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: Consultation Paper

dear sir/madam,

in regard to the Consultation Paper on The Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong (http://www.info.gov.hk/digital21/eng/structure/con_paper.html),

item 47:
i am strongly against the idea of charging annual or renewal fees. this will greatly reduce the attractiveness of registering a .com.hk domain. to address cleaning out of abandoned domain names, instead a policy should be made to enforce deletion of domain names registered under nameservers which are now lame for that domain. if hknic doesn't receive enough revenue from new registrations (estimated at hk$400,000/month) and modifications (probably a similar figure), the one-time and/or modification charge should be increased to match costs. if domain names are subject to an annual or renewal fee, people will be much more likely to register a .com domain with a us$8/year .com registrar. the cheaper .com registrars often have problems, and lost passwords are a major pain, both retarding the development of internet in hong kong. the current .hk domain registration system is very simple, straightforward, and doesn't have any problems with changing legal ownership or modifying nameservers, therefore increasing its attractiveness. nobody will be locked out of their .com.hk domain.

item 43:
multiple domains registered by a single company is a good thing, but will very quickly lead to squatting and greatly increased sale/trade of .com.hk domain names, which is undesirable. instead, i propose a maximum number of 5 or 10 domains for each company. this will allow the company enough freedom to register the domain names of their products and/or alternate company name spellings among other things, but prevents widespread abuse of squatting. it will happen, but this will keep it to a manageable level.

these two changes together will have a similar effect as charging a yearly renewal fee, but will maintain the attractiveness of .com.hk domains compared to .com domains. enforcing that nameservers remain authoritative for domains will make unused domains available for registration by others, as they should be. this also reduces the attractiveness of squatting, as you not only have to register the domain, but maintain the nameservers for them as well. the average user will not be able to do this, and most isp's would be unwilling to participate unless they get paid, which further reduces the attractiveness of squatting. hknic should charge whatever fee is necessary to maintain costs, but as a one-time-only fee. this fee might be re-evaluated from time to time to increase or reduce as appropriate. a yearly renewal fee is very likely to be unrelated to the actual costs of maintaining the registry, and might generate a lot more income than is needed, increasing the chances of corruption or mis-use of funds.