Public
Comments on the "Consultation Paper on the Review on Administration
and Assignment of Internet Domain Names and Internet Protocol Addresses
in Hong Kong"
| Reference
No. |
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DN06 |
| Date
of Submission |
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: |
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16.06.2000 |
| Submitted
by |
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: |
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Ms
Elaine Lau |
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Head
Legal Counsel, Legal & Regulatory Affairs |
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iSmart.net
Limited |
Dear
Sirs,
Re
: Consultation Paper on the Review on Administration and Assignment
of Internet Domain Names and Internet Protocol Addresses in Hong
Kong
We
refer to the above Consultation Paper.
We
generally support the suggestions set out in paragraph 50 of the
Consultation Paper. Our response to certain issues of paragraph
50 are set out below (following the numbering of the sub-paragraphs
in paragraph 50):
Sub-paragraph
(f): the existing arrangements for IP address allocation in Hong
Kong should continue
IP
addresses allocation is a scarce resource and with the rapid growth
of internet business, it is our view that the existing arrangement
can only meet the demands on a short term basis.
Currently,
APNIC (the IP address distribution body) applies a very strict approach
in checking the appropriateness for each IP address allocation.
Each
ISP is required to provide details and reason to justify each assignment
(even for simple based-line connection service). Further, APNIC's
responsibility cover a number of countries resulting in considerable
delay in processing each assignment. As each country has its own
unique technology development situation / stage, APNIC may not fully
understand the actual need of each locality e.g. some country use
CDMA while others use GSM mobile communications. It is not practical
for APNIC to fully understand the need of IP address allocation
for each technology. This would be more complicated with the introduction
of GPRS and 3G.
In
summary, iSmart recommends a single body to run the IP address allocation
in Hong Kong. This would expedite the process for the application
of IP address. We anticipate a surge of applications with the launch
of broadband services and recommend such a single body to be form
as soon as possible.
Sub-paragraph
(k): the registrar responsible for .com.hk, org.hk and .net.hk domain
names may engage agents to perform some of the routine registration
work.
The
engagement of agents may not expedite the process. The registrar
would have to manage the agents and their service level. We recommend
the registrar running the process itself perhaps with more built-in
automation process.
Yours
faithfully,
For and on behalf of iSmart.net Limited
Elaine Lau
Head Legal Counsel
Legal & Regulatory Affairs
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