From:           James Nimmo
Received:     8 June 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
I believe allowing second level domain names would confuse the general public, make New Zealand domain names too sparse and unfairly advantage large companies which can afford one. It would severely increase the risk of phishing attacks.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?

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

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
This is conditioning users to look at a domain name to tell if a site is genuine or secure, but the current DNS system is insecure, and what is to stop someone registering, and pretending to be a special protection site.

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?
Yes to prevent man-in-the-middle attacks taking advantage of the WPAD protocol.

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?
To reduce the impact of domain squatters.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Neither party without agreement of both.

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?
No Response

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