Re: My comments

[Karl Auerbach <karl@CaveBear.com>]

> >   - The very important and much-used .arpa domain is left orphaned.
> 
> Good point.  I'd guess that it belongs in .int or in its own category.  It
> is interesting by virtue of in-addr.arpa and no particular other reason, I
> believe.  The reverse-mapping function, however, makes it quite critical,
> and far beyond gTLDs.

Yes, it's the in-addr.arpa that I'm concerned about.

> >   - There is no mention of the privacy to be accorded to registration data
> >     or applications.
> 
> Good point.  I'm afraid that my personal inclination is to believe that
> there should be no privacy accorded to contact and descriptive information,
> only the financial data that is part of the private relationship between
> registrar and registrant.
> 
> There are two reasons for this:  a) the information which needs to be made
> public for trademark review, and b) ensuring that a registrant is able to
> move to another registrar easily means that the necessary information needs
> to at least be held in escrow by a third party, so the originating
> registrar does not have leverage.

Your inclination is in accord with my own feelings.  I would suspect that
there is some feeling by some people that all information that relates to
a identifiable individual should be kept private, however I doubt that
that would be workable given the importance of contacting people when
something at their site goes awry.

The collection of registration information is a marketing person's dream
and it does have commercial value.  There might be an interesting method
buried somewhere in this to obtain some revenue to help run CORE.

> >   - The 60 day waiting period is too long.
> 
> 	Karl, you know the Internet rule.  If you don't like a spec, you
> need to offer a counter.  Your web page comments suggest 2 weeks.  I fear
> that you actually believe that 2 weeks is enough for the crustry old,
> paper-based international legal world to function.  It would surprise me if
> other attorneys agreed with you, but let me verify:  you are suggesting
> 14-days as an alternative to 60-days, as a sufficient, global notice time
> for contestants (or whatever they are called) to initiate whatever actions
> are necessary?

Yes, 14 days after the effective date of the notice.  I don't think we
should cater to mark watchers who are still in the paper age.

There's some competing ideas, some pulling for a shorter time and some for
a longer time.

I think it was Carl O. who mentioned that there is a possibility that,
over time, the waiting period will evolve to have legal weight as a period
beyond which one complaining about a name conflict after the
expiration of the period will have to face a presumption that there is no
conflict.  In order for this desirable property to arise, the period will
have to be long enough so that it is really meaningful; so that one can
really say to a late complainer: "too bad, you sat on your rights".  It's
my feeling that this is perhaps the strongest argment against my 14 day
proposal -- that it will be so shockingly short in the minds of many that
it will never mature into a recognized period that establishes a
presumptive right.  (I think I outdid myself in this paragraph with overly
long sentences. ;-) 

> >   - NSI is given extremely deferential treatment.
> >     I believe that the major import of this report, if issued in its
> >     present form, will be to indirectly grant a permanent continuation
> >     of NSI's current de-facto monopoly.
> 
> 	We tried to provide encouragement to NSI to join CORE.  Existance
> of the Cooperative Agreement constrains things.

Is there any particular reason to say "as of Jan 1, 1996, *all* registrars
must meet these requirements"?

As a pragmatic matter, I have concern for the viability of this whole
process unless we have an effective alternative mechanism, ready to take
over the shared management of .com on the date that the existing NSF-NSI
"cooperative agreement" expires. 

> 	What the heck.  Given only days before Xmas, felicitations (of the
> navidad variety) are no doubt tending to wear thin, anyhow, especially on
> this well-behaved list...
> 
> 	In any event, *I* found your comments interesting.

Thanks.

By-the-way, I was wondering whether the web page based markeup is a more
or less effective mechanism as compared to commentary by e-mail

		--karl--