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A Preview - Iperdomes Response to the NOI
- From: Jay
- Date: Fri Aug 15 13:51:03 1997
What follows is a rough draft of Iperdome's response
to the U.S. Government's Notice of Inquiry. It is being
posted so that your comments can be incorporated before
our official submittal is made.
Many people, companies, organizations, and Government
officials were consulted for their perspectives on these
issues. While many ideas were gathered from these
stakeholders, none have approved this draft nor the
suggestions outlined below.
We suspect that few if any of the stakeholders will view the
suggestions outlined in this document to be their best
alternative. We do believe, however, that these suggestions
are the best compromise available given the current situation.
Please feel free to post your comments publically, or if
you prefer, you may send you comments privately. If they
are sent privately, we will honor your confidentiality,
however, we may incorporate your suggestions in our
final position paper.
Domain Name Compromise
Contrary to appearances, the Domain Name Crisis is *not* about
domain names. It is about control. It's about how the
Internet will look 20 years from now, and who will make those
The immediate challenge facing all Internet stakeholders is
how to deal with the IAHC proposal. It is the result of a
process initiated by the IANA, and orchestrated by the ISOC,
ITU and WIPO. While we don't necessarily oppose these four
groups' involvement in Global Internet Governance, we do
oppose their unilaterally deciding to take over this
governance, especially when it was done behind closed doors,
without legitimate authority, and counter to Internet
Other problems with the gTLD-MoU are:
* It ignores the vast majority of Internet stakeholders who
have not been and will not be represented under the proposed
* It creates a highly controlled, bureaucratically
administered name space, instead of a free market approach
that has fueled much of the Internet's world wide growth.
* It attempts to implement new global Trademark and IP
policies, without any authority delegated by the sovereign
nations that are being asked to acquiesce to these policies.
If the gTLD-MoU is accepted as the authority to determine what
is and what is not appropriate for the name space, it will
establish the first and only politically authoritative body
for the Internet that is trans-national in influence. Given
the current power vacuum, it is very likely that whatever
precedent is set for domain names will apply to other topics
Global Internet Governance is much too important to leave to
the IANA, ISOC, ITU, and WIPO alone, no matter how honorable
their intentions are.
Iperdome believes that the gTLD-MoU is the wrong solution for
Global Internet Governance (GIG), and the wrong solution for
the Domain Name Crisis. It is our opinion that GIG must be
postponed until the Internet has had a little time to mature,
and all Internet stakeholders have had an opportunity to
participate in the process that will profoundly affect them
for many years to come.
By the same token, the Domain Name Crisis must be addressed
quickly. Many companies have been harmed by the
anti-competitive state that currently exists (i.e. PG Media,
IO Designs, and other pending lawsuits), and the NSF has
indicated that they are canceling their cooperative agreement
with NSI when it expires in March of 1998.
Iperdome believes that the best compromise will result if we
separate the problem into its two separate components (GIG
<===> fixing the Domain Name Space). Then we can find a
temporary solution to the latter, while diverse groups of
Internet stakeholders formalize a solution to the former, and
As a point of reference, we have used the following goals to
help us determine what is in the best interest of the Internet
and the Internet Community.
* To keep the Internet open to free and fair competition.
* To limit regulation to the absolute minimum required to
provide stability and fair play.
* To honor the spirit and character that has made the
Internet a world wide phenomenon.
In light of our stated goals, we believe that the following
proposal is the best compromise currently available:
"Move .com, .org, .net, .edu, .gov, and .mil under .us"
When the DNS was established, the Internet was primarily a
U.S. phenomena. The TLDs that were established were
primarily for the U.S. name space. As the Internet went
global, however, these same TLDs became artificially
valuable because they were the only ones that did not have a
two digit country code suffix. Although still primarily
U.S. based, their existence resulted in global addressing
and Trademark issues.
This historical legacy has biased the potential solutions to
the artificial problems that were introduced because U.S.
TLDs did not require the .us suffix.
Rather than rush the implementation of Global Internet
Governance to address these artificial problems with global
addressing and Trademark issues, it makes more sense to fix
the name space before we grow the name space. That means
that .com, .org, .net, etc. should become .com.us, .org.us,
.net.us, etc. The resulting universal domain name space would
then consist of all two character ISO country codes, .int,
and .arpa (a historical reverse mapped TLD).
Some of the advantages to this proposal are as follow:
* Postpones GIG until Internet matures and consensus can be
* Allows each country to administer its own domain name space,
using the historical laws and traditions of their respective
countries (i.e. Italy has decided that domain names and
trademarks are two separate and independent issues).
* Allows U.S. IP, Trademark, and anti-trust Laws to redress
existing grievances under the former .com, .org, etc. TLDs.
Iperdome has prepared a much more extensive analysis of
the advantages and challenges that this proposal entails.
We will be posting it shortly.
President, Iperdome, Inc.