DNS Comments Submitted on 8/19/98

From: Chris Steele <csteele@oar.net>

To: NTIA.NTIAHQ(usdomain),NTIADC40.SMTP40("csteele@ra....

Date: 8/19/98 7:07pm

Subject: Re: ACTION: Notice, Request for Public Comment

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?

You already have a system that works, why break it? The whole purpose of the

US Domain was to get geographical diversity. What you are implying is opening

.us TLD so that every company that has registered a .com will also register

a .us. Is this really desireable?

You repeatedly state that you are looking to open the US Domain up for

commercial use, however you fail to miss, that it already is. A company can

By opening up the US Domain, you are suddenly creating a need for every

entity on the internet to have TWO registered domains, the one that is

registered in .COM and now the one in .US as well, whatever the structure

you may come up with.

Is this really what you are striving for? Name diversity in .com should not

be a problem unless companies have the same name, at which point they should

consider registering in something more geographical and local to their area.

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?

As the US Domain stands now, in assigning a state agency the state code they

represent, it would eliminate the need for an entity not familiar with

the state in question to have to control registering within that state.

It would reduce the time/manpower/costs that are needed to keep up with

requests that currently come in to the US Domain registry (ISI). There does

need to be restrictions on who can get a second level domain (under the current

layout) to assure that it does not fall into the wrong hands.

Requirements to consider for delegation of the state to an entity could

include the following:

The state manager must also have the proper authorization by the state

government to perform this role. [We don't want there to be any

fights about who should be the state manager, there must be a

preauthorization step where someone (the state governor ?) designates

who the state manager should be.]

Set up and operation of the primary name server for the state code.

Set up and operate a "rwhois" server for all third level delegations

under the state code

Set up and operate an email mailbox to receive and process requests

for registrations under the state code. This includes provisions

for forwarding requests for fourth level names to the delegated

third level managers.

Set up and maintain a web page with information about the state code

and registration procedures, policies, and processes.

Now, if you are going to totally restructure the US Domain, as your request

implies you are trying to do, you will only need another entity like Network

Solutions to maintain the new domains you create, just as the .com, .org,

and .edu domains are maintained. But like I said, is that what you really

want to happen? I don't think so.

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?

No, they should not. If they are, they should be created carefully and with

discretion, you don't want to overpopulate the US Domain. The current structure

serves its purpose well. You can easily tell where an entity is by its name.

If you are unable to type 'YourCompanyName.<locality>.<State>.US' then register

in the already existing .COM. DNS was created so humans could enter in a

unique _name_ to reach any given machine. Now, people are realizing somewhat

of a limit to the names available, but are not willing to accept longer names,

which alleviates the problem immediately in the first place.

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 .co.us

or .com.us be used for unrestricted assignment of domain names (as in .com)?

How should such unrestricted domains be administered and by whom?

Well, you can NOT use .co.us as that would be the domain used by the state of

Colorado in the current structure, unless you were going to completely dismantle

the current structure of the domain. Opening up .us to anyone and everyone

will only lead to the same results you have right now with .com, except every

domain registered will now have a '.us' on the end of it. This makes that

decision pretty pointless. As for how they should be administered, efficiently

and timely? A request should not take more than a day or two. By who? Not

Network Solutions, but presumably some company with a very similar role.

Again, all you will have accomplished is creating another place for every

company registered in .com to need to register.

For example, Microsoft.com would now also be Microsoft.com.us. Would this

change accomplish additional name diversity? Not really, just double the

amount of in-use domains.

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?

The IANA is the authority over all top level domains. Once a domain is assigned

to an entity, it would seem to belong to them. If beyond that, it goes to

court over who has the rights for it, that is the lawyer's problems, not the

administrators of the domain(s) in question. Long term, it should probably

remain with ISI unless IANA has another entity that it feels should be

responsible for the US Domain.

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

trademark in a range of subdomains?

No 'special' privledges should be granted. No favorites should be played.

All rules should be fair and apply to everyone at all levels. If you really

feel it necessary to assign someone the task of checking every domain that

gets registered with the trademarks registered throughout the world, then

you can check them when registered. Seems a bit extensive and tedious.

Most conflicts would be resolved rather easily, as they are now, with the

few exceptions that go to court. If an entity begins to register a series

of domains that do not get used, (mostly for the purpose of /selling/ them

to the company that is trademarked with that name) then the top level

authority should have the right to remove delegation of those domains

at their discretion.

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?

Should states and localities operate registries and accept registrations

directly? To what extent should state policies be coordinated and through

what mechanisms and procedures?

A state agency should be granted the ability to administer their own state's

domain. Commercial names should still register under the appropriate

third-level domains as they do now. Perhaps the addition of a .com.XX.US

would be an added option? But then again, that is what .gen.XX.US is for.

All state agencies that maintain a second level US Domain should have to

agree to meet certain requirements and adhear to certain rules before they

are delegated their domain. Furthermore, any violation of these rules and

requirements could lead to removal of delegation. But each state, as available,

should be allowed to get the appropriate state level domain registered to

its own government for purpose of maintaining it locally.

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?

The current method works fairly well, however the restrictions of 50 domains

per state is a bit tight. Some states have entities that could/should be

permitted to register more domains than 50 (for example, a state agency).

A very good improvement would be the delegation of the entire state domain

to the appropriate agency, which would reduce the need to remove the

restriction of the 50 domains. Registrars should be restricted to where

they can register based on their localtion. A company in Maine should really

have no reason to register a domain in California, especially at the third

level for jursdictional domains.

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?

A fee should be instituted for registry to aide in the funding, but it should

be a one time fee, as once the entry is there, it does rarely requires further

intervention. If a yearly fee were instituted, some billing arrangements would

need to be made, especially in the case of state delegations. Registrars

would already be contributing to the operation of the registry simply by

registering to administer a second or third level domain and paying any fees

that were instilled upon them.

10.What are best management and allocation practices for country-code domains?

What practices should be emulated or avoided?

Human intervention. Do not automate the process. If you have a staff reading

all registrations, you can pretty much ensure that no entity will horde any

series of domains that may have some future monetary value for that entity.

Most disputes in the US Domain seem to happen because people don't take the

time to explain things. If you delegate the second/third level domains to

parties who are responsible and understand how to maintain DNS properly,

you can avoid most disputes.

Also, lay down some governing policies and requirements for a registering

entity to follow, so there is some sort of guidelines to start with.

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?

Preferabbly, by a not-for-profit, government funded agency, since this is

.US we are talking about. Giving it to a for-profit, non-government agency

will only lead to conflict, complaint, and unfairness. By holding it under

government agencies, you can have a better control on the policies that

are in place for the domain.

CC: Chris Steele <csteele@ra.oar.net>

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