[comments-gtlds] http://www.icann.org/dnso/new-gtlds-01apr00.htm

[maruyama@nic.ad.jp]

Here are our comments.

-- Naomasa Maruyama

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Comments on the WG-C report (addition of new gTLDs)

0. Introduction
     This document describes opinions of an interested group from
JPNIC (Japan Network Information Center) who discussed the DNSO WG-C's
report on the addition of new gTLDs.  The following summarizes our
opinions:

* We agree with a rough consensus reached by the WG-C that new gTLDs should
  be added (Issue One of the report).

* We also agree with a rough consensus reached by the WG-C that 6 to
  10 gTLDs should be added at first, followed by a period of evaluation
  (Issue Two of the report).  However, prior to the addition of new
  gTLDs, it is necessary to deal with the following issues raised in the
  interim report submitted by the Names Council in November 1999:

  - How to determine the nature of new gTLDs?
  - How to implement transition to the expanded space?
  - Should each gTLD registry be shared?
  - Should each new gTLD registry be a for-profit or non-profit organization?
  - What process should be used to select new gTLD registries?

In addition, the following issues should be discussed prior to the addition.

* Strings that could be mistaken for ccTLDs should not be used as new gTLDs.
* We think new gTLDs should be added after a mechanism is established to
  protect famous trademarks.

     The present gTLDs with the most popular .com domain have created
an environment in which multiple registrars compete with one another,
eliminating the problem of monopoly from the standpoint of
registration business.  However, only three gTLDs, namely .com, .net
and .org, are now available, and .com has been attracting the greatest
number of registrations, resulting in quick depletion of its domain
name space.  Under such circumstances, it is necessary to create new
gTLDs that can compete with .com and stimulate proper competition
among gTLDs (that is, proper competition among registries).  In our
discussion, we gave priority to this issue.  In other words, our
priority is to increase the domain name space that anyone can use and
thereby encourage the wholesome development of the Internet.

     This document summarizes comments made by an interested group
within JPNIC, and represents neither the policy of all members of
JPNIC nor their policy as an organization.  These comments were made
in our effort to discuss the wholesome development of the Internet
from various points of view, not from the standpoint of ccTLD.


1.  Issue One - Should there be new gTLDs?

     We agree with a rough consensus reached by the WG-C that new
gTLDs should be added.  It is desirable that new gTLDs be added to
foster competition among gTLD registries and lower the concentration
of registrations in the existing .com domain.


2.  Issue Two - What Should be the Nature of the Initial Rollout?

     We agree with a rough consensus reached by the WG-C that 6 to 10
gTLDs should be added at first, followed by a period of evaluation.
Prior to adding 6 to 10 gTLDs, however, it is necessary to solve the
issues presented in the interim report of the Names Council for which
no consensus has been reached yet.  The issues presented by the Names
Council are as follows:

2-1.  Nature of new gTLDs
     The purpose of adding gTLDs is to create a competitive
environment for gTLD registries.  Now that the existing .com has
problems of insufficient name space, monopoly, and speculation of
registrations, priority should be given to the creation of gTLDs that
can compete with the existing gTLDs.

     When top priority is given to the introduction of new competitive
gTLDs, we think it is not be necessary that the initial 6 to 10 TLDs
are chartered ones.  It seems better not to initially add TLDs that
denote specific business fields (example: .airline).

     The WG-C report uses both terms "global" TLD and "generic" TLD,
and the meanings of the two terms are not defined clearly, while they
should be.  In this document, we define gTLD as a TLD that is open to
all nations and not chartered.

2-2.  Transition to the expanded space
     In the process of adding new gTLDs and expanding the domain name
space, we will have to evaluate the performance of the new gTLDs and
check if their introduction is successful.  ICANN, who has the final
say to the introduction of new gTLDs, will have to specify its own
evaluation criteria. Without such criteria, ICANN will not be able to
judge on a reasonable basis whether or not to approve the addition of
more gTLDs in future.
     Regarding the first 6 to 10 gTLDs, it may not be necessary to
determine strict evaluation criteria prior to the introduction.  We
may be able to supervise the performance of new gTLDs during the
implementation period and deal with any problems that might occur.

