From:           New Zealand Institute of Patent Attorneys, Corinne Blumsky
Received:    27 September 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example yourname.nz?
No
The NZIPA does not believe that any perceived advantages outweigh the obvious disadvantages if the proposal were to go ahead. We agree with the many submissions against the proposal which have pointed out those disadvantages.

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

Question 3. Should new second level domains be created to cater for particular interest groups, such as .wine.nz or .sport.nz?
No Response

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as .bank.nz?
No Response

Question 5. Should the registration of some names such as .com.nz or .gov.nz, be prohibited at the second level to minimise potential confusion? What names, if any, should be prohibited?
No Response

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?
Disagree
We believe that priority should be given to owners of legal rights (trade marks) to a name before third parties with no rights.

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 one with a trade mark registration.

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)
Priority to the one with a trade mark registration.

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?
Yes
But permanently, not just for a limited period.

Question 10. Is the approach as outlined in the proposed amended policy in Appendix C appropriate? Why?
Yes

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