
creating a very difficult to navigate network.  The text that follows are
my ideas on it's solution.  In writing this, I have primarily addressed
the main problem of domain registration.  I shall begin by giving a
somewhat general overview of what I think may solve several problems in
the current system, and further along, I shall go into more specific

New Internet Domain Infrastructure:

     First of all, the domain registration should be administrated by one
organization.  It would be preferably a federally funded operation, which
is also supported by the fees of domain registration.  This organization
would also be the home of the few domain nameservers.  New protcols would
need to be enacted to allow for the use of 128-bit IP addresses as well. 
These few nameservers would be the only ones operational.  I say this
because most of the Internet clutter is created by the popular "static IP"
which usually includes a domain such as "username.domain.ext" ... although
this 3 field URL is not particularly disorganized, sometimes they grow to
take up 5 or 6 fields.  This is completely ridiculous, and wasteful.  In
keeping with a few nameservers, running on high-speed connections
(multiple OC-3s or OC-12s) we could provide domain lookups for the world's
Internet community, and manage it easily. 

     The servers would be linked so that if one goes offline, another may
take on its load, as well as its own.  This would created a continious
domain service.  It would be advisable, though, that a few of these
nameservers be located in different locations as to minimize the chance of
a failure.  Caching servers may be setup as they are now, but may only be
modified by the main servers.  This would allow them to still recieve
queries, and still direct users to desired sites, but not allow useless
data to be entered by a user. 

     When a company or individual registers a domain name, there should be
a set cost.  This cost would include a block of rougly 5 IPs, instead of
the blocks of 256 given now.  Extra IPs may be purchased at a set cost,
and all DNS entries and "static IP" domains would need to be approved by
the new registry.  To be approved, they would have to submit a form
detailing the intended use of the domain, as well as information regarding
the user.  This would minimize the amount of "nonsense" domains currently
residing on the network nameservers.  Only domain administrators (working
for the new domain organization) will be able to make changes to the

     Domains would need to have longer extensions.  .com, .edu. .gov, etc,
usually are sufficient, but with more and more sites appearing with
different social orientations, these extensions will eventually become
unusable.  In place, I'd suggest something a little more descriptive and
restricted, .com domains would only be given to commercial sites, and they
would have to show proof of their business stance.  .edu isn't sufficient
for all of the educational resources available.  Possibly creating a
.highschool, .college, .university, etc would be more sufficient. 
Government organizations could be categorized in a similar way. 
.localgov, .federalgov, etc. 

     Locations need not be required in domain names.  These tend to be
pointless, in my opinion.  But geographic information SHOULD be stored, so
that if a query is performed (by dnslookup or finger) on a site,
geographic information can be obtained, as well as other information
submitted to the primary registry. 

     Essentially this is most of my suggestions.  If you have any
questions, please e-mail me or call me at 1-850-784-1253.  This new
organization should be called something such as "Worldwide Domain
Services" (www.worldwide-domain-services.system) ... the .system extension
referring to a critical component of the Internet.  Please send me your
comments on the above documents.  Thank you. 

     written by Daniel Prather
     e-mail: mystic.one@mci2000.com

Number: 10
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 1:47pm
Subject:  Trademarks

Network Solutions apparently with the blessing of the NSF has an absolutely
reckless policy as it pertains to registration of trademarked names by third-
party registrants. Their "dispute policy" is so irresponsible that it appears
encourage lawsuits for the enrichment of their attorneys.
I have a valid subsisting, unique and famous federal trademark that has been 
used in commerce since 1983. Now, because of Network Solutions policy I will 
have to spend a $150.00 filing fee, spend a day writing the complaint, and
two years for a federal court to order the transfer of the .com registration
back to
the trademark owner. 
The system is in need of change. 
Sincerely,  Darrell J. Bird, 3070 Southdale #D, Dayton, OH  45409

Number: 11
From:     Lori Henk 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 4:16pm
Subject:  Creation of New gTLDs #11

11. Should additional gTLDs be created?

  Definitely. The following ideas were proposed at an international level
more than a month ago regarding new gTLDs and the U.S. should remain
consistant with that proposal where possible. There is only one gTLD
proposed that I question and that is .store for retail sites. A more
appropriate gTLD, keeping with 3-4 letters would be .shop.