2-3.  Should each new gTLD registry be shared?  
     It is important to add gTLDs that can compete with the current .
com, .net and .org and create an environment to foster competition
among registries.  There is no need to have new gTLD registries
monopolize registrations as NSI did in the past.  We think the shared
registry system presently adopted by the NSI Registry is good.  To
realize fair competition among registries and registrars, no single
company should be allowed to become both registry and registrar of a
gTLD.

2-4.  Should new gTLD registries operate on a profit or non-profit basis?  
     When ICANN calls for applications for the new gTLD registries, it
should specify registry requirements and indicate whether each
registry should be a for-profit or non-profit organization.  ICANN
therefore must decide its policy on this matter.

     We think a gTLD registry could be a for-profit or non-profit
organization.

2-5.  What should ICANN's process be for selecting new gTLD registries?
     The WG-C report introduces three methods of selecting new gTLDs
and their registries: (1) ICANN should first select new gTLD strings,
and only then call for applications from registries wishing to operate
those TLDs. (2) ICANN should select new gTLD registries on the basis
of objective criteria, and allow the registries to choose their own
gTLDs in response to market considerations. (3) registries should
apply describing their proposed gTLDs, and that an ICANN body or
process would then make selections taking into account the
characteristics of both the registry and its proposed gTLD.

     We support Method (3) for the following reason:
The registry service itself is not a strong incentive for many
registry candidates.  They seem to find a greater incentive in the
prospect of becoming a "registry of a specific string".  For this
reason, it seems preferable that registry candidates propose gTLD
strings of their choice when making applications.

2-6.  Process for selecting new gTLD registries
     Registry candidates should be selected by bidding.  ICANN is
required to specify bidding criteria.  In this regard, ICANN must also
decide whether or not to allow one company to bid for multiple
registry positions, whether to consider geographic diversity in
registry selection and what documents should be submitted by registry
candidates to participate in the bidding.

3.  Others
     In our discussion, some participants commented that the
3-character ISO3166 code and other alphabetical characters that
indicates a specific country in other language than English, such as
"nippon" for Japan, should not be used as new gTLDs because they may
be mistaken for ccTLD.

     New gTLDs should not be added until a mechanism is established to
protect famous trademarks.  (The WG-B is making investigations on
famous trademark protection.)  Exclusion of famous trademarks and
strings that are confusingly similar to those famaous trademarks is
basically for consumer protection and for realizing the stable
operations of the Internet.  In this regard, our objective of adding
gTLDs can be achieved by taking these measures as well.

     However, some people oppose to the above opinion and think that
"UDRP can deal with trouble caused by new gTLDs until a mechanism is
established to protect famous trademarks".  Thus, we did not reach a
unanimous conclusion in our discussion.

Naomasa MARUYAMA (Domain Name Working Group, Planning/International Working
Group, Task Force for the Domain Name Dispute Policy, JPNIC)
Tsugizo KUBO (Domain Name Working Group, Task Force for the domain name
dispute policy, JPNIC)
Hiro HOTTA (Planning/International Working Group, JPNIC)
Toshi TSUBO (Domain Name Working Group, Planning/International Working
Group, Task Force for the Domain Name Dispute Policy, JPNIC)
Kozo YABE (Task Force for the Domain Name Dispute Policy, JPNIC)
Takashi ARANO (Planning/International Working Group, IP Address Working
Group, JPNIC)
Yumi OHASHI (JPNIC Secretariat)
Makiko MATSUMARU (JPNIC Secretariat)
Akiko KUSABA (JPNIC Secretariat)

----
Naomasa Maruyama (Vice President of JPNIC)
maruyama@nic.ad.jp

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