INTERNET DRAFT Stephen J. Page U.S. Data Highway Corp. January 1996 Expires: July 1997 draft-iahc-page-cogn-arch-00.txt Author: Stephen J. Page, c/o usdh@mail.ccnet.com Comments on IAHC Draft of December 19, 1996 Proposal for User-Centered Top Level Domain Structure Status of this Memo This document is an Internet-Draft. Internet-Drafts are working documents of the Internet Engineering Task Force (IETF), its areas, and its working groups. Note that other groups may also distribute working documents as Internet-Drafts. Internet-Drafts are draft documents valid for a maximum of six months. Internet-Drafts may be updated, replaced, or obsoleted by other documents at any time. It is not appropriate to use Internet- Drafts as reference material or to cite them other than as a working draft or work in progress. 0. Abstract This document comments on policies and procedures to allow open competition in domain name registration in the gTLDs which are described in a document entitled "Draft Specifications for Administration and Management of gTLDs", written and released by the IAHC on December 19, 1996 for public review to take place until January 17, 1997. Subjects addressed are: o inclusivity of IAHC and limitations of its public policy direction o def: "open and public", "service to the public", "openly balanced" o definitions of "stakeholders" o value of "generic" gTLDs and relationship to economic laws o the value of today's address structure (.xxx, .xxxx, .xxxxx...) o a proposal for implementing a cognitively-derived network architecture based upon principles of cognitive perception and language common to all human beings, regardless of geography; o ambiguities in some parts of the IAHC text; o the need for newly created gTLDs to be widely accepted o the introduction of a 60-day publication period to SLD registration Since this document comments on another published document, its style will be kept short and to the point and will therefore not follow the strict formatting of an Internet draft or an RFC. It is assumed that all terms used within this document have been defined or otherwise described in the original IAHC document. Also, since we have never submitted an RFC and feel that due to the imposed deadline that the content is most important to view publicly, we apologize for any straying from what is considered usual and customary for submissions. 1. Introduction On December 19, 1996, the IAHC released a draft document describing specifications for the Administration and Management of gTLDs. The document is valid for public review and comment until January 17, 1997. The IAHC will then take note of the suggestions made by the public and publish a finalised document on January 31, 1997 or by February 3, 1997 (I have heard both dates.) While most of the draft document released by the IAHC is very well written, there are comments which I would like to make regarding its conclusions. Secondly, the document leaves it until later to name the new gTLD(s) which will be created. Recommendations about producing truly internationally-accepted gTLDs should be included in the document. Furthermore, a controversial 60-day publication period in SLD registration processes may well change the way the Internet works to such an extent that it will change its growth. Each point will be addressed in a separate sub-section of this document. 2. Comments about the IAHC draft document 2.1 Omissions within IAHC draft o Quoting from 1. Introduction: "This proposal represents the preliminary recommendation of a committee formed to resolve a difficult and long-standing set of challenges in the Domain Name System, namely enhancing its use while attempting to juggle such concerns as administrative fairness, operational robustness, and protection of intellectual property." Comments: The Committee's membership is comprised of the following organizations (taken from www.iahc.org): ISOC, IANA, IAB, FNC, ITU, INTA, WIPO. The IAHC states in its Draft Executive Summary that it "International TLD space is a public policy issue and should be carried out in an open and public manner in the interests and service to the public." The represented members (listed above) can be categorized as representing constituencies which are at two extremes, either narrow in scope, sharply focused on operational issues (engineering) or very broadly focused, complex organizational decision making and policy arbitrating bodies (bureaucracies). ISOC (engineering) IANA (engineering) IAB (engineering) FNC (bureucratic) ITU (bureaucratic) INTA (bureacratic) WIPO (bureacratic) Nowhere does it seem that there are representatives of the constituency of "users" which is presumably the targeted group of the IAHC's mission "to carry out in open and public manner in the interests and service to the public." Is this an oversight? I would suggest that such an omission should and must be corrected prior to moving forward if nothing more than merely abiding by its Charter. Anything short of "openness" of back room decision making by such a limited organization is contrary to the goal of "resolving a difficult and long-standing set of challenges in the Domain Name System, namely enhancing its use" because it is precisely the users who have the most to lose (or gain) from their inclusion/exclusion. What I propose is that more time be applied to the "process" of decision-making so that the decision can create a truly "facilitative" TLD "network architecture" which brings as much value as possible to as many people as possible. In order to accomplish this goal, I propose: o. a delay in the decision-making process until inclusion of the following human-focused constituencies is made: - neuro-linguist trained in cognition & interface design - visual specialist for determining effect of new gTLDs on user acceptance of gTLD - representative of businesses