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Username: Spectral Web, Inc.
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Subject: “Spectral Web, Inc.’s Comments Regarding the Choice of New Top-Level Domains and Registries”

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Spectral Web, Inc.

“Spectral Web, Inc.’s Comments Regarding the Choice of New Top-Level Domains & Registries”

Forum: “ICANN Public Comment Forum ~ Forum on New TLD Applications”
Submitted: 4 November 2000
________________________________________________________________________
Spectral Web, Inc. is grateful for the opportunity to issue a statement on ICANN’s Public Comment Board on the matter of new Top Level Domains. We are all at a pivotal moment in the Internet’s history. Precedents will be set during the next several weeks and months that will have far-reaching implications on the domain industry, industry in general and on the global society. Matters of integrity, policy, practice, choice, fairness, competition and implementation strategy will all be monitored carefully; the process ICANN has painstakingly established will be appropriately scrutinized during this first new rollout.

Herein, Spectral Web will log its position on the proposed gTLDs and the respective applicants. The position is not merely shaped by Spectral Web’s specific charter, but also by what Spectral Web believes to be in the best interest of the Internet. Additionally, Spectral Web herein will share with ICANN, Internet professionals, educators, and other interested parties, an overview of some of the key components of the Spectral Web charter.

I. The Decision to Include More gTLDs

The inclusion of new gTLDs has been a long time coming, and Spectral Web opines that the correct decision was made in Yokohama this past July. Adding new gTLDs will enable new companies and users to join the Internet arena in a viable way, for these second generation participants will have at their disposal, attractive, generic, meaningful and memorable SLDs. With the number of Internet users climbing significantly every year, and the number of people registering domains for both profit and non-profit purposes, the urgency for new gTLDs increases at a steep pitch.

Many have expressed concern for intellectual property rights of trademark holders; Spectral Web respects and honors holders of trademarks, and believes that while certain unscrupulous people will no doubt squat on marks, the expanded availability of generic word and generic term namespace will actually result in broad-base compliance of trademark law among general domain registrants, for there would be fewer unintentional violations and encroachments. Quite simply, in the absence of generic words and terms, registrants are forced to invent word combinations and other descriptors, sometimes unwittingly infringing on or “approaching” another’s mark. As stated, the incorporation of new gTLDs into the Internet root will naturally alleviate this.

II. Spectral Web’s Choice of gTLDs

During the 1 September – 2 October 2000 filing period, ICANN received 47 applications from entities bidding for one or more gTLDs. Of these 47 applications, 44 are still active. Not accounting for duplicated bids, 189 gTLDs are under discussion.

Spectral Web feels that ICANN should select only a few gTLDs at this time, to monitor its impact on the Internet and on intellectual property concerns. However, we recommend that, after a period of no more than one year, ICANN phase in a new batch of gTLDs, if need is determined.

Spectral Web recommends the following gTLDs:

1) .Web

Spectral Web believes that .web will be the most desirable gTLD of those proposed, for the following reasons:

     a. The word “Web” is identifiable throughout the world. Hence branding of the gTLD is easy and the consumer and Internet user is likely to accept and embrace it. “Web” is common in terms and phrases such as “Worldwide Web," "Website," “Webpage,” “Web-develop,” “Surf the Web,” “Web-host,” etc.

     b. Since the word “Web” is globally identified, it has become a multilingual descriptor. As such, it is not English-centric, which is of major import.

     c. .Web is a generic gTLD. As such, its charter can not be blurred by those developing sites within that zone, as we have seen with the other unrestricted gTLDs. It is, in fact, more generic than .com, which itself indicates “commerce.” Naturally, not all .com websites are commercial in nature.

     d. While there are no technological limitation to the number of characters in a TLD string, .web has the traditional 3-character length, to which the Internet user is accustomed.


2) .Shop

Spectral Web, Inc. believes that .shop would also make a very attractive gTLD. Like .web, it is short, memorable, and thus lends itself to easy branding both as a TLD and as part of an SLD-TLD string.

The only hesitation that Spectral Web has in this choice, is in regard to the slant that the word “shop” lends. While it is perhaps one of the better gTLDs being proposed, it is not “purely” generic. In fact, .com is more generic than .shop, for while all shops are commercial entities, not all commercial entities are shops. Still, Spectral Web feels that .shop will find its niche on the Internet and would make a fine addition to the current assortment of gTLDs.


