07-07-97 Electronic Filings on Internet Domain Names

Number: 66
From:      Michael Perelman michael@ecst.csuchico.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 11:44pm
Subject:   domain names

This is an area where public entities should be in control.  It should
be a matter of book keeping -- rather than letting a private company get
a monopoly.
Michael Perelman
Economics Department
California State University
Chico, CA 95929
Tel. 916-898-5321
E-Mail michael@ecst.csuchico.edu

Number: 67
From:      "Scott Novotny" cyberhusker@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 9:13pm
Subject:   Re: Domain Delema

Dr Barbara

Its about time.  

The Federal Communications Commission has experience in regulating Amateur 
Radio.  This experience would prevent the "Internet Domain Name Crisis" from 
becoming critical.  Licenses could be issued in the same way Amateur Radio 
licenses are currently issued.  Without a license a "Domain Name" would be 
bootleg or illegal.

It is important to note that Amateur Radio is currently self regulating by a 
group of Volunteer Examiners (VE).

In the 1910's the Federal Communications Commission (FCC), probably called
something different at the time, started regulating Amateur Radio
requiring registration, regulation, and testing for technical competency. 
Upon completion of FCC requirements for an Amateur Radio Station License,
a certificate was issued.  There have been fees (i.e. monetary charges)
associated with this "privilege" of conducting radio communication.  In
the case of the Internet, fees could be applied to administration of this
valuable resource. 

Number: 68
From:      Todd Terbeek ToddT@TechWave.com>
To:        "'dns@ntia.doc.gov'" dns@ntia.doc.gov>
Date:      7/7/97 7:31pm
Subject:   Domain names

My concern is not so much about who has control over handing out the new
names, but more the process that will be used to assign them.  My
company has been developing its business around several of the domain
names that we have secured.  It could hurt our ability to conduct
commerce on line if the new names are given out with a first come first
serve process.  If we build an online store at one of our names with a
.com or .net ending, and some one takes the .store version of that name
before we can, it could hurt our business.

I believe that a process needs to be put into place that gives companies
that own .com or .net domain names the first shot at those same names
with the new extensions.  There are a good number of companies like mine
who have taken a big risk to pioneer Internet commerce.  While I agree
that the ex

Number: 69
From:      Franklin Seal Franklin@sisna.com>
To:        NTIADC40.SMTP40("dns@ntia.doc.gov.")
Date:      7/7/97 7:16pm
Subject:   domain name registry opinion

Thank you for accepting public comments regarding the domain name registry

I depend on the internet for my business as well as for much personal
information.  I have registered my company's name Handsondrums.com but have
yet to put it to use.  I paid $100 to reserve this name for a period of two

In my opinion the system used to date has worked well but is no longer
appropriate.  I believe the system should be changed and should reflect the
following principles:

1. It should be an open system - 
     - not regulated by a government or by a commercial enterprise.
     - the database of registered names should be open and searchable by anyone
(what purpose does it serve keeping ownership of names from public view?)
     - aquisition of a particular name should be on a first-come-first-served
basis and should not be screened by any other process or group
     - any legal conflicts resulting from prior trademark registrations can be
dealt with by the same jurisdictions as would handle trademark violations
in any other medium (we don't create a separate trademark resolution
process for each of the older mediums - television, radio, newspaper, books
etc... so why do so with respect to the computer/networking medium?)

2. It should be an open-ended system -
     - if the registry database is open to all and can be querried in real-time
from any where in the internet there is no technical reason that the number
of top-level domain names be limited to any pre-set group (eg. the old 7
.com .net .gov etc..., or the new 15, or whatever number).  Barring
technical reasons for limiting the number of top-level names the rules for
adding a new top-level name should be kept to a minimum (eg. number of
characters as large as feasible) and the process should be as accessible
and as flexible as possible.  This way, if someone has already taken the
particular name you want within your desired top-level, you can simply
choose a different top-level name, or invent a new one if all of those are
taken.  Given that cyberspace is infinite or nearly-so, the only reasons to
limit the "real estate" in cyberspace is to create artifical scarcity for
commercial explotation.  In the interests of the general public, your
commission should avoid making decisions favorable to the creation of
artifical scarcity.  And don't be suckered by the arguements that without
it, capital will avoid investing.  Even in a world of unlimited cyber real
estate, corporations will still have plenty enough to gain from investing
in cyber development to motivate them.

