From:	Michael Farrell
Sent:	Wednesday, 8 December 2010 3:44 AM
To:	lujia.chen@auda.org.au
Subject:	2010 Names Policy Panel review response

1A: I believe that the .au domain namespace should be for Australians first and foremost.  If a foreign 
entity wishes to register a domain, they should do so either under their own country's ccTLD, or under a 
global TLD such as .com.

Opening .au to everyone will simply pollute our ccTLD.


1B: Informal clubs should be continued to be able to register under within .org.au.  They are an 
organisation all the same as well, and should not be forced to go through formal registration where the 
only benefit is to be able to acquire a domain name.

The domain should be used for primarily non-commercial purposes.  Display of advertising on the site 
should not be restricted as some rely on it to offset the cost of running the website, but at the same 
time it should be not allowed if the site purely exists to display advertising and there is no actual 
content.

Informal clubs should only use .org.au.


1C: Policy enforcement in the .au domain space is poor.  As indicated, it has a large cost involved for 
anyone wishing to file a complaint about the use of a domain, and does nothing to address large scale 
abuse of the domain name system.  Such costs are not reasonable, particularly for small businesses and 
individuals.

It also allows groups to instead offer to sell or lease the domain at a lower (but still exorbitant) cost than 
the costs of filing a complaint.  Even though the practise in reality is entirely against regulation, there is 
little that someone can do about this.

There is currently no risk for someone to violate policies other than the loss of domain licensing fee for 
two years.  Spread out over thousands of domains, such a loss is a drop in the ocean.


1D: No comment.


1E: Registrants should not be allowed to lease their domain name to another entity.  They should be 
only available to registrants who hold a close and substantial connection with the domain name.

Allowing leasing of domain names will simply open the system to abuse as entities may purchase 
licenses for huge amounts of domain names and lease them at an increased cost to other businesses or 
individuals who want access to the name.

Additionally, such a system would make domains (and thus URIs) lose permanency.  As Tim Berners-Lee, 
inventor of the World Wide Web says, "Cool URIs don't change".


1F: Single character domain names should not be allowed.  It is also unlikely that a single letter will 
associate with a single brand for a majority of people, and only lead to confusion.


1G: No.  A person could set up the site as a subdomain of their own .id.au domain as an alternative.  For 
example, yachting.example.id.au.


1H: No.  The current 3LD structure keeps the .au domain space well organised.  Such a move will only 
obsolete existing 3LDs, and open up a new market of "renting" subdomains of official-sounding names 
like "example.co.au" and "example.biz.au" that aren't bound by any industry policies.


2: No comment.


3A:  Domain monetisation is the process of registering a domain with no clear connection to your own 
business, for the sole purpose of selling advertising to other businesses.

3B: Domain monetisation should not be allowed to continue.  Such registrations prevent legitimate 
businesses, organisations and individuals with a more substantial claim to the domain from registering 
the domain for themselves.

As an alternative, these companies may create directories of their own under their domain like 
"plumbers.example.com.au".  This establishes a clear and substantial claim for the company for their 
own domain, makes it very clear to visitors who is operating the website, and doesn't prevent 
businesses with a legitimate claim from registering a .com.au domain.

A company with a good business directory will quickly establish themselves as such, and become a first 
port-of-call for future queries.

3D: In order to defend against some actions, the complaint resolution process should be made easier 
and less costly, and the potential for fines should be leviable against those who make such bad faith 
registrations.

3E: Domain monetisation should be strictly prohibited in all .au domain spaces.


4: No comment.

Thanks for your request for comments.


~Michael Farrell