Hello All,

I support sensible debate on this mailing list versus personal attacks, or
commercially motivated attacks.

The following is a response to Larry Bloch's statements on ".au.com".

> 
> NetRegistry promoted .au.com as a viable alternative to 
> .com.au at a time
> when it took 10 days to register a .com.au. It also exploited the
> difficulties in obtaining a generic or arbitrary name in .com.au - a
> situation that remains the case today. 

I think that is a fair statement.  There is nothing wrong with operating a
private registry within the domain name space.  ".au.com" provides the basic
service of converting a text identifier into a physical Internet address.
It effectively competes against ".com.au" based on providing a more relaxed
policy for registration.  It is supported as part of the authoritative root,
and does not require changes in configuration of an individual's or ISP's
DNS software (as the alternate root approaches require).   In fact there are
private companies that operate country code registries (e.g ".cc", ".tv")
with a similar objective to provide an alternative to ".com", and the
restrictions on major country code registries such as ".au", ".uk" etc.
Other private companies have also done the same with other country codes
within the ".com" domain name space, e.g ".uk.com" etc.  So in other words,
a domain name in ".au.com" works in the same way as a domain name in
".com.au", ".com", ".cc" etc.

The policies for ".com.au" in contrast are now set by an Australian self
regulatory body (auDA), although they were originally set by one individual
(Mr Robert Elz).

Problems can arise in confusion between two domains that may look very
similar e.g
wxyz.au.com and wxyz.com.au.  A company registering in ".au.com" may believe
that they have registered in ".com.au", and a user trying to find a company
"wxyz" in ".au.com" may inadvertently type wxyz.com.au.  The converse also
applies.  This can also give rise to security problems.

The Names Panel ( http://www.auda.org.au/panel/name/papers/finalreport.html)
considered this issue and made the following recommendation for domains
within ".au":

**************

" 3.6 Domain names that match TLDs 

Recommendation: 
Domain names that match TLDs are not allowed. 

The Panel notes RFC 1535, which points out that domain names with two alpha
characters (eg. au.com.au) could 'trick' some types of client software,
thereby giving rise to possible security problems where the domain name is
the same as a ccTLD. Potentially, a domain name that is the same as a gTLD
(eg. com.net.au) could be misused in the same manner. The Panel therefore
recommends a prohibition on domain names that match TLDs. 


The Panel suggests that domain name licence applicants should be advised
that if they license a domain name that is subsequently allocated as a TLD,
then the licence may be revoked."

**********

At the recent ICANN meeting in Montevideo
(http://www.icann.org/minutes/prelim-report-10sep01.htm), this issue was
also considered with regard to registering names in ".info". 

The Government Advisory Committee to ICANN stated:
" ICANN's Governmental Advisory Committee (GAC) has concluded that "the
issue of geographical and geopolitical names is very complex, and the
subject of ongoing international discussion," and has stated its belief that
these issues are particularly important in the context of the new Top Level
Domain .info considering its "special nature";

.., the GAC has therefore suggested that "interim ad hoc measures should be
taken by ICANN and the Registries to prevent avoidable conflicts in .info";"


As an outcome, ICANN has temporarily stopped the registration of names such
as ".au.info" until the matter can be considered further. 

I stress that there is no right or wrong answer to this issue, it is merely
a matter of the community deciding collectively what they want to occur.  In
the case of ".com", the lack of any restrictions or discussions on this
issue, means that ".au.com" is quite legitimate.  

It is a matter of general consumer education to inform consumers that
".com.au" and ".au.com" are separate registries, and that ".au.com" is a
private registry operated with no outside regulation, and ".com.au" is
regulated by auDA with the oversight of the Australian Government (note
http://www.icann.org/cctlds/au-proposed-sponsorship-agmt-04sep01.htm clause
1.10: auDA and ICANN desire for the Government of Australia to assume
responsibility for overseeing the interest of Australia and its Internet
community in the .au top-level domain, with ICANN continuing its role of
preserving the technical stability and operation of the DNS and Internet in
the interest of the global Internet community. To implement an allocation of
the respective responsibilities of the Government of Australia and ICANN
with respect to the .au top-level domain on that basis, auDA and ICANN now
enter into this Agreement to formally reflect their commitments to one
another.).



> You may recall that 
> shortly after we
> introduced .au.com the time it took to register a .com.au 
> dropped from 10 to
> 2 days. There is no doubt that this was a competitive response from a
> monopoly when threatened. 

Well I certainly doubt this.  I understand that Robert Elz delegated the
administration of ".com.au" to Melbourne IT as a response to complaints from
the business community (as represented in an article in the Financial
Review) on the time taken to register a domain.  Melbourne IT then
instituted a service level agreement for a 2 day turn around, with a fast
turn around available at a higher fee.