3. The cost of maintaining the registration system should be spread as
evenly throughout the internet as possible.
     - an example would be to take the annual cost of maintaining the servers,
software development, administration etc... and divide the total by the
number of registered names.  Email the individual registered owners of each
name with the bill and give them a month to pay.  If they don't, the name
is up for grabs again.  Or if that is too unscaleable, bill each ISP or
host and they can just bury the cost in their fee.  It becomes part of the
price of the web server space.  The point is to keep the cost to a direct
portion of the actual cost of physically maintaining the system.  There is
no moral or economic reason for charging for the "privilege" of having a
name in cyberspace, anymore than there is a reason for charging people for
the privelege of having a personal name in society.

4. Given a registration system that is maximally open and inexpensive,
there would be a need to block individuals from trying to create an
artifical shortage of names by automatically registering millions of names
a day.  This could be accomplished by putting a limit to the number of
names registered per day/month/year by any given individual (in the same
fashion that banks put a limit to the amount of cash you can take from an
ATM within a single 24 hour period).

Thank you,

Franklin Seal

Hands On Drums
2691 Desert Rd.
Moab, Utah 84532

From:      Greg Shields hawkmoon@mindspring.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 6:11pm

I support the international plan to add new domain extensions.

I am against the monopolizing of domain name extensions by any
private source for profit.

                                      Thank you,
                                         Greg Shields

From:      "David Bowser" jhadas@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:49pm
Subject:   Domain Names

Although I agree that the movement away from the US gov't control of the
domain naming is correct, the responsibilities should not be transfered
until the new organization meets a few key criteria: 

1. Internationally recognized as non-profit organization
2. Knowledgeable leadership within the organization (i.e. computer
scientists and academics with international experience, not bankers and
business people)
3. Accountability to some organization like the U.N. (but not the U.N.!)

The internet is as free as is gets and we don't need a bunch of
governments trying to mold it into their ideal image. 

Thanks for reading,

David Bowser

From:      Marc Beauchamp mbeaucha@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:43pm
Subject:   Domain names

We don't need duplicative and chaotic domain names.  Neither do we need
an elaborate international bureaucracy to assign names and arbitrate
disputes.  Seems to me the procedure we've got right now is just about
right.  Except that the federal government can't leave a good thing
alone: i.e. the Justice Department's just-announced anti-trust
investigation of Network Solutions.  Which, like Microsoft, has done a
fine job thus far of keeping customers happy.

Marc Beauchamp
2231 Kings Garden Way
Falls Church VA 
Email: mbeaucha@ix.netcom.com

P.s. I thought clinton said he wanted Washington to adopt a hands-off
approach to the Internet and electronic commerce??!

Number: 73
From:      Jay Glicksman jay@jg.org>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 4:05pm
Subject:   Comments on Internet Domain Names

Addressing item C. Creation of new gTLDs, in particular points
11. additional gTLDs; 13. gTLDs vs. ISO country codes; and 14. other issues

The issue I want to raise is that of domain names for individuals. I
strongly support a hierarchical gTLD for individuals to prepare for the
time when there are hundreds of millions of people on the net that want to
be uniquely identified.

- there is a proposed gTLD: .nom for individuals. That is a start but I
think it requires more structure.

- personally, I don't like .nom and would propose .ind (for individual) as
the name for this gTLD

- this gTLD should be separate from the ISO country codes since individuals
move between geographic entities

- individuals should only be able to register variants of their own names.
If your name is Bob Smith, you can not register WilliamClinton

- nicknames should be supported but need to be identified via its own gTLD
or perhaps a subdomain of ind (e.g. flash.nick.ind)

- some sort of hierarchy is needed to separate names to avoid the
bob987654321 "syndrome" found on AOL and similar services. I don't have a
particular proposal on this issue but think that it is important

- in the future "appliances" will have internet addresses, so subdomains
below the individual's name will be necessary. For example, my car could be
designated honda.jay.ind. A standard format would help clarify the name of
the appliance from the name of its owner

I am in favour of a limited number of meaningful hierarchical gTLDs, so
that addresses scale and have identifiable meaning. Individuals on the net
with their own non-commercial domains will be a major growth area in the
coming years and think that this is the appropriate time to develop the
appropriate nomenclature.


     Jay Glicksman

Number: 74
From:      "Nate Lambeth" nlambeth@usa.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 3:17pm
Subject:   Request for Comments on Internet DNS

I believe that the DNS should be left as is. Either way it is managed will
inflame one party or another, so forget politics and leave the Internet to
manage itself. It has before, and it will continue to.

