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                            Before the
                  U.S. DEPARTMENT OF COMMERCE
    National Telecommunications and Information Administration
                       Washington, DC 20230

  In the Matter of                    )
  IMPROVEMENT OF TECHNICAL MANAGEMENT ) Docket No. 980212036-8036-01
                      Notice of Proposed Rulemaking

  Comments of Jay Fenello, Iperdome, Inc.
                                Jay Fenello,

                                Iperdome, Inc.
                                1150 Lake Hearn Dr., Suite 200
                                Atlanta, GA  30342
                                +1 404-250-3242

                                23 March 1998

Jay Fenello respectfully submits comments in this proceeding
published at 63 F.R. 8825 (No. 34, Feb. 20, 1998).

Jay Fenello is the President of Iperdome, Inc., a new company
offering Personal Domain Name services under the .per(sm)
name and Top Level Domain.  He has been active in the DNS
debate since Iperdome formed in January 1997.  He was . . .
  -  one of the founders of the eDNS movement.
  -  one of the first to ask for the U.S.
Government to review the activities of the IAHC.
  -  the only small company representative to attend
       the White House's IATF meeting on June 9th.
  -  one of the invited speakers at the Domain Name
Conference sponsored by the ITAA, CDT, and ISA.
  -  one of the first to frame this debate as
one of control, not domain names.

>I. Introduction

Although many do not yet realize the importance of these deliberations, the
Internet is about to undergo a birthing process.  When it is complete, we
will have established some ground rules for the newest human frontier.

Those who have ventured forth into the ether have found a new world -- one
of ideas, freedom, and commerce.  In fact, there is little that we do today
that we won't someday do on the Internet.  Things as common as working,
shopping, attending school, visiting friends and relatives, even traveling
will be available in our emerging cyber world.

What these deliberations are about is how we will get along in this cyber
world, who is in charge, and who gets to decide those questions that can
only have a single answer on the Internet.

Domain Names just happen to be one of those things.  To retain a single,
unified root, there must be a single decision making body.  The MOUvement
and the US Government both have very different solutions to this question.

The MOU puts a very small group of stakeholders in charge of these
decisions.  It features closed meetings and discussions, no due process,
has little if any representation, and is set up as a Swiss based cartel to
avoid anti-trust considerations.  It creates a highly controlled,
bureaucratically administered name space, instead of a free market approach
that has fueled much of the Internet's world wide growth.

In addition, the IAHC process broke long standing Internet traditions when
it discarded draft postel, and it ignored existing working code.  It also
included organizations like the ITU that were previously known to be
hostile to the private networks that make up the Internet.

Finally, the MOU goes to great lengths to define the name space as a public
trust.  This insidious designation has far reaching consequences that are
not obvious to the casual observer.  Primarily, this designation invites
governmental intervention from the likes of the ITU.  It is important to
note that, by definition, the name space is NOT a public trust.  Please see
the analysis as prepared by Open-RSC for more information on this topic:

In closing, we appreciate the efforts of the U.S. Government in the
preparation of the Green Paper and this proceeding.  Iperdome agrees with
most of the content of the Green Paper, and respectfully offers the
following suggestions for its improvement:

>IV. The Future Role of the U.S. Government in the DNS

>    This discussion draft, shaped by the public input described above,
>provides notice and seeks public comment on a proposal to improve the
>technical management of Internet names and addresses. It does not
>propose a monolithic structure for Internet governance. We doubt that
>the Internet should be governed by one plan or one body or even by a
>series of plans and bodies. Rather, we seek to create mechanisms to
>solve a few, primarily technical (albeit critical) questions about
>administration of Internet names and numbers.

While it would be extremely unpopular for the scope of this paper to
propose a monolithic structure for Internet governance, Internet governance
MUST be addressed here and now. 

As we have always suggested, the DNS situation must be resolved quickly but
Internet governance must be allowed to evolve over time.  That evolution
must be structured through this process.

For now is when the last vestiges of an authority on the Internet are to be
exercised in the formation of an independent organization.  Once complete,
that transfer will be almost impossible to undue, given the international
nature of the Internet and the lack of any jurisdictional precedents.

