07-06-97 Electronic Filings on Internet Domain Names

Number: 61
From:      wallace koehler wkoehle@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 6:08am
Subject:   Request for TLD Comments

Attached in Word 6 are comments on your request for gTLD comments

I appreciate the opportunity

wallace koehler (willing@usit.net)


Response to Department of Commerce Request for Comments on Internet Domain Names

Wallace Koehler (willing@usit.net)

A. Responses to General/Organization Framework Issues:

A. Comment: There has been much interest expressed about and interest in modifications to the domain naming structure, particularly to the gTLD .com domain. This concern resulted in a set of recommendations by the International Ad Hoc Committee (IAHC) of the Internet Society (ISOC) as well as a continuing commentary and criticism of the process and its recommendations. For example, the IAHC maintained a listserv (archived at the ISOC site (www.isoc.org)) and the issue was the subject of some debate at the INET'97 Meeting (ISOC Annual Meeting) in Kuala Lumpur in June 1997.

A.1. Argument Foci. The argument as presently constituted revolves around two related issues: (1) domain naming space has become congested, and (2) domain names may represent a threat to the trademarks of established corporations. Arguments and proposed solutions include recognition that the current gTLD structure is inadequate to manage the naming requirements of commercial entities worldwide and that trademark issues are important. The IAHC solution, meritorious as it is, fails in one key aspect. It seeks to impose a solution maintained and administered by what is essentially a technical non-governmental organization on a regime that is inherently legal, political, and economic in nature. NGOs, particularly technical NGOs lack the expertise, authority, experience, and jurisdiction to regulate in that environment. The IAHC also was very limited in its scope and membership, and did not address (nor did it seek to address) wider domain naming issues beyond expansion of the com domain, trademarks, and related matters.

In addition to the IAHC recommendations, others have suggested (1) creation of a flat TLD structure, allowing registrants to choose individual TLDs without regard to "controlled vocabulary" or "indexing"; (2) elimination of the TLD topography by either eliminating alphanumerics and reverting to IP numbers only or by generating random TLDs; and (3) migration from the functional TLDs (gTLDs -- com, net, org -- and the edu, gov, mil TLDs) to an exclusive adoption of the geographic (ISO 3166) two-letter codes now employed largely but not exclusively (.us) outside the United States.

Option 2 would eliminate trademark issues but would prove unwieldy and unpopular. Neither option 1 nor option 3 would address trademark questions.

A. 2. Other Stakeholders. This debate tends now to be dominated by three groups: Commercial interests seeking to protect oftentimes legitimate and sometimes questionable trademark rights, the technical Internet community, and the root domain registrars -- both the established and the hopeful. There are other constituencies and stakeholders with significant interests in the outcome of the TLD naming debate. These include governments (that the Department of Commerce has requested comments on this issue speaks for itself), the information science and library community, and the non-commercial and quasi-commercial domain and virtual domain name owners, as well as others.

Unfortunately, these other stakeholders have tended to be ignored. I am one of those other "stakeholders" in that I find that the TLD and second-level domain (2LD) tags of URLs can be used as an important non-keyword Internet search methodology. In that light, neither the geographic TLDs as well as both the functional TLD status quo as well as the IAHC proposal do not threaten the methodology. Flat TLDs would destroy the utility of the method while IP numbers would render it perhaps hopelessly complex.

It is undesirable to destroy any search methodology that helps organize and regularize the Internet. Searching on "URL fragments" is one such approach, and is supported by several major search engines. If anything, "controlled vocabularies" and "indexing" (both timetested and honored vehicles for information management and retrieval) should be expanded in the Internet context. It could be expanded by more universal use of standardized 2LD and 3LD tags now employed by some but by no means all geographic TLDs. Examples include gob.mx (government servers in Mexico), co.jp (commercial servers in Japan) and ac.uk (academic servers in the United Kingdom). Other variants include [state postal code].us, fi.cr (financial entities in Costa Rica), and tm.fr (trademarks in France). A somewhat universal application of standard 2LD tags together with existing TLD tags could improve "quasi-set" creation and, as a result, search precision.

A.3. Responses to: Issues 1, 2, 3, 5, 8, 9, 10, 11, 13, 14, and F "Trademark Issues"

1. Advantages/Disadvantages of Status Quo. The status quo does not address trademark issues, it cannot regulate either trademark rights nor the distribution of domain names in general, and the size of the com TLD is unwieldy. On the other hand, the functional and geographic naming system provide some classification and categorization structure.

2. Improvements. Expand as necessary TLD tags, but restrict that expansion to manageable limits. Expand the use of 2LD and perhaps 3LD standard naming conventions. Consider the use of .tm (trademark) to indicate a "protected" domain -- <corporate_icon>.tm.TLD would be restricted and protected. Non-.tm 2LD might not carry the same level of trademark protection.

