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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"


Subject: comments towards .hk name consultation paper

Dear ITBB: my personal humble opinions, totally independent from my employer and institutions:

> c. the corporation should be spun off from the JUCC initially, with
> an interim Board comprising directors from the academia, the
> industry and the Government;

the corporation should be started as soon as possible:

- JUCC should not be represented more than other sectors, and her role should diminish to a minority weight within a year. Afterall, academics don't play a major role in the internet anymore; - the new corporation needs time to train her staff, and write and tune her own software from scratch; give them at least 3 months after incorporation for preparations before taking on real registrations;

> i. the JUCC should continue to provide registration services in
> respect of the domain;

only if the education sectors of HK show approval; we should not automatically assume JUCC knows who is and who is not an educational institution. Definition of such always have a lot of grey areas. Default should be to let be treated like com/org/, unless the HK education sectors express their wishes to be otherwise;

> k. the registrar responsible for, and domain
> names may engage agents to perform some of the routine registration work;

to avoid conflict of interest, such agents must not be affiliated with ISPs or webhosting companies, otherwise the impartiality of such agents will be questioned if their affiliated ISP competes with another ISP (who has no agents) to register a name.

> l.a reserved list of domain names consisting of well-known
> international trademarks, service marks and brand names as well as
> some other names which are of restricted use, making reference to
> the reserved lists prepared by other ccTLD registration authorities,
> may be drawn up;

better default to no such list, unless we know how the list is made up, and who has the power to change it. Danger of having no such list is small.

> p.each organisation should be allowed to register more than one
> domain name under .hk;

but only for a small number of names; many names for each organization will result in hogging of names, whether or not they can be transferred to other organizations later;

> q.the transfer of domain names on valid grounds should be allowed;

commercial relationships between tranfer parties can be extremely complex, and it will be totally impossible for HKNIC (old or new) to draw up a satisfactory list of acceptable reasons for transfer. This "on valid grounds" clause is a time-bomb that will surely create lots of heated arguments. Let organizations transfer names whenever they want. Cybersquatting needs to be defeated by other means. Even if you don't allow transfer, companies will still hog lots of name, because you cannot tell/convince everyone that their names may not be transferrable.

> r.only companies and organisations registered or incorporated in
> Hong Kong should be allowed to register domain names ending with
> .hk initially;

delete the word "initially"; .hk names are like +852 numbers. Why should we let a US company register (e.g.) so HK companies cannot use it? If they want to do business in HK, let them register in HK, and use that HK identity to register .hk names.

> t.domain names should be subject to renewal at a fee;

very needed, and should be applicable to names already registered;

> alternative dispute resolution mechanism should be developed
> in Hong Kong to facilitate early resolution of .hk domain name
> disputes

The new HKNIC should give a reasonable timeframe (e.g. 6 months) to develop such mechanisms.

Others: we might approach the Business Registry to seek their opinion on whether they want to be the registry (or an agent) for names, which by nature are nothing more than Business names or labels. We might need legislation to achieve that purpose, but be assured that the technical part is the easy part: all that is needed: 3 more fields in a Business Registration Certificate: domain name, nameserver1, and nameserver2.

Advantage: every business knows how to do business registration, so they will know immediately know how to register names, and save them a lot of time. We can also mimic the mechanism to resolve who is most eligible for a particular business name, and try to apply it towards names, and this can solve a worldwide headache problem: who is the most appropriate party for a particular business name.

Thanks for you very nice consulation paper. Go for it. --kinming--

 /     ==#=i   __  #===# kinming Fung

/     ===#=|= #  # #___# representing himself only in these opinions

/ # ==7 ==#=|  #==# #   # and not reflecting positions at all, of

 #  /  ==#==  #__# #---# Chinese University of Hongkong

 # =\  ==#==      /    # and other institutions

 # =/ \======/   /    \#