From:	James Cullis 
Sent:	Thursday, 28 May 2015 1:43 PM
To:	jo.lim@auda.org.au
Subject:	2015 Names Policy Panel Issues Paper

Jo Lim, Chief Operations and Policy Officer, auDA 
email: jo.lim@auda.org.au fax: 03 8341 4112 

Dear Jo Lim, 

I, James Cullis, would like to make the following submission in response to the 2015 Names 
Policy Panel Issues Paper that was recently published for public review and comment. 

1)	Direct Registrations in .au 
There is clear demand for domain name policy that simplifies the .au space, increases choice for 
registrants and ensures the continuing relevance of the .au brand in a market flooded by new 
generic Top Level Domains. Now is the time to commit to the introduction of registrations in the 
second level (i.e anything.au). 

Other markets such as .uk and .nz have successfully enacted this change and provide compelling 
case studies for us to follow. There is too much poorly understood policy in the existing open .au 
domain spaces. New registrations should not be burdened by the same degree of red tape. New 
registrations in the second level must be open to anybody with an Australian postal address. 

The implementation process should be a separate project. It should involve a brief sunrise period 
to protect the rights of genuine, existing trademark holders. After the sunrise, the space should be 
opened to the public through a land rush process that allows for domains to be registered on a 
"first come, first served" basis. 

2)	Existing 2LD eligibility and allocation policy rules 
a.	The restriction of license periods to exactly 2 years is an administrative burden which 
limits choice. It serves no public benefit in a highly competitive market and should be 
immediately removed to allow for license periods of 1 to 10 years. 

b.	The principles of "first come, first served" need to be retained. Further, auDA should 
engage in a process of ongoing public education that reinforces this message.


c.	It is confusing to have different domain spaces with identical sets of policy rules (e.g.: 
.com.au/.net.au and .org.au/.asn.au). This should be used as an opportunity to streamline policy 
within existing spaces, making it accessible to the wide community of users. 

The rules for .net.au and .asn.au should be removed so that both become open spaces for all 
Australians. Restrictions should also be removed from use of id.au.

d.	The "close and substantial" rule appears to be working as is. 

3)	Other 2LD policy rules (reserved list and misspellings) 
The existing policies on the reserved names and misspellings are suitable as is. However, 
domains on the list should be not able to be registered at the Registry. They should show up as 
unavailable in a domain search. 

Sincerely,
James Cullis (Owner) @ Interactive Projects