From:           Andrew May
Received:     20 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
This will dilute the value of the intellectual property rights held by existing registrants and may open the way for compensation claims from them. Why were the existing registrants not notified of such and important proposed policy change which will effect them, as stakeholders. The insignificant number of submissions when compared to the total number of stakeholders affected, indicates that the consultation process has been totally inadequate.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
If they wish to proceed with this unnecessary change, the should start the process again, notifying all existing stakeholders (registrants) and polling them.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
We have too many already.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
We have too many already.

Question 5. Should the registration of some names such as or, be prohibited at the second level to minimise potential confusion? What names, if any, should be prohibited?
Would lead to confusion.

Question 6. Do you agree with the rationale for the Sunrise Period that would enable existing .nz domain name holders first chance to register names at the second level? Why?
I agree with section 9.3, that no one should be able to register a 2LD when there are competing 3LD registrations.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Nobody. Without voluntary consent of all parties, only the lawyers will benefit.

Question 8. Assuming only persons with a conflicting third level domain name may apply, how should that conflict be resolved? By consent? Or some other mechanism?

Question 9. Should the Domain Name Commission consider extending its Dispute Resolution Service for a limited period to cover particular sub-domains when considering whether a name registered at the second level infringes a complainant’s rights?

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?

Question 11. Are there any other comments you would like to make relating to this consultation?
This proposal is not good for anyone except the registrars and is unnecessary. A simple software solution would suffice. If say, is requested and there is no such domain, then is pointed to. If doesn’t exist then try ... and so on in order of popularity of 2nd levels.