From: Alan Schneider 
Sent: Sunday, 9 April 2006 5:38 PM
To: Chief Policy Officer auDA
Subject: Comments on Domain Monetisation Issue Paper

I find it personally quite disquieting to see that this issue was publicly announced in 
October 2005 and the issues paper was released in March 2006 but as of the 9th April 
2006, only 24 people have bothered to respond. This level of apathy is quite bothersome.

On the other hand it is interesting to review the comments by the respondents thus far.

The respondents arguing against Domain Monetisation seem to fall into two principal 
categories, the first being a quite succinct and pointed “I disagree because…” and the 
second being a literate, pertinent and well reasoned argument against the practice.

Almost without exception however, the respondents in favour of Domain Monetisation bring 
up red herrings, concentrating on side issues with little relevance to the central issue 
in an attempt to obfuscate the whole debate. In fact they are doing precisely that, using 
common techniques of debate to throw emphasis away from the indefensible position they 
have taken in an attempt to win debate points through misdirection.

The most frequent red herring to be brought up to date seems to be that of “freedom of 
speech”, in effect accusing auDA of attempting to regulate site content. This of course 
is totally off the topic, having no relevance whatsoever to policies affecting domain name 
regulation.

Freedom of speech is a very sensitive and emotive issue guaranteed to bring up many heated 
and opposing points of view. As such it makes an excellent topic to throw into the circus 
ring with the intent of distracting the audience from the magician’s sleight-of-hand. To 
put it bluntly, this particular argument falls entirely into the realm of “smoke and mirrors”.

One quite vitriolic response attempts to sidetrack the discussion into the rarefied realms 
of political discourse, Socialism versus Capitalism.

Another respondent seems to believe that search engines provide a panacea for any potential 
problems, ignoring entirely the problem that the search engine results themselves will become 
seriously polluted with valueless, irrelevant results in the face of widespread Domain 
Monetisation activities.

Another respondent argues that it is not auDA’s place to defend trademarks. Again this is an 
irrelevant side issue. It is auDA’s role to protect the integrity of the .au domain name 
spaces which makes monetisation of said spaces a very pertinent issue indeed. The same 
respondent further argues that there are several trillion possible domain names in the 
.com.au namespace, of which a mere 350,000 or so are currently in use. Oh please! Is this 
respondent seriously advocating the use of non-sensical and largely irrelevant alphanumeric 
labels for domains, creating a level of confusion and un-useability worse than raw IP 
addresses and effectively defeating the purpose of the Domain Name Server system?

Several other respondents argue that being directed to a page with pertinent links is vastly 
preferable to receiving a 404 Not Found. This would be a defensible argument, in my opinion, 
only IF said page did present pertinent links or information. In my experience however, in 
nearly every case of Domain Monetisation, the domain holder’s only interest is to attract 
traffic by whatever means in the hopes of either boosting traffic figures or profiting from 
an absurdly low volume of click-throughs to adverts. Any benefit accruing to the user is thus 
entirely accidental and unintentional.

The organisations and individuals that undertake large scale domain monetisation are, in my 
opinion, only interested in making a quick and easy buck and have no interest whatsoever in 
providing any level of service to Internet users or to contribute in any way to the Internet 
at large.

Now, with all that said, onto my comments about the Issues Paper.

Issue 1: Use of domain names.

Question: Do all or any of the above methods establish a close and substantial connection 
between the registrant and the domain name?

Response: Of the ways listed, I believe only two of them constitute acceptable practice under 
the principle of “close and substantial connection”, these being…
* Information website with ads: The domain name resolves to a website with a number of pages 
of articles related to the domain name. This website will use a service like Google Adsense to 
show content-related advertising.
* Developed website: The domain name (usually a high traffic generic domain name) resolves to 
a fully developed and maintained website which includes advertising and affiliate links.

Question: Are some methods of domain monetisation more or less acceptable than others?

Response: Absolutely. I consider acceptable use to be where the monetisation is a secondary 
consideration on a website that offers valuable and interesting content relevant to both the 
commonly accepted meaning of the domain name and the way in which the site is indexed by search 
engines. Of course, the monetisation techniques employed should also bear some relevance to the 
site topic and should not be of an overly intrusive or annoying nature.

Issue 2: Type of domain names

Question: Is it acceptable for generic domain names to be used for domain monetisation purposes, 
as opposed to non-generic domain names?

Response: I believe both generic and non-generic domain names should be subject to the same 
policy.

Question: 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?

Response: If an individual or organisation wishes to create a website that provides relevant, 
useful and accurate information pertinent to a generic domain name they should be permitted, 
even encouraged to do so.

An example of such usage would be a public information site for a geographic region. Any 
monetisation on the site should be relevant and of interest to potential users of the site. Any 
generic domain names not so used should be left vacant.

Issue 3: Volume of domain name registrations

Question: 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?

Response: I believe this practice is totally useless and indefensible.
It is a practice of interest only to domainers who, by and large, tend to register huge numbers 
of domains. If they only hold the domains for a few days and then delete them, the nett effect 
will be a dramatic increase in administration overhead and transient spikes in DNS loading.

The latter requires greater investment in hardware resources and bandwidth to handle such activity 
spikes without degrading overall service and the former necessitates additional personnel (and 
wage/equipment/office space etc costs). This will increase the cost of providing DNS services to 
the Internet community as a whole, requiring increased fees and disadvantaging all legitimate 
users .

Question: 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?

Response: I believe it does matter. No legitimate business usage should require any more than a 
couple of dozen unique domain names. And even then such numbers would be exceptional rather than 
the rule. For individual registrants to hold large numbers of domain names, I believe, 
significantly disadvantages legitimate users by increasing clutter and reducing the “signal to 
noise ratio” of information on the Internet, making it harder to find the information a user 
requires and making the Internet as a whole significantly less useful.

Issue 4: Public policy issues

Question: What effect might domain monetisation have on the character and utility of the .au 
domain space?

Response: As stated previously the nett result would be to increase the clutter of useless sites, 
making useful information significantly harder to find and adversely impacting the character and 
utility of the Internet as a whole and the .au domain space in particular.

Implementation options

I firmly believe Option 1 is the appropriate action for auDA to take.

I would further specify that the third bullet point … “registrants who register domain names for 
the purpose of providing a directory service or information portal would be required to provide 
an actual directory service or information portal for each domain name”

be extended to say something along the lines of… “registrants who register domain names for the 
purpose of providing a directory service or information portal would be required to provide an 
actual unique directory service or information portal for each domain name that provides content 
relevant to the apparent and/or commonly accepted meaning of the domain name”

Best Regards,

Alan Schneider
Melbourne