To Whom It May Concern:
The Walt Disney Company ("Disney") submits the application
of KDD Internet Solutions Co., Ltd. ("KDD") to add a new top-level domain .biz must
Disney owns subsidiaries engaged in motion picture production and
distribution, development, the operation of theme parks, television production and
broadcasting. Disney has also been an Internet pioneer. Through the creation
and development of disney.com, Disney has extended its market for family-oriented
entertainment onto the Internet. The Walt Disney Internet Group produces some
of the most popular online sites for sports information (espn.com), television entertainment
(abc.com) and news (abcnews.com).
Disney is a member of the Business Constituency.
a domain name registrant engaged in a variety of commercial enterprises, Disney welcomes
the addition of new gTLDs. In particular, Internet stability, commercial accountability
and consumer trust are enhanced by the prospect of additional, chartered, top-level
domains. However, Disney can only welcome such developments within the context
of a structure within which law, particularly those relating to intellectual property
rights, are applicable and enforceable. The KDD application fails to meet this
threshold and should be rejected.
KDD rejects any intention to permit open access
to the most fundamental information regarding the identity of domain name registrants.
This position against transparency and will encourage irresponsibility and undermine
stability of the Internet.
KDD's application is also unacceptably vague in terms
of other intellectual property protections. ICANN must require specificity
from applicants concerning their proposed procedures before those applicants should
be entrusted with the creation of new top-level domain name space.
Very truly yours,
The Walt Disney Company