3. .Museum

Spectral Web believes that .museum should be added for a variety of reasons. For one thing, the role that the Internet will have on museums as time goes on, will only deepen. The exhaustive and highly specialized information that museums have individually and collectively accumulated is so valuable to all the peoples of the Earth, that Spectral Web feels very strongly that a proper forum be provided for all participating entities. To date, .org has been the predominant landscape that museums have inhabited; and yet that forum seems not altogether fitting for the unique entity that is a museum.

As the Worldwide Web grows, more and more content will be available to researchers, students, educators, specialists, etc.. Let us devote a gTLD to such specialized human-interest material. The kind of information and knowledge that comes from museums is not generic in the least, and should be honored, respected and treated properly.

Spectral Web values education, society, human history, art, music, dance, etc.. Even though Spectral Web is not a museum and would not seek an SLD within the .museum gTLD, we would be delighted to see it come to the Internet for the good that it will do. Museums are not unlike universities in that they are specialized entities that do not fall under the traditional category of “company” or even “organization.” To be certain, there are many other such entities. .Gallery, .aquarium, .garden, .zoo, etc.. would also make viable options. However, Spectral Web believes that ICANN should approve .museum for this first rollout, and regard this period as a learning process for this special gTLD category.

Clearly, these gTLDs, like the .edu gTLD must be restricted, to avoid abuse and dilution. Inherent in this, is the predicament of determining which presiding body is qualified enough to judge whether or not a particular candidate for an SLD falls within defining parameters. Clearly, there will be much debate within the respective fields as to whether fairness and objectivity are being employed. Therefore, Spectral Web recommends that ICANN approach with caution, observe all steps of implementation and monitor the subsequent evolution. .Museum belongs to a special category gTLD that's importance to web culture and educational value cannot be underrated. What ICANN learns from the process of incorporating .museum into the Internet root will help shape its approach to similar gTLDs in the future.

III. Spectral Web’s Choice of Registries

1) .Web: Image Online Design, Inc.

Spectral Web is familiar with Image Online Design and respectfully asks ICANN to approve that registry for the .web extension, for the following reasons:

     a. Image Online Design has operated in good faith since the initial authorization given by IANA in 1996. Image Online Design is a pioneer in the domain industry, and has been a part of the process in a constructive, significant manner.

     b. Spectral Web finds Image Online Design’s technical plan to be very sound and is particularly pleased with the portions indicating database robustness and security. Image Online Design has illustrated technical viability; it understands the philosophy of keeping systems proficient, stable and up-to-date. While the other proposals are from ventures that were quickly formed for the singular purpose of applying for gTLD, Image Online Design has over four years of experience running a registry.

     c. Image Online Design will introduce competition to the domain industry, which is something ICANN has indicated is vital to the Internet. It is clear that ICANN is seeking smaller, technically proficient registries; therefore the applications of two direct competitors for the .web gTLD serve as a significant threat to fairness and competition; if one of these other applicants is chosen (not merely for .web, but for any of the gTLDs within its application), the entire process ICANN has established would be damaged.

     d. Image Online Design seeks only one gTLD. In their application, it does not include either a second choice or a line of gTLDs for approval. This is significant, particularly with regard to the latter. If any new registry were to acquire more than one gTLD, diversity would be greatly lessened within the industry; subsequently, service and pricing would be at risk. If ICANN approves one or both of the other .web applicants, Spectral Web strongly urges fairness in the decision. The approved entity/entities should only be assigned one of the other gTLDs listed in their application—-and only the one. If ICANN is to usher in the next era of the Internet, Spectral Web asks that it do so fairly and responsibly.

     e. Spectral Web is delighted to see that Image Online Design as not merely adopted ICANN’s Uniform Dispute Resolution Policy, but will also be enabling current .web registrants who, either intentionally or unintentionally infringed upon another’s trademark, the opportunity to exchange the domains in question for an equal number of generic domains. Also prudent is Image Online Design's decision that will allow trademark holders preemptive rights to challenge potential violations prior to .web’s incorporation into the Internet root.

     f. Image Online Design is a well-established, stable company.

