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[wg-c] comment summary
Attached, my informal summary of the comments on the wg-c interim report.
I've divided the comments, very roughly, into four classes. The comments
in Class I focus on the creation of new gTLDs; Class II on the stated need
to delay rollout until after the implementation of better trademark
protections; and Class III on Position Paper E. Class IV is miscellaneous.
Coming soon: a straw poll and plans for moving forward.
Raul Echeberria (NC member, NCDNH), for Latin American noncommercial
organizations — the creation of new gTLDs is important and positive, but
must go forward under defined guidelines. If trademark holders register
their domains under each new gTLD, then the creation of new gTLDs will
merely destabilize the ccTLDs with no corresponding benefit. ICANN should
approve a particular new gTLD only on a showing of a predefined level of
public support, and only pursuant to a plan to avoid massive speculative
purchases of domains in the new TLD. ICANN should create a limited number
of new TLDs, and evaluate their operation and market acceptance, before
creating or announcing more.
Hiro Hotta (NC member, ISPCP) — New gTLDs are necessary, and the passage of
the UDRP removed a big obstacle. New gTLDs should not be held back pending
work on famous-mark protection. It's appropriate for ICANN should start
with 6-10 followed by an evaluation period; but in order to avoid land-rush
and artificial values for the initial set, it should also announce at the
start its concrete plans (and schedule) for adding a much larger number.
Registries must be shared; selection of new TLDs and registries should be
market-driven. General-purpose gTLDs are appropriate. Limited-purpose
gTLDs may be appropriate, but present problems because they present the
need for ICANN to monitor that the registry is observing the charter and
not corrupting the gTLD into a de facto proprietary TLD.
Kathryn Kleiman (NC member, NCDNH) et al. — ICANN should add new gTLDs as
quickly as possible; it should roll out several hundred TLDs over the next
few years, and thereafter adopt a per-month cap. A significant percentage
should be used for names that reflect the distinct cultyral/linguistic
groups of the world community, in part by geographic region, and including
.naa. The answer to trademark policing concerns lies in making available
easily searchable lists of SLDs in the gTLDs. There should be both
general-purpose and limited purpose TLDs, and registries may be non-profit
or for-profit. Registry data must be escrowed.
Michael Schneider (NC member, ISPCP) — New gTLDs are necessary. Ideally,
an unlimited or large (similar to 500) number should be created, so that
it would not make sense for a given company to try to register its name in
all gTLDs. That would best enhance overall competition in electronic
commerce. I do not agree with PPC's statement that "appropriate
safeguards" must be in place before the addition of new gTLDs.
AXISNET (Peruvian Ass'n of Users and ISPs) — ICANN should declare its
intention to add 500 new gTLDs over the next three years. Of those, a
defined portion should be reserved for names reflecting distinct
cultural/linguistic groups, perhaps on the basis of ICANN's 5 geographic
regions. With respect to Latin America, ICANN should begin with the NOS
(Naciones Originales Sudamericanas) and/or LAT (LatinAmerican) gTLDs; it
should add 25 gTLDs each year corresponding to the various (more than 50)
languages spoken in the Latin American area. ICANN should not delay
further to accommodate trademark interests; we already have a UDRP.
CPSR (by Andy Oram) — PPB "offers the best route to achieving competition
in the registration of domain names, and furthermore that it is the paper
demonstrating most strongly the spirit of experimentation and open
standards that has characterized the Internet since its beginning." "We
believe the opening of the TLD space can be started right away, without
waiting for other technical or policy changes to fall into place."
InterWorking Labs — supports PPB. Concerned about the so-called
"safeguards" proposed by some to constrain the deployment of new gTLDs.
The new gTLDs should be deployed rapidly and the word "safeguards" should
not be code for obstruction and delay.
InterAccess Company — supports PPB. ICANN should immediately commit to a
vigorous increase in the number of gTLDs, enabling more people,
organizations and businesses to register the name that they feel best
describes them. Unnecessary bureaucracy and delay will help only those few
large businesses seeking to stifle competition.
Melbourne IT — supports PPA. This approach provides for the expansion of
the gTLD space in a stable, predictable and professional manner; is
responsive to the requirements of both commercial and non-commercial users;
and provides an opportunity for IP, consumer protection and other issues
associated with gTLD expansion to emerge progressively and be addressed in
a systematic manner.
Office of Advocacy, US SBA — There should be a limited introduction of new
TLDs, followed by a testbed evaluation, and then a steady introduction of
more gTLDs. A large number of TLDs will create more opportunities for new
entrants; the total should be bounded only by technical limitations. ICANN
should begin with a limited introduction of new TLDs followed by an
evaluation period, but the technical criteria for the evaluation should be
defined beforehand, and ICANN should declare in advance that it will add
additional TLDs if the technical criteria are met. Centralized whois info
should be available, but users should have the option of making their
contact information available only upon a showing of good cause. It is
appropriate to delay introduction of new gTLDs until after resolution of
the famous-mark protection issue, if this can be done in a timely manner.
