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

In response to the Consultation Paper on the Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong (URL: http://www.digital21.gov.hk/eng/structure/con_paper.html), the Joint Universities Computer Centre (JUCC) would like to submit the following comments for the consideration of the Information Technology and Broadcasting Bureau :

2. In general, the JUCC would consider that the proposals set out in the consultation paper are a bit too conservative and may not be able to response to the rapid development of the Internet world. We understand that the registration policy should need to be reviewed periodically by the new policy-making body in response to the changing needs. As the current proposals in the consultation paper only aim to answer the immediate requests, we anticipate that another review would be needed in a very near future.

3. We have much concern about some of the comments in paragraph 13. The JUCC has always been trying the best in carrying out the function to ensure that the interests of different sectors in Hong Kong are being taken care of. However, we believe that the direct participation of the stakeholders should benefit the future development and therefore, very much welcome about the current review process and inviting the participation of the community at large. The senior management of the Universities have strongly expressed that the JUCC should be openly recognized of its initiatives and contributions to servicing the Hong Kong community in administering the service in the past 8 years.

5. We would consider the suggestion that the corporation be spun off from the JUCC initially, with an interim board compromising of directors from the academia, the industry, the Government and certain selected interested organizations or individuals. The JUCC would continue its commitment to serve the community if the new operating environment after the review is still suitable for us to carry on the duties.

6. We recommend that the corporation should participate actively in reviewing the arrangements for IP address allocation in Hong Kong to ensure that it brings the best benefit to the HK Internet community.

7. We agree with the principle as suggested.

8. We advocate introduction of multiple registrars soon, say, within 6 to 12 months after the corporation is formed.

9. We would like to point out that the effort in maintaining the proposed reserved list would be enormous and that the process for identifying well-known international names, obscene and indecent names would be very much subjective to different peoples' understanding.

10. We recommend that a separate body other than the Registry might be more appropriate to maintain the reserved list in order to minimize the possible conflict of interest.

11. We advise that the registrar(s) should not be expected to assess the registration case by case if more than a domain name can be registered and that it would be more logical to expect the registrar(s) to hold the two simplest principles - "first come, first served" and "the applicant shall assume all responsibility for not infringing upon the intellectual property rights of a third party"

12. We consider the suggestion agreeable.

13. We consider the suggestion agreeable.

14. We clarify that

• there are also other known choices of technical set up for implementing multilingual domain names;
• the participation of HKNIC in the Chinese Domain Names Consortium formed in May 2000 is not known to JUCC
• there is no Chairman of HKNIC.

P T Ho
Acting Director
JUCC Ltd
July 15, 2000
HPT/AC