Sometimes thought-provoking, often self-serving, and occasionally downright wacky, the hundreds of public comments submitted over the past several weeks to the US Commerce Department on how to administer Internet domain names foreshadow unabated conflict over the most fundamental issues of running and expanding the system.
The summary statement that can be drawn from the 300-plus comments (drum roll, please): The current system needs to change.
Who should control registration when Network Solutions' contract with the National Science Foundation for administering generic top-level domains ends in March? How many new generic top-level domains should supplement the congested .com, .net, and .org domains? Who should mediate trademark disputes? Should the US government be involved? Ask 300 different people these questions, and chances are you'll get 300 different answers.
Jon Postel, director of the Internet Assigned Number Authority, which controls the number codes of Internet addresses and also administers the .us domain name, argued in his comments that 200 more generic top-level domains should be created, in addition to the 200-odd country codes now in existence. Postel said that 20 new gTLDs should be added initially, adding five more each year until the total reaches about 200.
"There are no technical issues that limit the number of gTLDs to less than a million," Postel wrote, though limiting the number to less than a million would "provide stability and minimize user confusion."
A proposal on the table by the now-disbanded International Ad Hoc Committee, which would create seven new generic domains such as .store and .firm, is criticized by some in the comments, and lauded by others.
America Online said in its comments that the system is "doomed to fail" because instead of creating a larger name space, it will prompt cross-registration among holders of valuable trademarks or brand names. The online giant instead suggests creating 42 new top-level domains that "match exactly the 42 international classes in which trademark owners can register their goods and services" to alleviate trademark disputes. In addition, AOL wants to set aside domain names for "global brand entities who wish to enhance and protect their global brands in cyberspace." For example, AOL would have permission to create .aol as its own domain.
Bell Atlantic, which like many of the Internet service providers submitting comments was most concerned about trademark disputes, disagreed with AOL's approach. It proposed setting up a global database against which name registrars would be required to check new registration requests. Armed with this tool, and with information from the US Patent and Trademark Office and similar agencies in other countries, requests for "confusingly similar" marks could be denied.
Bell Atlantic said such a regime could eliminate "cybersquatting" - the sometimes lucrative practice of taking advantage of the current first-come, first-served registration policy to grab names likely to be attractive to companies operating under the same name. Another anti-squatting measure Bell Atlantic proposes: setting name fees at a "significantly high enough level" to keep interlopers out of valuable space.
AT&T weighed in that trademark disputes can be resolved simply by making URLs more product-specific. For instance, two companies called Acme fighting over acme.com would share the name by adding the type of goods sold - as in acme-food.com and acme-toys.com.
That sounds reasonable enough. But listen to British Telecom and the Canadian Association of Internet Providers. Both said that the domain-name system is too US-centric - as the Canadians put it, "without regard to regional or national sensitivities."
The Asia and Pacific Internet Association holds up an example of such insensitivity. The designation of .kh as its national domain is an unpleasant reminder for many users there of the country's murderous Khmer Rouge regime.
"Domain names in one language can be very offensive in another," said the association, whose members include Telekom Malaysia, the Internet Association of Japan, and Cisco Systems of Singapore.
The Commerce Department also got suggestions about using top-level domains as a way of cordoning off pornography. British Telecom and others proposed setting up .xxx or .sex domain to make it clear what resides there.
"I don't mind xxx when I WANT xxx," said Brian Kitchen, a private individual whose email comments came from the cyberdude.com domain.
But perhaps the most detailed - and arguably radical - proposal came in a joint submission from trademark-focused Domain Name Rights Coalition and consumer-oriented NetAction. The groups suggested creating an Internet Council under the Commerce Department to administer name registration and domain caretaking. The council would be made up of individuals, businesses, ISPs, and other interested parties on the Net, and would act as an "advisory body" on domain-name protocols. In addition, generic top-level domains such as .pol for political speech, .pers for personal speech, and .sba for small businesses should be added to alleviate congestion on other gTLDs such as .com and .net.
Many submissions talked of the difficulty of managing such an unwieldy global system. But as one of the more philosophical commentators, Dennis Fazio of the Minnesota Regional Network, wrote: "Change is good for us. We should all seek any opportunity to change something in ourselves often."