OFFICE OF ADVOCACY
U.S. SMALL BUSINESS ADMINISTRATION
July 10, 2000
Sent via e-mail
Esther Dyson
Chairman
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way
Suite 330
Marina del Rey, California 90292
Re: Introduction of New gTLDs
Dear Ms. Dyson:
The Office of Advocacy, U.S. Small
Business Administration, thanks you for this opportunity to comment
on ICANN's consideration of expanding the domain name space by adding
new general Top Level Domains ("gTLDs"). Our positions are consistent
with our comments filed on January 10, 2000, April 4, 2000, and April
14, 2000. In short, they are.
(1) The need for new gTLDs is real and substantial.
There is a difference between technically feasible and commercially
viable domain names. While there are many technically feasible names
remaining in .com, names that have high numbers of characters are
not viable in a competitive marketplace.
(2) The introduction of new competitive gTLDs
is good for the Internet. It will encourage efficiency and innovation.
While there may be some consumer confusion at first, the new registries
will have sufficient incentive to raise consumer awareness.
(3) ICANN should maintain the stability of the
Internet throughout the introduction of new gTLDs.
(4) ICANN should expand the domain name space
in a measured and responsible fashion that is systematic and ultimately
limited by what the market can bear. ICANN should not place an arbitrary
limit on the total number but rather allow the number of applicants
or technical feasibility to do so.
(5) Advocacy supports the use of a test-bed of
a limited number of new gTLDs. However, that test-bed should be
large enough to provide ICANN with enough information to continue
the introduction of gTLDs after the test-bed is completed. Advocacy
supports Working Group C's determination that 6 to 10 new domains
are sufficient. In order to obtain the necessary variety, Advocacy
supports a number of test-bed gTLDs at the higher end of this range.
This will give ICANN experience in a variety of circumstances, including
domains that are designated using non-roman characters.
(6) For the test-bed to truly be a test, ICANN
must have a specific deadline to when the test-bed ends. That deadline
can be flexible as long as it is measurable and predictable.
(7) ICANN should commit to the continued introduction
of new gTLDs pass the test-bed. This commitment is necessary to
prevent speculation and other scarcity issues.
(8) ICANN should not act as a conduit, either
through its actions or through sanctioning private action, for the
expansion of trademark rights beyond those currently existing at
law
(9) ICANN should use as light a hand as possible
in overseeing the gTLDs. ICANN should insure the technical stability
of the Internet, while allowing the registries develop as they see
fit. The decision of whether to be open or chartered and how to
enforce that charter should be left up to the registry.
