NOTICE-97-02

ACTION: REQUEST FOR COMMENTS

ANNOUNCEMENT DATE: September 13, 1997

CLOSING DATE: October 13, 1997

SUBJECT: Review of new generic Top Level Domains (gTLDs)

ADDRESSES: Electronic comments should be sent to notice-97-02@gtld-mou.org. Comments submitted can be in ASCII, Microsoft Word, WordPerfect or HTML. The original mail archive of submissions can be found at http://www.gtld-mou.org/notice-97-02/.

Written comments or comments submitted on diskette can be sent to:

gTLD-MoU/Notice-97-02
ITU
Place des Nations
1211 Geneva 20
Switzerland

If further information is required on this notice, please contact poc-submit@gtld-mou.org.

A. BACKGROUND

The gTLD-MoU Policy Oversight Committee would like to provide these further background clarifications and dimensions to the issues of expansion of the Internet generic Top Level Domain name space.

1. There has been criticism that by selecting top level domains that overlap with other existing gTLD categories, the effect will be confusion for users. However, second level domain names registered under gTLDs, because they must be unique, represent a name space much flatter than real-world identifiers. This is especially clear with the mapping of company names, trade names or trademarks to domain names. Identical company names, trade names or trademarks can typically co-exist with little conflict over usage (e.g., United, Genesis, Acme). Identical second level domain names in a specific gTLD (e.g., .com) cannot co-exist since domain names must be unique.
2. As the Internet grows and more entities register domain names, it is impossible that domain names can remain "guessable"; there will need to be an increased reliance on directory services.
3. The current congestion and lack of availability of certain names in the current gTLDs (.com, .net, .org) has demonstrated that when entities wish to register a natural and mnemonic domain name (e.g., typically corresponding with an organization or company acronym), if that name or acronym as a second level domain name is unavailable in one of the current gTLDs, there is often a preference to register in another gTLD (if an appropriate one can be found), rather than select a less "natural" second level domain name in the originally desired gTLD. For example, when a desired name is already taken in the .com gTLD, entities often will register the same name in the .net gTLD, previously reserved for networking providers. The reasons are clear - there is typically more "attachment" by the registrant to a second level domain name than to the gTLD.
4. It is often suggested that strict gTLD categories should be created and registrants forced to comply with those rules. However, note that attempts to pre-screen registrations for suitability in registering in specific gTLDs have so far not been successful. For example, the gTLD .net used to have a requirement that the registrant be a networking service provider. This was eventually found impossible to enforce since entities who desired a specific name under .net would find a way to circumvent this qualification.
5. Since the vast majority of domain names registered under the current gTLDs (.com, .net, .org) are automated, any attempts to do pre-screening of registrations in any form, will result in delays in registration, increased personnel requirements (to evaluate applications), and consequently increased costs in domain name registration fees for those gTLDs.
6. All two letter gTLD names are permanently reserved for current and future ISO 3166 country code delegations (e.g., .us, .fr, .au).
7. Considering Internet growth rates, a "flat" name space at the top level of the world (as is the case with gTLDs) is ultimately unscaleable without the introduction of additional hierarchy entry points (either subdomains or additional top level domains) or additional qualifiers (e.g., numerical or sector categories) in second level domains.
8. The DNS was designed as a hierarchical name registration system. However, market forces (especially in the United States) have demonstrated a current unwillingness to be placed under deeper hierarchies (e.g. as exists for the .us country code which has subdomains based on geographical subdivisions). One reason is that market forces recognize the importance of mnemonic-recall of domain names by users (desirable attributes include short and memorable names).
9. The gTLD-MoU Policy Oversight Committee believes that since market forces place considerable importance of the mnemonic-recall value of domain names by users, the often-suggested idea to solve trademark/domain name conflicts by mapping trademark classification taxonomies into a sub-domain naming convention underneath gTLDs would be even more confusing to users and would be rejected by domain name registrants (see "Nice Agreement Concerning the International Classification of Goods and Services for the Purposes of the Registration of Marks" at http://www.wipo.int/eng/iplex/wo_nic0_.htm with specific classes at http://www.naming.com/icclasses.html).
10. The Policy Oversight Committee believes that there is little willingness in the marketplace to accept numerical identifiers added to names in order to provide unique differentiation between identical second level names (e.g., united1.com, united2.com, united3.com, etc.). Market forces have instead demonstrated there is a greater willingness to add further textual qualifiers (e.g., http://www.delta-air.com), if necessary.
11. The Policy Oversight Committee recognizes that entities who intentionally register well-known trademarks for speculative or other reasons is an issue for trademark holders. However, the Policy Oversight Committee also believes that there are abuses by trademark owners who attempt to claim "valuable" domain names that have been used in good faith (especially in the highly-sought-after .com gTLD). Methods include using Network Solution's dispute resolution policy or litigation (e.g., see http://www.clue.com or http://www.prince.com). The Policy Oversight Committee believes that a balance must be sought between the rights of trademark holders and domain name holders.
12. The Policy Oversight Committee believes that, considering Paragraphs 7, 8, 9, 10, & 11 above, without a considerable expansion of the gTLD name space permitting more self-selecting categorization (for example, in the two examples mentioned above, offering the possibility for trademark holders to register in gTLDs such as "clue.games" or "prince.sports"), conflicts will only intensify as more entities wish to register domain names and trademark holders, recognizing the Internet as an important commercial medium, attempt to assert rights in a limited pool of gTLDs.

