In the matter of				

Draft Specifications for Administration	and Management of gTLDs

International Ad Hoc Committee Draft		Released December 19, 1996

(Location: http://www.iahc.org/draft-iahc-gTLDspec-00.html)







	COMMENTS OF THE DOMAIN NAME RIGHTS COALITION


Michael T. Doughney, Executive Director
Kathryn A. Kleiman, Esq., General Counsel









FLETCHER, HEALD & HILDRETH, P.L.C.
1300 North 17th Street, 11th Floor
Rosslyn, Virginia 22209
(703) 812-0424

January 17, 1997

In the matter of				
Draft Specifications for Administration	and Management of gTLDs
International Ad Hoc Committee Draft		Released December 19, 1996
(Location: http://www.iahc.org/draft-iahc-gTLDspec-00.html)

	COMMENTS OF THE DOMAIN NAME RIGHTS COALITION

I.	INTRODUCTION
The Domain Name Rights Coalition hereby submits its comments in response to
the preliminary recommendations of the International Ad Hoc Committee
("IAHC") formed by the Internet Society in late 1996.  The Domain Name
Rights Coalition ("DNRC") represents the interests of entrepreneurs,
Internet service providers and individuals in the emerging policies of
domain names and Internet governance.  The DNRC website can be found at
http://www.domain-name.org.  As a participant in the State Department’s
Working Group on Domain Name, the DNRC has met and discussed these domain
name issues with many members of the IAHC Committee in the past and these
comments are drawn from the discussion of these meetings and further
evaluation of the IAHC recommendations with many domain name owners.
In these Comments, the DNRC agrees with IAHC that Internet space is a
"public resource" and must be better organized to allow for easier
navigation and voluntary grouping of parties with similar purposes, such as
trademark holders.  Given the broad charter of the IAHC to operate in the
"public trust," which we read as public interest, and the great need of the
Internet community to organize many aspects of Internet space, we believe
that the IAHC has construed its mission and its recommendations too
narrowly.  An entire community is waiting for better allocation of space,
not just trademark owners.  
To help the IAHC better serve the broader interests of the Internet
community, the DNRC Comments address three points:  the role of IAHC, the
need for public Internet spaces in addition to the .TM trademark spaces
recommended by IAHC, and the creation of a diverse, robust and competitive
registry system than that envisioned under the IAHC Draft Specifications for
Administration and Management of gTLDs ("Draft").

II.	ALTHOUGH IAHC LEGAL AUTHORITY DOES NOT EXIST, THIS PROCEEDING IS
IMPORTANT AND DNRC CHOOSES TO PARTICIPATE. 

The DNRC recognizes that IAHC is a voluntary body assembled at the request
of the Internet Society, largely from a subset of participants in the State
Department Working Group on Domain Names.  We further acknowledge and
anticipate the comments which will state that the IAHC has no authority to
advance, implement or enforce its decisions.  We agree.  
Nevertheless, we view this discussion as a noble experiment in
self-governance.  To the extent that the Internet can develop
self-governing, democratic structures that represent all of the communities
communicating over the Internet, noncommercial and commercial, we believe
that the advance of government regulation over the Internet will be stayed.
To that end, we participate in a discussion that we think is meaningful,
important and far-reaching. 
 III.  		TOGETHER WITH IAHC, THE DNRC AND ALL PARTICIPANTS TO THIS
PROCEEDING ARE SERVING A ROLE ANALOGOUS TO THE ZONING BOARD OF A YOUNG TOWN.

The DNRC shares the view of the White House, the United States Third Circuit
Panel, which reviewed the Communications Decency Act appeal, and most users
of the Internet, that the Internet is an electronic world that is a
microcosm of the physical world with all of its variety:
In essence, the Internet has become the vehicle of a new, global digital
economy which has enveloped the physical world, altering traditional
concepts of economic, political and social relations.  A Framework for
Global Electronic Commerce, Ira C. Magaziner, Senior Advisor to the
President for Policy Development, Background section, Draft #9 - December
11, 1996, http://www.iitf.nist.gov/eleccomm/glo_comm.htm. ("Framework for
Electronic Commerce")

