Public Comments on the "Consultation Paper on the Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong"

Subject: Comments on Consultation Paper on Review of Admin of Domain Names

I have a few comments on the "Consultation Paper on the Review on
Administration and Assignment of Internet Domain Names and Internet
Protocol Addresses in Hong Kong"

First, I did write a letter to ComputerWorld Hong Kong in April which is
relevant to this issue. Having read the Consultation Paper, I have modified
my opinion slightly, as detailed later. I include the full message to
ComputerWorld Hong Kong here:

------- Forwarded Message Follows -------
From: Allan Dyer
To:   ComputerWorld Hong Kong
Subject: Re: Viewpoint, April 21, 2000
Date sent: Fri, 21 Apr 2000 12:43:33 +0800

I will not stoop to Joe Sweeney's level of casting aspertions on the lavatorial
habits of people he disagrees with, but I really don't see the problem he, and
the frustrated clients of the Gartner Group are having about the one domain
name per business registration limit in .hk.

Firstly, you don't get one name, you get a whole sub-domain. Although most
people seem to stick with www, you could name your web servers by the
business line. For my own company, I could create (these don't exist)
candies.yuikee.com.hk, computers.yuikee.com.hk,
education.yuikee.com.hk ... you get the idea. This combines obvious
function with brand-name awareness. The name gets a little longer, but does
this matter? If the content of the site is good, people will bookmark it and
never type the name again. If the content is bad, a snazzy name will not
help.

Secondly, there is no lack of business registrations in Hong Kong, and they
often come in groups, as the number of Holding companies demonstrates (I
would have thought this was obvious to the Gartner *Group*). Just check
which of your subsidiaries don't have a domain name yet. All done, and just
got an idea for *the* killer domain name and application? Why not register a
new company to hold the name - it even makes it easier to go IPO later.

Shakespeare said something about roses, names and smell - he was right,
it's content, not name that is important. Yahoo wasn't even a dictionary entry
a few years ago, the content made the difference. When the dust has
settled, it won't be the best name that emerges the winner, but the best
content.

Regards,
Allan Dyer
----------------------------------------End of Forwarded Message

In-line with the sentiments expressed in my letter, I still do not see a need
for allowing unlimited domain name registrations. However, if the rule was
kept as "one company, one domain name", then trademark names might
remain unused, for example, where a company had more than one
trademark. Therefore, I recommend changing section (50.p) to a limit of one
domain name per company registration *and* one domain name per
registered trademark.

I do support introducing domain names for individuals (section 42.g). It would
be interesting, and could reduce the workload at the registry, if families could
administer their own sub-domains. For example, if the second-level domain
for individuals is person.hk, I could register dyer.person.hk, and create sub-
domains allan.dyer.person.hk (for myself) and james.dyer.person.hk (for my
son).

I disagree with restricting registration to a domain name resembling the
company name, its products or services (section 38). This restriction makes
difficulties for innovative companies with ideas for new businesses - for
example, company A has an idea for an entirely new way of providing service
X over the Internet. They do not currently provide service X, so they cannot
register the domain name without making detailed revelations of their plans,
or waiting until they have the new delivery method fully developed.
Meanwhile, a company providing service X by traditional methods could
register the name. With my suggested restrictions above to one domain
name per company and one per registered trademark, the risk of
cybersquatting is greatly reduced, so it is feasible to allow registration of
unrelated names.

Concerning the suggestion of replacing the HKNIC with a "non-profit making
and non-statutory corporation" (section 50.a), I recommend the principle of,
"if it ain't broke, don't fix it". In my dealings with HKNIC, I have found it to be
fair and efficient (as opposed to the technical staff of my ISPs, who were
surprisingly inefficient). Section 13 states, "However, with the rapid
development of the Internet and electronic commerce locally, there are views
as to whether the JUCC is able to adequately represent the interests of
different sectors in Hong Kong in carrying out this function." but it does not
justify these claims in any way. HKNIC has a proven track-record of providing
the administration function successfully. In comparison, the registries for
Chinese domain names are in total confusion - my company has registered a
Chinese domain name, but there are no clues as to when the system will
work. If the HKNIC and JUCC is happy continuing the work, then I see no
reason to set up a new body at great expense to replace them.

I hope my opinions are useful to you,
Regards,
Allan Dyer

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Allan Dyer, CISSP, MHKCS, DFCAE
Technical Director
Yui Kee Co. Ltd.