From:           Daniel Reurich, Centurion Computer Technology Ltd
Received:    Tuesday, 4 June 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
If there is a change to second level domains, allowing a transition period could be helpful, but in the medium term having third level domains as well as second level domains would require users and businesses to register domains in both 2nd level and the third level at additional cost to them. The burden should be on NZRS to provide a transition path that won't burden the registrants of existing domains with additional costs

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
Adding another level of possible domain name registrations in the .nz tld namespace will cause unnecessary confusion for both registrants and users. The transition should be done at the dns level in providing a permanent redirection to the new 2nd level domain name. There should be no allowance for registrations at both the third level and the second level of the .nz domains. Instead a hard cutover date & time should be employed upon which 3rd level domain registrations should cease being available and unfettered 2nd level registrations become available.

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
Furthermore it should be strongly encouraged, and where possible it should be an automatic transition from a 3rd level domain to a 2nd level domain without additional cost to the registrant. Where there is conflicts between the same 3rd level name is used by different parties in each of the 2nd level namespace, the burden should be on NZRS to find an amicable solution that suits all the effected parties.

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
Concurrent registration of 3rd level domains and 2nd level domains shouldn't be allowed. Prior to the change between 3rd and second level domains, current 3rd level domain holders should be given new 2nd level domains, with NZRS/DNC responsible for resolving conflicts between holders of existing 3rd level names in different 2nd level namespaces. In addition it may also be useful to limit registration to nz residents and nz registered organizations.

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?

No
This only creates a burdensome process for all concerned. Instead the current registrant should get given at no additional cost a 2nd level domain name and the existing 3rd level domain be redirected to their new 2nd level domain once the dns records are created.

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
The reservation requirement can be completely avoided as previously mentioned by a forced transition from 3rd level to second level domains.

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
By forcing a complete move from 3rd level to 2nd level domains in one go, any disputes over subdomains of second level domains should largely be mitigated because cake.shop.nz and fruit.shop.nz could easily be resolved by combining the sub domain and domain name to make cakeshop.nz and fruitshop.nz. It may be useful to block the registration of generic domain names like shop.nz or names that will likely cause disputes between multiple potential registrants.

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

Yes

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

No
1)The incidence of disputes between parties wanting the same domain name will no doubt increase.
2) If 10% of 3rd level domain names would clash in a move to 2nd level domain names, that's going to stretch the resources of the DNC in resolving those disputes. However if the transition is forced rather the having concurrent registrations of 3rd level and nd 2nd level .nz domains, this increase in disputes will be largely temporary.