From:           MSN New Zealand Limited, Liz Fraser
Received:    17 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
All businesses will need to register a second level domain name to maintain their brand and legal entity. This appears to be a money-making exercise for Internet NZ.

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
This blurs the line for businesses. Anyone could then register, using the McDonald's brand name and entity.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
Again, this means all banks would be required to register and pay for a second level domain name just to preserve their brand eg and For portals such as MSN, we would need to register many second and third level domain names eg,,,, ...

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?
If 2nd and 3rd level domain names are to go ahead, then all existing businesses that have already registered and/or .com names should be allowed to protect their brand name, at no charge. This is fine for individuals, but not for businesses. Why would it be ok for a government organisation to be protected and to minimise potential confusion? The same rule applies to all businesses. By creating 2nd and 3rd level domain names, this will naturally create confusion for customers and for all businesses.

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?
If the second level domain name has to be implemented, then of course businesses should be allowed to secure their own brand urls. Because of this, that is why it is a money making exercise.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
No Response

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)
The business should be able to secure their own brand's name at 2nd and 3rd level.

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?
But only if the process actually works.

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