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 Sir/Madam,

Re: Consultation Paper on the Review on
Administration and Assignment of Internet Domain Names
Internet Protocol Addresses in Hong Kong

I refer to the letter from Mr Rex Chang for Secretary for Information Technology and Broadcasting and the Consultation Paper. On behalf of the Hong Kong Computer Society, I provide the following comments:

1. In principle, we agree with the spirit, recommendations and guidelines in general, but there are a few points we would seek further considerations.
   
   
2. Para 50(c)
   
   The non-profit making and non-statutory corporation to be established would preferably be completely separate from JUCC to maintain an absolute independence. Adequate representation mush be ensured.
   
   
3. Para 50(k)
   
   Engaging agents to perform registration may result in poor standards of services as it would be a commercial arrangement. Adequate scrutiny and control need to be established. Alternatively the register could take up the work.
   
   
4. Para 50(n)
   
   There should be fair and adequate appeal mechanism.
   
   
5. Para 50(s)
   
   Individual domain names should follow names in personal Identity Cards.
   
   
6. Para 50(t)
   
   The fee should be reasonable.
   
   
7. Para 43
   
   The number of domain names a company allowed to apply for should be limited to a reasonable number (i.e. not excessive).
   
   
8. Para 32
   
   ITSD of HKSAR should be considered to take over from JUCC.