Nate Lambeth

Number: 75
From:      "admin2" admin2@caspers.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:34pm
Subject:   Domain Names

It is important to make it clear that the current naming system is
extremely over burdened and is in dire need of relief. Many of us who run
ISP's have found it difficult at best to deal with and/or work with the
current holder of the domain naming registrar of  the .com , .net . and
.org domains (Network Solutions). They have opposed all manners of reform
(adding more domains, splitting the current domains up to add better
service, etc.) myself and my associates find ourselves at the mercy of a
corporation that not only is acting as a money hungry tyrant but has
literally split in then face of the National Science Foundation, who did
not have to give them the contract in the first place, by stating they will
continue to hold control over the domains they currently administer. Well
we, the ISP's of the world having been talking between ourselves and we
pretty much agree that as soon as the new domains are in place we will push
to have our several million combined clients move away from the .com domain
in particular, we all, for the most part, got into the Internet for our
love of it and will tolerate no monopolies from Government or private
sectors what so ever. I will make one prediction you can bank on, those who
support openness and are genuinely so will prosper with our business, those
who don't will be a memory of what they could have been.

Shawn A Suzik
Network Admin.

Number: 76
From:      "Cay Villlars" cvillars@globaldialog.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:22pm
Subject:   Comments on IP address administration.

The issues I see are as follows:

Intellectual Property.  Although IP addresses were not originally designed
to be "intellectual property", as commerce on the net explodes it is clear
that they have become as critical part of a company's intellectual property
as a copyright, trademark or SMark, or even 1800 numbers.  Many of the
lessons learned from developing/managing these "properties" are applicable
in developing a method to managing IP addresses.   

IP addresses should, at a minimum, have some of the same features and
protections as Trademarks- you can apply in advance of use, but full
protection is only gained by actual use in a commercial venture, like
trademarks on a product. (to prevent IP hawks from buying up IP addresses
and selling at inflated prices) .  Like copyrights, continued coverage
requires continued use.

However assignments are made,  an IP address MUST remain unique (or there
should be an option even though it costs more).  That is, it is NOT
acceptable to have microsoft.com and microsoft.edu considered to be
different domain names.  Like a trademark, a company should be able to pay
more to exclude others from using any other Company.* designation that
would potentially cause "confusion". 

Sticky wicket-  obviously many companies have trademarks that are
identical, but acceptable, because they are in different class categories. 
(for instance FALCON, EXPLORER, etc.).  I don't have a brilliant suggestion
to address this, other than suggest that it may have to be resolved based
on FIRST commercial online use.

Access.  There should ALWAYS be free public access to search the IP
database to see if a name is available.

Affordability.  The question is, how to keep domain names that offer
"trademark-like" protection affordable?  The current fee of $100 for two
years is affordable. However, is this enough money to support a program
that would give domain names the same protection as a trademark?   I
suspect companies would pay a significant amount of money to insure
stronger protection for their domain name.  Perhaps their could be
different levels of protection that could be purchased.  Basic would be
$100, with higher levels of protection for company or tradenames.  Perhaps
a company could pay an extra $50 dollars when filing a trademark, S-mark
and get a "option" on  a IP address.  In order to become "active" the IP
address must be in use, say within 3 months of the Trademark registration. 

Speed and simplicity.  It seems that the current assignment process is
relatively quick and painless (it can be done online by the average person,
as opposed to paying an attorney). Can your agency help us keep it that
way, while providing the intellectual property protection that
entrepreneurial America desires? 

I think the pressure on your agency regarding this issue will be enormous,
and I wish you well in working it out.  I am  not an attorney, but have
delt with intellectual property issues as a marketing person for almost 15
years.   If I can help in any way, let me know.

Cay Villars 
Market Value Concepts

Number: 77
From:      "Theonly.com" neweyes@ix.netcom.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 11:03am
Subject:   Domain Names

I feel that there should be an unlimited # of domain name registrars. The 
Internet is about leveling playing fields not creating monopolies. Plus, 
if there we're many resistrars registrars will be able to help the people 
in their own countries much more effectively than one central company 
would be able to.

