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Username: ckarp
Date/Time: Fri, July 7, 2000 at 8:50 PM GMT (Fri, July 7, 2000 at 10:50 PM CEST)
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Subject: Comments on new TLDs from a museum perspective

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        The museum community registered its interest in a restricted
.museum domain early in the course of the new TLD deliberations.
A draft proposal was submitted in response to the IAHC call and a
similar proposal is planned within the context to be established
at the impending ICANN meetings.

The priority issue at this point in the museum endeavor is simply
to ensure that the ICANN call explicitly allows proposals for
chartered TLDs.

The following response to ICANN's request for commentary on their
"Suggested Principles for the Introduction of New TLDs" addresses
those questions that appear specifically relevant to the
establishment of a dedicated museum TLD.  I expect to coordinate
the authorship of a museum proposal (within the context of
previous action; I make no assumptions about similar activity
that may be in progress elsewhere) and will exemplify some of
what is said below in that light.

I am speaking here with the endorsement of the Executive Council
and Secretary General of the International Council of Museum, and
an as yet informal ad hoc consortium of directors of national
museums and national museum organizations.

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?

Total adherance to these protocols and standards should be
axiomatic. Equally obvious is the need for maintaining fruitful
liaison with these bodies should it ever be necessary for ICANN
to articulate needs for modification to the standards and
protocols.

Q2: What stability concerns are associated with the initial
phases of registration within the TLD?
&
Q3: What can be done to eliminate or reduce these stability
concerns?
&
Q4: Would these stability concerns be magnified by introducing a
large number of TLDs at once?

If there is genuine reason to doubt the extent to which the DNS
can be scaled into a significantly larger TLD space, it would be
prudent to regard any extension of this space as experimental. A
domain that could not conceivably be rolled back once brought
into operation would not be ideal as a test object.

Q5: Are there any practical means of reversing the introduction
of a significant new TLD once it goes into operation?

Any TLD created in the next wave will be significant for that
reason, alone. The provisional aspect of a new TLD may be
stipulated at the outset and all registration in it made
contingent upon explicit agreement to a trial period with no
guarantee of continuation.

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?

Yes. One attractive attribute of a TLD proposal might be the
existence of a fallback domain within the pre-existing TLD
structure into which all domains in the new TLD could be migrated
should it be discontinued at the end of the test. In the case of
the .museum community, the fallback could be to pre-existing
domains operated individually by the provisional "converts"
and/or, should the retention of a collective identity be desired,
by block transferral to a mutually acceptable second-level
domain. (Admittedly, if such a beast were apparent, the need for
a dedicated TLD might never have arisen.)

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?

One means to ensure the operational stability of a domain is to
anchor it in an organization that has clearly demonstrated its
own stability in relevant regards.  A meaningful chartered domain
will obviously require connection to a sound administrative body
with wide authority in its sector.

Notions of the administration and coordination of disciplinary
matters on an international basis are by no means unique to the
TLD initiative. A general long-standing solution to such problems
is reliance on the formally defined Non-Governmental
Organizations. Indeed, the experience of the NGOs in adressing
politically thorny international managerial issues might easily
be of benefit to the development of a truly international basis
for Internet governance. The possibility of establishing
collaborative bonds between NGOs and ICANN may be worth
consideration as an end in itself.

Q8: To what extent is the experience gained from introducing
gTLDs in the 1980s applicable to present-day circumstances?

We have learned that the current division of gTLD space serves a
useful purpose and that the technical underpinning provided by
the DNS works. If nothing else, a thriving Internet has developed
on that basis. Any doubts about this being the case are unlikely
to be put to rest by an arbitrary extension of the "test" period.

Q9: To the extent it is applicable, what are the lessons to be
learned from that experience?

See Q8.

Q10: What lessons, if any, can be learned regarding new gTLD
introductions from the experience of the ccTLD registries?

The ccTLDs have autonomously particulated their domain spaces,
developing and applying differing principles. Had there been some
coherent basis for delegation within the ccTLDs, many aspects of
the gTLD discussion might well have been different. It is,
however, difficult to see how any aspect of current deliberation
can retroactively modify the ccTLD situation.

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?

If the introduction of new TLDs is regarded as having potential
for endangering the stability of the Internet, it would be highly
ill-advised not to place limitations on the scope of the initial
rollout.

Q13: What steps should be taken to evaluate carefully the initial
introduction of TLDs before future introduction of additional
TLDs?

