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Roger Clarke's 'Direct 2LDs'

Direct Allocation of 2TLDs within .au

Roger Clarke **

Submission to the Names Policy Panel of the Australian Domain Names Administrator (AuDA) on 9 June 2015

(c) Xamax Consultancy Pty Ltd, 2015

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Jo Lim

Chief Operations and Policy Officer


Dear Jo

Re: 2015 Names Policy Panel

My apologies for the lateness of this Submission. (I've been travelling overseas from early May until late June).

I'm a Director and Secretary of the Internet Society of Australia, but I'm making this submission in my personal capacity.

1. Downsides of Direct Registration in .au

The proposal to permit direct registrations within .au represents a potential bonanza for get-rich-quick merchants, but it would be:

(a) a thorn in the side of large numbers of established organisations, and

(b) a serious threat to the high standing of auDA.

Until now, auDA has not been perceived to be a money-grubbing monopolist, as ICANN is. Opening up .au - or indeed creating unnecessary new 2TLDs within .au - would, in many people's eyes, significantly reduce auDA's well-deserved reputation.

2. A Necessary Complementary Design Feature

If the proposal is proceeded with, then it is essential that protections be built into the design, not only for existing registrants in existing .au 2TLDs, but also for future registrants.

I submitted a quite specific proposal in 2007 (and I'm a little disappointed that the Issues Paper failed to reflect its content).

The proposition is that, because of the greatly increased contention for common abbreviations, registrants in the direct .au namespace need to have imposed on them a contractual obligation to implement a suitably-formatted preliminary 'disambiguation page'.

As an integral part of this submission, I re-submit the original document, accessible at:

Thank you for your consideration.

Roger Clarke

Author Affiliations

Roger Clarke is Principal of Xamax Consultancy Pty Ltd, Canberra. He is also a Visiting Professor in Cyberspace Law & Policy at the University of N.S.W., and a Visiting Professor in the Computer Science at the Australian National University.

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The content and infrastructure for these community service pages are provided by Roger Clarke through his consultancy company, Xamax.

From the site's beginnings in August 1994 until February 2009, the infrastructure was provided by the Australian National University. During that time, the site accumulated close to 30 million hits. It passed 65 million in early 2021.

Sponsored by the Gallery, Bunhybee Grasslands, the extended Clarke Family, Knights of the Spatchcock and their drummer
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Created: 9 June 2015 - Last Amended: 9 June 2015 by Roger Clarke - Site Last Verified: 15 February 2009
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