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

1. The British Computer Society (Hong Kong Section), hereinafter abbreviated as BCS(HKS), welcomes the government's initiative on the review of the Administration and Assignment of Internet Domain Names and Internet Protocol Address in Hong Kong. A well planned strategy and widely accepted policy on these matters would strengthen Hong Kong's position in its long term development to become one of the most important Information and Internet Hubs in the world.
   
   
2. The proposals suggested in the Consultation Paper has addressed a few issues that have been inadequately handled under the existing rules of HKNIC, such as registration of multiple domain names by a company, transfer of domain names and domain names for individuals, etc. However, the proposals suggested are generally considered rather conservative. They could most probably be sufficient for tackling the issues that occur presently and those appeared in the past. However, one would expect that the suggested framework and guidelines would fail to handle many future cases due to the rapidly changing and innovative developments in Internet and the fast expansion in deploying Internet technology in all aspects of human society. The BCS(HKS) is of the view that a desirable policy, which could provide a good foundation for the administration of domain names and IP addresses of Hong Kong, should be one that can liberalize the various restrictions as much as possible by introducing competitive participation.
   
   
3. The suggestion of setting up an independent, non-profit making, non-statutory corporation to take charge of the overall policy-making and administration of the Internet domain name administration in Hong Kong is acceptable. We should anticipate that there will be fast and big development in Internet relating to all sectors of businesses in Hong Kong. The evolvement of IPv6 could also relieve the pressure in global contention of the limited number of available IP addresses. Hence, the corporation to be instituted should also take charge of the overall policy-making and administration of the Internet Protocol addresses within Hong Kong at an early stage. The suggestion in the Consultation Paper of continuing the existing arrangement for the allocation IP addresses should only be treated as an interim measure rather than a satisfactorily acceptable arrangement.
   
   
4. The suggestion of maintaining a common Registry for Domain Names in Hong is logical and technically reasonable. On the other hand, the suggestion of keeping a single Registrar for handling domain name registration in Hong Kong, which is practically maintaining the present practice, is rather conservative and very undesirable. The idea of creating a layer of Agents below the Registrar is in effect compounding the complexity, that should otherwise rather simple, of the organization of the parties that will be involved in the domain name registration work. The BCS(HKS) is of the view that the registration service which are on increasing demand in the Hong Kong community must be liberalized through the introduction of competitive participation by multiple Registrars; and that. the suggestion of maintaining a single Registrar should only be treated an interim measure and should not be continued for more than one year.
   
   
5. The BCS(HKS) welcomes the suggestion of allowing an organization to register more than one domain under the .hk ccTLD. It should be the best if an unambiguous policy could be instituted to govern the registration of multiple domain names by the same organization. For example, a company should be allowed to register multiple domain when it has more than one products or services with Registered Trademark registered under Hong Kong or under a recognized international trademark registrar. When defining such rules which should not discourage any legitimate and reasonable registration requests is considered administratively impractical, the BCS(HKS) is of the view that the registration of multiple domain names by the same organization should be liberalized by removing any known restrictions as much as possible. The BCS(HKS) is of the view that the cyber-squatting problems should be tackled by other means, say legally and/or financially.
   
   
6. The suggestion in the Consultation Paper that the registration authority in Hong Kong could draw up a reserved list of domain names. While the BCS(HKS) is open to this suggested arrangement whenever it is technically and practically feasible, we would raise that there would be considerable conflict of interest if the "registration authority" and any of the designated Registrars were not separate entities under different and separate management. To avoid such kind of scenario, the formation and management composition of the registration authority must be independent and separated from any of the Domain Name Registrars.
   
   
7. For transfer of domain names, the BCS(HKS) is of the view that transfer of all domain names under the .hk ccTLD should be allowed so as to liberalize the use of any registered domain names in an Internet-based business community. Unnecessary or "unwelcome" transfers could be discouraged by financial means, say a higher cost would be charged in comparison with that for a new registration.
   
   
8. To the best knowledge of BCS(HKS), the HKNIC under the management of JUCC is the only existing Domain Name Registrar in Hong Kong and it has not been known that a separate Chairman of HKNIC has been appointed. Hence, the related parts in paragraph 31 and Annex B of the Consultation Paper should be clarified and accordingly rectified.

Yours sincerely,

Dr. F.T. Chan
Chairman