Such safeguards should not expand trademark rights.
PSI-Japan — supports PPA
Register.com — We support Position Paper A and the controlled introduction
of new TLDs, both
general and special purpose, into the market. New TLDs will reduce the
focus on .com, and give customers more service offerings. It is critical
that all registrars should have equal access to the registries for the new
TLDs. Competition ultimately benefits the end user by giving them more
choices, better prices and better service.
TUCOWS.com — supports PPB. "As long as the new gTLD registries meet a set
of minimum acceptable technical standards, regardless of how liberal or
strict they may be, that the registry be allow to determine their own
business model and operational standards."
Bret Fausett — supports PPB.
Harold Feld — supports PPB. "It is crucial that new TLDs be added as
swiftly as possible. Furthermore, there must be no perception of artificial
scarcity. The limit on new TLDs should be set simply as a matter of
technical feasibility. Other concerns that favor special interests, such
as protection of trademark, have no place in these decisions."
Prof. Michael Froomkin — ICANN should announce that N new domains (N need
not be large) will be added each month. Starting just with a small number,
without an "upgrade path" to a larger number, will put unnecessary pressure
on the new domains and lead to many problems. PPC seems like a recipe for
needless endless delay; there should be mechanisms within whois to protect
privacy via the equivalent of an unlisted number. A gtld should be made
available, limited to noncommercial users, in which contact information is
shielded by the registry.
Rob Hassett — ICANN should begin with 10 new TLDs, coupled with a fixed
schedule permitting the addition of an unlimited number. This will most
effectively promote competition in the long run. Famous-mark protection is
desirable, and should be accelerated so as to avoid hindering the addition
of new TLDs. For-profit and not-for-profit registries should be allowed;
TLDs presumptively should be shared.
Irish <firstname.lastname@example.org> — supports PPB as providing the greatest
flexibility for consumer choice and technological advancement
Hal Lubsen (Domain Bank, Inc) — supports PPA.
Hans Klein, Chairman, CPSR — supports PPB. The artificial shortage of
domain names has resulted in inflated prices being paid for character
strings. The losers in this situation are individuals, non-profits,
people in developing countries, and small businesses. More gTLDs would
reduce the barriers facing smaller players.
Neal McBurnett — It is important to move ahead on opening up new gTLDs as
quickly as possible. ICANN must make a *commitment* that there will be
hundreds of new gTLDs as soon as is practible. The world must have
confidence that it isn't going to stop with the first few new gTLDs or else
the whole move to gTLDs will lose much of its purpose.
Michael McNulty -- supports PPB, but willing to support "A" in the spirit
of compromise. In the last six months, the lack of available names for
registration has been stultifying. The resultant selection of names that
are extremely capricious and fictitious have resulted in a stupid drag on
Prof. Malla Pollack — Open as many gTLDs as possible as quickly as
possible, and ban any one entity from registering the same domain name in
more than one gTLD. ICANN should declare domain names irrelevant to
"trademark claims," and insist that registries refuse to act on "trademark"
and "dilution" claims absent court order. The only way to open the
Internet for full communication or commercial use is to decouple domain
names and trademarks.
Prof. David Post: supports PPB.
Jim Rowe — the only gTLD that is open to commerce right now is .com. Due
to the overcrowding on that, we are having to use multiple hyphens in our
names. This is a big pain for our potential customers. Any new commercial
gTLDs would be greatly appreciated.
Don Stauffer — Slow rollout of new TLDs could cause people to register
addresses in domains that are suboptimal for them (and better-suited to
others), simply b/c these are the ones that were rolled out first.
Accordingly, after rolling out one or two low-volume special purpose
gTLDs to test registry and procedures robustness, ICANN should release a
reasonably large number (25 or so) of TLDs at once. These should include
multiple TLDs for personal or family use and also for business use.
Bob Stoddard — Of the position papers, B is the best b/c it urges a
"flexible, diverse, and open approach," believes that "the TLD policy ought
to reflect end user preferences," recognizes that creating only 6-10 new
gTLDs "risks creating an oligopoly," and urges that ICANN's role should be
limited to technical and administrative coordination of registry operators.
Ewan Sutherland, International Telecommunications Users Group — ICANN
should take rapid steps towards the introduction of a fairly large name
space, with the possibility that some will succeed and others fail. The
gTLD name space should be open for an organisation to propose being the
sole registrar for a TLD.