If the decades long history of present TLD space has failed to
allay fears about catastrophic limitations to its scalability, it
is difficult to suggest means for the short term evaluation of
adding additional domains to it.

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?

One condition for a provisional domain could be the length of
time prior to its evaluation. It might be a good idea to test
different intervals, if for no other reason than to optimize that
aspect of a future wave of similar activity.

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?

One purpose of the experiment ought reasonably be to establish a
long-term procedural basis for the continuing expansion of TLD
space. It is difficult to see how this can be done without at
some point testing the full spectrum of variable factors. Doing
so at the outset is one very obvious alternative.

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?

There is no purpose to be served by any a priori limitation in
the scope of proposals that may be submitted. Despite all the
effort that has been put into this endeavor, thus far, it is
entirely possible that innovative and genuinely useful ideas
may be found in any proposal.

Q25: Is increasing the utility of the DNS as a resource-location
tool an appropriate goal in the introduction of new TLDs?

The value of any resource-location tool is dependent on the
structure of the information base upon which it operates.
Applying the full battery of discovery tools currently resident
on the Internet is inadequate for all but the most trivial
searches. Realizing the fullest potential of the DNS as a
resource-location tool would be an extremely valuable
contribution.

Although this need not be an explicit goal in the introduction of
new TLDs, it would be remiss to take any action that might
inadvertently reduce the resource-location value of the DNS.

Q26: Would the introduction of unrestricted, undifferentiated
TLDs run counter to this goal?

The size and differentiation of new TLD space are not inherently
at odds with the purpose of maximizing the utility of the DNS as
a resource-location tool. It could easily be argued that the
semantic value of TLD space would increase in direct proportion
to its vocabulary.

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?

If enhancing the utility of the DNS can be served by expanding
TLD space, one consequence of such action will be having a larger
basis for competition on the registry level.

Q28: Is the concept of TLD "charters" helpful in promoting the
appropriate evolution of the DNS?

Yes. Charted domains would be a milestone development. Candidate
chartered domain namees, such as .union and .museum, are the
primary terms that would be used in searches for resources
relating to them. The essence of the argument for .museum is that
it could provide an intuitive and memorable point of entry into
the corresponding globally distributed information resource.
Having a shared identity on the domain level could, additionally,
provide incentive for museums to prioritize the contribution of
further information to the repository.

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?

Yes.

Q30: Do those principles preclude the introduction of any new
fully open TLDs?

No.

Q31: What types of TLDs should be included in the first group of
additional TLDs to best test the concept of chartered TLDs?

Two prime factors in making this decision should be the new
domain's potential value to the community and the
uncontestability of the authority of its regulatory body.

Q32: Should chartered TLDs be introduced according to a
pre-defined system, or should proposals be evaluated on an
individualized basis?

See Q16

Q33: If charter proposals are evaluated on an individualized
basis, should any steps should be taken to promote stable and
orderly evolution of the DNS overall?

The one line of approach does not preclude the other.

(Why is there so much fear about the fragility of the DNS?)

Q34: Has the inventory of useful and available domain names
reached an unacceptably low level?

Probably not, but the total dissolution in upholding the
initially intended meaning of the present open TLDs has depleted
their value to the point where action is necessary. This has been
exacerbated by the use of mnemonically convenient ccTLDs as
though they were gTLDs.

Q35: Assuming it is important to increase the inventory of
available domain names, should that be done by adding TLDs that
are not differentiated from the present ones?

No.

Q36: Should the formulation of policies for limited-purpose TLDs
be delegated to sponsoring organizations? In all cases or only in
some?

This depends entirely on the existence of a single undisputed
authority within the candidate sector. If there is one, policy
formulation can be delegated entirely to it. In other cases, a
greater degree of on-going involvement may be required of the
delegator.

Q37: What measures should be employed to encourage or require
that a sponsoring organization is appropriately representative of
the TLD's intended stakeholders?

At least at the outset, reliance should be made on pre-existing
mechanisms for the resolution of these matters. That's why such
things as NGOs were brought into existence, in the first place,

Q38: In cases where sponsoring organizations are appointed, what
measures should be established to ensure that the interests of
the global Internet community are served in the operation of the
TLD?

To the extent that there can be a coherent statement of the
interests of the global Internet community, require sponsoring
organizations to agree to support it and stipulate a period of
regular review of their continuing to do so.