which will be the primary payer for gTLDs - consumer advocate to speak for the "users" affected by IAHC' decisions Until these constituencies are represented, any solution will risk being unacceptable (in the worst case) or less than maximally acceptable (in the best case), because the human brain's evolutionarily perfected neurological network architecture is the common denominator which links all users worldwide to the process of communicating via the internet by the cognitively associative process which begins in the human brain's visual-processing organ, the eye. At that point, begins the process of integration of visual imagery (symbols and words which have evolved over thousands of years) with the invisible, and therefore illogical (the human brains see no assocations), and seemingly arbitrary structure of the Domain Name System. "The explosive commercialization" which IAHC decribed in 1.1 is a direct result of the increase in the usability of tools which made previously difficult techical hurdles more simple, while increasing the visibility of the content material to be communicated and the ease-of-use of the tools (browsers). Without expert knowledge represented by people who have studied language, visual perception, and/or cognitive processes, the IAHC's process is significantly flawed from the start. As a former principal investigator of an DARPA-funded small business Network Architecture project, who happens to be trained in visual perception, and cognitive information processing, it is clear that what is missing in the IAHC approach is a user-focused or user-centric approach, which is ironic because the users are the future customers of the Registries. If true "service to the public" is what is being pursued, then focusing on the common Network Architecture of the users' brain (which governs ultimate user acceptance of the Domain Name System) must be central to the IAHC's process. 3.0 Resultant Structural Changes Due to Omission o The logical structure of the addressing system as defined by Postel's IANA Proposal for creating competition among a number of registries includes the naming structure: .x, .xx, .xxx, .xxxx, and .xxxxx. This naming structure was created by someone's brain, an engineer who was functioning as a technical network architect. Therefore, the logic was derived from a source (the brain) in response to a technical problem (how do I create a logical structure for naming things.) This problem occurred back in the late 1960's when the defense department wanted to develop a system which enabled users to communicate and send data more quickly, easily, and efficiently across distances. "IAHC considers DNS as comprising three types of top-level domain names." (National, International, Generic.) Comments: How is this derived from the logical structure of the Network Architecture's design? From a cognitive network architectural perspective, there exists a structure which supports five-types of top-level domain names. The structure already exists, it was created by the creative minds of a team of engineers in the Dept. of Defense and BBN in the 1960s. I propose that this structure be leveraged and used, because its logic is sound, it has demonstrated its usefulness and robustness for a rapidly expanding community of users. The only thing that remains is to implement a name structure in a manner which "facilitates" maximum benefit for the maximum number of users. o Linking IAHC's Three Types of top-level domain names to the engineering structure: From Section 2. of the IAHC Draft " Nature of TLDs": .x (unused) .xx (National) .xxx (Generic Domains and .int "International Domain") .xxxx (Generic Domains) .xxxxx (Generic Domains) Comments: However, as I have stated before, there is a missing component of the entire process, which focuses on the human being, specifically which omits the network architectural value of the existing network architecture called our "brain". This omission, if remedied, can be linked into the existing engineering structure in the following manner, with little disruption to the system. .x (User-centric orgs, which incorporate value, innovation) .xx (International, ISOC/IAHC organizations, "serving the public") .xxx (National ISO 3166 country code-related organizations) .xxxx (Generic Domains) .xxxxx (Generic Domains) This structure recognizes the omission of the User or Human Being from the equation and remedies the omission by structurally implementing the phrase "service to the public" as the highest purpose and goal of the internet community's leadership by implementing a domain naming system which is structured around the principles of continuously adding innovation, and therefore on-going value to all users, everywhere. o Excerpted from IAHC Draft "It is noted that competitive shared access to any domain registry is a useful market control mechanism to reduce the risk of monopolistic trading practices" Comments: The terms "competitive" and "shared" when used to describe the same process make no economic sense in the world of reality which affects human beings or users. Economics is driven by the laws of supply (scarcity) and demand. The word "competitive" implies that there is a particular economic state of being where innovations can be protected by creators, innovators and risk takers for maximizing the value to accepting customers and therefore maximizing the return to the risk takers who supported the entrepreneur to pay returns to their investors and creditors. The word "shared" implies "cooperation" which is a different economic state of being than "competitive". Having experience in the process of building "administrative cooperation while maintaining marketplace competition" the rationale behind applying the continuous engines of innovation and human self-organization to economics shall be represented in the proposed