From: Ronald Jore 
Sent: Thursday, 23 March 2006 6:01 PM
To: jo.lim@auda.org.au
Subject: .au domain monetisation comment

Dear Jo Lim,

Thanks for putting this issue up for public comment.

As a general statement, I agree with the current auDA policy as signified by 
this warning on the website and think it should be kept:
"""
auDA cautions that registering multiple domain names for the primary purpose of 
capturing web traffic and/or selling click-through advertising may result in 
cancellation of the domain names for breach of policy.
"""
Further, in my view the described purposes do not even constitute a close and 
direct connection to justify the registration of a single domain name.

In detail, my personal answers to your questions follow.

Issue 1:
Q: "Do all or any of the above methods establish a close and substantial 
connection between the registrant and the domain name?"
A: In my view none of them does and all of them are just ways to make a quick 
buck off unsuspecting consumers and the good name of existing content and/or 
service providers.

Q: "Are some methods of domain monetisation more or less acceptable than others?"
A: In my opinion the differences are gradual. Of course a site providing real, 
targeted and maintained content would be less unacceptable than just a generic 
site, but even then these sites most often seem too generic to be of much use to 
the visitor - at least they usually aren't for me, rather than annoying, and I 
don't think I am that exceptional in that respect.

Issue 2:
Q: "Is it acceptable for generic domain names to be used for domain monetisation 
purposes, as opposed to non-generic domain names?"
A: I don't think it is. Rather than arguing that generic domain names usually 
don't infringe on another party's legal rights because the words cannot be owned 
by a single party, I think that they do infringe on the legitimate rights of 
everyone else who provides content and/or services in the same area by 
monopolising the use of the term.

Q: "Is it a better use of the domain space for generic domain names to be 
registered and resolve somewhere, instead of remaining unregistered? If so, does 
it matter where the domain names resolve?"
A: I would answer the second question first: if those generic names were to 
resolve "somewhere", it would matter a lot where that would be. 
As for the first question, I don't see a problem with generic domains not being 
registered at all and would in fact prefer it to be handled that way. 
If the consensus should turn out to be that they should be made to resolve I would 
much rather see them point to something like a public listing of all services 
catering for that particular market, product, service, or whatever the case might 
be, however in order to ensure that these listings don't become polluted or taken 
over by a similar sort of business model as the one we are talking about these 
lists would have to be moderated to strict rules regarding relevance and equality, 
accessible to everyone who qualifies for free or at cost, and ad-free. 
So basically they would have to be maintained to similar, yet much more complex 
and ambiguous, rules as the domains themselves, i.e. a can of worms.

Issue 3:
Q: "Is tasting or taste testing an acceptable practice? Does it matter if an 
increase in domain name registrations doesn't necessarily equate to increased 
revenue?"
A: As merely a registrant of one Australian domain I cannot answer this question 
from an economical point of view, however as a user of the system my impression 
is that this practice is sending the wrong signals by supporting a practice I don't 
see the benefits of for the intended users. I don't think a genuine registrant of 
a domain needs to "taste-test" it. 
I don't know if the practice matters to registries from a revenue-point of view 
but the whole model looks like a false economy to me anyway because in the end 
there is no more money generated anywhere in the chain; only the distribution of 
the existing flows is manipulated. Effectively wide-spread adoption of these 
business models makes it harder for customers to find providers directly by 
introducing an additional layer into the distribution network, adding complexity 
and cost and in the long term contributing to higher prices because the income 
of the middle layer is not generated by added value but needs to be paid for, 
most likely by the user/customer. Besides not making it easier for the user to 
find particular goods or services, it also makes it considerably harder to find 
genuine information on anything of commercial interest. I find that when 
searching for information in the .com, and even more in the .de domain, I am 
overwhelmed by secondary sites linking to purchasing information, eBay and 
other places and regurgitating product descriptions from other places, making 
it hard and sometimes impossible to find the information I am after. This 
basically negates the usefulness of the web as a tool to find information. 

Q: "Does it matter how many domain names are registered by a single registrant? 
What is the effect on the .au domain space if a single registrant holds a 
significant percentage of total registrations?"
A: In my opinion it does matter very much - not if some company holds one, three 
or five domains; but if they have hundreds, thousands or more they can not only 
seriously skew search results and the market but in doing so also make it 
infinitely harder for others to be found and for users to find what they are 
after. A single registrant holding a significant percentage of total registrations 
I would liken to one company taking over not only a significant percentage of 
all the shop fronts in a city, but also the street signs and advertising spaces. 
With the difference that in that case one could still come across a shop not 
owned by that company by just walking down a street, whereas there is no 
equivalent to that on the Internet (because one usually doesn't try out domain 
names at random or in any generic order). So I think the practice is mainly 
aiding monopolisation. It might be tempting for registries to sell large 
amounts of domains but in the long term it is counter-productive for everyone 
because it reduces the value of the Net for end users.

Issue 4:
Q: "What effect might domain monetisation have on the character and utility 
of the .au domain space?"
A: I've touched on this question a number of times before. In general I think it 
would lead to the loss of the (in my view positive and user-friendly) 
differentiation it has against the "open slather gTLDs like .com" as you call it.
A main difference between the .au and for example the .com domain space is also 
its size. While .com has in my view definitely suffered under the "domainers", 
"Google-bombers" and other "business models", it still manages to maintain its 
usefulness thanks to the sheer amount of genuine content and services offered 
within it. In the .au domain space much less content exists to begin with, much 
less business is done through the Internet in a much smaller market and much 
less Internet usage in general. If businesses that have been successful in 
the .com market with practices like those described jump into the .au domain 
space big time I suspect it could just totally drown the interest in it and 
kill the market. These businesses would not worry much about that effect and 
just move on to target other markets, but the Australian Internet users would 
feel the impact for years to come. This also includes the registries which 
managed to make a quick buck with bulk registrations only to then see their 
businesses come down just as quickly, and probably much further than they were 
before.

In conclusion and for the reasons set out above I strongly suggest to go with 
implementation option 1. 

Thanks again & best regards,

Ronald Jore