>V. Principles for a New System

In addition to the principles stated, we strongly support efforts that
limit oversight and regulation to the absolute minimum required to retain
stability in a fair and robust system.

>VI. The Proposal

>A. The Coordinated Functions

>    The U.S. government would gradually transfer existing IANA
>functions, the root system and the appropriate databases to this new
>not-for-profit corporation. This transition would commence as soon as
>possible, with operational responsibility moved to the new entity by
>September 30, 1998. The U.S. government would participate in policy
>oversight to assure stability until the new corporation is established
>and stable, phasing out as soon as possible and in no event later than
>September 30, 2000. The U.S. Department of Commerce will coordinate the
>U.S. government policy role. In proposing these dates, we are trying to
>balance concerns about a premature U.S. government exit that turns the
>domain name system over to a new and untested entity against the
>concern that the U.S. government will never relinquish its current
>management role.

The devolution of the current NSI monopoly, addressing the grievances that
have occurred over the last couple of years, and the corresponding
expansion to the name space should all proceed with all due speed.  To do
otherwise allows the currently unfair position of NSI and other chosen
registry operators an unfair windfall at the expense of the Internet
community and the free market entrepreneurs who have been diligently trying
to enter this industry.

That's not to say the new gTLDs must be entered into the root tomorrow,
only that a definitive policy must be announced that will enable all
participants to plan for that eventuality.

The establishment of "the new corporation" should be thoroughly discussed,
and after consensus is reached with International and domestic stakeholder
communities, should be established in as secure and protected manner as
possible.  This implies a congressional charter.

>    The board of directors for the new corporation should be balanced
>to equitably represent the interests of IP number registries, domain
>name registries, domain name registrars, the technical community, and
>Internet users (commercial, not-for-profit, and individuals). Officials
>of governments or intergovernmental organizations should not serve on
>the board of the new corporation. Seats on the initial board might be
>allocated as follows:

The ISOC and its affiliated I* organizations are directly responsible for
many of the fissures that now exist in the Internet community.  They no
longer live up to their self proclaimed definition:

  "The Internet Society is the international organization
  for global cooperation and coordination for the Internet
  and its internetworking technologies and applications."

Rather than cooperate and coordinate, they continue to split the Internet
community in a fatalistic attempt to implement their power grabbing scheme
at all costs.

For these reasons, the U.S. Government must be very careful in composing
this new board.  We suggest that the ISOC and its affiliated organizations
be censured from involvement in the initial composition of this board.

We would prefer to see the ISP/C or some other newly constituted
organization used to provide this initial representation.

>     Two members designated by the Internet Architecture Board
>(IAB), an international membership board that represents the technical
>community of the Internet.

The IAB is closely affiliated with the Internet Society.  Given the recent
actions of the ISOC, under their current leadership, any organizations
affiliated with or appointed by the ISOC should be considered suspect.
Iperdome suggests that other Internet and Industry organizations like the
ISP/C, NANOG or the IETF are better organizations for the stated purpose.

For more information about the IAB and its history, please see:

>    Seven members designated by a membership association (to be
>created) representing Internet users. At least one of those board seats
>could be designated for an individual or entity engaged in non-
>commercial, not-for-profit use of the Internet, and one for individual
>end users. The remaining seats could be filled by commercial users,
>including trademark holders.

Again, the ISOC should be disqualified from inclusion in this
representation.  Some organizations to consider include CIX, ISP/C, DNRC,
ISA, ITAA and the CDT.

>B. The Competitive Functions

>    Some have made a strong case for establishing a market-driven
>registry system. Competition among registries would allow registrants
>to choose among TLDs rather than face a single option. Competing TLDs
>would seek to heighten their efficiency, lower their prices, and
>provide additional value-added services. Investments in registries
>could be recouped through branding and marketing. The efficiency,
>convenience, and service levels associated with the assignment of names
>could ultimately differ from one TLD registry to another. Without these
>types of market pressures, they argue, registries will have very little
>incentive to innovate.

We strongly agree with this position.

