07-08-97 Electronic Filings on Internet Domain Names

Number: 85
From:      Jason Brown farland_er@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 1:03am
Subject:   New internet domain names

I personally like the idea of new domains on the internet, especially
.store and .web.  I also think there should be a board or some such
group (internationally) to assign and maintain domain names, outside of
a company, because the internet is too big to be controlled by a

Number: 86
From:      Alan Bleiweiss alanb@htp.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 1:30am
Subject:   Request For Comments - Domain Process

As an Internet Development Manager since 1994, I can simply state my
comments in one paragraph.  It is imperitive that the domain
registration process be freed of its current stranglehold by one
organization.  In order for the Internet to flourish and grow, as it
should, this process must be democratic and fairly distributed amoungst
many companies.  The present system is archaic, dictatorial, and
destined to cause severe havoc as the masses continue to move to this
new medium.
Alan Bleiweiss
Project Manager Web Implementation
NetHaven - The Internet Division of Computer Associates International

Chairperson, Long Island Webmasters Guild

Number: 87
From:      Michael Gersten michael@stb.info.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 2:27am
Subject:   DNS system comments

I want to support the EDNS style system, and the existing  
EDNS servers.

What are the benefits of the EDNS system? Simple. Anyone  
can start up a top level domain, by simply having a few  
basic, essential requirements taken care of. There is no need  
to be a big pocket, major cash player to play; it is very  
concevable that five or six different non-profit, hobbyist  
groups can get together and set up their own top level  
domains, at no cost to the users.

Compare this to Alternic's system, where you have to spend  
$1000 (I belive) to register a top level domain.

Or, compare this to the (now defunct) Postel Draft from  
IANA/ISC, where there was a 2% fee of any money collected  
from the registries, to support IANA (which now seems to be  
getting out of the business, although I may be mistaken  

Are there drawbacks to the EDNS system? Yes. First, you  
have a first come, first served system, with non-shared top  
level domains. Is this a problem?

First come, first served, is (essentially) how the current  
system of domain registration is _SUPPOSED_ to work. In  
reality, the people currently running the .com domain (which  
is what most people consider to be the domain name  
system) will arbitrarily yank a name if they think that  
someone else might have a trademark status that would  
result in their (the registry) being sued in court; this policy  
has, in fact, resulted in suits from people who have lost a  
domain name.

Is there a problem to first come, first served on the top  
level? No more than on the second level. Just as someone  
registered television.com, (and someone else then registered  
tv.com), just as two different acme corporations have to get  
different names (only one acme.com), just as I have seen the  
name "Common Sense Computing" taken in two different  
counties as a name for a computer consultant (two different  
people), any sort of "one name per world" will have overlap.  
This is not a serious objection.

Is there a problem to non-shared registries? Not really. A  
shared registry ultimately is silly. Computers do not look up  
your name by the registry, they look it up by the zone file. If  
two different registries are serving the same zone file, they  
have to share the data, and there is *NO* difference as far as  
any user can see in the service performed, the only  
difference is the price to register. This is not enough of a  
reason to force a lot of changes on the system.

A bigger question, and one of far more importance, is who is  
to own the existing registries. Right now, existing top level  
domain names have been given to people who have,  or are,  
abusing it. Examples? The .us domain, which is geographical  
by state. One state was given to an ISP in that state; the  
cities in that state then organized, and wanted to each be  
listed (sorry, I don't remember the name of the state) at the  
third level. Because of the large number of cities in this state,  
the ISP refused, and would only allow a small number at the  
third level (below which it would delegate out to others at  
that level). That may be appropriate for county level division,  
but that's not how the .us domain works, normally. Consider  
that we do not say "los-angeles.la-country.ca.us", we say  

Worse? One country is "lucky" enough to have the top level  
domain of ".tv". This is a little, poor country, offshore. This  
domain name is suddenly the most valuable asset it can  
have. Except that there is a private company, an ISP that  
was given control of that name.

I really think that fixing the existing bad delegations of  
names, away from ISP's, and towards the people who will  
actually USE the names, and who the names represent, is  
more important, in the long run, than worrying about  
expanding the top. And I think that a "no big pockets  
needed, simple and basic system" is the best way to go; this  
is the EDNS system (www.edns.com).