The questions before the Internet community involve the most fundamental
issues of organizing Internet space so that existing communities in physical
space can easily navigate and find areas of Internet space under rules which
are familiar and comfortable.  Accordingly, the role played by the IAHC, the
DNRC and all participants to this proceeding is analogous to the zoning
board of a young and booming town.  It its early days, the town had few
rules about building, but as the population grows and traffic increases,
there is a need to segregate public from private space, to separate
residential from industrial areas, and to zone areas for merchants, parks
and playgrounds. 
Zoning boards, regardless of the personal and professional interests of
their members, must operate in the public interest to promote "the health,
safety or general welfare of the public."  Purpose of Zoning Ordinances,
Virginia Code Annotated Sec. 15.1-489.  In the Commonwealth of Virginia, the
zoning boards have been charged to give "reasonable consideration to each of
the following purposes" (in the order set out in the Virginia statute):
• Adequate access and public safety;
• Reduce congestion in public streets;
• Facilitate the creation of a convenient, attractive and harmonious community;
• Facilitate the provision of adequate police and fire protection, disaster
evacuation... schools, parks, forests, playgrounds, recreational facilities,
airports and other public requirements;
• protection against the destruction of historic areas;
• protect against overcrowding, undue density, obstruction of light and air; and
• encourage economic development activities that provide desirable
employment and enlarge the tax base.

The DNRC submits that IAHC has advised us to jump too quickly to the seventh
priority, commercial development, while overlooking the first six
priorities.  Whether the Internet will accept the IAHC proposals depends on
how expansive and inclusive the IAHC vision becomes in the next draft (due
January 31, 1997) and how much attention it chooses to devote to the space
needs of individuals, schools and libraries, community groups, social groups
and political groups.  They, like trademark holders, seek easily navigable
space on the Internet operated under rules familiar to them from physical
space.  It is our fear that if the only space allocated, by the advice of
the IAHC, is trademark, we will be creating an Internet community which is
unlivable -- laying the groundwork for a ghost town.

IV. 		THE IAHC HAS PROPERLY IDENTIFIED THE NEED FOR A SET OF PUBLIC SPACES
FOR TRADEMARK, AND RECOMMENDED RULES THAT TRADEMARK REGISTRANTS WILL FIND
INTUITIVE AND COMFORTABLE.

In Section 6.2, Trademark-specific Domain Names Spaces, the IAHC proposes
the addition of a trademark-specific domain name in every country code and
also in the .INT international domain name space.  IAHC states, and we see
no reason to disagree, that trademark owners will engage in "voluntary
registration" of "trademark-specific domain names" in a space that provides
"an assurance that the domain name reflects a subsisting trademark
registration."  Draft, Section 6.2, para. 1-2.   The DNRC believes both
trademark holders and others will benefit from this creation of trademark
zones in cyberspace.  Further, it is appropriate that the .TM (or its
language equivalent) should be incorporated into each country code and also
allocated as a .TM.INT region in the international level, not just because
.TM is a country code already taken by Turkmenistan, but because it is good
organization of space by function.
In Section 5.4, Second-Level Domains, the IAHC proposes the creation of a
60-day publication period.  For trademark holders, such a public notice
period is acceptable as a matter of common practice.  Although we wonder why
the IAHC has proposed a 60-day public notice period and the International
Trademark Association, in its recently-released proposal
HTTP://PLAZA.INTERPORT.NET/INTA, has proposed a 90-day public notice period
(the U.S. Trademark Office only has a 30-day public notice period, and it is
our sense that timeframes should work faster, not slower on the Internet),
we recognize that public notice periods are proper and accepted practice in
U.S. trademark practice and accept the consensus of the IAHC, with its
leaders from the World Intellectual Property Organization and International
Trademark Association, that public notice is a standard practice worldwide. 
Similarly, the certifications of the proposed domain name application and
renewal applications listed in the Appendices are in keeping with trademark
practice.  For U.S. registrants, these proposed certifications will be
functionally identical to the U.S. trademark registration.  Currently before
the U.S. Trademark Office, applicants certify that they are the owners of
their marks and that their proposed registration is not infringing to prior
users.  The proposed language for the domain name certification is very close:
The applicant believes that the intended use of the domain name will not
infringe any rights of any other party."  IAHC Draft, Appendix A - SLD
Application Requirements.

For trademark holders, such a certification makes perfect sense.
A.		Great care has been shown to allocating trademark-specific Internet
space, but where are the space allocations for other communities just as
deserving of attention? 

