Comments on DotAsia from HKIRC

["Joseph Yu" <jonathan.shea@xxxxxxxxxxxx>]

Further to our email dated 2 March 2004, we wish to express our views on the
DotAsia bid as follows.

Firstly, the domain ".asia" may cause unnecessary confusion to the user
community.  With the current classification, each ccTLD represents a country
and there is no (or very little) overlap in the geographical area between
them.  A TLD with a regional scope such as ".asia" will cause overlap to
many ccTLDs.  When such a TLD is introduced, most users may be suggested by
their registrars that they should register both the regional and the
country-specific domain names to avoid their domain names being used by
others.  Many companies are already complaining about the proliferation of
new gTLDs which force them to spend more money to register these new ones in
order to protect their brands.  

Secondly, it violates the practice that each gTLD serves a specific type of
industry, organization or purpose without a geographical scope, while a
ccTLD serves the user community in a particular country (with a geographical
scope).  This clear and consistent structure will be broken if some domain
names such as '.asia' should be allowed to be introduced.  If there is
deemed to be a need for a regional TLD, one would question if other regional
TLD should be created at the same time as '.asia' - including '.africa',
'.namerica', '.samerica', '.europe', '.australia', and arguably '.world' or
'.earth'. (why not?)  Being a responsible body in the Asian region, we wish
to see that a clear and consistent structure of the domain name system will
be maintained and any initiative that may create confusion and clutter up
the current system should not be approved.

Thirdly, we believe that the DotAsia proposal cannot be evaluated on the
same basis as another gTLD.  It carries a geographical significance
involving all the countries in the Asian region.  Hence, a broad base of
support by a majority (if not all) of the governments and ccTLDs in the
region is essential to the success of any organisation wishing to administer
'.asia'.  Endorsement from a few ccTLDs is not sufficient.  The number of
supporting governments is even less.  As of today, neither the government of
Hong Kong Special Administrative Region nor HKIRC has expressed any support.

Fourthly, we are also concerned about the financial viability of DotAsia.
We are not aware of any viability study on the sources of start-up capital.


 From an operational point of view, we envisage a great deal of disagreement
in many terms and conditions of cooperation with various countries and
ccTLDs, particularly when there is a lack of support by the governments at
the very beginning. 

Nevertheless, on balance, '.asia' may be a good concept in the long run,
provided that the other regional TLDs such as '.africa', '.europe',
'.namerica' , '.samerica', etc. should be considered altogether on a global
rather than piecemeal basis.  In other words, if '.asia' is to go forward
and to be adopted, this must be done for all other regional TLDs in the
entire world at one go.  Whatever policies and procedures that are required
for their formation and adoption must be carefully deliberated at a very
high level of ICANN in conjunction with the GAC.

As it stands, we wish to register our opposition to the DotAsia proposal in
its current form.

Best regards,
Joseph Yu
Chairman
Hong Kong Internet Registration Corporation (HKIRC)