[comments-gtlds] Submission of Comments

[KathrynKL@aol.com]

  Comments to Interim Report of Working Group C:
  January 10, 2000
   
  The Undersigned from the Noncommercial Community have
  reviewed the interim report of the DNSO's Working Group C. We
  thank the members of WG-C for their hard work. 
  
  We wish to express our strong support for the addition of new top-
  level domains to the root of the domain name system as quickly as
  possible.  New gTLDs will create important new spaces for the
  domain names needed by noncommercial organizations and
  individuals. 
  
  We recognize that, aside from adding new TLDs, ICANN must
  make difficult policy decisions about how many to add, what
  names will be selected, and how the new registries will be
  administered. We also support many elements of Position Papers A
  and B, and certainly elements of Position Papers D, E and F.  
  
  We preface this paper with the idea that our support for numbers of
  new gTLDs - above and beyond 6-10   is unconditioned.  As for
  the rest of the ideas, we provide input and thoughts to help guide
  the WG-C, but hope that the WG-C will continue its superb
  leadership, continue to craft proposals for the implementation of
  new gTLDs and put these out again for public comment.
  
  OPEN THE DOORS TO NEW GTLDS!
  
  We agree with Position Papers A and B that new TLDs will create
  opportunities for new entrants and lower entry barriers. 
  Furthermore, they will allow competition to determine winners
  rather having a race to a single domain name.  New TLDs will
  expand Internet users' choice and help resolve trademark issues
  since multiple domains will lead to Internet users and consumers
  having more information about the underlying user of a domain
  name (such as perhaps a .AUTO).  We submit that there is
  abundant demand in the noncommercial community for new TLDs
  and current TLDs cannot satisfy the demand.
  
  COMMIT TO MANY NEW GTLDS
  
  We agree with Positions Papers A and B that a commitment should
  be made now to more gTLDs than 6-10.    We completely support
  the statements of Position Paper A that state:
  
  -  "The existence of many competing TLD registries will diminish
  the market power that any particular TLD will exercise."   and
  
  -  "... it would be undesirable to artificially limit the number of
  gTLDs short of the bounds of the technically feasible and
  operationally stable." 
  
  We also agree with Paper A's assessment of trademark concerns
  and its proposal that the answer to the trademark policing question
  (as it relates to gTLD issues) lies in making available "easily
  searchable" lists of second level domains in the gTLDs.  The
  power of the Internet should make policing of domain names easier
  in multiple gTLDs than in other communications mediums, such as
  hundreds of cable channels. 
  
  We support Position Paper B's advocacy of a large number of new
  TLDs to be created over the first three years.  We also support
  Position Paper A's idea of no limit, but rather a per-month rollout
  of new gTLDs to ensure that no one is overwhelmed.  We suggest
  combining the two proposals and request that ICANN commit to
  rolling out a large number of new gTLDs in the next three to four
  years (400-500 sounds like a good target), and thereafter adopt of
  per-month cap on additions. 
  
  We believe that this creation of substantial new gTLDs will serve
  the interests of the noncommercial communities, which does not
  have much space in the existing gTLDs (especially with .ORG
  being appropriated increasingly for commercial uses).  There are
  literally hundreds of new ideas for TLDs being considered and
  proposed around the world by arts groups, cultural and political
  organizations, ethnic groups, and so on. We need room for them!
  
  Also, we believe that in a world of artificial scarcity and very
  limited allocation of new gTLDs, the noncommercial community,
  and less wealthy interests, are the most likely to be excluded from
  running and being served by new registries and new gTLDs.  
  
  STABILITY AS KEY 
  We wish to express agreement with the idea in Position Paper D
  that multiple gTLD registries provide important protection for
  domain name registrants and the Internet community and, with
  proper planning, can reduce their losses from any
  economic/business failures of individual registries.  The reasoning
  of this paper about the need for the registry data to be escrowed in
  such a way that it can be made available to a second registry in
  case of "failure, mismanagement on the part of the registry
  operator, or similar reasons" is compelling. 
   
  ALLOCATING GTLDS FOR REGIONAL, CULTURAL,
  LINGUISTIC AND OTHER TYPES OF DIVERSITY
  
  We support the proposals of Position Paper B and implicit in
  Position Paper E that a significant percentage of new gTLDs be
  used for names that reflect the "distinct cultural/linguistic groups"
  of the world community. To date, the Internet's generic TLDs have
  all been in English and all use the roman character set.   In the
  future, many of us believe that the geographic, cultural, linguistic
  and ethnic ties will drive the need for new gTLDs which are not
  English, and reflect the world's cultural and linguistic diversity. 
  We believe the noncommercial community will have need for
  these names.
  