With regard to a monopoly, the operation of a domain name "registry" is a
natural monopoly.
Netregistry with ".au.com" is as much a monopoly (if not more) than
Melbourne IT is with the registry functions it provides for ".com.au" (note
The University of Melbourne/Robert Elz, and auDA also provide part of the
registry services).  Under the new competition model
(http://www.auda.org.au/panel/competition/papers/finalreport.html) the ".au"
registry and second level registries (".com.au", ".net.au", etc) will be put
out to tender.  This approach is based on the theory of using competition
during the registry bid process to ensure that the price of registry
services is as low as possible.  The alternative approach used in the case
of the monopoly services operated by Telstra, is for the Government to
regulate the prices of monopoly services.

> So there has been good for .au from 
> .au.com. Far
> from scrapping .com.au, NetRegistry's business is to a large 
> degree based on
> .com.au - we are one of INA's biggest customers.

Agreed.  The webpage
http://www.netregistry.com.au/domain/what_different.html even lists
".com.au" first :-)

> 
> And I do blame a culture that questions my companies motives. 
> Why should
> those motives be questioned? We, like most companies, are not 
> in business to
> take unfair advantage of anyone. We're here to try and make 
> an honest buck.
> To serve our customers and to do our best to be professional, 
> accountable
> and above all conduct ourselves with integrity and honesty. 
> This is the new
> business paradim, as far as I am concerned, and it is the 
> backdrop for the
> overwhelming antipathy towards companies like ING.

Glad to hear it.   This business paradigm is not new though :-)

> 
> We are not a well funded, global corporation looking to squeeze small
> players out. We are a small, unfunded, startup company that 
> has struggled
> our way through the tech wreck like all of you here. 

Agreed, Melbourne IT is a similar company in that regard.  The float of the
company was not a capital raising exercise, it was a privatisation of the
company in the same way that the Federal Government privatised part of
Telstra.

> I'd like 
> forums like
> this to be about cooperating with like minded players; not 
> use it as a forum
> to snipe at each other. Is that what the Internet and forums 
> like tihs are
> all about? Taking pot shots? Frankly, its more than a little 
> pathetic. There
> is much more to be achieved than that.

Agreed.  I also seek cooperation and the public discussion of major issues.

> 
> Why are we not addressing ING in a way that strives for 
> resolution? Why are
> we still mistrustful of auDA, when it is clearly the path 
> forward with no
> alternative (like it or not)? Come on everyone, we can actually make a
> difference if we can overcome this useless mud slinging.


> 
> As far as auDA is concerned, I have been far from a friend in 
> times past.
> But the point is that like it or not, it is going to be the de facto
> regulatory body. You won't make it go away by sniping, nor 
> will you change
> decisions by commenting after a process that was open to public
> consultation. ts precisely this sort of wasteful behavious 
> that retards
> progress. If you are interested, get involved in the process 
> - its the only
> way to have your voice heard and considered at this point.
> 

Agreed.  Melbourne IT is also a supporter of auDA, and in particular
commends the successful operation of the Names Panel and Competition Panel
Advisory committees.  It seeks to cooperate with auDA, NOIE, and the the
rest of the industry and consumers to ensure that the best result is
achieved for the ".au" domain space.  We also seek to ensure that all major
decisions are made in an open, transparent and consultative manner.

> My approach to DNS reform in Australia has always been to 
> strive to ensure
> that there is a level playing field, that the registry is run 
> as a not for
> profit entity and/or with strict regulatory control over 
> price fixing. I
> have advocated equal access to the registry for all players - 
> small and
> large - along the lines of hte UK system (where domain names 
> cost a fifth of
> what they cost here and get registered in seconds upon application).

Melbourne IT currently provides equal access to its ".com.au" registry
function for all domain name retailers at a wholesale price.  It also
supports the principle of equal access going forward into the future as
described in the competition panel report.

> 
> I do not stand for complicated accreditation regimes to allow 
> access to the
> registry. Registering a omain name is a simple activity and 
> the competitive
> nature of the market ensures in the UK and elsewhere that 
> little advantage
> can be gained by being able to apply for and register a name - so why
> restrict or overly accredit access?
> 

Well it seems to me that there has been a strong call for better regulation
of ".com.au" retailers through the licensing of some retailers as "auDA
accredited registrars" through the signing of an licence agreement as
discussed in section 2.4.5 of the competition panel report (which should be
available for public consultation).
I understand that the licence agreement will incorporate code of conduct
provisions as discussed in the competition panel report (section 2.4.10)
(again I hope the code of conduct will be available for public
consultation).  The accredited registrars will also be responsible for any
domain name retailers that use their service (ie a registrar could lose
accreditation to communicate directly to the registry if its resellers cause
their accreditation agreement to be violated).

 > As for AU.COM, the reality is that if you don't like it, 
> don't buy it. I
> fail to see why it should be so threatening. Its certainly 
> hardly a plot to
> subvert .au or .com.au  - that really is just flattery.

Yes - it is a consumer choice issue.  The challenge for the industry is to
ensure that consumers are adequately informed.

Regards,
Bruce Tonkin

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