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Username: travelocity
Date/Time: Fri, November 3, 2000 at 11:35 PM GMT
Browser: Netscape Communicator V4.7 using Windows 95
Score: 5
Subject: Opposition to "dot.travel" and IATA application

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Travelocity.com is opposed to the creation of a .travel gTLD and, particularly, to the selection of IATA as the registry should such a gTLD be created.

Travelocity supports the expansion of gTLDs when designed to benefit consumers, businesses, and individuals by making the Internet more efficient.  However, the proposed gTLD ".travel" is, by design, a restricted category that neither holds cross-industry appeal (as compared to  current gTLDs: .com, .net, and .org) nor any clear boundary that would separate those sites that would be under this domain as opposed to those that belong elsewhere.  For example, where would a tourism site for a county or city belong?  What about a site offering information about but not reservations capability for a specific kind of travel?   Absent such obvious boundaries and any cross-industry appeal, a .travel gTLD will actually limit the growth potential of the Internet by making it more difficult for consumers to locate information of interest to them regarding travel and tourism. 

We submit that consumers would be best served by the establishment of more generic gTLDs available for  both commercial and noncommercial uses.

However, if ".travel" is created, Travelocity believes strongly that it should be administered by a registry that is a clearly neutral party with respect to the proposed registrant constituencies --  particularly in the case where the registry sets its own restrictions defining admissible registrants and/or domain names.  Indeed, if such restrictions were in place, a neutral registry would be necessary to ensure that the interests of all future domain name registrants/applicants are fairly and equally represented. 

IATA, the trade group of the airline industry, is anything but a neutral party with respect to the distribution and registration of domain names.  Indeed, IATA members have made it quite clear that the airlines wish to use the Internet to limit the role played by third party intermediaries and travel agents.  For example, at an IATA conference earlier this year, an official acknowledged airline industry fears that absent decisive action by suppliers, "non-airline entities can use [Internet] technology to interpose themselves in our business." IATA Legal Symposium on eCommerce at Slide 5 (presentation by Michael Feldman, February 2000).   This was because, according to this official, airlines were "less aggressive" than other industry participants is adopting the Internet.

Given the current controversy over joint airline efforts to form joint Internet ventures designed to limit the viability of third party distribution channels -- as witnessed by inquiries now underway at the U.S. Department of Transportation, the U.S. Department of Justice, and the Senate Commerce Committee into joint airline travel agencies such as "Orbitz" -- selecting an airline trade group as the registry for a dot.travel gTLD would be a serious mistake.  Travelocity complete comments on this topic can be found in the link attached to this message.

Travelocity.com supports the Uniform Domain Name Dispute Resolution Policy, and believes that domain names registered under the new gTLDs should be subject to it. 

Travelocity.com opposes use requirements for domain names under the .travel gTLD, because registries should not subject domain name registrants to monitoring and/or controlling supervision.  Because the registry will not have a contract with the registrant, but will instead contract with registrars, this requirement places upon domain name registrants an undue burden for which there is no contractual protection or recourse.  The use of a domain name is a business or personal decision that should be dictated only by the domain name registrant.  Moreover, registries should not have the regulatory power to monitor content of websites and/or email and to revoke a domain name registration based upon that content.  That regulatory power currently and properly rests with the courts.

At present, there are no use requirements, registrant restrictions, and volume limitations for .com, .net, and .org domain names, while those rules are in place for some ccTLDs.  One need only compare the vastly different registration rates under these TLDs to see how use requirements, registrant restrictions, and volume limitations curb growth on the Internet. 

In summary, Travelocity.com supports the expansion of gTLDs in a manner that fosters growth on the Internet, for both commercial and noncommercial interests.   A dot.travel gTLD should be administered by a neutral party.  The Internet has advanced thus far under the guiding principles of free markets and freedom of expression, and cannot advance further if broad, restrictive powers are granted to non-neutral parties.

Andrew B. Steinberg
Executive Vice President Administration
General Counsel and Secretary
Travelocity.com

     
     
     
     
     
 
Link: Travelocity comments to the U.S. Dept of Transportation

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