The DNRC has searched in vain through the IAHC draft for a signal that other
much-needed public and private Internet spaces would be recommended and/or
allocated up-front in a manner similar to the .TM spaces.  We were sorely
disappointed to find that only the trademark community received space.
Accordingly, as a part of the Internet "zoning board," we take this
opportunity to recommend the addition of the following spaces to every
country (in its own language equivalent) and also allocated at the
International level: 
• .POL for Political Speech.  According to the Framework for Electronic
Commerce, there is great value in political speech on the Internet:  "the
Internet democratizes societies and empowers citizens with information."
The vital space of a town hall or public meeting house should be made
available to every community and encouraged in every country code.

• .LIB and .SCH should be allocated upfront for Libraries and Schools.  Both
of these institutions are coming online in record numbers, particularly as
industry and governments make the funds available for projects and
technological developments drive down equipment costs.  Again referring to
the Framework for Electronic Commerce, the importance of easy access to this
important information is key: 

Students across the world are benefiting from instantaneous access to far
flung libraries, universities, and other troves of data via the World Wide
Web.  A Framework for Electronic Commerce, Background section.

Space must be allocated for these groups to find each other and for a
information-seeking public to find them. 

• .PERS for  Personal Speech.  There is a great gap in current Internet
space, for there is no room or allocation for personal space.  Currently,
personal Web sites must be buried under an ill-fitting categories.  The
problem would be easily solved if a .PERS, or its equivalent, were allocated
under each country code, and also in the .INT International space.  It will
then be intuitively obvious to everyone where to go to find the personal
brochures, pamphlets, pictures and stories that have made the Internet such
a warm place.  For those who have not yet seen baby pictures posted within a
few hours of the birth to be shared with family and friends across a
continent, stories of travels shared daily with friends worldwide, or
artwork scanned and posted as soon as it is finished, the Internet will
offer a new dimension of personal communication.  As Central Park within the
middle of New York City allows people to get a breath of air, a personal
moment and a free thought, the allocation of a public personal space on the
Internet will provide important breathing space (a priority of all zoning
board).

B.		It is Only Fair that Domain Name Owners within these new Political,
Educational and Personal Internet Spaces Operate Under Rules Similar To
Those of Physical Space.

The IAHC has recommended a system of certifications and public notices that
will allow trademark owners to operate in an almost-intuitive manner online.
The transition from physical space to cyberspace will be quite easy, thereby
decreasing risk and increasing use. 
The DNRC believes that in public Internet space, as in physical spaces,
schools, libraries, political and community groups will choose their domain
names with the same care that they choose their names in physical space.
The purpose of these names will be identify and distinguish the group within
the community.  Such names in the physical world do not need to run the
gauntlet of public notice and such a requirement would be extraordinary and
unnecessary.  To impose such a requirement would cause immense problems in
cyberspace and very likely drive away the very groups we are working so hard
to encourage.
In addition, the delay of a public notice period would be completely counter
to our societal goals: we want public safety, political and community groups
to be able to respond to the needs of their communities as quickly as
possible.  For example, following a disaster, natural or manmade, there will
be the increasing demand for new domain names to organize information.
After the last earthquake in California, people set up websites to pool
information about communities and individuals.  Rather than continuing to
try to call the West Coast, Internet-savvy family and friends reached the
websites, thereby freeing the cellular system and other communications
infrastructure for the emergency medical and rescue calls that were critical
during the hours after the disaster.  It is clear that domain names for
public emergencies should be processed as fast as the automated queues of
the registrars can handle them (approximately 48 hours and dropping,
according to Network Solutions, Inc.).
Further, public notice periods would delay the usefulness of a community,
political or medical site, perhaps long past its purpose.  While a 60-day
public notice period is normal to a commercial entity that envisions years
of investment in a brand name, it is far beyond the planning times of most
community organizations.  A neighborhood block party will be completed and
forgotten within sixty days; an online protest of the passage of the Exon
Amendment to the Telecommunications Act (Communications Decency Act) will be
overdue and untimely, and the December notice from the PTA about the
dangerous new toy will be delayed long past Christmas, resulting in an
untold number of children needlessly hurt.
We note in passing that even commercial names in physical space are not
subject to a public notice period in the United States.  Registration of a
new corporation’s name in the State of Delaware can take place within a few
hours, subject only to a first-come, first-served name check. 
Overall, in the physical world, a Little League team, a Brownie troop, a
religious institution and a community volunteer group do not have to undergo
a period of public scrutiny and comment.  In the equivalent spaces of the
Internet, such notices will be unnecessary, burdensome and destructive to
these groups and the organization of these spaces.
C.		No Party, Private or Corporate, Should be Asked to Waive the 
Protections of Subject Matter and Personal Jurisdiction, or Venue as Recommended
by the IAHC.