     g. Image Online Design has demonstrated superior customer service in matters of timeliness, flexibility, openness, fairness, availability, reliability, cordiality, and trustworthiness. Spectral Web recognizes, that once approved, Image Online Design will take an increasing number of registrations and its operational base will balloon, altering somewhat the tone, texture, and tenor of its current customer service relations; however, the principles already evidenced by Image Online Design are worlds apart from those evidenced by Network Solutions, and Spectral Web expects the superior customer support to continue.

     h. As stated, ICANN is at a crucial moment in the history of the Internet. Its judgment in the case of Image Online Design will illustrate whether or not any applicant other than existing players will ever be taken seriously by ICANN. Clearly, with its superior history of operation, Image Online Design is the most prepared of all the applicants representing industry competition. To pass over Image Online Design at this point would be to negate the importance of experience, proficiency and a verifiable track record, again, beyond the existing registry and registrar players. Therefore, the open application process, with the $50,000 fee, would be highly questionable.


2) .Shop – Name.Space.com

Like Image Online Design, Name.Space.com is a pioneer in the new era of gTLDs. This gives them not merely credibility as one who did not enter in the eleventh hour; it gives them the experience which is so vastly needed.

Name.Space.com has applied for 118 gTLDs; however, as Spectral Web does not advocate for more than one gTLD per approved applicant, Spectral Web can only endorse the best, most useful gTLD within Name.Space.com’s application: .shop.

3) .Museum -- Museum Domain Management Association (provisional *)

Spectral Web believes that .museum should be run as a restricted gTLD by a devoted and well-established association within that specialty. Therefore, Spectral Web finds the application from the Museum Domain Management Association (MDMA) to be very strong. The MDMA has open membership, which Spectral Web admires; yet the association is asking that .museum be restricted, which Spectral Web strenuously endorses, for the sake of both the museum community and the Internet community.

Under MDMA’s plan, the prospective registrant would need to fulfill the criterion established by The International Council of Museums (ICOM) for what constitutes museum status.

The following is from ICOM’s statutes that relates to the defining features of museums:

1. A museum is a non-profit making, permanent institution in the service of society and of its development, and open to the public which acquires, conserves, researches, communicates and exhibits, for purposes of study, education and enjoyment, material evidence of people and their environment.

     (a) The above definition of a museum shall be applied without any limitation arising from the nature of the governing body, the
territorial character, the functional structure or the
orientation of the collections of the institution concerned.

     (b) In addition to institutions designated as "museums" the
following qualify as museums for the purposes of this
definition:

         (i)    natural, archaeological and ethnographic monuments and
                sites and historical monuments and sites of a museum
                nature that acquire, conserve and communicate material
                evidence of people and their environment;

         (ii)   institutions holding collections of and displaying
                live specimens of plants and animals, such as
                botanical and zoological gardens, aquaria and
                vivaria;

         (iii)  science centres and planetaria;

         (iv)   conservation institutes and exhibition galleries
                permanently maintained by libraries and archive
                centres;

         (v)    nature reserves;

         (vi)   international or national or regional or local museum
                organizations, ministries or departments or public
                agencies responsible for museums as per the
                definition given under this article;

         (vii)  non-profit institutions or organizations undertaking
                research, education, training, documentation and other
                activities relating to museums and museology;

         (viii) such other institutions as the Executive Council,
                after seeking the advice of the Advisory Committee,
                considers as having some or all of the
                characteristics of a museum, or as supporting museums
                and professional museum workers through museological
                research, education or training.

               (http://www.icom.org/statutes.html)


Spectral Web is also pleased with MDMA’s consideration of intellectual property concerns. They address seven precautions that will be part of the .museum charter, including the restricted nature of the gTLD and the requirement of all proposed designations “to be clearly derived from the well-known name of the registrant’s organization.” Spectral Web believes that all seven items will go a long way toward preventing trademark infringements.

Furthermore, MDMA has accounted for the matter of two or more museums existing which possess the same name. Spectral Web believes that the proposed country code descriptor will resolve this problem sufficiently. Hence, .us.museum, .uk.museum, .it.museum, au.museum, ca.museum, etc. would be feasible.
_______________________________________________________
(* Provision: MDMA has indicated that it is seeking CORE’s registry services for the .museum gTLD. Spectral Web is aware of CORE’s prominence throughout all 44 gTLD applications, and is concerned for the integrity of the Internet and industry as relates to diversity and competition in namespace. Spectral Web feels that ICANN must prohibit or restrict CORE’s involvement in the next rollout of gTLDs for precisely these reasons; thus Spectral Web respectfully asks both ICANN and MDMA to move slowly on .museum and to consider alternatives to CORE.)