Note that I'm not saying that I think that the people in charge  
of EDNS currently are the best qualified to run the top. At  
some point, some one person or group has to be  
responsible for saying what is and is not in the top. EDNS  
has some seemingly straightforward restrictions -- a top level  
name may be rejected for unspecified reasons (example:  
had the CDA been upheld, the name ".sex" would not have  
been allowed), or for perceived copyright reasons (example:  
someone registering ".ibm" or ".toyota" without actually  
representing the company in question). Although these seem  
like reasonable policies, there's a lot of actual cases and  
details to be worked out. The actual policies used in practice  
may not be so good, and may require the people who  
determine "what's in the top" to be changed.

Finally, there's a bigger problem: The top level is global, not  
US. I personally don't think that the U.N. is the right group to  
control this, nor would I trust any multinational corporation.  
If I had to name an individual that I thought could do it  
properly, I'd name Jon Postel of IANA/ISC, but even he will  
die eventually. I have no clue as to how to determine any  
sort of long term solution to this problem.
Michael Gersten     michael@stb.info.com      http://www.stb.info.com/~michael
NeXT Registered Developer (NeRD) # 3860 
Without Prejudice, UCC 1-207
** HIRE ME: http://www.stb.info.com/~michael/work/

Number: 88
From:      wallace koehler wkoehle@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 6:07am
Subject:   gTLDs

NOTE: I sent this in Word 6. I went to check the quality of transmission
at your site and was unable to open it. Here it is enclosed in email.

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

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

     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

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

     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

Number: 89
From:      Andrew Hofer ahofer@nstsystems.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 8:19am
Subject:   Comments on Domain Name Administration

I manage multiple domains for clients of my company, NST Systems, Inc. of
Stamford, CT. The paramount concern that I would have regarding a change in
administration of Domain names on the Internet is to make certain that a
SINGLE entity is responsible for registering and resolving names at the top

Please don't perpetrate another disaster on the American public in the name
of "antitrust" by breaking up a single, well-coordinated company into
dozens of competing, disorganized entities all vying for our attention and
screwing up our records.

When the US Government broke up the phone system, AT&T advertised only for
"corporate image" and otherwise ran a good system where the most important
feature was that you never had to think about their service... you just
took it for granted. Now the phone system has been a complete mess for
years, with hundreds of thousands of our dollars wasted on advertising to
get our business, dozens of little phone companies constantly trying to
switch our service and convince us that what we want is "choice." The
public doesn't want "choice" in what are perceived as utility services --
they just want SERVICE! The public doesn't care whether the service is
competitive -- the price we pay for competition is greater than what we pay
a monopoly! Just look into regulating these monopolies properly to keep
them reasonably fair, and otherwise don't bother them. If competition is so
great, why don't we allow alternative federal governments and let each
member of the public choose a governmental "service provider" according to
which government has the best rates and sales pitch? How effective would
THAT be as a way to run the country?

Andy Hofer
NST Systems, Inc.

From:      "techmage" techmage@peganet.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 8:47am
Subject:   NSI

Network Solutions Inc, as it currently operates is a monopoly in its most
clasical form.  Its rates are way outside what its service entales. $100
per domain, per year is ridiculos, when you consider what is costs them to
perform this service. 

The Dark Tower can be found at:

From:      whetzel@kpmg.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 9:32am
Subject:   DNS

I would prefer that the commerce department maintain the spirit of the
Framework for Global Electronic Commerce.  Though the CD has been tasked
by the president in a backdoor maneuver to evaluate the DNS issue, let the
the non-government, non-profit organizations continue to oversee these
functions (in the spirit of the Internet not being burdened by government

The Internet is one area which I would prefer not to see "the law" forced
upon Internet users for the sole reason that certain individuals feel
"law" should be in place.  If the government starts regulating the DNS
issue, then it's foot is in the door -- a fox in sheeps clothing.  Don't
evaluate; don't recommend. 

William D. Hetzel
1029 Blvd East, #5
Weehawken, NJ 07087

From:      Chrissy cmcguire@nkn.net
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 11:09am
Subject:   InterNIC

I work for an Internet Service Provider and am in charge of domain name
registration for our customers and have had nothing but trouble with
InterNIC's billing department.  I have had instances where InterNIC has
deposited our check and it has posted at our bank and then 3 days later,
they have put the domain that was paid for on hold for non-payment.  The
people that answer the phone are completely incompetent and all give
diferent answers to the same question.  I have then later talked with their
supervisors about it and they are just as incompetent and act like they do
not care.  Supposedly in April they overhauled their billing system but
nothing has changed.  I am so glad that they will not be handling domain
name registration after March of 1998.  My suggestion for the future of
domain name registration is to learn from all of InterNIC's mistakes,
especially their billing mistakes.  Thank you.

