INTERNET DRAFT O. Crepin-Leblond Global Information Highway Ltd January 1997 Expires: July 1997 Comments on Draft Specifications for Administration and Management of gTLDs draft-iahc-crepinleblond-tldspec-01.txt Status of this Memo This document is an Internet-Draft. Internet-Drafts are working documents of the Internet Engineering Task Force (IETF), its areas, and its working groups. Note that other groups may also distribute working documents as Internet-Drafts. Internet-Drafts are draft documents valid for a maximum of six months. Internet-Drafts may be updated, replaced, or obsoleted by other documents at any time. It is not appropriate to use Internet- Drafts as reference material or to cite them other than as a working draft or work in progress. To learn the current status of any Internet-Draft, please check the 1id-abstracts.txt listing contained in the Internet-Drafts Shadow Directories on ds.internic.net, nic.nordu.net, ftp.nisc.sri.com, or munnari.oz.au. 0. Abstract This document comments on policies and procedures to allow open competition in domain name registration in the gTLDs which are described in a document entitled "Draft Specifications for Administration and Management of gTLDs", written and released by the IAHC on December 19, 1996 for public review to take place until January 17, 1997. Subjects specifically addressed are: o ambiguities in some parts of the IAHC text; o the need for newly created gTLDs to be widely accepted internationally, and not to a specific english-speaking audience; o the introduction of a 60-day publication period to SLD registration processes; Since this document comments on another published document, its style will be kept short and to the point and will therefore not follow the strict formatting of an Internet draft or an RFC. It is assumed that all terms used within this document have been defined or otherwise described in the original IAHC document. 1. Introduction On December 19, 1996, the IAHC released a draft document describing specifications for the Administration and Management of gTLDs. The document is valid for public review and comment until January 17, 1997. The IAHC will then take note of the suggestions made by the public and publish a finalised document on January 31, 1997. While most of the draft document released by the IAHC is very well written and the procedures described are perfectly acceptable, it contains what can be seen as ambiguities in a number of paragraphs. Secondly, the document leaves it until later to name the new gTLD which will be created. Recommendations about producing truly internationally-accepted gTLDs should be included in the document. Furthermore, a controversial 60-day publication period in SLD registration processes may well change the way the Internet works to such an extent that it will change its growth. Each point will be addressed in a separate sub-section of this document. 2. Comments about the IAHC draft document 2.1 Ambiguities within IAHC draft o Quoting from Section 3.1, paragraph 2 of the IAHC draft: "Equally there is a body of opinion which suggests that there is a need to create alternative entry points into the DNS within the gTLD space. The basis for this view includes the observation that creation of such additional gTLDs would allow a form of natural competition with existing gTLDs, creating alternate entry points for access to the gTLD domain space, and that such natural forms of competition will assist in preventing the operators of any particular gTLD from assuming the role of a monopoly provider with the associated inherent risks of monopoly-based market trading practices." Clearly the mentioning of the operator of any particular gTLD assuming a role of a monopoly provier does not stand since later on the the document, recommendations are to have multiple operators for every gTLD including the current gTLDs: (Section 3.1, paragraph 6) "In addition IAHC has decided to ensure that the new gTLDs are all to be operated in a shared fashion across a number of domain operators. [...] " Furthermore, it is not clear why more than one entry point in the gTLD space will promote competitivity if all gTLDs are shared anyway. The only reason for having multiple entry points to the gTLD space looks to be the creation of more "space" for SLD names which are similar. This solution does not address the reaction of an SLD owner which will find that the same SLD was allocated to someone else under another gTLD, especially if the original SLD owner holds a trademark on the SLD itself. o Quoting from Section 3.3 of the IAHC draft: "The IAHC recommends that all existing gTLDs be shared in the same fashion as mentioned in section 0." Section 0 does not exist. o Quoting from Section 4.1, paragraph 6 of the IAHC draft: "Oversight responsibility for a registry rests with a STEWARD. If the registry is a monopoly, the steward, the registrar, and the operator of the repository are typically one in the same. [...]" Since is has been widely mentioned that no monopoly will exist in respect to any gTLD registration operation, this paragraph is redundant. If this is not the intended subject, then this paragraph is ambiguous. o Quoting from Section 6.1, paragraph 5 of the IAHC draft: "Addition of .tm. IAHC recommends that the functional name .tm., or a local language equivalent thereof, be added to the functional name set documented in section 6.1.1 of this document, above, as described more fully in section 0 of this document (see below)." Section 6.1.1 and Section 0 do not exist. o Quoting from Section 6.1, paragraph 7 of the IAHC draft: "IAHC notes that the implication of the recommendation in section 0 is that there will be a consequent market demand for domain names which are available within a more rapid period than 60 days. [...]" Section 0 does not exist. 