From:           Jim Cheetham
Received:     1 June 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
Given that ~90% of nz registrations are already in, what problem besides vanity will be addressed by having

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
Moderate the contents of at least and (i.e. grandfather in all current registrations, apply a policy to new registrations, and have a dispute policy to allow old registrations to be compared to policy). Create and mirror 100% of into it -- that extra 't' is inane, and impossible to pronounce, and unexpected from a global perspective.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
Allow new 2LDs by all means, but only after comparing them to existing 1LDs (of which there will now be arbitrarily more) and popular 2LDs of others. But own them, don't delegate them (i.e. can complain to DNC)

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
If there is a reasonable policy, and the 2LD passes the tests in my previous answer, DNC should allow the domain, and quickly. As long as the policy used is open and accepted by the membership, apply it and let the members of the 2LD police it themselves.

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?
Block everything that's a top-level domain? Block everything that's a popular 2LD elsewhere.

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?
Existing nameholders are currently involved in the DNC by participation, they have an investment in the NZ domain space. Reward that.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Anyone at all; if an existing name holder of 3LD didn't register during sunrise, they obviously don't want their name enough.

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?
In your own words, "A fundamental policy principle of domain name registration in New Zealand is that registrations are on a ‘first-come first-served’ basis. " So the first registration is the one that wins. If you run an extended submission period in order to collect requests and to evaluate them before allowing them, you are violating that policy. However, the dispute resolution service actually contradicts that policy, doesn't it?

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?
If you want this, then the whole .NZ has to become moderated. isn't moderated today. Is there a real problem that isn't dealt with?

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
tl;dr Actually, I'm just not interested at the moment in those modifications because I don't agree that should be allowed anyway.

Question 11. Are there any other comments you would like to make relating to this consultation?
I haven't seen a compelling reason to allow at all so far, only "well other people have got them". I'm in favour of more regulation of names (i.e. moderating more 2lds) than otherwise. What real operational issues would be solved with this proposal? Nothing. You introduce a significant level of confusion with the question of ownership/responsibility for a 2ld name -- at the moment it's 100% DNC, who may be running a policy on behalf of someone else (e.g., which is also a stupid domain, and only necessary because of the presumption that "meant" Company, as if it had a controlling policy, which it doesn't) Tin-pot registrars who enjoy frivolous money-making registrations have open 2lds. NZ is not cc, ly, me or anything like that. Keep our domain neat, organised, and meaningful please.