Christinia McGuire

Number: 93
From:      cardclb cardclb@swva.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 2:01pm
Subject:   Sincere suggestion for domain names.

Domain names should be set up like the phone book.

For ex.:

www.government should take us to a very patriotic and official page with
links to all gov't related sites (i.e. www.government/congress).


www.church should take us to a page with every type of church. Then
www.church/catholic should explain the catholic faith and have links.


www.computer should be related to the industry with appropiate links.


www.personal would lead to www.personal.johnsmith

I would leave off that "www.", too, if it were me. 
Thank you for your time, if you bothered to read this far. -Chad

Number: 94
From:      Arlie Davis arlied@microsoft.com>
To:        "'dns@ntia.doc.gov'" 
Date:      7/8/97 3:23pm
Subject:   Comments on the InterNIC

I helped to found a small, successful Internet service provider.
Interaction with the InterNIC was a crucial part of the job.  So I am in
a good position to comment on the quality of the InterNIC's service and
their policies.

First of all, the quality of the service at the InterNIC has gotten much
worse since they started charging for domain names.  The service is, at
best, inconsistent.  Sometimes requests sent to the InterNIC would be
processed within a week; very often, requests would take more than a
month or would simply be lost.  The InterNIC argued that charging a
(very high) fee for its services would guarantee fast, professional
service.  It has completely failed to deliver on its promise.  As a
partner in a small Internet provider, our ability to serve our customers
(who needed domains registered) was severely hampered by the
inefficiencies and high cost of dealing with the InterNIC.

Second, the quality of the policies of the InterNIC are not
satisfactory.  There needs to be a system of arbitration for domain
names.  The responsibility for choosing who gets to register a domain
name needs to be separated from the companies that provide the
root-level name service.  The idea of a single, private company like
Network Solutions having absolute control over the namespace of the
Internet is abhorrent; imagine if a single company governed what other
companies were allowed to name themselves, or goverened how street
addresses were assigned in new cities.  This needs to be done by an
external body which does not have a financial interest in the outcome of
the decisions.

The InterNIC has no pressure at all on it to increase the efficiency and
decrease the cost of its services.  It is impossible for a competing
company to provide the same services.  The best solution would be to
separate the responsibilities of the InterNIC into two types of
organizations.  The first would necessarily be a single organization,
possibly an agency of the US federal government or an international
body.  This organization would govern the namespace of the Internet, and
would arbitrate disputes over domain names.  The second type of
organization would simply provide the actual network services required
to provide the Domain Name System; it would not make any policy
decisions.  Many different companies could act in this role; the
competition among them would necessarily allow for a cheaper, more
robust, and less easily-monopolized Internet.

Thank you for your time.

-- Arlie Davis

Number: 95
From:      calvin calvin@ibm.net>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 4:02pm
Subject:   government operation of domain name system

I personally don't see why the government couldn't continue to run the
domain name operations.  To feasibly run the system the government could
just turn part of the operations over to the patent office and when they
issue a company a patent on their trademark why not at the same time
issue the company a patent for a domain name with the same as that of
the trademark?  The other alternative is to set up a computer program
that would automatically generate a domain name based on the patent
number given to the company for their trade mark.  The latter of the two
solutions I suggest would eliminate squabbling over who gets what domain
name.  To pay for the government operation would also be quite easy. 
All the government would have to do is to add a small tax of say $.05 to
$.10 cents per month onto all personal ISP accounts and $.15 to $.20
cents per month onto all business ISP accounts.

Number: 96
From:      Glen McCourtie gfmccourtie@juno.com>
To:        NTIADC40.NTIAHQ40(dns)
Date:      7/8/97 7:08pm
Subject:   Internet Domain Names

I believe the government needs to stay out of the Internet.  The
government has already, with little success, tried to "help" the
Internet.  But, it has caused more harm to the the Internet than any
"good intentions" it has tried to act upon.

Glen McCourtie
238 Ballard
Jackson, MI 49201