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[comments-gtlds] Commenting WgC
The ISPCP has, in its past physical meetings, intensely discussed the
question of whether the Domain Space needs new gTLDs or not. There was no
general view that there truely is a need for the addition of gTLDs to the
current Domain Name System. Should additional gTLDs be added to the current
system, it should either only be one with a well defined second level
structure, or a significant number of new gTLDs.
As stated in the position paper B of WG-C, meaningful names are becoming
increasingly rare in the existing system, whereas meaningless domains are
plentiful and readily available.
Should only few gTLDs be added, the names that are interesting, known or
similar to famous trademarks etc. would be delegated right away, most of
them to those already owning the same name in a different domain.
Especially the Trademark owners would react quickly and ensure "their"
names were registered to them.
Consumers will not stop using the Domain Name System as a directory (which
they currently are) unless numerous gTLDs are added to the system. The
ISPCP agrees (as laid out in paper A) that the value of Domain Names is
artificially high due to their scarcety and that (as stated in Paper B)
cybersquatting could be eliminated by the addition of unlimited gTLDs. Of
course, expansion would also give smaller companies a chance to register
the same domain name as a large corporation, but again only if so many
gTLDs were created that one single company could not possibly try to
register its name in all of them. Hence, overall competition would be
enhanced in electronic commerce as companies of all sizes could register
Domain Names associated to their company name.
I agree with Paper A that competition among gTLDs would be created, and
that new registries would create a new market. However, this is only true
if the purpose of the new gTLDs was not limited but rather general. It may
be true that some limited-purpose domains might be valuabe for the system,
but not in our view necessary.
In view of the above, I am also of the opinion that Paper A does not go far
enough in requiring minimum numbers of gTLDs to be added. As the authors of
Paper B say, numbers similar to 500 in the next three years and no limit
afterwards would create a basis for competition. "Clear, objective,
quantitative indicators of problems that would justify an interruption or
cessation of the process" need to be defined.
I do not agree with Paper C, stating that "appropriate safeguards" must be
in place before new gTLDs can be added. Rather, Paper D seems right, as the
creation of new registries will support and enhance the stability of the
Internet by making the WHOIS-data more stable and the DNS independent of
I would say that if in the long term a larger number of new gTLDs exists,
it cannot be sensible to assign them all to one registry; nor can it be
economic to have a separate registry for every gTLD. I personally believe
that registries should be shared so long as it is in a balanced manner, by
some sort of bundling. If more than one registry exists, it will also be
necessary to ensure global distribution. I believe however that before
allowing bundling between a ccTLD and a gTLD, all implications would have
to be carefully reconsidered.
I also believe that as long as the legal system of the country in which the
registry is located does not seriously inhibit a non-profit from working
efficiently (e.g. by prohibiting the creation of reserves), a registry
should be non-profit.
And finally, to the process of selecting new gTLDs: if the number of new
gTLDs is limited, there would be no way around letting ICANN make the
decision of which to create. If the second best solution of many new gTLDs
is chosen, ICANN would only have to keep an eye on the fact that no names
are chosen which infringe the rights of third parties. Finally, if
unlimited gTLDs are created, one could think about creating them on demand,
i.e. letting the market decide.
Michael Schneider, NC
| Michael Schneider CEO, AboveNet Deutschland GmbH |
| CEO, World Switch GmbH |
| MD, Schneider & Schollmeyer Law Firm |
| Director, European ISP Association (EuroISPA) |
| Member, Names Council of ICANN |
| Eschborner Landstrasse 112, D-60489 Frankfurt am Main |
| Phone: +49 69 975 44 0 Michael.Schneider@abovenet.de |