From:           AJ Park, Damian Broadley
Received:    Thursday, 25 July 2013

Question 1. If you consider registering a .nz domain name in the future, would you like anyname.nz to be an option rather than a name under just the second levels, e.g. anyname.co.nz?

No
This is a terribly misleading question. The simple answer in any particular case might be 'yes', but it is the implication for existing registrations and the implications for registrants that don't want to register an xyz.nz that is the problem, not any new registrations per se. None of the proposed changes to the initial draft policy make any difference to those issues raised in our earlier submissions.

Question 2. Would likely short term confusion over a transition period be an acceptable consequence for offering a long term option of allowing .nz registrations at the second level?

No
This question presumes that any confusion would be short term and over a transition period. We disagree. In some cases confusion (and increased costs) would be substantial and ongoing.

Question 3. Do you agree that existing .nz registrants should get a priority right in obtaining their name at the second level if this proposal proceeds?

Yes
But we propose a tie breaker if there are more than one. Either the oldest registrant or one who owns a registered trade mark. Preferably the latter since trade marks are recognised in every other sunrise period everywhere ever.

Question 4. Do you agree with the approach in the draft amended policies if we proceed with this? What, if anything, would you change?

No Response

Question 5. Do you support the proposal that a current registrant of a .nz name at the third level should be able to reserve that name at the second level for no cost if they wish to block others from registering it but not actually utilise it themselves?

Yes
But we probably wouldn't use it for ourselves or our clients. The cost of the registration is negligible in the bigger picture, it is the management time and cost and risk and work required to minimise confusion that is problematic. Doing this for 2 years and then having to register the domains anyway just adds more work in two years time. Businesses will need to own the .nz permanently anyway, so it will be easier just to register it in the first place.

Question 6. Is two years an appropriate time to wait before reviewing policy to allow a reservation at no cost? Should this time frame be longer?

No
See above.

Question 7. Is two years an appropriate time to wait before reviewing the policy to extend the Dispute Resolution Service to sub-domains of second level registrations? Should this time frame be longer?

No
Longer please.

Question 8. Do you see any benefits from allowing registrations at the second level which have not been covered in this paper?

No

Question 9. Do you see any detrimental effects from allowing registrations at the second level which have not been covered in this paper?

Not that haven't been canvassed already.