Recommended language of the IAHC proposes that domain name applicants,
private and corporate, waive legal protections provided by legislatures and
courts worldwide.  The DNRC strenuously objects.  According to the IAHC
Draft, Appendix A, a domain name registrant must agree to the following
extraordinary statement: 
That the applicant submits to the personal and subject matter jurisdiction
and venue of a competent tribunal in the country where the registrar resides
for purposes of any action brought under trademark law, unfair competition
laws, or similar/related laws arising out of actual or intended use of the
domain name applied for; and applicant waivers all rights to challenge such
personal jurisdiction, subject matter jurisdiction and/or venue.  IAHC
Draft, Appendix A, Section 11.1.

For DNRC to fully list its concerns regarding this suggested waiver of
treasured constitutional protections for U.S. citizens and other citizens
worldwide would take more pages than any reader will want to see.
Accordingly, we will limit our response to raising some basic questions
about why such waivers and such deep damage to valued due process
protections are necessary.  We ask that the "old guard" of Internet
protectors, namely, the Internet Society, National Science Foundation,
Internet Architecture Board, and other participants in IAHC think carefully
and delete these waiver provisions immediately.  
In brief:
• How and why should a domain name applicant waive subject matter
jurisdiction?  Subject matter jurisdiction is the ability of a court to hear
a certain type of case and it cannot be waived in the United States and we
expect worldwide.  In the United States, a court cannot waive subject matter
jurisdiction and, by definition, a court cannot be a "competent tribunal" if
it does not have subject matter jurisdiction to hear the case. 

• Why should a domain name applicant, either individual or corporate, be
forced to waive personal jurisdiction to obtain a domain name?  Personal
jurisdiction in the United States is a constitutional protection which
limits states and courts from reaching "persons or things outside their
borders" Civil Procedure, Friedenthal, Kane & Miller, P. 97.  Courts
worldwide are struggling with the question of jurisdiction for activities
conducted over the Internet, just as courts one hundred years ago evaluated
new questions of personal jurisdiction as people and companies expanded the
geographic scope of their activities using telegraphs and telephones.  We
see no reason to preempt or circumvent this process.  We certainly see no
reason to ask individuals to waive constitutional rights of where they can
be called before a judicial tribunal merely from the filing of a domain name
application.

• Why is the court of the registrar the appropriate site for a lawsuit
between two parties seeking the same domain name?  According to the IAHC
Draft, "Registrars will be initially allocated equally to each of the six
(6) ITU designated geographical world zones."   IAHC Draft, Sec. 4.2.  Thus,
the location of the registry will be increasingly invisible and irrelevant
to the domain name applicant.  The DNRC submits that it is only right and
fair that the location of the disputing parties be evaluated in deciding
where the lawsuit may take place. 

• Regarding service of process, why would the IAHC want to make individuals
appoint themselves as agents?   As DNRC and the IAHC know well, many domain
name applicants are individuals.  The concept of "agent for service of
process" is a uniquely corporate one.  Service of process is the way courts
give notice to a defendant or other party to a lawsuit that there is a
proceeding and that they should appear.  When the defendant is an
individual, every country has well-developed laws as to how the individual
is to be notified.  In the U.S., for example, we generally want the
individual to receive the notice personally and we do not allow it to be
left with, say, the individual’s nine year old child if no one else is at
home.   Corporations, however, do not have physical entities and therefore,
states and countries make them appoint people who will receive notice of
lawsuits and other legal matters.  When a corporation expands its activities
into a state beyond its state of incorporation, the state will generally
make it appoint a person local to the state to receive any legal notices
from local employees, vendors and customers who may have disputes and
lawsuits.  But our legal practice has always drawn a clear line with
different sets of rules and protections for individuals and corporations.
Why would we want to waive these valued rights by the mere filing of a
domain name registration? 

Overall, the DNRC recommends that the Internet community and that IAHC
propose more public spaces, allow participants to operate in these spaces
under rules corresponding to those of physical space and not require
individuals and corporations to waive much-valued legal protections. 

V.		THE DNRC SUPPORTS REGISTRY COMPETITION AND SUBMITS THAT SOME SIMPLE
STEPS WILL MAKE THIS COMPETITION MORE DIVERSE AND COMPETITIVE.

