From: <David.A.Zelin/>
To: NTIA.NTIAHQ(usdomain)
Date: 10/6/98 9:45am
Subject: Request for Comments on the Enhancement of the .us Domain Space

I would like to submit the following comments:

1.How should the present geographic structure of .us be extended or modified? What changes should be made in RFC 1480 or the posted policies for .us?


By doing so, companies would be allowed to reserve attractive domain names, such as YAHOO.US, MICROSOFT.US or JOESPIZZA.US while not interfeing with the existing hierarchy whatsoever. All domain names or 1, 2, 3, (or possibly 4) characters should be reserved for use by subdomains, including all the current geographic and government subdomains that currently exist.

Please consider this carefully, as I believe this suggestion allows all currently existing domains to continue to work unaffected, while allowing US companies and individuals to get  attractive domain names. Without allowing attractive, 2nd-level domain names to be registered, I beleive any other proposal would fail since other options such as foriegn domains that allow domains to registered as ".TLD" such as .CC,.TO, and .AT, or lengthy .COM names would be more attractive to them than a 3rd- level "COMPANY.WHATEVER.US" domain. I also beleive that any proposal that would require any existing domain names to be changed would also fail due to resistance from existing domain name holders.

2.What are the benefits and costs of different options for allocating second-level domains under .us? How should the allocation of such second-level domains be decided and administered? What should be the terms of delegation?

The cost would be that of setting up an new NIC server. Please check the servers at TONIC.TO and NIC.CC . I beleive both of these site are great examples as to how simply and efficently a NIC server can be run, although obviuosly might need multiple dedicated servers to handle the load of requests and to prove redunancy against server failure.

3.Specifically, should special-purpose second-level domains be created under .us? What are the benefits and costs of creating particular special-purpose domains (e.g., industry-specific, credentialing, zoning)? How should such domains be created and administered? Are there reasons to map names and other addressing and identification systems (e.g., postal addresses, telephone numbers, longitude and latitude, uniform resource numbers or others) into .us?

Indivuals and companies should have the right to register 2nd- level domain names of a mimimul name-length automatically and without restriction. When a person/agency/company wants to create a subdomain, there should be a committee to deicde if  a 1, 2, or 3-character 2nd-level domain should be allocated to them. Specifics of creating this committee should NOT interfer with immediate approval of allowing 4 or 5 character or longer 2nd-level domains directly under the .US domain.

4.Alternatively, should .us be treated as an unrestricted top-level domain like .com or should one or more specific second-level domains such as or be used for unrestricted assignment of domain names (as in .com)? How should such unrestricted domains be administered and by whom?

An automatic NIC should be created, similar to NIC.CC or TONIC.TO to allocate domain on a first-come first-serve basis, restircted only by a modest per-domain-name name. No other restriction should be place on 2nd-level domains 4 or 5 characters mimimal length.

Domain disputes resulting from trademarks can be handled by the courts, without any offical NIC involvement, asside from revoking, suspending and transfering domains in compliance with any court order.

5.How should conflicting proposals and claims to manage or use .us subdomains be resolved? Who should have responsibility for coordinating policy for .us over the long term? What public oversight, if any, should be provided?

A commitee should be formed to address 1, 2, and 3-letter 2nd- level subdomains on a 1-by-1 basis. The specifics of how to impliment such a commitee should not interfer with the immediate creation on an automated NIC to handle 2nd-level domain names of 4 or 5 letter in length.

6.What rules and procedures should be used to minimize conflicts between trademarks and domain names under .us? Should this problem be treated differently at international, national, state, and local levels? Should special privileges be accorded to famous trademarks, such as a right to register directly under .us or a procedure to preempt the use of the trademark in a range of subdomains?

Domain name disputes ought to be handled by the courts. In the case of famouus trademarks, it should be easy to  obtain a court order to transfer to the domain as appropriate. The court system should continue to handle trademark litigation and that power should not be transfered to any other agency specifically for the purpose of domain name registraton.

7.What role should states play in the allocation and registration of their respective subdomains? Should commercial names be permitted under states as third-level domains? Or should such third-level domains be limited to special categories such as domestic corporations or other state-licensed entities?

The states have already been allocated 2-letter 2nd-level domains and should be allowed to handle them through existing domain-name registration processes and/or local legislation.  They should not control the general purpose 4-5 letter 2nd-level domains which should be handled by a federal registry as provided by the US constitution's permission for the Federal government to regulate interstate commerce.

Should states and localities operate registries and accept registrations directly? To what extent should state policies be coordinated and through what mechanisms and procedures?

States have been allocated 2-lette 2nd-level domain names and write legislation to either administer them directly or allow other entities to administer them on thier behalf.

8.How well has the system of delegating third-level domains (localities) to private registrars on an exclusive basis worked? How could it be improved? Should registrars be accountable to their delegated localities (just as country-code registries are accountable to national governments)? Should registrars be limited to a single jurisdiction? Should multiple competing registrars be able to register under any local, state, or special-purpose domain under .us as in the plan proposed for generic Top-Level Domains?

I believe that the largest problem with existing domain name registration is lack of domain for cumbersome and unattractive 3rd level domains.

I beleive new domains ought to become available immediately as outlined above, and that states ought to regulate thier own local 2nd-level domains as they see fit.

9.How should the operation of the .us registry be supported? Should uniform registration (and renewal) fees be instituted? Should registrars contribute to the operation of the registry?

I beleive that an automated process with uniform registration and renewal fees should be instituted. I have no strong suggestion or preference as to who administers it, other than to say that it should be done effiently and through automatition.

10.What are best management and allocation practices for country-code domains? What practices should be emulated or avoided?

Automated registers, allowing immediate and direct registration online should implimented. Access password should be issued immediately for DNS updating and modifications to billing and owner information.

I believe the registries at and should be emulated. I beleive that any process that requires human interaction and email forms should be avoided whenever possible, although email-registration and phone and mail-based customer support should be available at the customer's request.

11.By what type of entity should .us be administered? Private, governmental, or quasi-governmental? For profit or not-for-profit? What are the advantages and disadvantages of using one type of entity (private, public, for profit, not-for-profit) over the others?