John Catlin
President, TheOnly.com
3 Shore Dr.
Shutesbury, MA 01072

           John Catlin  ---  NewtonCentral
      john@theonly.com & neweyes@ix.netcom.com
        Daily news and updates for the Newton

Number: 78
From:      Annie Keitz keitz@his.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 10:32am
Subject:   Domain Names

To Whom it May Concern:

I run the website for Viewers for Quality Television (http://www.vqt.org/).
 We are a low budget (shoestring actually...) non-profit organization
devoted to educating the public about the television industry.  As such we
are very much in favor of keeping the Internet as a place where the little
guys like us can rally the people.  Currently, Internic charges an
inordinate amount of money for a domain name -- and does not provide timely
quality service for the money they take from us.  We had to mail and fax to
Internic copies of credit card bills not once but three times to prove that
we had paid for our domain name, each time Internic threatening to cut us
off.  I'm certain that if Internic did not hold a monopoly on domain name
registration,  it be would cheaper to register domain names and the billing
process would not be so error laden.


Annie Keitz
Annandale, VA USA

Number: 79
From:      "Ashton, Mark" Ashton@csi-health.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 9:52am
Subject:   naming schemes...

Top level domains should be to the internet what zoning strategies are
to a city. By glancing at a domain name, one should be able to tell
generally what one is getting. This helps users better understand the
sites they are thinking of visiting. The current system has not worked
out too well, since the majority of sites cluster in the .com domain.
Perhaps some differentiation among .com sites (perhaps along industry
lines) might be in order. I think an important domain that should be
added is something like .adt, for sites serving only adult material.
This would be equivalent to many city schemes for throwing adult stores
into one area of the city. It makes these sites easier to keep track
off, harder to simply stumble across, and keeps them out of more
legitimate areas.


Number: 80
From:      "J. Woody Meachum" akawoody@imaxx.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 6:12am
Subject:   Domain Names

I am not opposed to the addition of more extensions.  In many ways it
will help the user better identify and police their individual systems.

One prime example of this would be for a topic that I have been
discussing with my wife who is a librarian.  They are require to NOT
limit access to the Internet for their patrons, but they have been
receiving complaints by parents for allowing children access to
pornographic material.

With an addition of a .PRN extension, this would allow be like putting
that type of material behind the counter at a convenience store. 
Children will know it is there, but they will also know that it is
probably something they shouldn't look at until a certain age.  Also,
policing software could more easily be constructed to block out the .PRN

The Adult Entertainment business shouldn't be too opposed to this
either.  You are giving them their own section.  If someone wants that
type of information, they will know where to go.

It would be up to the Hosting Service to police their servers as far as
compliance of the rule.  I believe the government should not get
involved in the policing of this rule.

Other extensions we have discussed could be .MED (medical) and .MAG
(on-line magazines.

Thank you for allowing my input.

John E. Meachum
Oak Park, IL

Number: 81
From:      "Micha Hackett" mikehack@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:45am
Subject:   the US gov. must get out of domain name biz ... best left to UN
and the Swiss

US gov. must get out of domain biz ... leave it to UN and ITU.

Number: 82
From:      Herman Jusuf minkx@tamu.edu>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 5:23am

let the international ad hoc committee do the job. stop the monopoly.
Number: 83
From:      "Robert Vasilik" robert2000@msn.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 2:48am
Subject:   Domain Names

The current system of registering domain names is out of control. Neither 
InterNIC nor TABNet (The American Business Network) provide any notice to the 
user that he/she may, in fact, be committing trademark infringement by 
attempting to register a domain name.

A sytem must be put into effect which would make it mandatory for the domain 
registration PROVIDER to first check for trademark ownership before allowing a 
user to register a domain name. We can't expect millions of Americans to go 
online doing extensive trademark searches when the PROVIDER can accomplish 
this easily. 

I personally had to pay TABNet's $50 fee even after I notified them that my 
requested domain name was found to be in violation of trademark laws. Their 
attitude was one of disinterest. TABNet seems to be solely in the business of 
collecting as many $50 fees as they can get without regard to who may own 
rights to a similar name.

And what about the case of "XYZ Inc." which owns the trademark to "XYZ" and 
has the domain of "http://www.xyz.com?" Does another individual who registers 
"http://www.xyz.org," or "http://www.xyz.net" put themselves in jeapordy for a 
lawsuit for trademark infringement based on the usage of "XYZ"? 

Robert Vasilik

Number: 84
From:      "Douglas A. Wright" darkwing@storycity.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/7/97 12:51am
Subject:   Domain names

I believe we should adopt new names. It would serve to clarify where you
are going & help new people to the Internet look for what they want.

I also believe Network Solutions Inc. in unjustified in their stance, they
are just worried about losing their monopoly.

Also I think something should be done about these upstarts that are
purchasing names they believe some Co. will want & then selling them for
exorbitant amounts. I'm all for free-enterprise but that's border-line

Douglas A. Wright