From:           Nicola Tewhare, Internet Marketers Ltd
Received:     1 June 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
The although intended for commercial organizations was also considered the premium domain extension in NZ and people secured their domain names based on that assumption. They spent money and time on marketing their websites and in doing so branded themselves and their websites. If this new proposal goes ahead then businesses and individuals who want to secure their .nz equivalent will not only have to seek consent, but also spend more money and time on updating to a new domain extension. And that is provided their application for the new .nz is accepted.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
An email should be sent out to inform all domain holders of the new proposal.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
We should delete some of the ones we have now.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
If there was such an extension that was intended for a business group that required protection then Yes. But having that business set up a website on that particular domain extension is the problem. Up until now banks for example have been quite content with the

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?
These names could confuse people and mislead them into thinking they were official websites.

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?
These domain name holders have demonstrated a use for the name. We should offer them the first chance to register a domain at the second level.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
The oldest registration should be awarded with the .nz domain extension. In case the domain holder does not want it the new .nz domain should be awarded to the next oldest registrant.

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)
As above. Oldest registrations get awarded the new domain extension.

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?
Trademarks should be protected. However I do not agree that generic domain names should lead to dispute.

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?