B. GENERAL QUESTIONS

Generally, how many new gTLDs do you think should be created?

[0 __] [1-10 __] [10-50 __] [50-150 __] [150 or more __]
 

C. CHOICE OF gTLDS

How would you rate each of the following gTLD names selected by the IAHC?

a) .firm  (intended for businesses, or firms), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .firm in
this category? ______

Special note: A common suggestion is that business term-related gTLDs like .inc, .corp, .ltd, .plc, .gmbh, .sarl should be selected instead of general terms like ".firm". However, these terms have legal significance and it is typically illegal to use them unless the registering entity actually is "incorporated", a "limited liability company", a "public listed company", etc. Verifying this would most likely require pre-screening activities by domain name registrars (as is the case in the UK with plc.uk and ltd.uk) and probably result in increased registration costs and submission of proof of related legal status. Also note that since all 2 letter TLDs are reserved for ISO 3166 country code delegations (e.g., .us, .fr, .au), equivalent business legal abbreviations commonly used in other languages (e.g., "sa", "sc", "oy", "ab", and "sl") could not be allocated.

Considering above, would you still prefer to have legal term gTLDs? [yes__] [no__].

If so, which ones (in order of preference)? _____________________

b) .store (for businesses offering goods to purchase), check one of the below:
 
[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .store in
this category? ______

Special note: There have been many suggestions that .store be replaced by .shop which has significance in
multiple languages and, unlike .store, has related verb and noun meanings. Do you think .store should be replaced by .shop? [yes__] [no__]

c) .web (for entities emphasizing activities related to the World Wide Web), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .web in
this category? ______

d) .arts (for entities emphasizing cultural and entertainment activities), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .arts in
this category? ______

e) .rec (for entities emphasizing recreation/entertainment activities), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .rec in
this category? ______

f) .info (for entities providing information services), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .info in
this category? ______

g) .nom (for those wishing individual or personal nomenclature, i.e., a personal nom de plume), check one of the below:

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you disapprove or strongly disapprove, what gTLD would you suggest in place of .nom in
this category? ______

Special note 1: Since this gTLD is for individuals and registrations could number in the millions, if not hundreds of millions, there is naturally concern about the scaleability of a personal name space gTLD. There have been suggestions that in order to improve the scaleability of the .nom name space, a numerical identifier should be added to the .nom gTLD from the outset (e.g, .nom1, .nom2, .nom3, etc.) Do you agree? [yes__] [no__]

Special note 2: There are often suggestions that names like .id, .me, ind, or .per should be used as a "personal" gTLD. Please note the following reasons for rejecting these names:

TLD	Reason for Rejection
.id	.id is already allocated as the ISO 3166 two-letter country code for Indonesia all two-letter top level domain are reserved for future ISO 3166 country-code allocations
.me	all two-letter top level domain codes are reserved for future ISO 3166 country-code allocations
.ind	.ind is the three-letter ISO 3166 country code for India, we considered it prudent to hold this code in reserve
.per	.per is the three-letter ISO 3166 country code for Peru, we considered it prudent to hold this code in reserve

 
2. Creation of gTLD Indicating Adult-Oriented Content

There is often the suggestion made that a dedicated gTLD indicating the equivalent to a "red-light-zone" would be useful in isolating and filtering adult-oriented content from minors on the Internet. There are differing opinions on how effective this would be. The most common suggestion is the request to create a gTLD .xxx. Do you think that a sort of "red-light-zone" gTLD should be created?

[strongly approve __] [approve __] [no opinion __] [disapprove __] [strongly disapprove __]

If you strongly approve or approve, do you think this should be the gTLD .xxx? [yes__] [no__].

If you have replied "no", what gTLD would you suggest in place of .xxx in this category? ______

3. Other Suggestions

Please make any other suggestion concerning the names of the new gTLDs not covered above.

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