  Position Paper E proposes a TLD for the National Congress of
  American Indians/Assembly of First Nations takes us the first step
  in this direction.  We support the call for this TLD, and trust that
  these Native American communities will support the general
  principle that other recognized indigenous groups (such as those
  recognized by the United Nations), as well as large religious,
  ethnic, cultural, tribal and clan groups worldwide should be able to
  seek out their own TLDs. 
  
  Position Paper B calls for distributing new TLDs according to
  ICANN's geographic regions to allow the new names to be defined
  in a way that better reflects cultural and linguistic diversity.  We
  support some allocation by geographic region.  While this method
  is not perfect, the reservation of a certain portion of new TLDs to
  distinct geographic areas at least ensures that all the new TLDs will
  not continue to be dominated by the North American and European
  regions and their languages, and that TLDs will be ready when
  communities decide they need them (now or in the future).
  
  GENERAL AND LIMITED PURPOSE; OPEN AND LIMITED
  MODELS OF ACCESS
  
  We again combine concepts in Position Papers A and B to arrive at
  the ideas we support. Both Position Paper advocated general and
  limited new gTLDs.   We think Paper A eloquently expressed our
  need for "general-purpose" gTLDs to provide effective competition
  to .com.  It seems to us if these general-purpose gTLDs are created,
  open to all on a first-come, first served basis, that the method of
  access should be equal access   all accredited registrars may
  register into them and the registry will bear the cost of full and
  open access.  We believe these names will have wide appeal and
  many registrations.  
  
  We also wholeheartedly support the idea of "limited-purpose"
  domains.  Registries should be able to approach ICANN with ideas
  for domains which serve a set of interests and needs narrower than
  "all .COM" or "all .ORG."  These domains may require some sort
  of review or certifications such as a .POL for political speech,
  .LAW for lawyers, and .AUTO for automobile companies.  For
  limited-purpose domains, we do not believe ICANN should dictate
  whether the access should be open to all registrars or limited to a
  subgroup. The limited-purpose domains will have the overhead of
  reviewing appropriate documentation or certifications; it will also
  have many fewer eligible applicants than a general-purpose gTLD. 
  Accordingly, it is the registry providers who should decide what
  makes financial sense: working within an open or more limited
  registrar access model.  We ask that two safeguards be added if the
  limited registrar access model is chosen: that access be made
  available to at least one registrar in each geographic region, and
  that registration be nondiscriminatory and first-come first served
  among all applicants meeting the registration criteria of the gTLD. 
  
  FOR PROFIT OR NOT FOR PROFIT
  We have looked at the passionate arguments on both sides, and
  ultimately side with a "registry's choice" model.  We know of
  systems in other industries, such as telecommunications, where
  nonprofit companies provide services that are more expensive, less
  responsive, and less technologically up-to-date than for-profit peers
  (generally located in other countries).  For those who feel
  passionately about non-profit registries, we urge you to offer this
  service to the Internet community.  For those who feel that they can
  offer a for-profit registry service that meets the requirements of
  Internet community and ICANN and compete cost-effectively with
  the non-profit registries, we would like to watch you grow as well. 
  
  CONCLUSION
  New gTLDs should be rolled out quickly, for general and limited
  purposes, with a presumption that registries should define new
  gTLDs and their own policies--- subject to guiding principle stated
  in Position Paper F, that the Internet is an essential facility for the
  public and access to "mnemonically and semantically useful
  domain names" is and will increasingly be "an important and
  convenient tool of human communication."
  
  SIGNED:
  Kathryn A. Kleiman, Esq. 
  Alexandria, Virginia
  USA
  KathrynKl@aol.com 
  
  Wawa A. Ngenge
  National Coordinator, SDNP CAMEROON
  B.P. 836
  Yaounde, Cameroon
  wangenge@sdncmr.undp.org
  www.sdnp.undp.org/sdncmr/wawa.htm 
  
  Mark Perkins
  SPC Library
  BP D5
  98848 Noumea Cedex
  New Caledonia
  MarkP@spc.org.nc