From:           Joel Wirāmu Pauling
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 is a directory service, any arbitrary restrictions on that fact only confuse the matter.

Question 2 Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
I think the consultation paper adequately goes through the main points (such as reservation of several 'PHISHABLE' or objectionable 2tlds)

Question 3 Should new second level domains be created to cater for particular interest groups, such as or
Oversight as is used for the existing and other 2lds should remain in place where there is disputes - but regulation around registration etc has not and should not be enforced beyond existing status quo norms. It is arguably a legacy function to have .govt. .co. .net. .org. etc etc let's not stoke that fire.

Question 4 Should new moderated second level domains be created to cater for domain names that require special protection, such as
If there is significant interest in obtaining and using a specific TLD then let that be resolved in retrospect. My suspicions based on experiences with .mobi. etc are that there will not.

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?
Where there is risk to the dignity and/or standing of existing norms then there should be some appropriate reservations. Including the legacy subset that are commonly used as partially regulated 2lds over seas ( etc etc ) as well as those which potentially might be used for hate speech purposes ( ,, ) etc etc. ). However as with the existing 2lds these are the same issues. So the same set of rules and norms as exist should be applied. Effectively this means giving registrars guidelines and for them to be arbitrators of registration, with the DNC stepping in if there are issues.

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?
It is an open market - if there is a significant threat to their branding/trademark then they are welcome to seek that avenue for objection if a party is unable to secure their preferred 2ld.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
It is a directory service for IP address's not an organisational structure. Arguably hierarchies exist now for purely historical reasons - anyone should be able to register.

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)
through the usual DCN process.

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?
as above

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