Jonathan Cohen (now an ICANN Board member) — supports PPC
Dr. Victoria Carrington (NC member, IPC) — supports PPC
AOL — supports PPC. AOL opposes compounding the existing problems by
adding new gTLDs until workable solutions to cybersquatting have been found
and tested. In addition, prior to the introduction of any new gTLDs, a
mechanism needs to be established to allow fair access to the new names
and to avoid a free-for-all as numerous people simultaneously seek to be
the first to register generic names (e.g., "computer") as well as well
ASCAP — generally supports PPC. Imperative that ICANN ensure that
registrars maintain freely accessible accurate whois data, including
contact information, so that ASCAP can locate Internet actors infringing
its members' copyrights.
Bell Atlantic — Supports PPC. It is questionable whether introduction of
new gTLDs would further Internet growth and benefit Internet users. After
implementation of UDRP and famous marks procedures, there must be a study
and evaluation period to ensure that those procedures are working as
intended. This study should include the introduction of a single new gTLD,
as a testbed. In the interim, steps that can be taken to mitigate any
problems with crowded domain name space include: "Consider adding further
domain names to the left of the dot (e.g., acme.cars.com, acme.tools.com)."
British Telecom (by John C. Lewis) — No new gTLDs before assessment of the
adequacy of the UDRP, improved registration procedures, famous-mark
protection, "guidance" from ICANN on cross-jurisdictional issues involving
ICANN and national anti-cybersquatting remedies. After that is done, a few
narrowly-defined gTLDs could be introduced on a trial basis. ICANN should
map out a framework of defined purpose TLDs so that users can rely on the
structure of the DNS to find particular businesses; it should not add TLDs
on an unstructured basis.
Disney — supports PPC. Currently, the UDRP is untested & unworkably
narrow; similarly, the operation of whois in the competitive registrar
context is undefined and untested. There should be no gTLD expansion until
these problems are solved.
International AntiCounterfeiting Coalition — First need improved
registration procedures, implementation of a quick and effective UDRP, and
Mike Heltzer, for INTA — supports PPC. "There has been no consensus --
rough or otherwise -- with respect to new gTLDs."
Nintendo of America — supports PPC. The necessary safeguards for the
addition of new gTLDs are not in place, given the countless abusive gTLD
registrations under .com, .net and .org for which there is no sufficient
remedy under the current system.
Software & Information Industry Ass'n (by Mike Flynn) — unwise to add new
gTLDs until ICANN has ensured the creation of a robust, responsive whois
system, and addressed the problems of site identification, in the existing
gTLDs. Once that is done, we would support adding new gTLDs.
Time Warner — supports PPC. Once famous-mark protection is in place, a few
new gTLDs should be introduced slowly to study the effect on DNS stability
and trademark protection; only afterwards should more gTLDs be added. While
the rapid addition of many new gTLDs may reduce the speculators' market for
common word domain names in the short run, the resulting consumer confusion
and irreversible effect on Internet commerce could be severe.
John C. Lewis, for some members of the Business and Commercial
constituency: The case for introducing new gTLDs has not been convincingly
made. Before introducing any new gTLDs, problems relating to UDRP
implementation and "jurisdictional domains" must be resolved; also, there
should be a thorough examination of the implications. After this is done,
a very small number of narrowly-defined gTLDs could be introduced on a
trial basis. [Note: I have received messages from other members of the B&C
constituency, including MCI Worldcom, disavowing this statement — jtw]
Angela Babineck (Associate, Intellectual Property & Public Policy,
Interactive Digital Software Association) — supports PPC
Marilyn Cade -- There remain serious potential problems that must be
resolved, and criteria that must be in place, before any new gTLDs are
introduced. There has been no rigorous examination of whether gTLD
expansion will in fact be beneficial. Confidence in the newly established
UDRP process must be built, and there must be famous-marks protection:
otherwise, companies with famous marks will have no choice but to register
those marks in each of the new gTLDs. There must be dialogue with the
ccTLDs. Once criteria are developed and implemented, then a very small
number (preferably one) could be introduced.
J. Scott Evans (trademark and copyright attorney, and chair of INTA's DNS
Subcommittee) — supports PPC
Elissa D. Hecker, NMPA — "it is necessary to first have improved and more
specific domain name registration procedures, the implementation of quick
and effective uniform dispute resolution procedures for abusive
registrations, and the creation and implementation of a system to safeguard
famous and well-known trademark across all gTLDs."
Mike Kirk, AIPLA — "no new gTLDs should be introduced until 1) the new UDRP
and its implementing rules . . . have proven themselves to be effective and
2) a workable system for protecting famous marks is in place and has also
proven to be effective. There is simply no urgent need to add huge numbers
of gTLDs at this time."
