From:           William Hoyle
Received:      30 May 2012

Question 1. Should the New Zealand domain name space be extended to allow registration at the second level, for example

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
Interest groups are free to enforce whatever third level rules they want after registering their second level domain. Any sufficiently qualified group will already have a third level domain and be eligible to register it during the sunrise period.

Question 4. Should new moderated second level domains be created to cater for domain names that require special protection, such as
If someone wants to carve out their own space they can.

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?
Yes and should be delegated for redirect.

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?

Question 7. Who should be allowed to register a domain name at the second level when there are competing registrations at the third level?
Anyone (although registrations from third level name holders should take precedence).

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 oldest registration. First come, first served is the traditional method of determining ownership in the DNS world.

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?
It doesn't include a sunrise period dispute resolution process (Question 8 mechanisms). Without a simple dispute resolution mechanism (such as first registered third level name) the "gold rush" is likely to result in tens of thousands of disputes and associated delays. The rule "Dave’s application for will only be granted if he can get Michael’s and Sarah’s consent" will result in a lengthy nightmare.

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