From:           Karl Ogle, KIWIreviews.co.nz (KIWIreviews.nz)
Received:    Friday, 14 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?

Yes
Registrations at the Second Level are fairly commonplace nowadays, and as such there are plenty of precedents to study for potential benefits and pitfalls. Taking that into account, phasing out the generic SLDs may prove highly problematic unless a rigid and definitive DRS policy is in place first. Concurrent 2-level and 3-level domains are confusing and will rapidly become unacceptable. A short lead-up period ahead of a rigid cut-over would be smarter. A transition policy should be put in place where old 3-level names get automatically redirected at the DNS level to the new 2-level domains for a period of 2 years, by which time companies and individuals have time to adjust branding, merchandise, advertising, etc.

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?

Yes
People will adapt quickly. They have in the past, they will in the future. This will not be an easy transition, but if it really does create long-term benefit, then it should be adopted.

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
This will go a long way to ensure protection of intellectual property rights and branding. Companies with existing .co.nz domains should be given their .nz domain for no extra charge until the end of current registration periods.

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

A hard cut-over should be set up, after an 6 month "application consideration" period to determine who, if more than one party, has a valid claim on the name. Automatic progression to the new namespace, by collapsing the Generic SLDs out of the namespace, should be actioned, with a prioritisation policy in place for those cases where no applications have been received. A transition policy should be put in place where old 3-level names get automatically redirected at the DNS level to the new 2-level domains for a period of 2 years, by which time companies and individuals have time to adjust branding, merchandise, advertising, etc. Consideration timeline: Day 0: Applications for a anyname.nz domain name can begin. Day 90: Applications close and applications start getting processed. Day 180: All applications should be resolved by this time. Day 181: Cut-over. Prioritisation: (Where no applications for potentially conflicting names has been received.) .govt (Although this should become a reserved domain, with all existing sites becoming subdomains) .mil .edu/.school/.ac .co .gen/.geek/etc - lowest priority eg. hamstead.ac.nz would have precedence over hampstead.gen.nz - thus hampstead.ac.nz -> hampstead.nz

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
AMBIGUOUS QUESTION. I think having 3-level and 2-level domains in play at the same time will prove far too confusing for the average internet user, and a hard cut-over is the wisest policy. This, there will be no need to allow for this situation. Furthermore, I think ALL domains, at any level, should have an "activity requirement" placed upon them. If the domain is not pointed at an active, functional site within 30 days of first registration, or becomes pointed to a non-active site - eg. a "this is the future home of..." holding page - for a period of 60 days, then a claim can be put against it by another party. If that party can show just cause for claiming the domain, the original holder should be given 28 days to get it active, or it should be transferred to the applicant. This will provide options and protections against cybersquatting.

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?

Yes
AMBIGUOUS QUESTION. No change, that's a good "warming in" period.

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
If a hard cut-over is actioned, there won't be anywhere near as many conflicts. If a solid policy is already laid out, disputes can be handled very quickly.

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

Yes
Where the domain name does not conflict with a NZ-based business, overseas registrants can be attracted by the phonetic use of the shorter namespace. eg. epinions.com -> epinio.nz

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

No
Nothing of any great or insurmountable relevance, if a hard cut-over is implemented and a solid DRS policy is in place prior to action.