FLASH: One DNS user likes the draft

[Steve Peterson <stevep@ry.com>]

There's been some discussion of a "consensus" forming, and I want to get my
two cents in as a user before things solidify.

#include <I'm not a potential registrar; just a DNS user>

1.  Generally, I support the draft.  IMore detail is needed in many areas
but conceptually I believe it is a workable scheme that will serve domain
name users' needs.

2.  Publication period

I'll start by restating my understanding of how the publication period works.

-- RESTATEMENT ON --

If I understand it correctly, the goal of the publication period is not to
allow competing potential owners of a SLD to have their dispute resolved by
the registry.  Instead, it allows a time period for a dispute to be
resolved using a dispute resolution process other than the registry (i.e.,
negotiation or the courts).

When the time period expires, the registry puts the domain name into
operation.  There are only two events that could cause the domain name not
to be put into operation at the end of the publication period -- an order
by a court having jurisdiction, or at the request of the application for
the SLD.  These are also the same two events that could cause a SLD to be
"shut off" after the publication period.

-- RESTATEMENT OFF --

If my understanding is correct, I believe that a shorter waiting period
than 60 days is sufficient.  It is not necessary for the dispute to be
resolved prior to operation;  it is sufficient that others be informed of
the SLD application and have time to react through negotiation and, failing
that, through procurement of a court order prohibiting the creation of the
domain.

I believe a two week waiting period is sufficient to allow a trademark
owner to react to a SLD application that threatens their mark.  Trademark
owners are incented to keep up with the list because reacting quickly lets
them prevent conflicting domain names from being implemented.  DNS users
benefit because once a SLD is allocated only their agreement or the order
of a court can take it away from them.

3.  gTLD names

I agree that they should represent 'real world' entities, e.g. .BIZ, not
technical things like .WWW.  It would be useful to have more detail on how
they will be selected.

4.  Multiple registrars per registry

This is clearly the best situation for the users.  Having one registrar per
gTLD does nothing to improve service, and the example of the US toll-free
telephone number database (800/888) clearly demonstrates that the shared
registrar model is technically and operationally feasable.

It should be explicitly stated that all pending applications for monopoly
gTLDs are denied.

5.  Number of gTLDs

I agree that starting out with a small number if gTLDs is reasonable.  We
need to understand the operational issues relating to gTLDs and starting
out with a few is reasonable.  There is also value in initially limiting
the number of gTLDs so that it can be ensured that the cost of supporting
registries does not increase linearly with their number.  If the costs do
behave this way, a more permanent limitation on the number of gTLDs may be
useful.

6.  Registrar selection process

>From the user's standpoint, there should be a sufficient number of
registrars to ensure competition, but not so many that the system breaks
down from an operational standpoint.  A strategy of 'start out small and
grow', as proposed, implements this requirement.  Since in the initial
stages there will probably be more organizations wanting to be registrars
than makes sense, there needs to be some way of selecting among the
potential registrars.  From the user's perspective, setting a baseline
level of performance and then choosing randomly from those who qualify will
be more likely to provide a variety of service and price choices than
selecting the 'absolute best' organizations to be registrars.  It will also
be easier to get consensus on the minimum performance requirements than
absolute ones.

Some observations
-----------------

1.  Based on the economics of this model, most registrars will be part of
ISPs or backbone providers.  Many organizations will not have 'standalone'
pricing for registrar services;  instead, domain creation will be performed
as a customer service function.

2.  For those purchasing business-oriented services, domain registration
will essentially be free.  If the cost of creating domains becomes very
low, it may be essentially free for anyone who wants one.

3.  In order to make the adjudication of competing claims as predictable as
possible, it would be useful for registrars in each country to agree on one
court of competent jurisdication and have their domain name users agree to
resolve their claims there.

4.  The impact on root nameserver operation needs to be considered.


--
Steve Peterson                                    Reality Interactive, Inc.
stevep@ry.com
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