IV. .Kids Recommendation

1. Overview

To date, the Internet community has seen a significant number of websites that most would agree are inappropriate for a child or teen audience. More and more children are using the Internet for education, research, recreation and exploration; yet all too often objectionable material is easily found, and quite often by accident. Given this predicament, Spectral Web believes a system must be implemented that will give reasonable support and security to parents, and ample protection to children. With the growing number of children and teenagers becoming involved in online activities, age-appropriate content must be organized in some sensible, coherent manner.

Spectral Web strongly supports the request for a .kids registry. True, it is not ICANN’s mission to judge content or to rule on what is age-appropriate and what is not; however, ICANN can, in an expression of good will, a) approve a gTLD that will serve parents and children, and b) select the best applicant to run the registry. Naturally, the registry for the .kids gTLD must be qualitatively different from registries of most other gTLDs, given the nature of the community it would serve and the breadth and depth of related issues.

Spectral Web understands that the .kids gTLD comes with unique circumstances and challenges. Some are substantial and onerous. It is for this reason that Spectral Web urges ICANN to proceed with caution in matters relating to this gTLD; yet it is important that .kids be given its day despite the difficulties. The benefits of a well thought out, organized, carefully implemented .kids are too strong for the gTLD to be prematurely dismissed. In many ways, the registry for .kids will have a responsibility unlike other domain registries.

Spectral Web is itself interested in registering a small number of SLDs within the .kids gTLD as they relate to the appropriate segments of the Spectral Web child-safe, family-friendly charter; however, Spectral Web would be more than willing to wait for a proposal that is fully thought out, offers flexibility for the diverse cultures of the world, acknowledges the varied age levels of children, unites relevant agencies and associations in matters of research, policy formation and outreach, and is equipped to handle charter violations among registrants.

Understandably, the .kids registry cannot be expected to singularly handle all of these issues. Traditionally, a registry is principally involved in the technical aspects of namespace. However, as stated .kids intrinsically calls for greater involvement at the registry level. With minor exception, this necessity was not adequately met by any of the four .kids applicants, though each of them seems to possess a component or two that makes its respective plan at least partially desirable. Should ICANN decide to pass on .kids at this time, Spectral Web respectfully asks future applicants to treat .kids as an inherently different gTLD that needs not merely a distinct vision and system of principles, but a carefully prepared implementation and regulation policy.

Furthermore, Spectral Web recommends that one of the current .kids applicants, DotKids, Inc., be granted preliminary authorization as a significant candidate of a future rollout. The criteria ICANN has provided for gTLD applications for the current process is inappropriate for .kids, given its uniqueness. Spectral Web respectfully recommends that ICANN develop additional non-technical criteria and give said applicant a reasonable amount of time to meet the criteria. Spectral Web acknowledges that ICANN’s principle function is to serve as the technological manager of the Internet, and that the scope of revising non-technical criteria might fall outside of ICANN’s charter and area of expertise. Therefore, Spectral Web advises that ICANN, DotKids and other agencies work in concert toward drafting new criteria.

Without a doubt, the trickiest part of developing the plan for .kids, philosophically, is the matter of cultural sensitivity; not all cultures acknowledge the same parameters and definitions of what might be deemed “appropriate” and “inappropriate” content. This is more than a mere logistical concern. It cuts to the heart of individual and social sensibility and perception, which is a volatile enigma at best.

Spectral Web is not certain as to what might be the best compromise; but if there is to be a single .kids gTLD, a crude compromise would be the natural result. Since "compromise" in this case will not likely be synonymous with “consensus” among the entire umbrella of cultures and societies of the world, ICANN might want to consider enabling country-specific .kids domains; for example, .us.kids, .jp.kids, .eg.kids, etc.. Another option would be a rating system, which might indeed be viable; then individual households can screen according to their preferred system.

