Comments on new generic Top Level Domains

Sirosh, Joseph (sirosh@hnc.com)
Mon, 15 Sep 1997 19:44:01 -0700

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VERSIGHT COMMITTEE

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. Comments related to this request for comments
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 International Ad Hoc Committee (IAHC) in its final report, available
on the Internet at
http://www.gtld-mou.org/draft-iahc-recommend-00.html, recommended an
initial set of 7 new generic top level domains (gTLDs). These
proposed gTLDs are:

.firm
for businesses, or firms
.store
for businesses offering goods to purchase
.web
for entities emphasizing activities related to the World Wide
Web
.arts
for entities emphasizing cultural and entertainment
activities
.rec
for entities emphasizing recreation/entertainment activities
.info
for entities providing information services
.nom
for those wishing individual or personal nomenclature, i.e.,
a personal nom de plume

The generic Top Level Domain (gTLD) names selected by the IAHC were
chosen to intentionally represent broad categories and were a
synthesis of public comments, previous proposals, contributions and
discussions during the International Ad Hoc Committee's activities
(e.g., see http://www.iahc.org/contrib/informal.html).

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

1. Number of gTLDs

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

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

C. CHOICE OF gTLDS

1. Review of IAHC-Suggested 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 _X_] [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_X_].

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: