gTLD registration comments and objections
Regarding the upcoming change to the creation of top-level generic TLDs, we at Fitch Surveillance Systems have a few general observations to make and one very specific complaint. In specific, we note the application by Symantec to control the .security TLD as a closed domain. We are opposed to anyone operating this domain as closed, because it is not in the best interests of the security industry. Symantec, a vendor of information systems security, simply does not represent security in a broad sense. They do not provide security services such as intrusion alarms, CCTV, access control, security guards, or many other aspects which could reasonably be considered part of a .security TLD. Even if Symantec were to provide such services however, operating as a closed domain would give them an unfair competition advantage, giving them the ability to control who can advertise competing services to their own. This would be anticompetitive and against the public interest. In general, this does not merely apply to Symantec. Our concern applies to any company that would attempt to register such a diverse term as "security" as a closed domain. If a company registers a TLD of ".security", or other generic name, it must be a registration open to anyone to join, such as exists for current TLDs like .com and .net. We do not deny corporations such as Symantec the right to register a closed generic domain, but we would expect such registrations to be similar to trademark registrations. They could register the .symantec domain without worry as that is their trademark, and no one else has the rights to use Symantec in a computer context. They cannot register "security" as a trademark because the word is too generic, and so we would expect such a word to be too generic for a closed domain. Using this as an example, we would expect that ICANN reject any request for a closed generic TLD on any name that is in itself generic, whether ".security" or otherwise. We would suggest this be made clear as part of the terms for registering new generic TLDs. This should be the case whether the proposed domain is ".security", ".computer", ".sale", ".home" or any other generic name. All of these, if allowed to be registered, must be registered as open domains. If an existing application has been made for one of these TLDs as a closed domain, the application should either be rejected outright or required to open the TLD. We firmly believe that any company that wishes to operate a generic TLD should support the interests of all who might benefit from that domain. Closed TLDs support only the interests of the company that registers them, and should be rejected when not also in the public interest. Jason Bere IT LEAD Fitch Surveillance Systems Inc. 14 Meteor Drive Toronto, Ontario M9W 1A4 P (416) 235-1818 ext. 336 F (416) 235-1226 This communication may be confidential and the information in it may represent a privileged communication which should not be misused or forwarded. If you have reason to believe that you are not the intended recipient of this communication, please contact the sender immediately.