2.2 International dimension of gTLDs While the IAHC document goes to great lengths to mention that gTLDs are not regarded as being truly international in nature, the gTLDs are used internationally. In Section 3.2 of the IAHC draft, paragraph 2: "These new gTLD's will consist of letter strings of three to five letters each. IAHC has also decided that each gTLD should have general, contextual meaning, i.e. the gTLD should suggest a connection with the Internet, with business or with personal uses." Clearly at this point, the international use of gTLDs should be mentioned, and the contextual meaning should not be restricted to the English language. The paragraph would be benefit from being written as: "These new gTLDs will consist of letter strings of three to five letters each. IAHC has also decided that each gTLD should have general, contextual, or widely accepted meaning, i.e. the gTLD should suggest a connection with the Internet, with business or with personal uses and be already widely accepted by non-english speaking users of the Internet." 2.3 SLD 60-day publication period This section relates to paragraph 7 of Section 5.4 of the IAHC draft. "In light of the legitimate interests of domain name holders and trademark owners, and in the overall interests of consistency and fair play, IAHC strongly believes all gTLD registries and ISO country code registries should, therefore, publish applications for SLDs, for a period of sixty (60) days prior to assigning the requested SLD to the applicant. Such publication should take place on a publicly available, publicized web site and include the SLD and the contact and use information contained in the application (see Appendix A)." The purpose of the above procedure is to compress the vulnerability of a domain name by ensuring any objection to the domain name is filed within the first 60 days of publication of the name. A trademark owner would theoretically have a harder time reclaiming a domain name after the 60-day publication period expires. However, it is worth considering that: o Until the first court case of a domain dispute where the domain has gone through the 60-day approval/publishing process takes place, the idea that domain names are going to be safer from dispute, and that this will make the Internet domain naming more stable is speculative. o The 60 day waiting period will slow-down business on the internet. It will put a strain on startups both in the connectivity business and Web design business. An Internet year is widely recognised as being 3 months long and 60 days is 2/3 of an Internet year. o Publication of a domain name for 60 days prior to its use is detrimental to open competition in some cases, by taking away the element of surprise for a project to be made public. o The prevention of domain hoarding by "extortionists" as described by the IAHC document (Section 5.4, paragraph 4) will be replaced by a trade in readily-available "off the shelf" SLDs which have already gone through the 60-day approval period. This clearly opens the door to the same extortionists described in the IAHC document. In view of the above facts, it is suggested that the 60-day publication period is made optional. In most cases registered SLDs do not require a safety net due to their specific nature. It should be up to the domain applicant to choose whether a 60-day publication period is suitable for their purposes. The market will decide by itself which option is more commonly used. Any compulsory 60-day publication period is more detrimental to the Internet community as a whole than its potential benefits. 2.4 Addition of .nui. This section relates to paragraph 7 of Section 6.1 of the IAHC draft: "IAHC notes that the implication of the recommendation in section 0 is that there will be a consequent market demand for domain names which are available within a more rapid period than 60 days. IAHC recommends that the administrators of ISO3166 name spaces consider the addition of a functional name space, proposed to be a network user identifier: .nui." . The characteristic of this space is that it would be filled by randomly generated, meaningless alphanumeric strings, available within a short period after application, in order to provide an alternative mechanism to the process of obtaining a specified name which may include a 60 day notification period." While it is correct that there will be a market demand for domain names which are available within a more rapid period than 60 days, the implementation of a 60-day "optional" period as described in section 2.3 of our document will solve this problem. Furthermore, the above acronym "nui" is unknown to the Internet community at present, and a string of "meaningless alphanumeric strings" is little more helpful than the use of native IP addresses of the type xxx.xxx.xxx.xxx. The use of the meaningless native IP addresses will be more easily acceptable since meaningless numbers are already used in telephony. The addition of an "nui." domain will only serve to complicate processes in respect to SLD allocation and administration. 2.5 Lifting of special criteria of .org and .net Quoting from Section 2.3, paragraph 3 of the IAHC draft: "Recognizing the de facto present situation, IAHC recommends that the existing special criteria should be lifted from .org and .net and they should be considered to be gTLDs." The special criteria is not mentioned. It is assumed that this is: (RFC1591) "NET is for the internal infrastructure of service providers, and ORG is for miscellaneous organizations (e.g., non-profit corporations, and clubs)." The lifting of this criteria is detrimental to the structure of the Internet since NET and ORG were meaningful acronyms. The creation of new gTLDs will in fact assist in clearing the current SLDs which are not strictly following this criteria from ORG and NET. Lifting the special criteria from ORG and NET may confuse those wanting to register new SLDs by making too many choices with no criteria available. 3. Security Considerations There are no known security considerations beyond those already existant in the DNS apart from a recommendation to ensure smooth operation of the DNS at all times by following a gradual approach to the introduction of new gTLDs. 4. Main References IAHC, "Draft Specifications for Administration and Management of gTLDs" December 19, 1996. 5. Author's Address Olivier MJ Crepin-Leblond Managing Director Global Information Highway Limited Phone: +33 (0)956 841113 8 Palace Place Mansions Fax: +33 (0)171 937 7666 36 Kensington Court Email: ocl@gih.com London W8 5BB United Kingdom