Though Spectral Web believes that .kids is a very desirable, very necessary gTLD if it is properly handled, as stated, we are not entirely pleased with the four applications submitted to date. Indeed, as Spectral Web’s charter is, to a large extent, devoted to education and child advocacy, .kids is one of the main TLDs Spectral Web would like to see manifest. Nonetheless, Spectral Web respectfully recommends that ICANN bring this gTLD to drawing boards for the purpose of developing a desirable, efficacious plan and registration policy, with appropriate safeguards. If .kids is approved at this time, enormous difficulties will naturally cascade from said approval. Rolling it out now, only to rewrite policies later, retract rights and undermine an incalculable number of businesses that will have become firmly rooted, would be devastating. Conversely, a well-thought out, well-organized and well-run .kids should one day do very well both as a gTLD and for families.


2. The Applicants

Spectral Web found the following basic problems with each of the applications, respectively:


Blueberry Hill, Inc. – Blueberry Hill’s application was glaring in that it did not offer an elaborate implementation plan that the uniqueness of this gTLD so vitally needs. For reasons stated below, .kids needs to be monitored in a manner that is not necessary for most gTLDs, both existing and proposed. Spectral Web feels that Blueberry Hill’s application glosses over these concerns, all too lightly, and does not offer a plan for long-term evaluations.

Furthermore, Spectral Web, Inc. finds it troubling that Blueberry Hill nonchalantly states that “there is active and ongoing international debate about who should make decisions concerning Internet content. Worldwide governments, educators, researchers, organizations and industry partners are actively examining issues related to access and content regulation.” While Blueberry Hill acknowledges, that it should not become caught up directly in these concerns, without a doubt they, as the .kid registry, are responsible for establishing a detailed, elaborate, reasonable registration policy that will take into account content, global differences as relates to child-safe sensibilities and a means by which these different thresholds might “cohabitate within the gTLD." Where .kids is concerned, it is not enough for a registry to merely provide the technological necessities; it must provide a stronghold against child-unsafe material and predators upon minors.

Curiously, Blueberry Hill says in their application, “The establishment of .kids will not create new problems as to access and content, those problems already exist, but rather .kids will provide the motivation and incentives to focus international attention and public and private resources on solutions.” While this is no doubt true, Spectral Web believes it is Blueberry Hill’s responsibility to provide more of an answer than, “.kids will provide the motivation and incentives to focus international attention and public and private resources on solutions.” Quite simply, it should be Blueberry Hill’s responsibility to join the communities it identifies and itself devote focus and resources toward said solutions.

Blueberry Hill spends considerable time discussing the ideals of a .kids gTLD, the market it will find, the audience it seeks to attract, and the content that logically should fill the .kids gTLD. However, Spectral Web is disheartened to find that Blueberry Hill sidesteps real life pragmatics, particularly with regard to what might be reasonably expected to fill the new landscape; in short, without regulation and monitoring provisions established, abuses will proliferate .kids as it does the current gTLDs.

Blueberry Hill seems to approach the matter of abuses within its application; and then it stops short of offering anything tangible:

     “What about the potential for inappropriate content?

     “Currently, efforts to protect young people from objectionable
      content on the Internet are, at best, marginally successful.
      By all accounts, existing governmental efforts to 'childproof
      the net' have failed.

      “The Children's Online Privacy Protection Act recently enacted
      by Congress is languishing and under legal challenge,
      ‘Getnetwise.com’ the industry's recent attempt to regulate the
      internet by providing parents with a centralized website
      replete with information regarding safety for children on the
      net as well as over 80 different software tools for parents to
      protect their children online is too little too late. The new
      gTLD .kids will provide for a new opportunity, a virgin
      cyberspace arena, to implement and evaluate future mechanisms
      to protect children from inappropriate content.”


In short, unless provisions are made, this “virgin cyberspace arena” will experience the same problems that proliferate the other TLDs.


DotKids, Inc. – Of the four .kids applicants, Spectral Web feels that DotKids represents the best model for the .kids gTLD. Spectral Web feels comfortable with the choice of Comdisco provider of registry systems, and SARAF as provider of registry software; both are strong, stable entities within their respective fields.

DotKids seems to have the beginnings of an appealing plan for the .kids gTLD; its plan “to introduce a 'green space' for kids and teens on the Internet" is the mere start of a very long but necessary process. The intended collaboration of children's organizations, education professionals and children themselves is particularly appealing. (All too often adults decide what is best for children without even consulting those most intimately affected.) The company's plan "to provide a safer Internet" is not only admirable; it is essential.

