From: Alison Norris 
Sent: Thursday, 29 July 2004 11:29 AM
To: 'Jo Lim'
Subject: Review of auDA policy - restriction on geographic names in com.au and net.au

I would like to respond to the submission made by Sam Bauers regarding his interpretation of my earlier 
submission documenting the feedback from participants of community geographic 2LD test cases. 

 

The suggestion that the test case community groups “do not want to go through the process of becoming 
legitimately aligned with the communities as per the requirements of the new 2LDs” is, from my experience 
speaking with and observing these communities, entirely incorrect. All three communities involved in the 
test cases have worked very hard to be inclusive of all members of their respective communities. The 
major challenge faced by these communities has been the paper-work associated with legitimising their 
position as a representative community group. These groups are not-for-profit, community-based 
organisations, and all participants are volunteers. As a result, completing the community geographic 2LD 
paperwork requirements has required a huge commitment from all members of this group. However, while 
this has required extensive time and effort, many of the requirements are certainly essential to ensure 
that the community geographic domain names go to the right people. 

 

As indicated in my previous submission, these community groups DO care about their communities – this is 
why they have made such a huge commitment. The communities want their domain names to be representative 
of the community to which they refer. If other geographic domain names were released, it is logical that 
these communities would want to ensure that they also were kept for use by the local community. It is 
also only logical that, where two (or more) domain names, both with the geographic community name, are 
available, communities would be inclined to apply for the one which requires the least paperwork. It is 
for this reason that I recommended, based on discussions with members of three communities, that should 
auDA decide to release the geographic .com.au and .net.au domains, it is essential to offer them to 
in-community groups first. While I recognise that the .com.au was designed for the commercial sector, in 
reality this is not how people use the Internet. 

 

Feedback from the test case participants, and my personal opinion, is that the release of the geographic 
.com.au and .net.au is not appropriate. As well as the issues raised by the release of these names so 
close to the release of the community geographic domain names, and the need for auDA to undertake 
extensive community education about the community geographic domain names, auDA must consider the 
potential legal issues associated with such a release. How can any organisation assert that they have 
the single legitimate claim to a geographic domain name when there are likely to be hundreds of businesses 
which also have the geographic name in their business name? One must only look to the situation in USA to 
see the problems that will be faced with the release of the geographic .com.au and .net.au domains. 

 

I would not seek to comment on the reasons for the development of the initial OCOS policy, as I did not 
become involved in the project until after the policy was being tested. However, now that the community 
geographic 2LDs have been trialled and proved to have strong community support, I would urge auDA to focus 
their attention on further developing these domains before releasing what would be, essentially, 
‘competing’ domain names. If auDA believes that the geographic .com.au and .net.au domains should be 
released, I again suggest a minimum delay of 18-24 months to allow the community domains to be fully 
established.

 

Regards,

Alison Norris 
School of IT & Computer Science
University of Wollongong