From:            Jed Laundry
Received:      30 May 2012

Question 1 Should the New Zealand domain name space be extended to allow registration at the second level, for example
It pains me to come to this conclusion, as it is evident reading this consultation paper that there has been great effort and thought put into this proposal, and as public perception of 2LDs is changing perhaps I stand alone. However; - I believe the current .nz layout promotes structure and well represents New Zealand, in comparison to the clutter, chaos and under-utilisation of other ccTLDs, namely .us. - I believe there could be a place for more g2LDs or s2LDs in .nz which are available to all, which would be removed by allowing closed organisations to reserve 2LDs. - And, selfishly, I do not ever want to see a variant of again, which would be made easier with opening of the .nz 2LD space, i.e. or

Question 2 Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
I have no answer.

Question 3 Should new second level domains be created to cater for particular interest groups, such as or
We should be careful to allow more g2LDs or s2LDs such as or The biggest problem I see is that if public perception is that "structure is creating clutter, therefore remove the structure", 2LDs should only be created if there is sufficient interest/demand for it.

Question 4 Should new moderated second level domains be created to cater for domain names that require special protection, such as
Certainly would seem logical from a security perspective, if the banks were willing to move their domains. However, as per my answer to question 3, public perception of clutter needs to be considered.

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?
Absolutely. Any regional variant (, or obvious keystroke error ( would be obvious, would not) of any current or future 2LD should be restricted.

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?
(in)voluntary consent should be the only mechanism for conflict resolution - if this means private buyouts or civil court action, so be it. It would be a different story if there was an existing mechanism for contesting an existing 3LD registration on the grounds of squatting.

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?
The DRSP should be applied permanently, not temporarily for 2 years, to offer the same protection to future trademarks.

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?
No Response