Disapproval of .mobi

[Koki Higashida <higashida@xxxxxxxxxx>]

Stance of JPRS

As the sponsoring organization and DNS operator for .jp top-level
domain, JPRS exercises technical and operational leadership in
management and administration of the domain.  Also, JPRS believes that
it has a role in preventing confusion or trouble on the Internet.

JPRS submits the following comment as a result of study of each
application from the aforementioned standpoint.  We expect ICANN's
serious consideration of our comment.

Introduction of new TLDs may result in addition of new value and
interest for the Internet community; on the other hand, it may result
in unnecessary confusion and disbenefit of the community.  Therefore,
decision to introduce any of the proposed TLDs must be made based on
the thorough evaluation of experience of the seven TLDs introduced in
2000.

Disapproval of .mobi

Japan is one of the countries where use of Internet via mobile
devises, especially mobile phone, is common.  Based on the situation
and experience of the usage, we envisage that there is no need to
introduce .mobi, and that it does not add value to the users, since it
hinders the use of other TLDs in mobile businesses.  And we are
opposed to introduction of .mobi top-level domain for the following
reasons:

1. Unnecessary segmentation of the Internet

   At the layer of accessing Internet with domain names, mobile
   devices should not be regarded as special.  As the technology
   develops, service and contents are removing the borderline
   between PC's and mobile devices.
 
   The technical necessity advocated in the proposal is already
   implementable in the existing domain name space without any new
   specific TLD.

   .mobi will only create a partial network which appears to be
   functionally specialized and independent.  However, it is only a
   part of the Internet, and there does not exist distinct "mobile
   Internet" in reality.  It is not the creation of the sponsored
   community.

   What led the Internet to success as we know it today is the
   principle that mobile and other services on the Internet should
   be provided seemlessly.
   .mobi defies this idea and is to segment the Internet by devices.

2. Burden on contents providers

   In Japan, Internet use via mobile devices, especially mobile
   phone, is already common.  Over 40% of all the Internet users in
   Japan are mobile users.  The number of customers subscribing to
   Internet access service through mobile device is the largest in
   the world.

   Provision of mobile service contents is integrated into Internet
   usage through PC, and it is inseparable.

   Under this circumstance, introduction of .mobi and inclusion of
   mobile service contents into the .mobi space will place a heavy
   burden on many mobile contents providers who conducts the
   services with existing domain names.

Sincerely,

Koki Higashida
President, Japan Registry Service Co., Ltd. (JPRS)