Steve Metalitz -- new gTLDs should not be established absent "established
and proven procedures . . . to improve the quality and accessibility of
registrant contact data, as well as satisfactory dispute resolution
Andrea Morisi, American Red Cross — support PPC; "I would recommend the
adoption of a few
(from 1 to 3) gTLDs for a test."
Judge Steve Russell
Laurie Anne Whitt
Martha E. Ture
Jody Peiffer Willett - Nokwisa Yona
R. Richard Valencia, for Oregon Chicano Coalition
Elsie Herten (executive director, KOLA International Campaign)
Harold P. Koehler
Brian Hirsch, Ph.D.
Michael Nelson ("Rainman")
Pamela M. Creasy
Mishuana R. Goeman
Cara A. Cowan
E. F. Aranyosi
Lynn John and Walter John
B. Black (Waya-nvwati)
Prof. Peter d'Errico
Ron Andrade, for the Los Angeles City/County Native American Indian Commission
Jim RabidWolf Hickinbotham
Les St. Pierre
"Marion & Don" <email@example.com>
Douglas Gravestock (Suye'ta)
David Crockett Williams
Judge Ron Johnny
Prof. David M. Mednicoff
Michael D. Caesar
Wayne Neighbors, Ph.D.
Robert J. Conley
Amy J. Ruggles
Mark J Wheeler
Lisa A. Nelmida
Terrie S. Restivo & Kay Cope, Turtle Island Dignity & Education
Joan J.R. Brown
James A. Casey
Amy S. Davis
Preston Hardison, for the Indigenous Biodiversity Information Network
Ron Maurice (didn't actually file a comment; he sent a supportive message
to Eric Brunner, which Eric posted to comments-gtlds)
Astrida R. Blukis Onat
Pablo Lonesome Wolf
David C. Ergo
Bobbie L. Robinson
Diane Spears Lowry
Manny Questions <firstname.lastname@example.org>
Mrs. Ami Offenbacher
Trudi ( BlueT5@aol.com)
Mr Dawson Her Many Horses
Sandra I. Ehrhorn
Louis Axeman, Jr.
Bill Wiyaka `Oeta
Angeline Greensill & Tainui Hapu
Patricia Christine Aqiimuk Paul
Cheryl L. Spaniola
Manuela Ribeiro Sanches
Lisa A. Nelmida
Jimmy Boy Dial
*other comments regarding PPE*
Carla Walker — It will be difficult to determine who is a legitimate .naa
registrant, and to decide who should participate in making that determination.
Chris Cota — Does the Intertribal Council On Utility Policy actually
represent all of the Tribes? And what process was used to select particular
entities to do the administration?
Thomas Trischler — Tribal governments and Indian nations should be able to
use the .gov TLD.
*Class IV -- Miscellaneous*
Dave Lalande — supports Simplified Domains, a proprietary root system that
would include all possible three-letter combinations as TLDs
Jason Dwyer -- supports Simplified Domains. Registries cannot effectively
screen applications for SLDs in special-purpose TLDs. No gTLD taxonomy can
work, b/c the gTLDs will either be too broad to be useful, or be too
numerous to remember
Robert Stoddard -- supports Simplified Domains.
Robert Thorstensen -- supports Simplified Domains.
email@example.com — supports Simplified Domains. Adding new
"extensions" will simply lead registrants to register the same names in
multiple TLDs, without public benefit
Adria L. Chappell — .porn should be made available to facilitate filtering
Craig Cockburn — Scotland should have its own TLD
Kendall Dawson, Bob Stoddard — IOD's .web should be added to the legacy root
Steve Finn — Any domain name holder that intends to hold its SLD for the
long term should have the right to that character string across every TLD.
David Golamb — presents a plan for converting the DNS into a "name /
category / class / location identification system"
Paul Gregson — TLDs should be optional
Dr. Ian Jay Kaufman — ICANN should implement the Nice classification
taxonomy (so that, for example, the gTLD .39 would refer to packaging for
sale of food products).
Ram Narula — I would like to propose the idea of new gTLDs being com.1,
com.2, com.3....com.99999, net.1, net.2 to net.999999 and org.1, org.2, to
org.99999. Say company.com is taken, and Mr. X wants to register
company.com, Mr. X would get company.com.2, then if Mr. Y wants to register
company.com after company.com.2 is taken, he would get company.com.3.
Robert Simpson (World Wide Web Shop) — ICANN should not approve both .shop
and .store except under a system in which a registrant in one automatically
has the option of registering the same SLD (or preventing others'
registrations of that SLD) in the other
Miesha Vukasinovic — introducing lots of new gTLDs will confuse users and
will add to the problem of domains registered in the wrong TLDs, absent
legislation to ensure that the new TLDs are used in the manner in which
they were introduced originally. Possible new TLDs: .gov (available to
all national governments), .sex, .alt (for noncommercial uses that do not
belong in .com)