  The following gTLDs were proposed:
  .firm  - business
  .store - retail  (alternative .shop)
  .web   - web related services
  .rec   - recreation
  .info  - resource/information
  .nom   - personal sites
  .arts  - art related sites

thank you for your time,
Lori Henk
Web Designer
Number: 12
From:     Nickolai Zeldovich 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 5:09pm
Subject:  Comments on Policies for Registries

See the attached file.
Policies for Registries

Domain name registries should not charge excessive amounts of money from
individuals and/or companies and/or organizations registering domain
names, except for what's absolutely needed for the operation of the
servers. Obviously the current $50/year fee generates much more money for
InterNIC than they need for normal operation of the nameservers and other

| Nickolai Zeldovich       | ZEPANET              | UCF Math Department      |
| http://www.kolya.ml.org/ | http://www.zepa.net/ | http://www.math.ucf.edu/ |
| nickolai@kolya.ml.org    | nickolai@zepa.net    | nickolai@math.ucf.edu    |

Number: 13
From:     Jim Cerny 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 5:22pm
Subject:  comment on adding DNS top-level domains.

Dear NTIA:

In following the attempts by Internet groups to expand the
number of top-level domains in the last six months, I
think the following clearly emerges regardless of who runs
the registries and regardless of just how many new domains
are added and what they are called:

     Legal counsel for companies will regard it as
     their duty to recommend, for any corporate
     names that have trademark or copyright status,
     the registration of these names in EACH new

That will, of course, tend to undo many of the benefits of
expanding the namespace.  The solution, at least from the
point of U.S. law, would seem to be national legislation
that prohibited that kind of multiple registration.  I have
no idea if it is possible to argue for this from some 
parallel situation that has already been legislated.  Some
would suggest a pricing mechanism as an alternative to
legislation, with sharply escalated fees for extra 
registrations.  If it were just a matter of charging $100
(say) for the first registration and $10,000 (say) for each
additional one, that would be hard to administer with
competing registries and would discriminate strongly against
small companies (for a large corporation the $10K would be
a trivial cost of business).

  Jim Cerny
    Web manager, University of New Hampshire
Number: 14
From:     Dennis Fazio 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 7:26pm
Subject:  On the Registration and Administration of Internet Domain Names 

Comments in response attached as ASCII text.

My full contact info:

Dennis Fazio
Executive Director
Minnesota Regional Network
2829 University Ave SE
Minneapolis, MN 55414

(612) 362-5850

Dennis Fazio
Minnesota Regional Network -- Gabnet: (612) 362-5850

Comments in response to a Request for Comments on the Registration and
Administration of Internet Domain Names, Docket No. 970613137-7137-01. 

Section A. Appropriate Principles 

I agree with all six principles

Section B. General/Organizational Framework Issues 

Questions 1-9: The current domain name system has been overrun by the
growth of the Internet; it no longer scales with the need. Generic Top
Level Domains should be retired and the use of the US Domain, as currently
defined in RFC 1480, should be mandated for the United States in its
place. Detailed explanation and justification follows: 

 I believe any scheme predicated on an extension of the current,
essentially flat naming system is doomed to failure. The recent proposal
by the International Ad Hoc Committee (IAHC) to add a limited number of
new Top Level Domains does not seem to be a scaleable solution and will
not likely ameliorate the major issues of trademark infringement. 

It seems the key problems are: 
a. Demand by several parties for the same name 
b. Use of the domain name system as a directory service 
c. Technical and operational management of the growing Domain Name System 

Most all of the rest of the issues and problems are a result of these three.

It would be easiest of these had apparent technical solutions.
Unfortunately, they all don't. The second problem could be solved with a
mix of policy (adhere to a standard) and technical (implement a separate,
easy-to-use directory service). The third is partly policy (agree on some
practices; again, standards) and implement them (mostly

It's that first one that is the real source of all the ruckus. One path to
a possibly easier solution would be to look at the world we had
pre-Internet and see how we dealt with those issues of similar naming and

We deal with them now by allowing the use of the same name as long as they
are in different areas of activity or in different states. This leads us
to a solution that doesn't perturb the current setup all that much:
mandate the use of the US domain. 

