Forwarding a message from Michael Malone:
>             Proposed Australian BIZ.AU Registry

Comments below...

> 
> Summary
> -------
> 
> It is proposed that a registry for BIZ.AU, intended for
> all Australian businesses, be established under the
> proposed guidelines of the DNS Summit.
> 
> Public comment is invited.
> 
> 
> Overview
> --------
> 
> This document proposes to produce a working model based
> on the DNS Summit document papers produced by Geoff
> Huston and Michael Malone. These papers are available at
> 
>         http://www.intiaa.asn.au/dns/
> 
> The new 2LD "BIZ.AU" will be established, and control
> will be vested jointly to
> 
> 	iiNet Technologies Pty Ltd (iiNet)
> 	Internode Systems Pty Ltd (Internode)
> 
> These two companies will establish competing registries
> offering registration and delegation services under the BIZ.AU
> domain name according to the attached policy document.
> 
> iiNet and Internode will be developing pricing models
> independently. True competition between the organisations
> may mean that their pricing models may or may not be similar.

As both of these organisations are active ISPs with presumably significant
requirement for registering commercial domain names, it seems to me that
there is a conflict of interest involved when each organisation needs to
register biz.au domain names for its own clients. I see the C.O.I. in two
areas: charging and application of rule policy. In the case of charging,
the cost to the organisation is the net cost of processing of each
registration, whereas the cost to everybody else is the gross cost, which
includes a profit margin. In case of application of rule policy, there is
the opportunity for each organisation to "relax" requirements for their
own customers.

I think a simple way around the C.O.I. problems is that each registry will
be obliged to submit applications "for their own clients" through the
registration process, and pay the charges of the _other_ registry.

> It is proposed that BIZ.AU be administered exclusively by
> Internode and iiNet for a period of eighteen months.

Does this mean then that Robert Elz will be (if he wants) the permanent
domain administrator, to delegate for 18 months according to the paragraph
above?

> In
> exchange, iiNet and Internode will agree to develop for
> the Internet community:
> 
> o Software to handle registrations via WWW forms; and
> o Software to handle redelegations automatically; and
> o Standards and software to handle merging of databases; and
> o Documentation of administration procedures.

Cool :-)

> In the event that iiNet becomes unable to manage registrations
> within BIZ.AU, Internode agrees to assume iiNet's BIZ.AU client
> base and existing contracts at no additional cost to clients,
> excepting that owed to iiNet.
> 
> In the event that Internode becomes unable to manage registrations
> within BIZ.AU, iiNet agrees to assume Internode's BIZ.AU client
> base and existing contracts at no additional cost to clients,
> excepting that owed to Internode.

And if they both suffer disaster, then...?

> Domain name allocation operates on a "first-in, first-served"
> basis.

Ok

> A) corporations registered under the Corporations Law, statutory
>    corporations, statutory authorities, incorporated associations;
>    and also independent businesses operating under registered business
>    names within one of these organisations, 

Ok

> B) partnerships and businesses trading under a registered business
>    name without an ACN, 

Ok. Is it necessary to mention the registered business number?

> C) any other legal entity which can show it is a trading commercial
>    organisation, such as a person trading under their own name.

Hmm - how can the registry verify the person is trading under their own
name? The id.au domain is for individuals.

> The information that these types of organisations must provide is:
> 
> i)   full registered name of the organisation
> ii)  a Postal address
> iii) either the ACN, or for organisations without an ACN, an
>      equivelant registration number (if available),

sp "equivalent"

> iv)  a Statement of the legal status of the organisation,
> 
> v)   in the case of an independent registered business operating
>      under a registered business name within a larger organisation,
>      the full registered business name, the business registration
>      number, and the State of business registration,
> 
> vi)  any information that confirms that the entity is a legal
>      commercial organisation or trading entity.
> 
> vii) the full name, email address, postal address and contact
>      telephone numbers for each of a technical contact, 
>      administrative contact, and a billing contact person,
> 
> 
> Modification to Details
> -----------------------
> 
> Each applicant will be provided with a pass phrase that will
> allow certain details, such as delegation details, to be modified
> without intervention. A copy of all such changes will be forwarded
> to each of the contacts by email

Ok

> The Domain Administrator or any one of the contacts will have
> the ability to stop such changes being committed. If there is
> no intervention, changes will actually occur a minimum of one
> full business day later.

This sounds like a service-level type guarantee which might differ
between the registries rather than a policy of the domain as a whole.