The DNRC supports a competitive registry environment, and feels that further
steps should be taken to ensure that the registry business is a viable one
and that the spirit of competition prevails.
A.	The DNRC does not support shared gTLD or shared second level domain space.
Although we understand the desire to break up the monopoly of early entrants
such as Network Solutions, Inc., with its .COM commercial organizations
Internet domain space, the DNRC feels that it is in the long-term interest
of Internet growth to allow all registries to exclusively manage a full
domain space.  Registrar entrepreneurs would obtain rights to market a
distinctive service to customers worldwide.  Through careful development of
marketing and sound business practices, the new registries would develop
their unique domain space to be an Internet brand name which would be
recognized quickly, accumulate customer good will and be readily associated
with the quality of the business practices of the registrar.  We quickly
believe that the cachet of .COM will slip in the face of the aggressive
marketing efforts of new registrars.
 B.		The DNRC Questions Whether the Council of Registrars Will  
Be Seen As An Attempt At Anti-Competitive Activity.  

The Council of Registrars ("CORE"), as discussed in the IAHC Draft, will
provide "the necessary contractual, legal, oversight and public policy
framework under which CORE and the individual Registrars must operate."
IAHC Draft, Sec. 5.1   This wording come as a surprise to DNRC, since it
seems to exclude many of the obvious areas of competition between the
registries.  It is our opinion that entrepreneurial registries will want and
must be allowed to establish their own contracts, policies, pricing models,
marketing package, customer help desks, forms and software for registering
domain names.  Provided there is rapid and complete distribution of
information (which there should be on the Internet), the consumers will make
their own market choices.   The consolidation of the decision making power
to the CORE certainly opens the CORE to allegations of antitrust.  Also, the
CORE appears to be an organization which has no defined accountability or
"auditability" to domain name owners who are the Internet public.  	
Rather than a centralized and highly powerful CORE, we advise the creation
of a loose and optional union of registrars in an international trade
association .  This Association could appear before the World Intellectual
Property Organization and the International Telecommunications Union to
lobby for the common interests and needs of its members, but policies,
procedures and pricing models would be matters left strictly to the
individual registries.
 C. 	The DNRC Recommends A Hybrid System to Encourage Competition 
and Protect Registries.

After careful consideration, the DNRC proposes that registries be given one
of two options under which they may operate.  Registries should either
choose to mediate or not to mediate their domain name spaces, and for those
who do not choose to mediate, there should be immunity from intellectual
property infringement damages.  The choice should, of course, be made known
to all domain name registrants prior to registration.
1. 	Moderated Sites
Registrars who so choose, should be allowed to select the category of
individuals or organizations who they will serve, and then actively monitor
their site to enforce the criteria.  By contracts drafted by the registries
specifically for the type of domain name registrant they seek, registries
will attract and retain a specific group, such as sports club owners or
children’s after school programs.   How well the registrar monitors and
enforces the provisions of the contract will become known in the Internet
community and either enhance or reduce the reputation of the particular
registry business.
2.	Unmoderated sites with immunity
In Section 6.2, the IAHC set out its belief that trademark owners will
voluntarily seek to congregate in trademark-specific domain names.  We
agree, and also believe that the other Internet communities described above
will voluntarily seek to congregate in their own communities. 
For registrars who choose to only be registrars alone, and to rely on the
voluntary incentives of congregating groups rather than the policing power
of contracts, we hereby recommend immunity for the registrar from the
charges of contributing to or diluting intellectual property rights by
virtue of acting as a registry.   This proposition is completely in keeping
with United States trademark law, 15 United States Code, Sec. 1114(2), in
which a printer of signs, banners or newspapers is not required to be the
"intellectual property police" of all intellectual property with which
he/she works.  Rather, the printer is considered an "innocent infringer"
and, in the event an injunction is obtained against the further use of the
intellectual property by the party that contracted services with the
printer, the printer must stop printing.  The printer does not have to pay
damages -- he/she is not involved!   
The IAHC should adopt the model of the "innocent infringer" as the consensus
that the Internet supports for registries that choose not to police their
marks.  This immunity would allow registries to drop or never adopt the
hated Domain Name Dispute Policies.  In an unusual alliance in late 1996,
the DNRC and Network Solutions, Inc. drafted and together submitted a
proposal regarding registry immunity to the State Department Working Group
on Domain Names.  The text is attached as Exhibit I.  Immunity is proposed
only for the direct acts of (a) registering and (b) not revoking domain
names.  All other acts of negligence or malfeasance would, of course,
subject the registry to suit.  We request that the IAHC adopt the language
and intent of this proposal in its next draft as an option for registries.
In our discussion with clerks and judges, we believe that the consensus of
the Internet community that such registries should be protected, like the
printer, as "innocent infringers" would be adopted and followed by courts. 
This immunity would greatly reduce the operating costs of a registry, and
therefore, make it cost-effective for certain registries to devote
themselves to better organizing political, community and personal domain
names space.  As a matter of policy, we ask that the registries who
undertake to manage the proposed .POL political speech, .LIB and .SCH
educational speech and .PERS personal be required to choose the
non-mediation, immunity path.  Similarly, we would expect that .TM spaces
will be assigned only to registries in the former, moderated category which
agree to publish notices, monitor and protect the domain name space. 
We note in passing that the random number alternative may well be a viable
option for a registry to undertake by choice.  As an option for all
non-trademark owners or for all who seek to avoid conflict with trademark
owners, it is neither realistic nor practical.  We do not assign random
numbers to children’s sports teams to avoid their use of a animal
trademarked to a professional sports team.  Similarly, random numbers will
not solve the commercial/ noncommercial allocation concerns discussed above.
   