First, it's heirarchical and does not suffer the scaling problem of the
current proposals, even as they are themselves increased with more
top-level domains. There are 50 states and thousands of localities in
which to fit your organization's name. 

Second, it allows for either a single registration authority or the
logical division to any number of registration authorities, each of
different size and scope of operation according to their capabilities. 

Third, it permits multiple organizations to have the same name.
Acme.Minneapolis.MN.US and Acme.Los-Angeles.CA.US can both exist and keep
their names if they are in different business lines. In those cases where
the same name is to be used in the same community, categorical names could
be slipped in: Acme.Paints.Minneapolis.MN.US,

Fourth, it provides some semblence of a limited directory service. Right
now, if we know the name of a prominent company and add .com, we can go to
its web server. However, that only works for one company with that name.
With an heirarchical US domain, we only need know the company name and
where it is to find their web site. Note that we will still have need of a
good directory service to really make the system work, but it's always
nice to have some shortcuts. 

Fifth, and most important, it helps leverage the existing practice we now
use to keep trademarks manageable because it provides a system very much
like the real world we now are familiar with. It's not a perfect match,
and some new policies, procedures and perhaps new law will have to be
created to make it really work well, but nowhere near the mess and
seemingly insurmountable task we now see before us with the current

There have been many objections to the use of the US domain, some
specious, the rest, nonconsequential. 

1. The names are too damn long:  This is just a fact of life when so many
are now involved. You need more characters to differentiate organizations
when you get into the thousands and millions. The best solution is to use
already familiar names that are easy to remember. There are plenty of
features in email (aliases) and web programs (bookmarks) that make it
unnecessary to type in the actual name very often. Most email is a
response to another email; the address is never entered in those cases,
but automatically entered by the email client. We deal with long names in
our lives all the time anyway. Many of us use long street addresses or
long town names that we have to write time after time on our applications,
documents, forms, etc. or US Mail letters. We deal with it. This objection
is specious. 

2. People and organizations move and would have to change their domain
names:  What happens when a person or organization moves now? First you
have to get a new telephone number (though this necessity may change in
the future). You perhaps need a new driver's license as an individual. You
need to print tons of new stationary. You need to send out large
quantities of "change of address" postcards. On the Internet, it's a 5
minute job to send "change of address" messages to all your correspondents
(all of whom are conveniently cataloged with nice short aliases in your
mail client) and mailing lists. I hardly think that sending out some email
change notices adds all that much to the overhead necessary when you move
your household or your business. What if you graduate and get a job?  What
if you get a new job? Your email address will change. It happens all the
time to lots of us now anyway. 

Life means change. We change schools, homes, workplaces, favorite foods,
spouses, family size. A major portion of the population still changes
their names at some time in their lives. Businesses move, change products,
change their corporate names. What can be so difficult about changing an
email address or corporate domain name once in a while. Change is good for
us. We should all seek any opportunity to change something about ourselves
often. This objection is also specious. 

3. In Cyberspace, names shouldn't be tied to physical location:  Most of
those arguing for the abstraction of a "Cyberspace" as a new "lifespace"
seem to be denying or attempting to put aside the real world. I think it
is more important for us to encompass the real world in this new virtual

Seeing that someone is associated with a particular university or
corporation, or is located in a particular place humanizes the message or
the information. All I have in front of me is a screen full of words or
images. The organizational or geographic mapping in their return address
or the web site gives a small amount of identity to the person who wrote
those words or placed those pictures. The tendency to respond rudely and
viciously is amplified when there is no real person looking you in the
eye. We've all seen evidence of that on the Internet. If there was no
shred of identity association at all, the messenger becomes even more
abstract and dehumanized. Discourse can degenerate quickly when all you
debate with are disembodied words. 

Cyberspace is floating too freely as it is. It needs some anchors in
something now existing so that newcomers feel welcome and not just lost in
a strange new world with absolutely no familiar touchstones. 

If we want this new and growing facility to be used by the greater
population, then we have to make it accessible, we have to build it having
an association with the familiar REAL WORLD that we all live in. We are
all real people in real physical places. With few exceptions, almost all
of our sense of community comes from our geography: school, church,
neighborhood, social organizations, civic organizations, government
participation, etc. It is what helps make us human and social beings. We
don't need the concept of an abstract "cyberspace" to bring new people
together on the Internet. The concept of a diverse set of people
geographically dispersed over great distances, yet brought together by
electronic communications can be a powerful draw. A
locality/geographical-based naming system helps us to build that concept.
This objection is inconsequential. 

