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Summary and Analysis of Comments

  • To: "biz-alloc-amendment@xxxxxxxxx" <biz-alloc-amendment@xxxxxxxxx>
  • Subject: Summary and Analysis of Comments
  • From: Patrick Jones <patrick.jones@xxxxxxxxx>
  • Date: Mon, 16 Mar 2009 09:31:53 -0700

Summary and Analysis of Comments for:
.BIZ Proposed Amendment for Single and Two Character Domain Names

The comment period ran from 13 February to 15 March 2009. Two substantive 
comments were received - one from Michele Neylon of Blacknight Solutions and 
one from Chuck Warren on behalf of Overstock.com. The public comments on the 
proposed contract amendments can be found at 

Michele noted his support for the NeuStar proposal. He stated "Apart from 
anything else, the fact that ICANN has permitted other gTLD
operators to allocate them means that not doing so in the case of .biz will 
lead to a greater level of confusion."

He also noted a concern "that trademark holders would attempt to do a landgrab 
on some of the domains without actually making any attempt to add value to the 
namespace ie. the domains they may register would merely serve as protective 
registrations and redirect to their existing .com domain." See 

Chuck Warren's comments were also in support of the NeuStar proposal, but 
focused strictly on the release of single characters in .BIZ, not on 
two-character domain names. Overstock has indicated its interest in registering 
and using the single letter - O - in its online identify and operations. He 
notes that the allocation of single letters by NeuStar would enable parties 
like Overstock to participate in the proposed RFP process.

"The approach proposed by the registry appears, to the best of my knowledge, to 
follow the recommendations of ICANN's GNSO Reserved Names Working Group, which 
provided for the 'sponsored' registry strings to have the option to develop 
additional elements for their allocated string that are suitable to the 
circumstances of the string. .biz, while not a fully sponsored category, is a 
restricted category, focused on the registration of commercial entities of any 

 Chuck also provided a comment of concern. "Applying for the allocation of and 
using a single letter in biz cannot preclude a party from seeking to use a 
single letter associated with their trade/brand name in a different gTLD or 
ccTLD... NeuStar's proposal seems to be a useful approach to limit merely 
defensive registrations' and to ensure that the single letters are put into 
active use."

"With the assurance that co-existence of registration and use in more than one 
single letter is allowed, as it exists today for other second level
registrations, I support the NeuStar proposal for moving ahead with allocation 
of single letters in the manner they have proposed."

Patrick L. Jones
Registry Liaison Manager &
Support to ICANN Nominating Committee
Internet Corporation for Assigned Names & Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292
Tel: +1 310 301 3861
Fax: +1 310 823 8649

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