Received: 11 March 2014
Thank-you for the opportunity to submit comments on the proposed registration of .nz domains at the second level.
Many companies and individuals register more than one second level variant of their domain in order to protect themselves from typosquatting. For example it is common to register (e.g.) example.co.nz, example.org.nz and example.net.nz. I am concerned that clause 8 (Preferential Registration Eligibility) doesn't appear to allow for this possibility and therefore such registrants wouldn't receive preferential registration eligibility even though they are in effect the only registrant of the domain. I believe that 8.1.a(ii) and 8.1.b(ii) should be changed to recognise multiple variants of .co.nz, .net.nz, .org.nz by the same registrant as one domain.
I also suggest that where multiple domains were registered before 30 May 2012, then preference be given to the earliest registrant if that registration occurred more than 1 year before all other registrations of that name.