Public Comments on the "Consultation Paper on the Review on Administration and Assignment of Internet Domain Names and Internet Protocol Addresses in Hong Kong"

Comments on Consultation Paper
 

The Hong Kong Web Hosting Association is founded by a number of local web hosting companies in April, 2000. Our mission is to promote the web hosting and domain name services industry and protects the industry interest. Regarding the Consultation Paper on the future arrangements for the administration and assignment of Internet domain suggested by the Task Force, we agree with most of the policies. However, judging from the point of view of the industry interest, we do have the following suggestions that represent the common needs and concerns of our members.
 

1. (k) The registration from .com.hk, .org.hk and .net.hk domain names may engage agents to perform some of the routine registration work.
We suggest that the registrar should not be involved in the routine domain registration work. The current policy in which customers should register local domain names through ISP or web hosting companies with local DNS servers should be kept. If customers can register any domain names through an online registration form provided by the registrar, the application system must be well security built and the primary and secondary DNS must be presented when application taken.
 

2. (l) A reserved list of domain names consisting of well-known international trademarks, service marks and brand names as well as some other names which are of restricted use, making reference to the reserved lists prepared by other ccTLD registration authorities, may be drawn up.
Disagree. The free market policy has been proven successful in Hong Kong. Such restriction will only limit the growth of the Internet market development. Also, it is hard to well define the list. The implementation of the rule will be difficult. Instead of setting new restrictions, the task force should consider releasing number the restrictions on registering number domain names and single-character domain names to promote the domain name service industry. Such kind of domain names are very popular in the US and there is no such kind of restrictions for registering any .com domain names.
 

3. (m) The 2nd-level domain category being selected for a particular domain name application should correspond to the business nature of the applicant.
We disagree with it because it is very difficult to prove the relationship of the name and the business nature of the applicant. It may also increase the work load of the local ISP and web hosting companies if they need to help the applicants go through the approval procedures.
 

4. (o) The domain name applicant should declare, when making an application, that to its best knowledge, the domain name applied for does not infringe upon the intellectual property rights of a 3rd party
Even if the applicant has made such declaration, argument may still arise because a regular applicant will not have sufficient information nor knowledge to determine whether or not the domain name has infringe the intellectual property rights of a third party. Such policy may not be enforceable.
 

5. Each organization should be allowed to register more than one domain name under .hk.
Multiple domains registered by a single company is a good thing, but will very quickly lead to squatting and greatly increased sale/trade of .com.hk domain names, which is undesirable. Instead, we propose a maximum number of 50 domains for each company, same as the policy set by CNNIC. This will allow the company enough freedom to register the domain names of their products and/or alternate company name spellings among other things, but prevents widespread abuse of squatting. It will happen, but this will keep it to a manageable level. These two changes together will have a similar effect as charging a yearly renewal fee, but will maintain the attractiveness of .com.hk domains compared to .com domains. Enforcing that name servers remain authoritative for domains will make unused domains available for registration by others, as they should be. This also reduces the attractiveness of squatting, as you not only have to register the domain, but maintain the name servers for them as well. The average user will not be able to do this, and most ISP would be unwilling to participate unless they get paid, which further reduces the attractiveness of squatting. hknic should charge whatever fee is necessary to maintain costs, but as a one-time-only fee. This fee might be re-evaluated from time to time to increase or reduce as appropriate. A yearly renewal fee is very likely to be unrelated to the actual costs of maintaining the registry, and might generate a lot more income than is needed, increasing the chances of corruption or mis-use of funds.
 

6. (t) Domain names should be subject to renewal at a fee
We are strongly against the idea of charging annual or renewal fees. This will greatly reduce the attractiveness of registering a .com.hk domain. To address cleaning out of abandoned domain names, instead a policy should be made to enforce deletion of domain names registered under name servers which are now lame for that domain. If hknic doesn't receive enough revenue from new registrations and modifications, the one-time and/or modification charge should be increased to match costs. If domain names are subject to an annual or renewal fee, people will be much more likely to register a .com domain with a us$8/year .com registrar. The cheaper .com registrars often have problems, and lost passwords are a major pain, both retarding the development of Internet in Hong Kong. The current .hk domain registration system is very simple, straightforward, and doesn't have any problems with changing legal ownership or modifying name servers, so it increases its attractiveness. Nobody will be locked out of their .com.hk domain.
 

7. Other suggestions:
a) With reference to the domain name policy in United Kingdom(.UK), India(.IN), Hungary(.HU), more second-level domain names, such as .ltd.hk and .pri.hk, should be made available for applicants to choose from. A higher registration price may be acceptable to the public. Therefore, not only will it generate higher revenue for the registrar, but it will also increase the source of income for the web hosting industry.
 

From our members' experience, many customers register a domain name but never build a web page with it. It, to some extend, may lead to squatting, which is undesirable. We suggest that each domain name should be developed, with at least one welcome page. If it is left blank for a certain period of time, the registrar should reserve its right to delete the domain name and release it again.