>    Others feel strongly, however, that if multiple registries are to
>exist, they should be undertaken on a not-for-profit basis. They argue
>that lack of portability among registries (that is, the fact that users
>cannot change registries without adjusting at least part of their
>domain name string) could create lock-in problems and harm consumers.
>For example, a registry could induce users to register in a top-level
>domain by charging very low prices initially and then raise prices
>dramatically, knowing that name holders will be reluctant to risk
>established business by moving to a different top-level domain.

These are valid concerns that can be solved without resorting to a single
monopoly registry, nor resorting to exclusively non-profit registries.

Iperdome, for example, has implemented Renewal Price Guarantees.
Basically, we promise to never charge existing clients more for their
renewal fee than the Suggested Retail Price at the time of their original
name reservation (adjusted for inflation).

Other groups, like Open-RSC have proposed solutions like a Domain Name
Holders Bill of Rights (Appendix 4), and a Registry Code of Ethics
(Appendix 5). 

We believe that these issues can and should be addressed using industry
standards and competitive market forces.

>C. The Creation of New gTLDs

>    Internet stakeholders disagree about who should decide when a new
>top-level domain can be added and how that decision should be made.
>Some believe that anyone should be allowed to create a top-level domain
>registry. They argue that the market will decide which will succeed and
>which will not. Others believe that such a system would be too chaotic
>and would dramatically increase customer confusion. They argue that it
>would be far more complex technically, because the root server system
>would have to point to a large number of top-level domains that were
>changing with great frequency. They also point out that it would be
>much more difficult for trademark holders to protect their trademarks
>if they had to police a large number of top-level domains.

The market will adapt to any fair policies that are implemented on a
non-discriminatory basis.  Specifically, new gTLD creation should be
available to all companies large and small, without regard to country of

>    We believe that during the transition to private management of the
>DNS, the addition of up to five new registries would be consistent with
>these goals. At the outset, we propose that each new registry be
>limited to a single top-level domain. During this period, the new
>corporation should evaluate the effects that the addition of new gTLDs
>have on the operation of the Internet, on users, and on trademark
>holders. After this transition, the new corporation will be in a better
>position to decide whether or when the introduction of additional gTLDs
>is desirable.

While we understand the rationale for a limit of five new gTLDs, we don't
necessarily feel that is enough.  Rather, we prefer a process as outlined
in Open-RSC (http://www.open-rsc.org/draft/v5/v5.1/slow_start/) that's
referred to as a gating function. 

Here, a new gTLD will be added every month.  Based on the impact of these
additions, this process can be slowed, stopped, or if no problems are
encountered, increased.

>D. The Trademark Dilemma

Historically speaking, Iperdome has not taken much of a position with
regard to the Trademark Dilemma.  This is primarily due to the nature of
our TLD, which by definition, is "personal" in nature.

It is our belief, however, that the Trademark issue is the fundamental
roadblock standing in the way of new gTLDs.  For this reason, we
respectfully submit the following analysis and proposal:

According to the USPTO, A TRADEMARK is either a word, phrase, symbol or
design, or combination of words, phrases, symbols or designs, which
identifies and distinguishes the source of the goods or services of one
party from those of others.

While there is a clear need to provide similar protection for the sources
of goods and services visible on the Internet, the fundamental problem is
that Domain Names are not Trademarks, and Trademarks are not Domain Names. 

Trying to map literally millions of Trademarks, in hundreds of
jurisdictions, across multiple classes of goods and service into a single,
global name space is simply not possible.  Any attempts to do so results in
an unnatural expansion of trademark law outside it's current scope, and
inhibits innovative growth in favor of commercial protectionism. 

Current proposals to deal with this situation have many problems.

First, they allow any Trademark owner in any jurisdiction to contest any
Domain Name after it has already been issued.  Complex arbitration and
appeal procedures have been proposed to deal with this approach.
Unfortunately, the aggregate overhead associated with this approach is
huge, since every single registration is subject to claims of infringement,
arbitration, appeal and further law suits.

Second, they don't recognize the inherent differences between Trademarks
and Domain Names, nor the physically impossible task of mapping existing
Trademarks onto the global name space.

For example, there are many Trademarks like "Prince" that are protected in
multiple jurisdictions under multiple classes of products or services.
Trying to map these Trademarks onto the name space results in multiple
conflicting parties that have a legitimate claim to use that mark in the
global arena.

