From:           Tim Wild, Wild Photography
Received:     31 May 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example
If this had been done years ago it'd have been a good idea. Now though domain owners will have to register each .nz domain for their domains to protect their trademarks and brand. This provides no real benefits to anyone, other than revenue gathering. It will result in the same website on multiple domains, probably forwarded to one domain or other. It will cost small businesses double each year for domain registration.

Question 2. Are there any other undertakings that the Domain Name Commission should make while developing/implementing the policy?
Domain owners will have to register the .nz domain to protect their trademarks and brand. All owners of domains should be given free registration of the .nz domain for 2-4 years while they migrate to the .nz domain, and registrations of their domain should be prevented. I agree that domains should be phased out if .nz is bought in. Each domain owner should be contacted by email to ensure they're aware of these changes.

Question 3. Should new second level domains be created to cater for particular interest groups, such as or
Multiple websites with different suffixes will be confusing for the public.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
This will help protect the general public ensure they're not being scammed.

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?
Anything reasonable to ensure security and minimise confusion.

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?
This is absolutely essential, plus every current domain owner should be notified by email to ensure they hear about it. If it's not done, and widely published, domain name speculators will grab domains and try to extort business out of significant amounts of money.

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 person or company who registered the descriptive part of the domain earliest.

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?
A quick read suggests the approach is to say "not our problem" and let the courts resolve it. That's expensive for everyone.

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