Q19: Would the introduction of additional undifferentiated
TLDs result in increased inter-TLD confusion among Internet users?No. Commercial
TLDs will have every incentive to differentiate themselves from others through marketing
and branding. Non-commercial TLDs will also have adequate incentives to appeal to
specific communities.
Furthermore, I reject categorically the premise that DNS
should serve as an intuitively accessible catalogue of the Internet.
For American
Internet users, the paralysis on new TLDs has made dot com the defacto root, the
default value. Any name that does not use .com or that is not readily guessable within
the com space is just as likely to generate "confusion" as ten new TLDs.
Here
is the critical point: The larger the Internet and the name space become, the more
domain names will devolve into what they ought to be: unique identifiers with mnemonic
value to those who know them -- nothing more, nothing less. Any attempt to make domain
names into keywords that can be used on a global basis as a directory or intuitive
locator is bound to fail and should not be encouraged. Such an approach to domain
names only exacerbates name speculation and trademark problems.
Q20: Taking all
the relevant factors into account, should one or more fully open TLDs be included
in the initial introduction? Q21: How many?
There should be at least 5 new fully
open TLDs included in the initial introduction. These should be given a strong expectation
that they will be allowed to add at least two more names to their repertoire, in
order to match NSI’s repertoire, at some point in the not-too-distant future.
Q22:
How effective would other fully open TLDs be in providing effective competition to
.com?
This depends on who runs them, how well-financed they are, how well-conceived
their marketing is, and the excellence of their services. This means that if you
are to err, you should err on the side of more TLDs, rather than less. Some new registries
simply will not find the right strategy, others will. The simple grant of a name
cannot guarantee that alternative registries will be successful.
Q23: What can
be done to maximize the prospect that new fully open TLDs will be attractive to consumers
as alternatives to .com?
Very simple: you can maximize the opportunities for entrepreneurs
to enter the registry market. The telecommunications world has more than a decade
of experience with the introduction of new competition. We have learned the hard
way that duopolies and other attempts at managed competition do not work. Only open
markets can ensure that the best idea and the best people have a chance to win.
Q24:
Would the likelihood of effective competition with .com be enhanced by making one
or more of the single-character .com domains (which are currently registered to the
IANA) available for use as the basis of a third-level registry (i.e. a registry that
took registration of names in the form of example.e.com or example.1.com)? Should
the single-character .com domains be made available for possible registry usage in
conjunction with the initial group of additional TLDs?
Everything we know about
the market for domain names tells us that when given a choice, users prefer fewer
levels of hierarchy in their domain names. All of the issues of confusion are made
worse by sticking a single letter in between “com” and another SLD. Third-level domains
are so far down the contractual chain that no self-respecting business will pin their
global visibility on them. Their destiny is under the control of too many other parties.
This
is not to say that we oppose the release of the single-letter SLDs per se, only that
it is not an effective way of promoting effective competition with gTLDs.
Q25:
Is increasing the utility of the DNS as a resource-location tool an appropriate goal
in the introduction of new TLDs?
If by "resource location" you mean "guessing
a domain name to find web site," then No. Jon Postel said it perfectly four years
ago: "The Domain Name System provides a name to address look up service. It assumes
that one starts with the exactly correct name and allows the look up of information
associated with that name. The Domain Name System does not (and never was) intended
to provide a general search facility. It is much more appropriate to use application
level search tools [for that purpose]." (draft-postel, 1996)
Q27: If so, are there
ways of accommodating the goal of enhancing registry-level competition with the goal
of enhancing the utility of the DNS?
Competing, generic, exclusive registries will
attempt to differentiate their names and services. To some extent, this will enhance
the utility of DNS. (On the other hand, registrars have little if any incentive to
differentiate or brand TLD strings, since they make money exclusively from the registration
account.)
Q28: Is the concept of TLD "charters" helpful in promoting the appropriate
evolution of the DNS?
This is a troubling issue. In general, my answer is that
charters are to be avoided like the plague.
First, a definitional issue. We must
distinguish between a "registry policy" and a "charter." Registry policies are registration
criteria that are defined and enforced by the registry operator. "Charters" I understand
to mean a registry policy that is part of the contractual basis of a TLD delegation.
The latter implies some kind of official sanction by ICANN and at its most extreme,
that ICANN shares with the registry some responsibility for enforcing the charter,
e.g. by withdrawing the delegation from a party that fails to fulfill it.
Registry
policies are not problematical as long as the creation of new TLDs is reasonably
unrestricted. If, for example, a registry acquires the TLD .family and wants to strictly
limit registrations to pro-family content, the registry itself is responsible for
defining what it means by "pro-family" and for enforcing those criteria. The policy
is "enforced" primarily by the registry's reputation in the marketplace. Anyone who
doesn't like that policy can start another TLD.
If on the other hand "charters"
are part of the contractual arrangement between ICANN and a registry, they become
grants of a public trust. ICANN is put in the position of deciding who best represents,
e.g., the banking, airline or museum communities before designating an official "bank"
TLD, an official "airline" TLD, an official "museum" TLD, and so on. This raises
all the thorny political issues that the delegation of country codes raises -- indeed,
the problems are exactly parallel, except that in the case of country codes we have
a much clearer situation because we know which institution officially governs a country
(national governments). This is NOT the case with most potential chartered TLDs.
The choice of ISO-3166 as the standard for country codes was meant to keep IANA
out of the business of deciding what is a country. Even so, delegation of country
codes has proven to be a highly sensitive issue, because in a monopoly situation
(one code to a country), ICANN must ensure that the delegation is held by someone
responsible to the named community.
Imagine what delegation of country codes would
be like it there were no ISO-3166-1 list. Multiply the political chaos by ten, and
this is the situation ICANN would find itself in if it chose to "charter" TLDs. Numerous
groups claiming to be representative of some industry sector, civil society sector,
special interest and so on will come to ICANN seeking official sanction. ICANN becomes
in effect a global regulatory authority with the power to issue special privileges
to favored segments of the global community. I cannot think of a better way to further
politicize DNS.
ICANN's delegation decisions need to be based primarily on technical
and operational criteria and not on registry policies.
Q29: Are the first three
principles outlined in the second additional consensus point of WG-C's 17 April 2000
supplemental report (quoted above) appropriate criteria for selecting TLDs to be
introduced in the first group?
They are appropriate criteria for selecting among
competing, mutually exclusive applications for TLD string assignments. ;-)
Q30:
Do those principles preclude the introduction of any new fully open TLDs?
No. Records
of the working group make it clear that "fully open" was viewed as a particular type
of policy that might be proposed by a registry.
Q32: Should chartered TLDs be introduced
according to a pre-defined system, or should proposals be evaluated on an individualized
basis?
Neither. ICANN’s job is to coordinate name assignments at the root level.
It is not mandated to decide what is a good registry policy and what is a bad one,
nor is it mandated to decide which applicant best represents a community.