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[comments-gtlds] Comments on the position papers

Of the documents on offer, I could most easily support position papers A
or B.

I think that the overriding problem with gTLDs at present is an artificial
scarcity of "attractive" domain names.  The next largest problem is a
"land rush" mentality that would be caused by failing to introduce new
gTLDs in a predictable and orderly manner.

In a perfect world, I'd like to see a policy that N new domains would be
introduced each month (N need not be large).   I'd also like to see a
variety of "closed" and "open" gTLDs.  Starting with just a small number,
without an "upgrade path" to a larger number, will put unnecessary pressure
on the new domains and lead to many problems.  A large number of gTLDs
will probably cause less cybersquatting than a small number since the
scarcity value will disappear.

I oppose position paper C, which seems like a recipe for needless endless
delay, especially as two of the three preconditions (" ii) implementation
of speedy and effective uniform dispute resolution procedures for abusive
registrations; and iii) adoption of a system for protecting famous and
well-known trademark across all gTLDs.") are already satisfied today.

I also oppose the privacy-destroying endorsement of an open whois
database.  There is a need for the Internet equivalent of an "unlisted

I also oppose position paper D because I think it fails to address the
"land rush" problem, and would in fact make it worse.

To the extent that one or more gTLDs proposed in position paper E could be
created without substantially reducing the supply of gTLDs available for
other purposes, I think this is a valuable proposal.

Position paper F contains several valuable ideas, notably paragraphs 3,8
and 9 which could be incorporated into whatever proposal is finally

Position paper G seems to require too much bureaucracy and top-down
control for me to support it.


A. Michael Froomkin   |    Professor of Law    |   froomkin@law.tm
U. Miami School of Law, P.O. Box 248087, Coral Gables, FL 33124 USA
+1 (305) 284-4285  |  +1 (305) 284-6506 (fax)  |  http://www.law.tm
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