From: Sam Ivey Sent: Friday, 19 October 2007 1:53 PM To: Jo Lim Subject: Comments on Draft Recommendations (September 2007) Jo, As per the draft recommendations document, September 2007, I submit these comments: Draft Recommendation 1 – I strongly agree. The .au namespace should not be opened up to direct registrations at this time (or any time). Draft Recommendation 2a: - I agree. auDA should have the ability to suspend a domain name without notice at the request of an Australian regulatory or law enforcement agency. Draft Recommendation 2b: I agree. The eligibility criteria for existing 2LDs should remain unchanged. Draft Recommendation 2c: I agree. Registrars should continue to be required to verify registrant details. Draft Recommendation 2d: I agree. The registrant warranty statement should be strengthened in relation to providing true and accurate eligibility details at the time of registration. Draft Recommendation 2e: I strongly agree. Registrants should be able to license domain names for 1, 2 or 3 year periods. Draft Recommendation 2f: I agree. The close and substantial connection rule should remain unchanged, but the clarification policy relating to domain monetization should be strengthened to provide additional protection to brand names. In relation to issue 3, I believe Proposal 3b is the best option, to allow sale and transfer through an open secondary market. I believe an open market would be the fairest and safest transaction system. It would further educate the market and allow equal opportunity for potential buyers. The ability to see "open market" offers and sales will set pricing precedents that can assist businesses in making decisions about potential transactions. Hiding transactions in a private marketplace could create potential for fraud and breach of the current rules and regulations. Thanks, Samuel Ivey