From: Karl Schaffarczyk 
Sent: Wednesday, 13 June 2001 6:11 PM
To: Jo@auda.org.au
Subject: Submission


Ms Jo Lim
Executive Officer
AuDA

Jo@auda.org.au

SUBMISSION ON NAME POLICY PANEL REPORT REGARDING POTENTIAL ADDITIONAL 2LDS

Inspired Networking commends auDA's emphasis on a domain administration regime that is 
stable, functional, equitable and transparent. That emphasis is important because auDA 
must act in the national interest. Its will be judged by whether it satisfies community 
and business expectations about the dot-au space, rather than the success of the 
registration industry. It should build on existing practice, which has minimised disputes 
that would require the proposed auDRP or court action and which is intelligible by 
internet users in Australia and overseas.

Inspired endorses the Panel's recommendations about derivation, good faith and speedy, 
consistent automated processing of applications. We are concerned however that proposals 
in the 2LD report are inconsistent with preceding recommendations and with the experience 
of the Australian internet community.

The Panel has not demonstrated a need for additional 2LDs in the dot-au space. In essence, 
if the dot-au space is not broken, do not fix it by adding additional 2LDs that do not 
fill a real need, that overlap with existing 2LDs and that will cause confusion and 
disagreement.

The Panel's willingness in the current report to highlight a number of potential additional 
2LDs is commendable. It would not be appropriate to adopt those proposals as experiments. 
We should hasten slowly, learning from the experience of overseas. ICANN is experimenting 
with dot-biz, dot-pro, dot-info, dot-name and other gTLDs. We should and can afford to wait 
until we have seen whether internet users and registrants adopt those domains. Looking at 
other countries there is a clear and compelling trend to open up each national domain space 
(e.g. the Netherlands, Belgium and Canada) rather than to spawn additional 2LDs that offer 
no substantive advantages for registrants and that confuse users. It is unfortunate that 
the Panel has not opened up the dot-au space in that way.

Australia already has a dot-asn and dot-org 2LD. The Panel has not demonstrated that there 
is a compelling need for an overlapping 'associations' 2LD. Introduction of such a new 2LD 
would cause confusion. A 'directory' 2LD is inconsistent with how people actually use the 
net. It is not the task of auDA to create a 2LD for every trade or industry sector; that 
is not what users want. The proposed 'biz' 2LD will simply be confusing and will not address 
demand problems because any large business will seek to register a com 2LD, a biz 2LD, a 
com TLD, a biz TLD, a net TLD, a net 2LD Š and an entry in any pertinent 'directory' 2LD 
(with consequent disputes).  One result of creating gimmicky 2LDs is that Australian and 
overseas users (and thus registrants) will continue to rely on 'recognised' 2LDs and TLDs.

We strongly urge auDA not to create new 2LDs unless
a) there is compelling evidence that additional 2LDs are required immediately
b) introduction of those 2LDs would not result in new problems auDA should concentrate on the 
introduction of competition, backed up by effective dispute mechanisms, rather than introducing 
unnecessary complexity through additional 2LDs. A decision on new 2LDs should be deferred 
until after we have seen whether the new TLDs are effective and auDA has demonstrated that 
changes to the dot-au space are required. A decision to introduce a new 2LD on the basis of 
what, in at least one instance, appears to be a single suggestion, will not be respected by 
the community.

Inspired Networking is an Australian-owned internet service provider that operates in 
Queensland, New South Wales, the ACT, Victoria and South Australia. Comments in this submission 
are those of Inspired and do not necessarily represent the views of clients.






--
Proprietor
Inspired Networking