3. Administration of domain name systems. Technical NGOs are inadequate to the task. Perhaps the system could be managed by an arm of the ITU, advised by a board consisting of the interested stakeholders and constituencies. That board could be nominated by important NGOs, other IGOs, commercial entities and trade associations, governments, universities, governments, the intellectual property bar, etc.

5. Retire gTLDs. I see no compelling reason to do so. Some see gTLDs as indicating implicitly an American registry, others have accepted it as more universal. The geographic TLDs are sometimes interpreted, particularly in commercial circles, as more parochial or regional in character. As a consequence, non-US commercial entities sometimes adopt functional rather than geographic registrars. That may lead to minor confusion. However, many corporations have a global character and the functional TLDs may reflect that.

8. Transition to New System. Slowly, if at all.

9. Other issues. Use of 2LD and 3LD standard tags.

10. Technical, practical, policy restraints on new gTLDs. From a practical/policy perspective, gTLD proliferation can lead to confusion and perhaps a breakdown in its usefulness as an information organizing medium.

11. Create new gTLDs? Yes, or move to a 2LD system. But limit the number of gTLDs.

13. Separability of gTLD from ISO 3166 TLDs. Certainly there are jurisdictional and syntax differences between geographic and functional TLDs. gTLDs, other functional TLDs, and geographic TLDs are administered by different root registrars. That is manageable. However, all registrars need, no, must follow protocols and standards which facilitate Internet communication.

14. Other issues. Please consider the adoption of 2LD and 3LD standards as well as a reasonably rational approach to the allocation of TLDs by group and classification.

F, Trademarks. The trademark issue will dominate the TLD debate since interests are so vested and extensive. All sides in the debate make valid points. While trademark law is extensively developed, its application tends to be more national than international in scope. There does not yet exist an adequate body of international jurisprudence to mitigate the challenges resulting from the Internet, a largely unregulated and truly international medium. Reliance on national regimes will likely prove inadequate. Moreover, efforts by technical NGOs to regulate this issue will not only fail, but will probably significantly reduce the perceived competence of such NGOs in their established areas of expertise and proficiency.

B. Background

I am a student in the MSLS program at the University of Tennessee writing a thesis on the longevity and constancy of Web pages and Web sites. I hold a PhD in government from Cornell (1977). I am author/co-author of a number of papers on Internet searching, cataloging, and related issues. Most recently I presented at the Internet Society Meeting (June 1997) on search methodologies. I have also been employed by an information broker/consultant as a senior researcher to a US government agency to develop methodologies for WWW cataloging (for a list, my c.v. can be found at http://www.public.usit.net/willing)

Number: 62
From:      Surffing The Net rev@starnetinc.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 11:44pm
Subject:   Domain names

Yes you should control names, but for adult or porn sites it should NOT
HAVE A: .com, .gov, .org or any ext. like what we use. Its early in the
game of the internet and NOW YOU can do something. Make a new ext. for
all the "Adult" sites so our filters can avoid them. Our teens using
computers at schools and other public places can't get "adult" sites.
Don't take away freedom of the net. We can't look over what our teens
are seeing on the net, but we can do something about access to the
sites. Filters work but what if some teens want to learn about safe sex.
The filters we now have will not let the word "sex" go. 
Here, I have a new ext. for all the "adult" sites: .adt or .21
Please look into this.

Thanks for reading this. :)
  Ron Vikara        rev@starnetinc.com
  Villa Park Il.

Number: 63
From:      "David A. Matson" dmatson@bigfoot.com>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/6/97 8:08pm
Subject:   domain names

The best thing to do about domain names is just let go of them.  Let
competing technologies try to figure out what should be done and create a
De Facto standard.  Why? 

1. It won't cost the government any money.
2. It has worked for everything else on the Internet.
3. The best, or one of the best technologies will become the standard.
4. When privatized, almost everything becomes better.

I hope this helps.

David Matson

Number: 64
From:      Paul Nixon colt45@netvalue.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 4:30pm
Subject:   Re: Commerce Department Domain Name Proceeding

>"The Internet has thrived in an environment of communal discussion and
>consensual decision making, largely free from government regulation," said
>Commerce Secretary William Daley.  "Many believe that its extraordinary
>growth and success stem, at least in part, from its decentralized structure
>and bottom-up self-regulatory governance.  The Clinton Administration
>strongly believes that our challenge is to resolve these issues within that
>unique structure and governance."

The above is exactly why the Clinton administration, the Commerce Dept, and
the Federal Government as a whole should stay the heck out of any effort to
resolve this issue.  Let is resolve itself: it will, likely better without
bureaucratic involvement.

Number: 65
From:      Bonita Walker bonita@4dcomm.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/6/97 1:53pm
Subject:   Domain Names

I am not sure about alot of this but I was thinking about the porno on
line problem and  wondered it it would be feasible to end all the names
with .sex. That way browsers could have options not to let them in and
if they put it out with another ending they would be fined or something.
Just a thought.