> Multiple Domain Names
> ---------------------
> 
> BIZ.AU has no restriction on the number of domain names held
> by a single organisation, provided that a reasonably apparent
> relationship between the trading name and each proposed domain
> name can be shown.
> 
> 
> Domain Name Rules
> -----------------
> 
> Any domain name is acceptable so long as it: 
> 
> 1) is unique within BIZ.AU (name uniqueness tests for BIZ.AU are
>    case insensitive), 
> 
> 2) is at least two characters long, 
> 
> 3) contains only alphanumeric characters and hyphens, and starts and
>    finishes with an alphanumeric, 
> 
> 4) is closely derived from either the legal name of the applicant
>    organisation, or has been registered as a business name
>    by an appropriate government authority in Australia. 
> 
>    For example, the full name, an acronym, a concatenation or
>    abbreviation,

Ok

> 5) is not a word defined to be vulgar in a standard Australian English
>    dictionary word,

check grammar

I have a problem with this rule. English has a plethora of vulgar words
which won't be found in any dictionary. Combinations and juxtaposition of
words can become vulgar.

Let's look at an example I read on USENET today: cumhard.com (yes, it really
exists!) ... "cumhard" won't be found in any dictionary, although "cum" may
be. Better to restate the rule as something like "vulgar words or
words with vulgar imputation will not be accepted".

Perhaps you should cut the rule entirely - vulgar is, after all, in the
eye of the beholder.

> 6) does not contravene any third party's rights to use of the name. 

You mean trademarks? How is the registry to tell?

> 7) is not reserved for future use (eg: the Australian state initials).

Is it possible to form a list of these reserved names? If not, how will
capricious denial be avoided? (say, somebody thinks up the coolest domain
name on earth, like "big.biz.au" and applies for it, and the registry
thinks "wow that's cool, why didn't we think of that? - let's deny it
under rule 7 and use it later)

> Warranties
> ----------
> 
> In administering BIZ.AU, reliance is placed on the information
> and warranties provided by the applicants. 
> 
> Applicants warrant that: 
> 
> 1) the information provided in the application is true and correct, and 
> 2) the name sought does not breach any third party's rights. 
> 
> It is an express condition of applications that applicants indemnify
> the DA to the full extent legally permitted against all claims
> and demands from third parties regarding registration and continued
> use of domain names. 
> 
> 
> 
> Acknowledgement of Rules
> ------------------------
> 
> Continuation with the registration process is an acknowledgement that
> the applicants have read and understood these rules and proceed expressly
> on the basis that the rules are legally binding on the applicants. 
> 
> 
> Licence Rules
> -------------
> 
> Registration constitutes a licence to use the domain name for a given
> period (two years for the initial registration), and annually or
> biennially renewable by paying the appropriate fee. 

Ok

> If the application for the domain name is accepted, but the delegation
> request submitted on the same form is unsuccessful, the licence for use
> of the domain name is retained. In such cases the delegation application
> must be resubmitted after isolating and correcting the configuration of
> name servers to be delegated according to the diagnostic information
> provided in the reply sent to the source contact. 
> 
> The licence is not transferable to another organisation. 

Ok

> The licence is revocable: 
> 
>      for failure to pay a proscribed fee, 
> 
>      for breach of applicant warranty, 
> 
>      for making an untrue or fraudulent statement in an application, 
> 
>      where a court of competent authority determines that the name
>      should not be allotted to the applicant or should be allotted
>      to another party, 
>      where the applicant ceases to exist, or when a business
>      registration that was used to obtain the licence is revoked
>      or lapses, 

Ok

>      where the applicant changes the organisation name, or 

I have a problem with this rule, since it is a denial of an existing
domain name. There might be significant reasons why a domain should
continue to be used (like, thousands of users' E-mail addreses, or the
business's clients know that domain name) even though the organisation,
for one reason or another, must change its organisation name.

>      under instruction by the applicant. 
> 
> If revoked the domain name will remain dormant for up to one month.
> Within this period, the original owner of that domain name can apply
> to have the domain name re registered. After the period has expired
> the domain name can be allocated to a third party. 

Ok

> 
> Dispute Resolution
> ------------------
> 
> Decisions on BIZ.AU domain name administration are made by the chosen
> registry. In case of a dispute the registry will comply with the
> determination of a dispute resolution process to which all parties
> agreed to be bound. 
> 
> In case of a dispute with the registry, the disputant(s) agrees to submit
> to, and be bound by, the dispute resolution process put in place. The
> dispute resolution process provides for mediation and resolution by
> an industry-accepted arbitral process. 
> 
> The chosen dispute resolution process is: 
> 
> i)   The originator of the dispute must notify the registry that there
>      is a dispute, 
> 
> ii)  The originator, the registry and any third party must attempt to
>      settle the dispute by negotiation and conciliation, and 
> 
> iii) If not settled by negotiation or conciliation any disputant may
>      refer the dispute to resolution by an expert appointed by the
>      Internet Society of Australia. All parties agree to be bound by
>      the ruling of the arbiter. 

Ok

> Rule Applicability
> ------------------
> 
> It is expected that BIZ.AU will be able to accept new registrations
> from 1 January, 1997. These rules will apply after 1 January, 1997.

Cool :-) Appreciate discussions on my suggestions above.

Nick.
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