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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 Sirs,

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

We refer to the above Consultation Paper.

We generally support the suggestions set out in paragraph 50 of the Consultation Paper. Our response to certain issues of paragraph 50 are set out below (following the numbering of the sub-paragraphs in paragraph 50):

Sub-paragraph (f): the existing arrangements for IP address allocation in Hong Kong should continue

IP addresses allocation is a scarce resource and with the rapid growth of internet business, it is our view that the existing arrangement can only meet the demands on a short term basis.

Currently, APNIC (the IP address distribution body) applies a very strict approach in checking the appropriateness for each IP address allocation.

Each ISP is required to provide details and reason to justify each assignment (even for simple based-line connection service). Further, APNIC's responsibility cover a number of countries resulting in considerable delay in processing each assignment. As each country has its own unique technology development situation / stage, APNIC may not fully understand the actual need of each locality e.g. some country use CDMA while others use GSM mobile communications. It is not practical for APNIC to fully understand the need of IP address allocation for each technology. This would be more complicated with the introduction of GPRS and 3G.

In summary, iSmart recommends a single body to run the IP address allocation in Hong Kong. This would expedite the process for the application of IP address. We anticipate a surge of applications with the launch of broadband services and recommend such a single body to be form as soon as possible.

Sub-paragraph (k): the registrar responsible for, and domain names may engage agents to perform some of the routine registration work.

The engagement of agents may not expedite the process. The registrar would have to manage the agents and their service level. We recommend the registrar running the process itself perhaps with more built-in automation process.

Yours faithfully,
For and on behalf of Limited

Elaine Lau
Head Legal Counsel
Legal & Regulatory Affairs