Even still, Spectral Web believes that the plan DotKids describes is vague, sketchy and incomplete, and approval at this stage would be premature. Spectral Web would feel more comfortable with a .kids registry that had not merely an assembly of specialists and industry leaders recently gathered, but a well-oiled group that has aggressively detailed a point-by-point set of objectives, policies and implementation strategy, along with a set of contingencies for when things might not go as expected. The .kids gTLD warrants this.

Spectral Web recognizes and appreciates that DotKids has the Internet Content Rating Association (ICRA) and is pursuing the ICRA as an accredited rating service to assist in creating the value of the .kids gTLD. Again, however, Spectral Web would feel more comfortable with a viable, efficacious plan being ironed out between these two parties, and between DotKids and other parties, prior to approval of DotKids. It is no doubt important that a member of ICRA sits on DotKids’ Advisory Board; but what policy, what plan, what strategy has the board established?

In short, Spectral Web would most likely endorse DotKids for the .kids gTLD, provided that it addresses the concerns expressed herein. No doubt that given the uncertainty of their current standing in the application process, some commitment should be extended from ICANN to DotKids in the form of an initial authorization pending the completion of clearly defined minimal expectations; this process is reasonable and would optimize readiness and viability. Spectral Web feels that the DotKids application merits this special status over the three other current .kids applicants; and though new applicants should be permitted to bid for the .kids gTLD in a future applications process, in truth, any such applicant that could soon step forward would more than likely be even less prepared than DotKids currently is, or they would have applied for the gTLD in the current process.


ICM Registry Inc. – Spectral Web finds ICM’s auction model for registrations to be less than acceptable, as such a system clearly favors those with the financial backing to offer the highest bid. Spectral Web feels that the Internet should provide an equalizing milieu where the prince and the pauper alike may register high level domains; thus, auctions are biased against individuals, small companies and start-ups. 

Additionally, and most significantly, ICM is very vague as to how the intended theme of the.kids TLD will be made safe for children. Certainly, the inherent principles othe TLD itself are not sufficient. Screening software, which is currently used for the Internet at large, hardly seems adequate.


KIDS Domain, Inc. – Spectral Web again finds the details underlying the principles to be less than clear. KIDS Domain is reasonable in their twofold vision. The first vision seeks to offer a means by which “businesses can effectively and appropriately reach online the most educated, enlightened, and successful young generation in history.” Spectral Web respects this vision highly. However, Spectral Web also finds the means by which they seek to fulfill this ideal to be quite unsavory; furthermore, it seems as though the plan itself was all too casually conceived, without an address to pragmatics.

KIDS Domain suggests that .kids be a restricted domain. Without a doubt, Spectral Web believes that the safeguards protecting our children should be clear, concise, capable of being monitored, and should describe repercussions for blatant abuse. (As in the case of pornography within the gTLD.) KIDS Domain’s plan indicates that registrants must submit to annual audits to be made by independent agencies. Spectral Web finds this component to be haphazard.

Firstly, what assurances can KIDS Domain make that, as domain registrations within the .kids gTLD increase, all websites developed will indeed be audited and in a timely fashion? How well will sites be investigated? How can the annual self-arranged audits of individuals be trusted? Can not an individual change content before an audit to something more sanitary, and then return it to its former state after the audit? How will KIDS Domain designate the various sites that are not clearly defined as either “personal” or “corporate?” In such cases, will investigations exceed the site homepage, or will it include all pages within the site? Will findings be made public? What accountability will KIDS Domain and the Policy Board have in the event that there is an oversight?

Secondly, the KIDS Domain plan accounts for distinctions between personal sites, business sites, portal sites and specialty sites; each comes with a different pricing plan. How will KIDS Domain verify the veracity of statements from registrants? What will they do when a site changes its scope from one function to another, mid-term? What will KIDS Domain do in the event that a given site cannot be clearly labeled?

Thirdly, how will cultural diversity be accounted for in said criteria? Clearly, the Internet is global and different cultures regard content differently and according to different guidelines and thresholds. How might the Internet community expect KIDS Domain or the selected Policy Board to rule?