Let us think about what we are trying to accomplish and the best way to
encourage that. The best new things are those that have some sort of
usefulness or tie that people can tie to something already familiar to
them. It is what helps new things grow and flourish most rapidly. 

In summary, we can probably futily attempt to pull and stretch and warp a
current system that was never intended to scale to this size and scope, or
give up and adapt something entirely different, very familiar, and staring
us in the face all along. 

Section C, D, E:  I have no supplementary comments on these sections
beyond what has been already covered above. 

Dennis Fazio, Minnesota Regional Network   --|||--   Gabnet: (612) 362-5850

From:      Ringmaster 
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/1/97 7:46pm
Subject:   About InterNIC...

Well I just have a little comment, the system InterNIC is using right
now is way to stoneage. For ex. if you wanna update your profiles it
takes days to get it done and e-mails has to be sent back and forward to
the hostmaster (or whatever), wouldn't it be easyer if they just could
get a real system up and running where you can update your info on-line,
internet is commercial and not only the "old" computer nerds are using
it anymore...

My two cents...(or is it one cent?)

[minimjuk] Ringmaster
 - http://www.geocities.com/~gcring/
 - minimjuk@geocities.com

Number: 16
From:     Charles 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 10:15pm

To whom it may concern,
     I am inclined to aggree with the executive summary on almost all
aspects of included content. I am strongly in favor of the internet
being regulated by the public sector, leaving legal enforcement matters
to the government agencies. As far as domain names are concerned they
should open more domains for the use of public as well as business
concerns, cost of which should be absorbed by the users. Business should
pay their part as well as the private sector. As a private user of the
internet I have found it increasingly difficult to log on to my service
due to the rising amount of usage, as well as the many larger servers
being brought down due to the massive hits to their systems. These facts
alone are proof something need be done and very soon. I can see a major
failure happening within the next few years due to the steady rise in
traffic and stress on an already taxed system. Regards Charles Leffler 

For quik contact= Mailto:leffler@okeechobee.com
Home Page= http://www.okeechobee.com/~leffler/index.html
Truckers Page=

CC:        NTIADC40.SMTP40("jerry@southeast.net")

Number: 17
From:     Jesse Kornblum 
To:  NTIADC40.NTIAHQ40(dns)
Date:     7/1/97 11:40pm
Subject:  Comments on DNS issues


1. Problems with current DNS system: 

   Under the current system, if a person registers for a DNS entry, but
later another company that holds a trademark to that name (e.g.
www.superbowl.com) wants that domain name, the first person is stripped,
without compensation, of the name. I believe that trademark holders should
be able to purchase the domain names of trademarks they hold, but at a
fair market value. (Perhaps the cost of the registration fee for as long
as the person held the name...)

5. The existing gTLDs should not be retired, but new ones should be
created. It might be a good idea to have a .us domain, and then the US
could administrate everything in that domain, but who would decide other
country codes? And how would those debates be decided? I like the idea of
InterNIC, a semi-autonomous organization that runs the whole deal. Like
the UN, only for the Internet. (Please note that the Internet should NOT
be under control of the UN.) :)

7. Well, I'm going to get a little technical here. Remember that DNS names
(e.g. www.whitehouse.gov) are only nicknames for the *real* addresses,
which are IP addresses that look like this:, etc. It may very
well be necessary to expand IP addresses to five blocks. (Each block can
range from 0-255) Having existing systems work with these new systems
would require updating the Internet, a daunting task, but nonetheless

C. New gTLDs

1. Yeah. Nothing should be banned. If you want a site
www.profanity.#!@#??, then you should be able to get it.

2. YES! The current system is too restrictive. For example, .isp for
service providers, .store for well, stores, .adult, for sites with adult
content (great for filtering software!) 

Thanks for listening,

Jesse D. Kornblum             |         Even if the voices aren't real,
403 Memorial Drive - DKE      |           they have some good ideas
Cambridge, MA 02139-4397 USA                             
617-494-8250, ext. 114   http://mit.edu/jessek/www/