Q39: How should global policy requirements (adherence to a TLD's
charter, requirements of representativeness, interoperability
requirements, etc.) be enforced?

Again, stipulate exactly what conditions must be fulfilled and a
period for their regular review.

Q40: Are there any types of new TLDs that should not be included
in the initial introduction? If any types should be excluded,
why?

There are no types that in principle should be excluded from
making their proposals. These can then be evaluated to
eliminate counterproductive redundancy. See Q16.

Q45: What mechanisms for start up of a new TLD should be followed
to ensure that all persons receive a fair chance to obtain
registrations?


In the case of chartered domains, unequivocal and stable criteria
for registration in them must be available prior to the
initiation of their operation.

Q47: Should introduction of new TLDs await completion of an
evaluation of the operation of the UDRP and be subject to a
finding that the UDRP has been successful in meeting its
objectives? How long would such an evaluation likely take to
complete?

No.

Q48: Should introduction of new TLDs await extension of the UDRP
to cover claims for transfer of domain names based on the
relevance of a well-known trademark to a chartered gTLD? How long
would implementing such a revision to the UDRP likely take?

No.

Q49: Does the schedule allow sufficient time for formulation of
proposals?

Yes.

Q50: Does the schedule allow sufficient time for public comment?

Yes.

Q51: Should all proposals be posted for comment simultaneously to
maintain equal time for public comment? Should all proposals be
posted for public comment as they are received to allow the
greatest possible time for public analysis and comment?

Any action that might be regarded as deliberately causing
obscurity is perhaps best avoided.

Q52: Should the formal applications be posted in full for public
comment? If not, which parts of the applications should remain
private?

Applicants should be allowed some say in this, relative to a
standard for minimum disclosure.

Q53: Should proposals choose a single proposed TLD or numerous
possibilities?

Ultimately both. At the outset, however, it might be best to
prioritize tightly focused proposals.

Q54: Should ICANN select the TLD labels, should they be proposed
by the applicants for new TLD registries, or should they be
chosen by a consultative process between the applicants and
ICANN?

In consultation.

Q55: Should there be minimum or maximum length requirements for
TLD codes? Are restrictions appropriate to avoid possible future
conflicts with ISO 3166-1 codes?

This is a hard call. Perhaps syntactic ground rules might help.
Otherwise there will be proposals for .newdomain, .new-domain,
and .newdomains all with the same nominal purpose and in bitter
competition. The development of ISO 3166-1 should be anticipated
and respected.

Q56: Should there be restrictions on the types of TLD labels that
are established (for example, a prohibition of country names)?

Any category already equated to a family of TLD labels probably
doesn't need another one, as for example country names.

Q57: What should be the criteria for selecting between potential
TLD labels? Should non-English language TLD labels be favored?

Selection should be based on semantic value, fully accomodating
the language structure of the real world, but acknowledging that
the shared second language of the Internet is likely to remain
English.

Q58: How many new TLDs of each type should be included in the
initial introduction?

As far as chartered domains are concerned, one for the museum
community (.museum) and as many others as may prove desirable in
light of further proposals.

Q59: Which types of TLDs will best serve the DNS?

The DNS probably doesn't care a whole lot about this. The user
community will be best served by injecting more direct meaning
into the TLD structure.

Q61: Which types, if any, are essential to the successful testing
period?

Any type that lacks counterpart in the present structure and is
regarded as of potential utility should be included in the first
wave.

Q63: Should ICANN accept proposals from companies formed/forming
for the purpose of operating or sponsoring a new TLD? If so, how
should ICANN determine the competence of the company?

For open domains, unless there is a logistic reason for
restricting the number of proposals, why not allow new companies
to argue their credibility in that context?

Since acceptance within their sectors is such a vital issue, at
least the first wave of chartered TLDs should probably be
restricted to the sponsorship of organzations of some standing.

Q66: How much capital should be required? Should it be a fixed
amount or should it vary with the type of proposal and the
sufficiency of the business plan? How should the sufficiency of
capital be evaluated?

It should vary. One important evaluation criterion should be the
extent of the burden imposed on ICANN if a new domain should be
taken out of operation.

Q68: What measures should be in place to protect registrants from
the possibility of a registry operator's business failure?

This depends on the scope of potential damage to the registrants.

Q69: What should be the minimum technical requirements to ensure
sufficient stability and interoperability?

This depends on the size of the domain.

      

     

 


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