The domain name system should not allow one of these multiple, legitimate
users of a mark to circumvent "First Come, First Serve" rules by preventing
others from using that mark in a global domain name.  On the other hand,
there are certain marks that should never be used by others in a domain
name (i.e. IBM). 

The questions is, where do you draw the line?

To provide a mechanism to restrict uses that are clearly not allowable
while permitting those that are, Iperdome suggests an alternate form of
protection for the small number of companies that are truly entitled to
global protection of their name and their mark:
   "According to research widely attributed to D&B, less
   than 50 companies do business in more than 50 countries,
   and less than 200 companies do business in more than 30

Iperdome believes that it makes more sense to deal with this problem from
the perspective of the 200 or so companies likely to be most affected from
domain name infringement.

To solve this quagmire for marks that already have globally recognized
significance, Iperdome proposes the following:
   The establishment of a private certification of world
   wide Trademark status known as a "Domain Mark"(sm) and
   represented by a stylized, lowercase (dm)(sm) surrounded
   by a circle.  It will be awarded in a process similar to
   that used by Underwriters Laboratory (UL) to certify
   electrical appliance.
This mark will be awarded to companies that meet certain global recognition
standards that Internet stakeholders or the new non-profit corporation
shall set. 

For example, one such standard could be that any company that can show that
they have existing Trademark protection in more than 50% of the global
Internet community shall receive this designation.

To prevent Trademark infringement, all new gTLD "Registries" would agree to
check a publicly available database for these global Domain Marks(dm)(sm)
before issuing a new registration.

Concurrent with this submittal, Iperdome has started this "for-profit"
Domain Marking Service.  (http://www.iperdome.com/dms/)

For a fee of $4,995 per year, Iperdome will independently verify all claims
to foreign and domestic Trademarks through the independent law firm of
Hassett, Cohen, Beitchman & Goldstein, with all verification costs to be
billed separately.  (http://www.internetlegal.com/)

Iperdome will then publish these independently confirmed results in a
shared database in a standard format so that every "Registry" world-wide
can do a free Domain Mark(dm)(sm) search before issuing a new domain name.
Clients who meet the requirements for a Domain Mark(dm)(sm) as established
above will be designated as such, and any attempts to register that mark
will be refused.

Some will argue that it is inappropriate for a private company to profit
from this service.

We would argue that, especially on the Internet, Intellectual Property is
the most valuable commodity.  Those who solve difficult problems through
creativity, risk taking, exposing themselves to ridicule, etc. deserve to
be rewarded for their efforts.

Should we lose this argument, however, Iperdome will be happy to spin off
this service to an independent organization (profit, non-profit, or
otherwise) to serve the greater good of the Internet community.

>VII. The Transition

>    5. The new corporation must establish processes for determining
>whether an organization meets the transition period criteria for
>prospective registries and registrars.

The USG must also address the pending grievances of those who have been
harmed under the apparently illegal and anti-competitive activities of the
IANA and other government authorized entities as part of this transition plan.

>A. The NSI Agreement

NSI has received many benefits through its contract with the USG.  Since
NSI has fulfilled the terms of their contract in a responsible manner,
neither they nor their shareholders should be penalized.

At the same time, they should not receive special consideration either.  If
it is decided that new gTLDs will be added to the root, one per "Registry",
then NSI should be held to this same standard.  Consequently, in this
event, they should be required to divest two of their three gTLDs.

>B. Competitive Registries, Registrars, and the Addition of New gTLDs

>    Over the past few years, several groups have expressed a desire to
>enter the registry or registrar business. Ideally, the U.S. government
>would stay its hand, deferring the creation of a specific plan to
>introduce competition into the domain name system until such time as
>the new corporation has been organized and given an opportunity to
>study the questions that such proposals raise. Should the transition
>plan outlined below, or some other proposal, fail to achieve
>substantial consensus, that course may well need to be taken.

Many companies have tried to enter this new industry, and many companies
have been wronged in their quest.  Some have paid $10,000 to a group who
has failed to follow through on their promises.  Others have invested
significant time and money, only to find their options limited because of
unfair trade practices and collusion.

