Comments of Friedrich KistersPrefactory
comments:
ICANN poses 74 questions. Question 41 to 43 and 70 are dealing with the
intellectual property rights. Whoever supports the idea of creating a .reg gtld should
answer to these questions.
As we learned from Dr. Mueller, the stability of the
Internet will not be affected at all, when new gtlds are intoduced. I would therefore
very much like to know from ICANN, why this question has been asked? Didn't you know
what Dr. Mueller knows?
Further on Dr. Mueller convincingly explained that there
is no difference between introducing a new cctld or gtld. I would therefore again
like to know from ICANN, why this question has been asked at all? Are we discussing
the "new dresses of the emperor" here? (In german: "Des Kaisers neue Kleider")
I
am urging ICANN to give a proper answer to these two questions, otherwise its credibility
can impossibly be maintained.
On to the specfic questions:
Q1: In the introduction
of new TLDs, what steps should be taken to coordinate with the Internet Engineering
Task Force, the Internet Architecture Board, and other organizations dealing with
Internet protocols and standards?
Obviously none.
Q2: What stability concerns
are associated with the initial phases of registration within the TLD?
Obviously
none.
Q4: Would these stability concerns be magnified by introducing a large number
of TLDs at once?
Obviously not.
Q5: Are there any practical means of reversing
the introduction of a significant new TLD once it goes into operation?
Of course.
You can take it out of the root. But why should this make sense?
Q6: Is it feasible
to introduce a TLD on a "trial basis," giving clear notice that the TLD might be
discontinued after the trial is completed?
Of couse it is "feasable", but IANA
has done so with IOD already and the result is what you can read in this forum. The
message is clear: It makes no sense at all, but creates a lot of problems, especially,
if this trial basis is thought to last for 5 years!
Q7: To ensure continued stability,
what characteristics should be sought in a proposed TLD and in the organization(s)
proposing to sponsor and/or operate it?
The same as currently asked from new cctld
registries or the old gtlds, if any. There should generally be protections to 100%
prevent the loss of data.
Q8: To what extent is the experience gained from introducing
gTLDs in the 1980s applicable to present-day circumstances?
To a great extend:
In both cases we are talking about a huge amount of new registrations of domain names
and the stability of the Internet.
Q9: To the extent it is applicable, what are
the lessons to be learned from that experience?
Lesson 1: Even though there was
an enormous and unexpected amount of new registrations of domain names, the Internet
proved to be stable. Obviously there is no reason, why it shouldn't anymore, if ne
gtlds are introduced.
Lesson 2: The experience tell us that no further testbeds
are needed. Reality was the better teacher.
Lesson 3: A Trademark area has to be
introduced to the Internet. I strongly recommend the introduction of a .reg gtld
for international trademarks and the automatic addition of an "r" to ALL cctlds and
gtlds. The "r" stands for "registered area". The result is a ".com" plus a ".rcom",
a ".web" plus a ".rweb". Generally the "r"-gtld area would be reserved to international
trademark holders (e.g. microsoft.reg, microsoft.rcom) and the "r"-cctld area to
national trademark owners (e.g.: mybiz.usr, yourbiz.ukr). In cctlds the "r" should
follow the country code (easier to read). It should not be possible to register a
trademark in none "r" areas of the Internet. Each registry applying for a new gtld
HAS TO OFFER both Versions, the reg-area one AND the open one (e.g. .games AND .rgames).
Q10:
What lessons, if any, can be learned regarding new gTLD introductions from the experience
of the ccTLD registries?
That there is no serious reason not to introduce new gtlds.
Q11:
Can lessons relevant to introduction of new TLDs be learned from the recent decisions
by a number of them to operate in a globally open manner? If so, what lessons?
Maybe
there should be higher expenses for getting a 1-4 letter name than for a 5-x letter
name.
Q12: Is the Names Council's recommendation that a "limited number of new
top-level domains be introduced initially" a sensible way to minimize risks to Internet
stability?
After this forum I no longer believe in a restriction of new gtlds.
Just don't forget adding the parallel "r" gtlds for trademark owners, please.
Q13:
What steps should be taken to evaluate carefully the initial introduction of TLDs
before future introduction of additional TLDs?
Step 1: Recognize that the Internet
has remained stable during the initial introduction.
Step 2: Introduce new gtlds,
because you know that it will remain stable again.
Q14: Should a fixed time be
established for all the evaluations, or should the time allowed vary depending on
the nature of the TLD and other circumstances?
Yes, unless it takes another 5 years
to fix it.
Q15: Should choices regarding the types of TLDs included in the initial
introduction seek to promote effective evaluation of:
- the feasibilty and utility
of different types of new TLDs?
- the efficacy of different procedures for launching
new TLDs?
- different policies under which the TLDs can be administered in the
longer term?
- different operational models for the registry and registrar functions?
-
different institutional structures for the formulation of registration and operation
policies within the TLD?
- other factors?
Yes, unless it takes another 5 years
to choose.
Q16: Should any particular goal for, or limit on, the number of TLDs
to be included in the initial introduction be established in advance, or alternatively
should the number included in the initial introduction be guided by the extent to
which proposals establish sound proofs of concept of varied new TLD attributes?
Any
limit is obviously artificial.
Q17: In view of the current competitive conditions,
should the promotion of effective competition in the provision of registration services
continue to be a significant motivation for adding fully open TLDs?
Yes, it should.
There
must be further price reductions to come as well as gtlds which are completely free
of charge (e.g. .kids, - but not the .rkids gtld for reg. companies).
Q18: Should
the desire for diverse vendors of registry services in open TLDs be an important
motivation in adding fully open TLDs?
Yes, it should.
Q19: Would the introduction
of additional undifferentiated TLDs result in increased inter-TLD confusion among
Internet users?
No. Even if there will be a computer.shop, computer.com, computer.sale
you will always individualize and remember which shop had which advantages. It's
similar to saying "I'll go to the supermarkets" and only afterwards, which supermarket
you where talking about in this particular moment.
Q20: Taking all the relevant
factors into account, should one or more fully open TLDs be included in the initial
introduction? Q21: How many?
At least one fully open TLD and 5 restricted TLDs.
There should be at least 6 new fully open TLDs included in the initial introduction:
.reg, .rcom, .rnet, .rorg, .web, .rweb. The "r" standing for registered: Access only
for registered trademark holders, as explained under Q9. In my opinion, ".rcom" should
be run by the .com registry, and so on ...
Q22: How effective would other fully
open TLDs be in providing effective competition to .com?
Try and see.
Q23: What
can be done to maximize the prospect that new fully open TLDs will be attractive
to consumers as alternatives to .com?
Just give them a chance and introduce new
gtlds. Otherwise we will never get to know it
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?
I think it is better to keep those for future discussions.