From:           Buy NZ Made, Trina Snow
Received:    27 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example yourname.nz?
No

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
Yes
Buy NZ Made agrees with Digimark: that the creation of second level registrations will create confusion amongst internet users and whilst may create short term ‘opportunities’ for cyber squatters will lead to higher costs for registrants looking to protect their trademarks and existing domain names. Accordingly if the creation of second level registrations were to be allowed then priority registration would need to be given to current registrants and also ways of reducing the cost burden should be assessed e.g. half price registrations of second level registrations if have corresponding third level registrations etc.

Question 3. Should new second level domains be created to cater for particular interest groups, such as .wine.nz or .sport.nz?
Yes
Yes. We support choice in the market place where the adoption of new extensions does not undermine the existing extensions or create confusion. However, we would like to point to the recent launch of .kiwi.nz which was on a first come first served basis with no sunrise period has already created issues where we have already had our domain names registered by a party that has no perceivable direct interest in the name.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as .bank.nz?
No

Question 5. Should the registration of some names such as .com.nz or .gov.nz, be prohibited at the second level to minimise potential confusion? What names, if any, should be prohibited?
Yes
Any names likely to cause a lot of 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?
Agree
It provides opportunity for companies to protect their IP

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Where there is an obvious company connection to the domain name and there is an active website in use under the domain name for that company, that company should not be held to ransom by cyber squatters holding onto the same third level domain name.

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?
Other (below)
In many cases consent may work, however where cyber squatters have registered domain names which are not actively pointing to any web site, as mentioned in Question 7, they should not be able to hold active users of domain names to ransom or hold up any consent.

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?
Yes

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

Question 11. Are there any other comments you would like to make relating to this consultation?
No Response