[comments-gtlds] Comments of the American Society of Composers, Authors and Publishers on WG-C

[smosenkis_@ascap.com]

     The American Society of Composers, Authors and Publishers ("ASCAP"), the
oldest performing rights organization in the United States, representing over
95,000 songwriters, composers and lyricist copyright owners, file these comments
on the report of Working Group C.   ASCAP does not take a position on whether
new gTLDs are necessary.  That is not the critical question in our minds.   The
critical issue, ignored by the report, is the requirement for preconditions for
initiating new gTLDs.  Without such preconditions, listed below, even one new
gTLD would be too many.  The preconditions are at a minimum:

(1) Registrant Contact Data - registrants must be required to submit accurate
contact data

(2) WHOIS Access - Managers of each gTLD must provide free real-time world wide
web access to a current database of registrants that contain such registrants
contact information.

(3) Effective Dispute Resolution Policy

(4) Compliance Review - A workable mechanism by which gTLD compliance can be
monitored.

These preconditions are easy to effectuate and necessary to a workable expansion
of the domain name system.

Respectfully submitted,

American Society of Composers, Authors and Publishers
One Lincoln Plaza
New York, N.Y.  10023

Joan McGivern
Sam Mosenkis