Ultimately, it is the U.S. Government that is directly, although not
deliberately, responsible for this very contentious situation that now
exists in the Domain Name Expansion debate.

The U.S. Government is directly responsible because certain government
contractors were operating without proper supervision, and engaged in
certain anti-competitive and potentially treasonous activities.  This was
recently highlighted when one contractor re-directed more than half of the
world's root servers to an alternate source.

The U.S. Government is not deliberately responsible because many of the
actions of these contractors were cloaked in technical details, and easily
hidden.  Complicating matters even further were the number of funding
sources and points of supervision.  Finally, decisions made to accommodate
moderate growth were inadequate in the bright light of the exponential
growth the Internet has experienced.

So while we understand that the U.S. government would prefer to stay its
hand, we would argue that the U.S. Government is obligated to address the
grievances of the various groups as part of the solution, and as part of
the transition plan. 

>Registries and New gTLDs
>    This proposal calls for the creation of up to five new registries,
>each of which would be initially permitted to operate one new gTLD. As
>discussed above, that number is large enough to provide valuable
>information about the effects of adding new gTLDs and introducing
>competition at the registry level, but not so large as to threaten the
>stability of the Internet during this transition period. In order to
>designate the new registries and gTLDs, IANA must establish equitable,
>objective criteria and processes for selecting among a large number of
>individuals and entities that want to provide registry services.
>Unsuccessful applicants will be disappointed.

Iperdome also supports a go slow approach with regard to actually adding
new gTLDs to the root.  Rather than an arbitrary limit of five, however, we
suggest that other factors determine the exact number.

As mentioned above, we feel that the USG has an obligation to address the
current grievances of those who have been harmed by the actions and
inaction's of certain US Government contractors before the new non-profit
corporation takes over.

Current estimates indicate approximately 15 companies have actively
participated in approximately 200 free market TLDs (Appendix 3).  Actively
participated, in this case, includes TLDs that have been defined, publicly
announced, with at least a SOA record in the alternate root zones.

This criteria can be further defined to include tests for actual
operational intent and execution.  Even today, many on this list are not
properly configured, are not accepting registrations, have little or no
data in their TLD zone, have no lookup capabilities, and have not been in
continuous operation.  Using these more stringent tests, there would only
be around five companies representing about 25 gTLDs.

And, as a totally self-serving exercise, only Iperdome meets all of these
requirements and offers our clients immediate visibility in the Legacy Root
Zone (under the .nu and .to TLDs).

We should also include name.space and CORE.  While they may or may not meet
the criteria outlined above, they also have pending claims for certain TLDs.

By way of compromise, Iperdome suggests that each of these organizations
get to choose one gTLD to develop.  The rest will become available to other
entities on the net.  This implies that NSI will divest itself of two
existing gTLDs.

Depending on the actual criteria used, that would mean at most 20 new
gTLDs.  It would also eliminate many lawsuits and years of additional
delays and fighting.

To summarize, Iperdome suggests:
  -  Increase the number of transitional gTLDs from 5 to
at most 20 to accommodate a brokered solution for
existing claimants to new gTLDs.
  -  Use a gating function to add one new gTLD per month, and
adjust this rate depending on experience.
  -  Use the new Domain Mark (dm) procedure to protect
multinationals from Trademark infringement in cyberspace.

>E. The Process

There is a certain order to pending events that will make this transition
process work more smoothly.

1. A decision must be made as to which registries have a legitimate claim
to a new gTLD, as well as their relative position in the queue.

2. The technical, financial, and managerial requirements for a Registry
must be finalized.

3. The gating function should be implemented based on the order in which
the legitimate claimants (as defined in #1) prove their compliance with the
final Registry requirements (as defined in #2). 

Finally, claimants should be allowed to trade their position in the queue. 

For example, even though Iperdome has signed agreements to upgrade our
technical capabilities to meet the proposed terms of the Green Paper, and
could do so in short order, we would prefer to gain entry in three to six
months.  This would give us time to plan for a coordinated launch with
media and our industry partners.

Other registries, like IO Design, might opt to be first in line.  Once the
three decisions above are made, however, the market can easily resolve the
order of new TLD entries.