Domain Name System as: .x (User-centric organizations, which incorporate value, innovation) (Intellectual Property-related, which is protectable, therefore subject to the laws of scarcity and demand and therefore "competitive") .xx (International, ISOC/IAHC organizations, "serving the public") (Administratively Cooperative, sharing expenses, therefore "shared") .xxx (National ISO 3166 country code-related organizations) (Administratively Cooperative and Marketplace Competition) .xxxx (Generic Domains) (Administratively Cooperative and Marketplace Competition) .xxxxx (Generic Domains) (Administratively Cooperative and Marketplace Competition) o Excerpted from 3.2 Which gTLDs to Create, "These new gTLD's will consist of letter strings of three-to-five letters each...the gTLD shall suggest a connection with the Internet, with business or with personal uses." Comments: Based upon our discussion above, we propose a naming structure which opens the structure of naming from one-to-five letters each. Based upon our discussion above, we propose that openness to "User" groups be allowed prior to any decision-making occurs. o Excerpted from IAHC's Draft, 4.2 Choosing gTLD Registrars, "The selection of registries in a region will be by lottery among qualified applicants." Comments: The lottery process removes all incentive for assuming risk, planning ahead, and investing in improvements under the guise of fairness, because the "luck of the draw" can usurp all planning, foresight, and value-creating. The systems users lose under this plan because innovation is squelched. We propose a system which intellectual property is allowed to flourish, which enables the creative sparks to continually improve and make the system more beneficial for users. Anything short of allowing free market principles to flourish restrains competition. (the top level.) o 4.2. "Each application must be accompanied by a $20,000 fee. This fee will be refundable in the event that an applicant is found to be not qualified." Comments: This fee serves as a barrier for innovators and investors, and should be removed. An application fee which recognizes inclusivity and openness, rather than exclusivity, should be implemented. $1000 is recommended. ($20,000 is the same order of magnitude which CommerceNet implemented when it began to commercialize the Internet in 1993, only to be trumped by a competitor which gave away browsers, now known as Netscape.) 4. Included Comments from Others Excerpting from the Comments from Global Information Highway Ltd: 3.1 Ambiguities within IAHC draft o Quoting from Section 3.1, paragraph 2 of the IAHC draft: "Equally there is a body of opinion which suggests that there is a need to create alternative entry points into the DNS within the gTLD space. The basis for this view includes the observation that creation of such additional gTLDs would allow a form of natural competition with existing gTLDs, creating alternate entry points for access to the gTLD domain space, and that such natural forms of competition will assist in preventing the operators of any particular gTLD from assuming the role of a monopoly provider with the associated inherent risks of monopoly-based market trading practices." Clearly the mentioning of the operator of any particular gTLD assuming a role of a monopoly provier does not stand since later on the the document, recommendations are to have multiple operators for every gTLD including the current gTLDs: (Section 3.1, paragraph 6) "In addition IAHC has decided to ensure that the new gTLDs are all to be operated in a shared fashion across a number of domain operators. [...] " Furthermore, it is not clear why more than one entry point in the gTLD space will promote competitivity if all gTLDs are shared anyway. The only reason for having multiple entry points to the gTLD space looks to be the creation of more "space" for SLD names which are similar. This solution does not address the reaction of an SLD owner which will find that the same SLD was allocated to someone else under another gTLD, especially if the original SLD owner holds a trademark on the SLD itself. o Quoting from Section 3.3 of the IAHC draft: "The IAHC recommends that all existing gTLDs be shared in the same fashion as mentioned in section 0." Section 0 does not exist. o Quoting from Section 4.1, paragraph 6 of the IAHC draft: "Oversight responsibility for a registry rests with a STEWARD. If the registry is a monopoly, the steward, the registrar, and the operator of the repository are typically one in the same. [...]" Since is has been widely mentioned that no monopoly will exist in respect to any gTLD registration operation, this paragraph is redundant. If this is not the intended subject, then this paragraph is ambiguous. o Quoting from Section 6.1, paragraph 5 of the IAHC draft: "Addition of .tm. IAHC recommends that the functional name .tm., or a local language equivalent thereof, be added to the functional name set documented in section 6.1.1 of this document, above, as described more fully in section 0 of this document (see below)." Section 6.1.1 and Section 0 do not exist. o Quoting from Section 6.1, paragraph 7 of the IAHC draft: "IAHC notes that the implication of the recommendation in section 0 is that there will be a consequent market demand for domain names which are available within a more rapid period than 60 days. [...]" Section 0 does not exist. 