From:           T Oaks
Received:     11 June 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
The current scheme is well understood on the internet and mirrored by many other countries. There is no additional need for added complexity by more names for the same organisation - as everyone will scramble for the new names. Additional names will dilute the logical effectiveness of the current name space in my view. It also just looks like a grab for more revenue.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
It seems there is good consultation, please weigh the value of commercial and non commercial equally.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
What are other countries doing? The current small set of domains clearly indicate what type of organisation one is going too on the internet, this is very useful for those that look at these things.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
If second level names such as this are created, some definitely require moderation.

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?
As mentioned in the first comment, the two main schemes - eg similar to the US, or similar to the UK have served us well so far, going for a mixed model will just muddy the waters.

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?
Yes - Only in the event second level names are issued then allowing existing organisations to acquire their "branded" names seems fair. It also prevents name brokers getting in quickly and then making a killing for no effort.

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
If second level is approved, then government and non commercial should have preference in my view.

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?

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?
No Response

Question 11. Are there any other comments you would like to make relating to this consultation?
I would hope that allowing 2nd level names is not just a revenue generation exercise. I see second level names muddying the waters of a currently fairly logical naming scheme.