>Appendix 1--Recommended Registry and Registrar Requirements

>Registry Requirements

While desirable, these requirements represent a step beyond where any
Registry is today.  Only a handful are even close, NSI being one of them.

The vast majority of TLDs, especially among ccTLDs, have substantially
lower standards.  That's not to say the higher standards are not desirable,
only that they are overkill for most TLDs.

Iperdome suggests a sliding requirement scale that becomes stricter as the
number of SLDs in a zone increase.  The same standards should apply to
ccTLDs as to gTLDs, based upon SLDs per zone.

Given free market competition, infrastructure will likely be enhanced as
needed to respond to unique factors and to position one gTLD over another.

For example, commercial transactions may eventually require some type of
"Secure DNS" to facilitate commerce.  If .biz were to implement this value
added service, they might have a competitive advantage in the commercial

At the same time, it might not make sense for other TLDs like .per(sm) to
incur the bandwidth overhead to provide "Secure DNS" to individual
Netizens.  The market is the best decision maker in this regard.

>Registrar Requirements

Technical requirements for Registrars are probably too strict, fiduciary
responsibilities are probably not strict enough. 

>Appendix 2--Minimum Dispute Resolution and Other Procedures Related to

As outlined above, Iperdome supports a prevention strategy rather than a
reactive strategy.  Not only will this be far less expensive, but it will
enable better privacy rights for registration information.

One of the big issues that apply especially to Personal Domain Names is one
of privacy.  Iperdome currently has a policy to release personal
information on an as-needed basis only.  We consider making detailed
ownership information publicly available on private Netizens as an
unnecessary infringement on their privacy.

Appendix 3 -- A Concise List of New TLDs That Appear Real.

as prepared by Richard Sexton for Open-RSC:

 TLD           Steward                                       Operational
 ===           =======                                       ===========
 INC           GLOBECOMM, NY, NY, US                            May 96
 GAMES         GLOBECOMM, NY, NY, US                            Nov 96
 ASIA          GLOBECOMM, NY, NY, US                            Nov 96
 KIDS          GLOBECOMM, NY, NY, US                            Nov 96
 EMAIL         GLOBECOMM, NY, NY, US                            Nov 96
 GLOBE         GLOBECOMM, NY, NY, US                            Nov 96
 LEARN         GLOBECOMM, NY, NY, US                            Nov 96
 LAW           GLOBECOMM, NY, NY, US                            Nov 96
 800           VRx, Bannockburn, Ont, CA.                       Jul 96
 888           VRx, Bannockburn, Ont, CA.                       Jul 96
 FAQ           VRx, Bannockburn, Ont, CA.                       Jul 96
 DDS           VRx, Bannockburn, Ont, CA.                       Jul 96
 ZOO           VRx, Bannockburn, Ont, CA.                       Jul 96
 LLB           VRx, Bannockburn, Ont, CA.                       Jul 97
 PRICES        VRX, Bannockburn, Ont, CA.                       Jul 97
 GALLERY       VRx, Bannockburn, Ont, CA.                       Jul 97
 NIC           VRx, Bannockburn, Ont, CA.                       (Jan 96)
 SQL           VRx, Bannockburn, Ont, CA.                       Feb 98
 LIST          VRx, Bannockburn, Ont, CA.                       Feb 98
 GMBH          VRx, Bannockburn, Ont, CA.                       (Jul 96)

 ENT           ITC Canada, Toronto, Ont, Ca.                    Aug 96
 SEX           ITC Canada, Toronto, Ont, Ca.                    Jun 96

