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

Dear ITBB: my personal humble opinions, totally independent from my
employer and institutions:

> c. the corporation should be spun off from the JUCC initially, with
> an interim Board comprising directors from the academia, the
> industry and the Government;

the corporation should be started as soon as possible:

- JUCC should not be represented more than other sectors, and her role
should diminish to a minority weight within a year. Afterall,
academics don't play a major role in the internet anymore;
- the new corporation needs time to train her staff, and write and tune
her own software from scratch; give them at least 3 months after
incorporation for preparations before taking on real registrations;

> i. the JUCC should continue to provide registration services in
> respect of the .edu.hk domain;

only if the education sectors of HK show approval; we should not
automatically assume JUCC knows who is and who is not an educational
institution. Definition of such always have a lot of grey areas.
Default should be to let edu.hk be treated like com/org/net.hk,
unless the HK education sectors express their wishes to be otherwise;

> 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;

to avoid conflict of interest, such agents must not be affiliated
with ISPs or webhosting companies, otherwise the impartiality of
such agents will be questioned if their affiliated ISP competes
with another ISP (who has no agents) to register a name.

> l.a reserved list of domain names consisting of well-known
> international trademarks, service marks and brand names as well as
> some other names which are of restricted use, making reference to
> the reserved lists prepared by other ccTLD registration authorities,
> may be drawn up;

better default to no such list, unless we know how the list is made up,
and who has the power to change it. Danger of having no such list is
small.

> p.each organisation should be allowed to register more than one
> domain name under .hk;

but only for a small number of names; many names for each organization
will result in hogging of names, whether or not they can be transferred
to other organizations later;

> q.the transfer of domain names on valid grounds should be allowed;

commercial relationships between tranfer parties can be extremely
complex, and it will be totally impossible for HKNIC (old or new) to
draw up a satisfactory list of acceptable reasons for transfer. This
"on valid grounds" clause is a time-bomb that will surely create lots of
heated arguments. Let organizations transfer names whenever they want.
Cybersquatting needs to be defeated by other means. Even if you don't
allow transfer, companies will still hog lots of name, because you
cannot tell/convince everyone that their names may not be transferrable.

> r.only companies and organisations registered or incorporated in
> Hong Kong should be allowed to register domain names ending with
> .hk initially;

delete the word "initially"; .hk names are like +852 numbers. Why
should we let a US company register hkfood.com.hk (e.g.) so HK companies
cannot use it? If they want to do business in HK, let them register in
HK, and use that HK identity to register .hk names.

> t.domain names should be subject to renewal at a fee;

very needed, and should be applicable to names already registered;

> v.an alternative dispute resolution mechanism should be developed
> in Hong Kong to facilitate early resolution of .hk domain name
> disputes

The new HKNIC should give a reasonable timeframe (e.g. 6 months) to
develop such mechanisms.

Others: we might approach the Business Registry to seek their
opinion on whether they want to be the registry (or an agent) for
com.hk names, which by nature are nothing more than Business names
or labels. We might need legislation to achieve that purpose, but be
assured that the technical part is the easy part: all that is needed: 3
more fields in a Business Registration Certificate: domain name,
nameserver1, and nameserver2.

Advantage: every business knows how to do business registration, so they
will know immediately know how to register com.hk names, and save them a
lot of time. We can also mimic the mechanism to resolve who is most
eligible for a particular business name, and try to apply it towards
com.hk names, and this can solve a worldwide headache problem: who is
the most appropriate party for a particular business name.

Thanks for you very nice consulation paper. Go for it. --kinming--

  /     ==#=i   __  #===# kinming Fung

 /     ===#=|= #  # #___# representing himself only in these opinions

/ # ==7 ==#=|  #==# #   # and not reflecting positions at all, of

  #  /  ==#==  #__# #---# Chinese University of Hongkong

  # =\  ==#==      /    # and other institutions

  # =/ \======/   /    \#