I feel that it would be a grave mistake for you to implement new TLD's.
The main arguments for this (with the exception of .xxx) seem to be to
allow for duplicate second level domain names (typically company names)
and to retain the current "guessability" of a domain name.
While these are both admirable reasons, I do not see any way that you
will be able to attain your goals without a tremendous amount of
monitoring and paperwork associated with the domain name registration
process. Of course, the added beuracracy will increase the registration
costs which will remove the common playing ground that companies
currently have on the Internet (a small business can appear as large as
an AT&T).
The reason I do not believe that you will be able to attain these goals
is that companies currently see their right to a second level domain
name as a kind of trademark. While they understand that they are not
protected, they feel that the name entitles them to the traffic of
anyone typing in "ibm.TDL" in their browser window. An increase in the
number of TDLs will just be an increase in the number of registered
ibm.TDLs. Even with an increased registration system, the situation is
bleak. IBM, for example, could justifiably register all of the
following: .firm, .store, .web, and .info.
Suppose that somehow you are able to classify every company into a new
TDL and only allow any one company to register their name under any one
TDL. This will, in no way, retain the "guessability" of domain names.
Instead of having one known value -- .com -- and a reasonable guess at
the second level domain name, users will now have a resonable guess at
the seond level and a guess at the TDL. Is IBM a .firm, .store, .web, or
a .info?
There will be, of course, an increase in the number of domain names
registered. Which, will lead to increased profits for the companies that
offer services to fill out the registration forms.
As for the .xxx TDL -- I have mixed feelings about this. I can see where
it will be easier to keep minors from visiting adult-oriented sites, but
there are already quite a few companies that have taken care of most of
the problem. Browser add-ins which restrict access and age verification
services will all be put out of business instantly if this addition is
successful -- but I'm sure you'll here more from them.
For this TDL to work, though, we assume that operators of adult-oriented
sites will voluntarily (or will they be forced?) line up to move their
site over to a new TDL -- something that I doubt will happen. There is
no incentive for them to move unless they are forced. And if they are
forced, it leads back to the same problems as administering TDLs for
businesses.
Overall, I feel that introducing new TDLs would be a mistake. Hopefully
more users will respond on this rather important issue and you will
reconsider your stance.
Thank you for allowing us to comment on this issue.
--Kevin Gates