 SKY           ATC Canada, Toronto, Ont, Ca.                    Aug 96
 ART           ATC Canada, Toronto, Ont, Ca.                    Aug 96
 ARTS          ATC Canada, Toronto, Ont, Ca.                    Aug 96
 BANK          ATC Canada, Toronto, Ont, Ca.                    Jan 97
 DIR           ATC Canada, Toronto, Ont, Ca.                    Jan 97
 FILM          ATC Canada, Toronto, Ont, Ca.                    Jan 97
 FUND          ATC Canada, Toronto, Ont, Ca.                    Jan 97
 HELP          ATC Canada, Toronto, Ont, Ca.                    Jan 97
 RADIO         ATC Canada, Toronto, Ont, Ca.                    Jan 97
 VIDEO         ATC Canada, Toronto, Ont, Ca.                    Jan 97
 HOTEL         ATC Canada, Toronto, Ont, Ca.                    Jan 97
 MUSIC         ATC Canada, Toronto, Ont, Ca.                    Jan 97
 ISP           ATC Canada, Toronto, Ont, Ca.                    Jan 97
 ZINE          ATC Canada, Toronto, Ont, Ca.                    Jan 97
 MED           ATC Canada, Toronto, Ont, Ca.                    Jan 97
 XXX           ATC Canada, Toronto, Ont, Ca.                    Jan 97
 EUR           Netnames, Lodon, UK                              May 96
 WEB           IO Design, San Luis Obispo, Ca, US               Jul 96
 BIZ           Macro Computer Solutuions, Chicago, Il, US       Dec 95
 NPO           Macro Computer Solutuions, Chicago, Il, US       Dec 95
 K12           Macro Computer Solutuions, Chicago, Il, US       Dec 95
 CORP          Macro Computer Solutuions, Chicago, Il, US       Dec 95
 ANIME         Software Customization                           Aug 97
 SOFT          Software Customization                           Aug 97

 USVI          de Blanc, St. Thomas, USVI                       Aug 96
 TOUR          de Blanc, St. Thomas, USVI                       Aug 96
 ZONE          de Blanc, St. Thomas, USVI                       Aug 96
 MALL          UNIR, Napierville, IL, US                        Mar96
 HIGGS         Higgs America, Wash DC, US                       Jun 96
 NEWS          Higgs America, Wash DC, US                       Jun 96
 COUPONS       Higgs America, Wash DC, US                       Jun 96
 REBATES       Higgs America, Wash DC, US                       Jun 96
 FREE          Nair, Selangor, Myandar                          May 96
 FAM           Lanminds, Berkeley, CA, US                       Aug 96
 PER           Iperdome, Atlanta, Ga, US                        Jan 97
 LIVE          Iperdome, Atlanta, Ga, US                        Mar 97
 CHIRO         Iperdome, Atlanta, Ga, US                        Mar 97
 I             Page Optometry, Pleasenton, Ca, US               Mar 97
 A             Page Optometry, Pleasenton, Ca, US               Mar 97
 GAY           Cognoscenti, Chicago, Il, US                     Mar 97
 VID           ????                                             Apr 97

Appendix 4 -- Domain Name Holders Bill of Rights


      A domain name holder has the right to reasonable service.

          A domain name holder has the right to use their domain for any
          legal purpose consistent with the published policies of the
          registry involved.

          A registry shall not act to in any way interpret the potential
          legality of any use of a domain. Only a court of appropriate
          jurisdiction and venue can make such a determination and it is
          an inalienable right of a domain name holder to operate under
          the expectation that the registry will not intervene unless so
          ordered by the courts.

          A Registry will publish their TLD fee raising schedule.

          A Registry will publish their invoice terms and their removal
          schedule for non-payment of invoices.

          A Registry is not obliged to make a domain operational prior
          to payment, but such service can be made available.

          A domain holder gains the perpetual right to maintain
          ownership of a 2nd level domain in exchange for timely payment
          of posted yearly rates.

          A domain name holder has the right to expect the the
          Association of Internet Registries shall endeavor to keep all
          TLDs active, even in the event of business failure of a
          registry. This endeavor shall be on a 'best effort' basis and
          does not include long-term operation of a TLD that proves to
          be un-viable.

Appendix 5 -- Registry Code of Ethics


          I will not gouge domain name holders.

          I will make domain registrations available as cheaply as

          I will ensure continuous and robust operation of DNS services

          I will run a TLD according to it's charter.

          I will not make arbitrary and capricious changes to policy or
          operations.  If there is a problem that requires such changes,
          the Internet community will be made aware of the problem and
          possible solutions will be discussed in an open manner.

          I will abide by local laws and be responsive to the internet

          I will process domain registrations, modifications and
          deletions in an expeditious and secure manner and will do my
          best to ensure only a domain name holder can modify or delete
          a domain.


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