From: <dfazio@MR.Net>

To: NTIA.NTIAHQ(usdomain)

Date: 8/26/98 11:56am

Subject: Request for Comments on the Enhancement of the .us Domain Space

Response to the Dept. of Commerce NTIA Request for Comments on the

Enhancement of the .us Domain Space

Docket No. 980212036-8172-03

Questions 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?

The current system was designed and enhanced over a period of time and works pretty well as is. The only change that might be helpful would be a replacement for the current gen second level domain, which is clumsy and odd, and a better accomodation for organizations of statewide scope that aren't tied to any one locality.

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 state level domains should be delegated to some statewide civil authority in each state. This provides local control, something we consider good in our federal system, yet there is a national consistency of rules. The delegated authority in each state whould show that it is responsible, either by itself or by an outsource arrangement, to competantly administer and further sub-delegate the name space it has. A state government agency or public body would be the most likely candidate. Each state should be able to define the rules for its further subdelegation and administration with a limited set of high-level constraints and guidelines from the new IANA.

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?

Special second level domains should NOT be created. Suggestions to implement or, as may be done in other countries should not be taken, as they will not solve any problems we currently have with the name collisions of the flat domain space of the .com comain. The US is too big of a market to do such a thing and the division of the .us TLD into 50 or so subdivisions provides for a greater heirarchy. This accomplishes three desirable things:  

1. It disperses the responsibility for registration to a wider set of organizations, preferably that are located in the geographic area of the subdomain name

2. It increases the heirarchical depth of names to reduce the problems of name collisions.

3. It most closely maps the domain name system onto a name system that is already in place and with which everyone is already familiar.

The necessity for non-geographic names for organizations of national scope is not really necessary. We don't have that now in our non-Internet addressing systems and it has not proven to be an impediment. There may be some benefit in simplifying naming, and perhaps there may be some instances, hopefully few in number, where a variation from the heirarchical state-based naming system may be useful. But the costs in confusion could by high of a general consistency in the heirarchy of the naming system is not maintained.

There are some objections to the use of geographical naming systems to "cyberspace" which is supposed to be "without borders." But new boundaryless communities can still be created and maintained regardless of the individual names of people or organizations. The arguments about the difficulties of changing names when physically moving are specious, since so much has to be changed already and the ease of forwarding is so great on the Internet, that the cost is insignificant.

There are also some objections to the length of names in the .us domain. However, most mailers and browsers are point and click and a lot of email is in response to other messages, that the need to actually type a full name is not that extensive. It should also be recognized that longer and familiar names are often easier to type than shorter nonintuitive abbreviations of those names.

A lot is made of the fact that cyberspace is not held to geographic boundaries, and that is true, but everyone and everything has some kind of identity and that is usually the organization that they are a part of or the part of the world in which they reside. I think it important to recognize and acknowledge those associations and that diversity they represent. The use of highly-abstract naming system with no association to anything physically or organizationally real, like phone numbers, zip codes or the like, only serves to further dehumanize the words we read on our screens by removing the organizational or physical location context from them. The civility of discourse we desire on the Internet is made more difficult when we mostly deal with disembodied words.

One thing is really important to note: The Internet is not truly part of our lives yet as is the telephone, automobiles, radio and television. Only a minority of the population really uses the Internet much. However, it will be a central part of our lives soon and will provide immense benefits when it is. In order to expedite that, it is important to make it feel like familiar territory--not something so foreign and mysterious. It needs some anchors in something now existing so that newcomers feel welcome and not just lost in a strange new world with absolutely no familiar touchstones from which to start. By using an addressing system that highly parallels the present system of organizational and physical addresses, we provide that anchor for millions of newcomers.

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?

There should be no unrestricted domain names. It only perpetuates the current difficulties and solves nothing. We should recognize that the US is different from most other countries in that we are larger and already divided into 50 separate somewhat autonomous political divisions. We should continue to take advantage of those well-defined subdivisions to distribute the name heirarchy over a wider namespace.

Likewise, the further divisions into locality domains gives each state the ability to further subdelegate under existing familiar logical means.

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 .us domain should be administered by an organization with national respect that can administer a public trust.

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?

By using the state-name and locality-name heirarchy, we automatically reduce name collisions. By using a geographical system of naming, similar to what we already have, we can take advantage of the current trademark laws and regulations regarding the use of similar names in the same or different states or localities. No non-federal governmental organization should be registered directly under .us.

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?

The state government should administer and subdelegate the state-level domains. Commercial and nonprofit names should not be permitted under the state-level name, but rather as currently defined, must be under some locality. State agencies can administer the domain directly or outsource it, but the rules and guidelines are defined by the state authority with constraints and guidelines from the national authority to provide consistency and fairness.

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?

Delegations to private authorities works well if those delegatees treat their authority in a responsibile manner as a public trust. The delegated authority should be located in the state in which it has its responsibility. Registrars should be accountable, by affiliation or contract, to their state agency that administers and delegates the locality and other subdomains. A competitive system of multiple registrars could be established by the state authority.

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?

It should be supported by state subsidy or fees, as the individual state agency chooses. The national authority should be self-supporting by fees from the state-level delegations.

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

Country code domains should be managed by the new IANA replacement with delegations given to individual national authorities. A set of guidelines to insure worldwide consistency and fairness should be established. The existing gTLDs like .com, .edu, etc. should eventually be phased out completely in favor of country code domains only.

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?

The .us domain should be administered by a trusted government agency or a nonprofit corporation. Models can be taken from the administration of the postal service with zip codes or the phone companies administration of the area code and phone numbering system.

Dennis Fazio


2829 University Ave SE

Minneapolis MN 55414

(612) 362-5850