Petition US Dept. of Commerce in support of NAME.SPACE

pgMedia info at
Thu Aug 7 19:26:25 PDT 1997

Hello All!

The US Department of Commerce is soliciting
comments on the future of domain names on the

We here at believe that we have designed and
implemented the most all encompassing solution for the good
of the internet and in the interest of the public and free

This is a call to action in support of NAME.SPACE...

Please go to:

and "sign" the petition with your name and email
address, then submit the form to the mailbot who
will send it along to the US Department of Commerce.

For those who choose to write their personal views,
or otherwise comment on the petition,
please use the optional doit yourself form linked to
from the petition page.  All individual comments will
be emailed to USDoC as well as be posted on the public
forum on the NAME.SPACE website.

Please take this time to make your voices heard!

so please don't wait! time is running out.

For a preview, the full text of the petition appears below.
If you know people who lack web access, please pass it along
so they may participate via email.  Such submissions should
be sent to dns at

Please take a few moments to review the contents of the
petition and please, do pass this info on to as many people
as possible.

Thank you for your time and for your support.

Best Wishes,

Paul Garrin

----------------------full text of petition follows------------------


                   (The New Paradigm for the Old DNS)

I [YOUR NAME WILL BE INSERTED] do hereby support the design of the
expanded toplevel Internet namespace which is currently operated by
pgMedia, Inc.'s NAME.SPACE(TM) service, located on the internet at (or

The paradigm implemented by NAME.SPACE(TM) is the most
pro-competitive, democratic and open system proposed so far with
respect to opening up the administration and operation of the
Domain-Name-System ("DNS"). The structure advocated by NAME.SPACE(TM)
removes the artificial barriers to entry that exist today as a result of
the monopolistic control over the domain name registration market
exerted by Network Solutions, Inc. ("NSI"). The NAME.SPACE(TM) paradigm
incorporates a fair, competitive structure which encourages
investment and innovation by companies wishing to compete in the
provision of this service which is essential to the operation and
continued growth of the Internet.

pgMedia, Inc. has created, through substantial private investment in
research and development, its NAME.SPACE(TM) registry administered by
thirteen toplevel root-directory servers located in five countries. The
NAME.SPACE(TM) registry uses innovative and creative techniques which
bring the old DNS out of the Cold War and into The 90'S.

The NAME.SPACE(TM) system decentralizes the administration of DNS and
enables open competition in the Public Domain Toplevel Namespace
without regulation by any governments or quasi-governmental
authority, nor does it require the enactment of new laws or regulations.

Description of the NAME.SPACE(TM) service:

On the NAME.SPACE(TM) system, name registrations are taken by
registrars who administer client accounts under the given toplevel
name categories (publicly shared toplevel namespace). All registrars
must register their digital ID with a trusted third party/parties which
authenticates and authorizes them to function as registries. The
application process is administered by an independent company, similar
to the process used by banks when authorizing merchant credit-card
accounts, and the operation of secure servers used in commercial
transactions on the Internet today.

Registries update the database on demand based on the availability of a
given name address using the IDSD system (IDSD=Integral Database
Synchronizer Daemon), a secure protocol developed by pgMedia which is
available, without limitation or charge. (A detailed description of the
IDSD protocol can be found at IDSD
makes it technically feasible for ALL registries to share the toplevel
namespace equally, eliminating any technical justification for
"exclusive" control over any given toplevel name by a single registry,
such as NSI currently enjoys with ".com".

Registration is accomplished instantaneously through an interactive,
form-based interface on the World Wide Web with online payment
options via a secure server. During the registration process, a
registrant establishes an account, a contact "handle" and, of course its
"name". The registrant has the option to choose whether or not its
personal contact information will be publicly listed. All other account
information, of course, remains confidential. The registrant may then
establish a Portable Address Record, over which it has full
administrative access on the NAME.SPACE nameservers. This service
allows a registrant to change service providers and easily take its
"name" to a new host without delay or complications. Upon completion
of the registration process by the registrant, the NAME.SPACE(TM) system
immediately processes the information and creates the second level
entry into the toplevel database, which is then distributed to all other
root-servers via the IDSD protocol. The registration process and the
creation of Portable Address Records are instantaneous, and function
on the Internet within minutes, not days or weeks as in the current

Issues and Answers

Under the NAME.SPACE(TM) paradigm, the toplevel namespace functions as
a Global Directory Service and would be managed within the
competitive marketplace in the general interest of the Internet public
through the various independent registrars. Each generic TLD ("gTLD") is
administered by all registrars who wish to offer services thereunder
with no exclusive claim of ownership of any toplevel name by any
individual, corporation or government, subject to existing intellectual
property law.

These gTLDs may be added or removed based on public demand. Also,
gTLDs may include languages other than English, limited only to the US
ASCII character set, the English alphabet plus 10 digits and the hyphen
for a total of 37 characters.

All leading authorities are in agreement that there is no limit to the
number of possible toplevel names, as there is no limit to the number
of root directories under the UNIX file system. As NSI admits:

"DNS is highly scaleable. There is no technical limit to the number of
new top-level names that could be introduced. The original designer of
DNS, Paul Mockapetris, has verified the scalability of DNS."


Thus, any claim that expanding the toplevel namespace is technically
not feasible is simply unfounded. The proponents of such claims seem
to be guided by a desire to limit the potential market so as to create an
artificial scarcity which translate into higher prices and profits.

The use of arbitrarily defined and limited categories such as ".com" has
forced many registrants to engage in verbal gymnastics, and to rely on
unwieldy content-based search engines - this would be obviated by the
full implementation of the NAME.SPACE(TM) paradigm. Thus, for example,
Acme.computers and could both have a presence on the
Internet without having to artificially pervert their names. The
"byte-counter mentality," which has plagued us with the dreaded
"Millennium Bug," was responsible for the initial constraints on the
toplevel domain name nomenclature. The NAME.SPACE(TM) system simply
recognizes that such limitations have long since been eliminated and
are wholly artificial.

With respect to intellectual property issues, no regulatory framework
can assure the complete protection of holders of such rights against
infringement by unauthorized parties. However, the potential for such
infringement, which exists in all published media, should not be used as
a basis to limit the free speech rights of the vast majority of law
abiding users of the Internet, while protecting artificial monopolies.
Furthermore, it is wholly inappropriate to empower any registrar to
adjudicate the rights of holders of intellectual property, for that role
must ultimatly reside with the courts.

Fees for registration services should be dictated by the market. Waiver
of fees and discounts should be considered for qualifying educational
and non-profit organizations, as well as a selection of totally free
categories (such as the Free.Zone provided currently by NAME.SPACE(TM)).

In conclusion, NAME.SPACE(TM) has developed and implemented a new
paradigm for the Global Directory Services on the Internet by bringing
the function of the old DNS, a legacy of the Cold War, into sync with the
current dynamic of the public, global, civilian and commercial Internet.

The NAME.SPACE(TM) system is a reality today. The NAME.SPACE(TM)
automated registry has been fully functional for nearly one year now
and has proven its reliability and desirability as evidenced by the
thousands of users who have been using the NAME.SPACE(TM) servers to
resolve their DNS and those who have registered their names in

I fully endorse and support the endeavors of pgMedia, Inc. and the
NAME.SPACE(TM) system and highly recommend that the U.S. Department of
Commerce recommend and concur in its full implementation on the

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