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[comments-gtlds] Submission of Comments
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
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
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
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
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.
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."
Kathryn A. Kleiman, Esq.
Wawa A. Ngenge
National Coordinator, SDNP CAMEROON
98848 Noumea Cedex