V. 	ADVANTAGES OF THE DNRC VISION FOR THE INTERNET
The recommendations included in these comments will provide numerous
advantages that further the goals set out by the IAHC:
• Much better organization of Internet space.  Not only will trademark
owners have their space, but other worthy groups will be able to assemble
with like-minded domain name owners;

• The voluntary separation of Internet space will protect trademark owners
by giving them less Internet territory to patrol.  One of the criticisms of
the IAHC draft from the community of trademark attorneys is that it would
make life worse, not better for trademark owners in cyberspace: 

Of the six attorneys interviewed for this article, most said that such
measures [IAHC proposals] ... would likely make matters worse. For one
thing, under the proposal, companies with exclusive rights to a name would
have to police more Internet real estate to ensure that no one infringes
their trademark.  Legal Times, Week of January 6, 1997, p. 2.

The DNRC proposal will introduce areas in which trademark owners need not
patrol.  Thus, according to our discussions with judges and their clerks,
JANEMCDONALDS23145.PERS would no more need to be policed by McDonalds than
in a physical space where Jane might post her name outside her house.  

• The protections of a robust communications and free speech system will be
maintained.  In its decision setting aside the Communications Decency Act,
the three-judge panel in Philadelphia explained that "As the most
participatory form of mass speech yet developed, the Internet deserves the
highest protection from government intrusion. ACLU v. Reno, 929 F. Supp. 824
at 883.  Commercial speech is much more easily regulated, as broadcasters,
cable operators and those who seek to advertise liquor and cigarettes over
these communications mediums can attest.  For those seeking to keep the
Internet free from government regulation, we believe that it is the
noncommercial speech that continues to make the strongest argument for the
"hands-off" approach by governments.


VI.	DNRC RESERVES THE RIGHT TO RESPOND TO THE JANUARY 31 RECOMMENDATIONS

According to Section 1.2 of the IAHC draft, the IAHC will be reviewing
comments and compiling a final version of its recommendations for
distribution on or before January 31, 1997.  Given the robust dialogue and
debate of the discussion group and numerous revisions requested in these and
other formal comments, the DNRC expects that the final version may well
contain significant new information.  In keeping with standard
administrative procedures, DNRC reserves a period of fifteen days in which
to review and comment on this new information.  We recommend that all
participants be accorded such an option, even at the cost of a slight
rollback of the schedule. 
 VII.	CONCLUSION
Internet space must reflect physical space, not just for trademark owners,
but for all major communities.  Only careful crafting of the new domain name
spaces for public and private purposes and carefully-constructed competition
between registries will encourage people to explore the Internet, protect
them as they venture into unknown space, and ensure a brand name and
identifiable Internet service as an entrepreneurial registry.  
We urge redrafting of sections of the IAHC recommendations in accordance
with the goals, recommendations, and comments set out above.

Respectfully submitted:
DOMAIN NAME RIGHTS COALITION

By:_______________________
Kathryn A. Kleiman, Esq., General Counsel

/s/ Michael T. Doughney             
Michael T. Doughney, Executive Director

/s/ Harold Feld                            
Harold Feld, Esquire

/s/ Robert Cannon                         
Robert Cannon, Esquire					
FLETCHER, HEALD & HILDRETH, P.L.C.
1300 North 17th Street, 11th Floor
Rosslyn, Virginia 22209
(703) 812-0424

January 17, 1997
DNRCcomments