Fourthly, Spectral Web does not support registry auctions for SLDs, even in the pretext of “conscientiousness.” Spectral Web believes such a practice to be biased toward more affluent entities; this should remain outside of a registry’s charter. Under this KIDS Domains regulation, un-funded, not-for-profit agencies, small pro-child companies, community-driven Boys and Girls clubs, modest religious institutions and small schools would be unable to register one these “glamorous” SLDs, which seems to be in conflict with KIDS Domain’s pretense of being pro-child and pro-education. Since KIDS Domain will be retaining fifty percent of the selling price, Spectral Web sees this proposal as nothing more than an attempt by the applicant to increase revenue by denying namespace to the very community is claims to service.


3. A Word About Regulation

Spectral Web does not at all advocate for a reduction in the protected areas of speech, thought and expression. To be certain, these areas are, and should continue to be, granted optimum protection in all other TLDs. However, as stated, .kids is a unique gTLD that inherently addresses matters of content. Generally speaking, this is the nature of the gTLD. Spectral Web maintains that a properly regulated .kids gTLD will not be advocation of censorship, so much as it would be a broadening of opportunities for families. Those who believe that .kids is an exercise in censorship often feel that the gTLD should be summarily rejected. Yet since all content in the .kids gTLD would be an enhancement to the current body of developed websites, the exclusion of the gTLD would itself be a restraint.


V. Additional gTLDs

Spectral Web finds the following gTLDs to be both useful and attractive. No endorsement of any particular registry, including the current applicants, is implied. Where some of the following are already included in current applications, Spectral Web does not find the respective applicants to be either desirable or particularly compelling. ICANN is urged to go slowly with the immediate and all future gTLD rollouts, and approve applicants that bring diversity, competition, strength and innovation to the Internet community. Toward this end, from this day forward, no registry should be granted more than one gTLD.

     .bank        -- industry, restricted
     .biz         -- commercial, unrestricted
     .geo         -- generic, unrestricted
     .go          -- generic, unrestricted
     .health      -- industry, restricted
     .inc         -- corporate, restricted
     .info        -- generic, unrestricted
     .movie       -- industry, restricted
     .online      -- generic, unrestricted
     .store       -- generic, unrestricted
     .tm          -- intellectual property, restricted
     .union       -- labor, restricted
     .world       -- generic, unrestricted

VI. About Spectral Web

Spectral Web was established by members involved in such areas as Education, Health, Horticulture, Language, Arts and Humanities, Business, Advertising, Travel, etc. Its principle focus is the development of Web communities that are primarily formed according to particular themes and charters that occupy the full spectrum of human knowledge and experience. Part of Spectral Web’s charter is commercial in nature, with a fair amount of the charter devoted to not-for-profit and enrichment interests.

Although Spectral Web believes in freedom of speech, thought and expression, to a large extent its members have been dissatisfied with both content on the Internet and the state of child safety. Hence, Spectral Web is developing a charter in which users may opt to participate.

The following is an overview of Spectral Web’s business plan. Spectral Web will

     · build forums in the hopes of catalyzing connectivity and
       interactivity among people of similar interests and needs;

     · shape its communities around the interests of merchants,
       non-profit organizations, educators and students,
       professionals, businessmen, scientists and technicians,
       healers, specialists, artisans, hobbyists and the general
       Internet user;

     · promote literacy and student education in school-outreach
       programs;

     · compose and sponsor meaningful, educational content
       wherever possible;

     · devote resources to human rights, civil rights, child
       advocacy and general human-interest initiatives;

     · create family-friendly/child-safe forums;

     · promote the humanities, partnering with galleries, museums,
       artists, writers, musicians, etc.;

     · produce low-cost specialty e-Zines. Spectral Web is looking
       into the possibility of producing an e-Zine in partnership
       with schools throughout the world, to be offered to
       subscribers free of charge. This e-Zine would focus on all
       major content areas as well as teen culture;

     · provide free or low-cost email, message board and bulletin
       board services

VII. Closing

Spectral Web again thanks ICANN for the public comment period and appreciates the opportunity to voice thoughts, opinions and suggestions. We hope that ICANN considers some of the items discussed above and recognizes the significance of the stage we are about to enter. Your decisions, choices, rulings and implementation strategy will set many precedents.

Spectral Web looks forward to participating in future forums.
________________________________________________________________________
Statement prepared by Spectral Web, Inc.
       
     
     
     
     
     
 

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