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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 Sir/Madam:

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

Chinese Domain Name Corporation Limited (CDNC) is in the business of helping establish Chinese identities on the Internet, starting with Chinese domain names. Domain names form the critical first point of contact with users, yet they are restricted by legacy to Western language. For the exploding online Chinese population, this is unnatural; for the equally exploding number of companies targeting Chinese consumers, this gap translates to higher marketing costs and greater business risks. CDNC offers officially sanctioned, market leaders backed, Chinese domain name registration for generic TLDs. Together with the market, business, regulatory, and technology partners, CDNC aims to help businesses establish and enrich their online Chinese identity, and make the Internet more natural and intuitive for millions of the Chinese users. A quarter of humanity is hard to ignore in the New Economy.

After studying your Consultation Paper published earlier, please find our views and responses with respect to various sections outlined as follows:

1. Chinese Domain names (section 16-18)

  • We would suggest that the non-statutory corporation (which is proposed in section 27) should work with CNNIC and the 4 Chinese NICs regarding the Chinese domain names services. This corporation/HKNIC should be prepared for this and be ready when a more clear picture and standard of this becomes available.

2. Proposed Institutional arrangements (section 20-28)

  • We would to clarify the mechanism how the board of the non-statutory corporation is being selected in the initial transformation period from JUCC

3. Registrar and agent (section 31-33)

  • We would suggest that instead of government and JUCC to take care .gov and .edu registrar function, the task force may consider one single registrar but for .gov and .edu domain names, the registrar needs to follow the instruction from Government and JUCC respectively. Domain names registered under .gov and .edu is probably not large enough and separate registrar would not be cost effective.

4. Domain name registration guiding principles (section 34c)

  • While cybersquatting should not be promoted and encouraged, domain name trading should be part of normal business dealings as long as 2 parties agree to do so.

5. Registration guidelines- reserved list (section 37)

  • Case by case assessment is not feasible from the operational point of view. It increases administrative cost and involvement of subjective judgment is prone to argument.

6. Format and business nature of domain names (section 39)

  • Domain name is not only used for a company to promote its product or service, it is an identity for corporations or individual in the cyberspace, it is a branding for a lot of different purposes that my be in existence or non-existence, therefore restricting names that is "similar" to a company is not reasonable. It also restricts the creativity how a user can make use of a domain name for building a new service/concept in the cyberspace.
  • It is also difficult to judge what is "similar" and what is not. With the same rationale of the comment made for section 37, it increases administrative cost and is not feasible as far as operation is concerned when a huge amount of registrations need to be handled on a daily basis.
  • It is suggested that as long as domain name dispute policy is in place and clearly communicated to end users, and that a mechanism and dispute resolution centre exists, the registrar should only perform a service provider function and let the dispute handled by appropriate party.
  • While discouraging cybersquatting is important, a balance between development of electronic market space and the restriction to minimize cybersquatting should be maintained

7. Transferability of domain names (section 44)

  • With the same rationale as stated above, transferability of domain names should be done as long as 2 parties agree and should not be judged by the registrar. It would be difficult to determine what is a "valid ground".

In summary, we would suggest the following:

  • Registrar should perform the function of administering a centralized database for .hk domain names and ensure the .hk DNS infrastructure is robustly and securely run.
  • Registrar should be a facilitator to provide registration services for agents and end users with a clearly defined set of rules that do not involve human judgment on whether a domain name should be registered or transferred.
  • It is not feasible for the registrar operation to determine "non-quantifiable" parameters such as "similar", "valid ground" to determine registration and transfer of domain names, particularly when the registration volume increase and human involvement will delay the whole process, and therefore the development of electronic commerce.
  • Other than identity protection such as registered trademarks, service marks, and restriction of registration of improper language (such as foul language), all other names should be allowed to register through the registrar. Any domain name dispute that is arisen beyond restricted list mentioned above, the parties should take it to accredited resolution centre. The registrar should not be in the position to determine whether such names should belong to which party
  • As such, the registrar should allow transfer of domain names as long as 2 parties involved agree to such transfer

We certain hope that our responses could be helpful to the Task Force in reviewing the Administration and Assignment of Internet domain names and Internet protocol addresses in Hong Kong. If there is any publication or circulation in the future, we would be grateful if you could add us - Chinese Domain Name Corp. - to your circulation list. We would very much like to contribute in any way to help the developments on Internet domain name administration as well assisting businesses set up and enrich their online Chinese identity and branding. Together, we believe we can bring the Internet to millions of Chinese users and these millions of Chinese users to the Internet.

Sincerely yours,
Woody Ho