Public Comments on the "Consultation Paper on the Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong"

Reference No. : DN05
Date of Submission : 15.06.2000
Submitted by : Mr Allan Dyer, Technical Director, Yui Kee Co. Ltd.

Subject: Comments on Consultation Paper on Review of Admin of Domain Names

I have a few comments on the "Consultation Paper on the Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong"

First, I did write a letter to ComputerWorld Hong Kong in April which is relevant to this issue. Having read the Consultation Paper, I have modified my opinion slightly, as detailed later. I include the full message to ComputerWorld Hong Kong here:

Forwarded Message Follows

From: Allan Dyer
To: ComputerWorld Hong Kong
Subject: Re: Viewpoint, April 21, 2000
Date sent: Fri, 21 Apr 2000 12:43:33 +0800

I will not stoop to Joe Sweeney's level of casting aspertions on the lavatorial habits of people he disagrees with, but I really don't see the problem he, and the frustrated clients of the Gartner Group are having about the one domain name per business registration limit in .hk.

Firstly, you don't get one name, you get a whole sub-domain. Although most people seem to stick with www, you could name your web servers by the business line. For my own company, I could create (these don't exist) candies.yuikee.com.hk, computers.yuikee.com.hk, education.yuikee.com.hk ... you get the idea. This combines obvious function with brand-name awareness. The name gets a little longer, but does this matter? If the content of the site is good, people will bookmark it and never type the name again. If the content is bad, a snazzy name will not help.

Secondly, there is no lack of business registrations in Hong Kong, and they often come in groups, as the number of Holding companies demonstrates (I would have thought this was obvious to the Gartner *Group*). Just check which of your subsidiaries don't have a domain name yet. All done, and just got an idea for *the* killer domain name and application? Why not register a new company to hold the name - it even makes it easier to go IPO later.

Shakespeare said something about roses, names and smell - he was right, it's content, not name that is important. Yahoo wasn't even a dictionary entry a few years ago, the content made the difference. When the dust has settled, it won't be the best name that emerges the winner, but the best content.

Regards,
Allan Dyer

End of Forwarded Message

In-line with the sentiments expressed in my letter, I still do not see a need for allowing unlimited domain name registrations. However, if the rule was kept as "one company, one domain name", then trademark names might remain unused, for example, where a company had more than one trademark. Therefore, I recommend changing section (50.p) to a limit of one domain name per company registration *and* one domain name per registered trademark.

I do support introducing domain names for individuals (section 42.g). It would be interesting, and could reduce the workload at the registry, if families could administer their own sub-domains. For example, if the second-level domain for individuals is person.hk, I could register dyer.person.hk, and create sub-domains allan.dyer.person.hk (for myself) and james.dyer.person.hk (for my son).

I disagree with restricting registration to a domain name resembling the company name, its products or services (section 38). This restriction makes difficulties for innovative companies with ideas for new businesses - for example, company A has an idea for an entirely new way of providing service X over the Internet. They do not currently provide service X, so they cannot register the domain name without making detailed revelations of their plans, or waiting until they have the new delivery method fully developed.

Meanwhile, a company providing service X by traditional methods could register the name. With my suggested restrictions above to one domain name per company and one per registered trademark, the risk of cybersquatting is greatly reduced, so it is feasible to allow registration of unrelated names.

Concerning the suggestion of replacing the HKNIC with a "non-profit making and non-statutory corporation" (section 50.a), I recommend the principle of, "if it ain't broke, don't fix it". In my dealings with HKNIC, I have found it to be fair and efficient (as opposed to the technical staff of my ISPs, who were surprisingly inefficient). Section 13 states, "However, with the rapid development of the Internet and electronic commerce locally, there are views as to whether the JUCC is able to adequately represent the interests of different sectors in Hong Kong in carrying out this function." but it does not justify these claims in any way. HKNIC has a proven track-record of providing the administration function successfully. In comparison, the registries for Chinese domain names are in total confusion - my company has registered a Chinese domain name, but there are no clues as to when the system will work. If the HKNIC and JUCC is happy continuing the work, then I see no reason to set up a new body at great expense to replace them.

I hope my opinions are useful to you,

Regards,
Allan Dyer