3.2 International dimension of gTLDs While the IAHC document goes to great lengths to mention that gTLDs are not regarded as being truly international in nature, the gTLDs are used internationally. In Section 3.2 of the IAHC draft, paragraph 2: "These new gTLD's will consist of letter strings of three to five letters each. IAHC has also decided that each gTLD should have general, contextual meaning, i.e. the gTLD should suggest a connection with the Internet, with business or with personal uses." Clearly at this point, the international use of gTLDs should be mentioned, and the contextual meaning should not be restricted to the English language. The paragraph would be benefit from being written as: "These new gTLDs will consist of letter strings of three to five letters each. IAHC has also decided that each gTLD should have general, contextual, or widely accepted meaning, i.e. the gTLD should suggest a connection with the Internet, with business or with personal uses and be already widely accepted by non-english speaking users of the Internet." 3.3 SLD 60-day publication period This section relates to paragraph 7 of Section 5.4 of the IAHC draft. "In light of the legitimate interests of domain name holders and trademark owners, and in the overall interests of consistency and fair play, IAHC strongly believes all gTLD registries and ISO country code registries should, therefore, publish applications for SLDs, for a period of sixty (60) days prior to assigning the requested SLD to the applicant. Such publication should take place on a publicly available, publicized web site and include the SLD and the contact and use information contained in the application (see Appendix A)." The purpose of the above procedure is to compress the vulnerability of a domain name by ensuring any objection to the domain name is filed within the first 60 days of publication of the name. A trademark owner would theoretically have a harder time reclaiming a domain name after the 60-day publication period expires. However, it is worth considering that: o Until the first court case of a domain dispute where the domain has gone through the 60-day approval/publishing process takes place, the idea that domain names are going to be safer from dispute, and that this will make the Internet domain naming more stable is speculative. o The 60 day waiting period will slow-down business on the internet. It will put a strain on startups both in the connectivity business and Web design business. An Internet year is widely recognised as being 3 months long and 60 days is 2/3 of an Internet year. o Publication of a domain name for 60 days prior to its use is detrimental to open competition in some cases, by taking away the element of surprise for a project to be made public. o The prevention of domain hoarding by "extortionists" as described by the IAHC document (Section 5.4, paragraph 4) will be replaced by a trade in readily-available "off the shelf" SLDs which have already gone through the 60-day approval period. This clearly opens the door to the same extortionists described in the IAHC document. In view of the above facts, it is suggested that the 60-day publication period is made optional. In most cases registered SLDs do not require a safety net due to their specific nature. It should be up to the domain applicant to choose whether a 60-day publication period is suitable for their purposes. The market will decide by itself which option is more commonly used. Any compulsory 60-day publication period is more detrimental to the Internet community as a whole than its potential benefits. 3.4 Addition of .nui. This section relates to paragraph 7 of Section 6.1 of the IAHC draft: "IAHC notes that the implication of the recommendation in section 0 is that there will be a consequent market demand for domain names which are available within a more rapid period than 60 days. IAHC recommends that the administrators of ISO3166 name spaces consider the addition of a functional name space, proposed to be a network user identifier: .nui." . The characteristic of this space is that it would be filled by randomly generated, meaningless alphanumeric strings, available within a short period after application, in order to provide an alternative mechanism to the process of obtaining a specified name which may include a 60 day notification period." While it is correct that there will be a market demand for domain names which are available within a more rapid period than 60 days, the implementation of a 60-day "optional" period as described in section 2.3 of our document will solve this problem. Furthermore, the above acronym "nui" is unknown to the Internet community at present, and a string of "meaningless alphanumeric strings" is little more helpful than the use of native IP addresses of the type xxx.xxx.xxx.xxx. The use of the meaningless native IP addresses will be more easily acceptable since meaningless numbers are already used in telephony. The addition of an "nui." domain will only serve to complicate processes in respect to SLD allocation and administration. 3.5 Lifting of special criteria of .org and .net Quoting from Section 2.3, paragraph 3 of the IAHC draft: "Recognizing the de facto present situation, IAHC recommends that the existing special criteria should be lifted from .org and .net and they should be considered to be gTLDs." The special criteria is not mentioned. It is assumed that this is: (RFC1591) "NET is for the internal infrastructure of service providers, and ORG is for miscellaneous organizations (e.g., non-profit corporations, and clubs)." The lifting of this criteria is detrimental to the structure of the Internet since NET and ORG were meaningful acronyms. The creation of new gTLDs will in fact assist in clearing the current SLDs which are not strictly following this criteria from ORG and NET. Lifting the special criteria from ORG and NET may confuse those wanting to register new SLDs by making too many choices with no criteria available. 4. Main References IAHC, "Draft Specifications for Administration and Management of gTLDs" December 19, 1996. January 17, 1997 Comments from Global Information Highway Ltd. 5. Author's Address Stephen J. Page 1700 Stoneridge Mall Rd. Pleasanton, CA 94588 T. 510-227-1650 510-484-0448 usdh@mail.ccnet.com