RFI Response_ Connecting NYC by hcj


									                       Creating a Safe and Vibrant Space on the Internet for New York City

May 27, 2009

Paul Cosgrave, Commissioner
Department of Information Technology and Telecommunications
  via email

Dear Commissioner Cosgrave;

The .nyc TLD provides the opportunity for New York City to fashion the Internet to further
its own local civic and global business opportunities.

Our long standing and carefully designed vision as presented in the enclosed RFI will allow
NYC to take its place atop the Internet’s borderless state to provide preeminent
connectivity, utility and security for residents, visitors and businesses.

Our wiki, blog, website and outreach efforts continue to ring valuable insight into the most
advantageous methods for operating the .nyc TLD. We will periodically appraise you and
other entities interested in .nyc’s developments.


Thomas Lowenhaupt

Thomas Lowenhaupt, Founder and Chair
Connecting.nyc Inc.
Jackson Hts., NYC 11372
718 639 4222
Web - Wiki - Blog

              Comments in Response to the
          Request for Information on the .nyc TLD

                   To the City of New York,
Department of Information and Telecommunications Technology

                  by Connecting.nyc, Inc.

                       May 27, 2009

              Connecting.nyc Inc. & the .nyc TLD

Introduction - From Resolution to Reality

When Internet technology became a global force in the 1990's, it reduced the
limitations of time and space and suggested that travel was no longer necessary to
exchange ideas and to evaluate people and products. With broad acceptance of this
notion the Net diminished the proximity advantage that cities have historically
offered. As well, by scattering resident and organization websites over dozens of
Top Level domains or TLDs - .com, .net, .gov, .org, .tv, etc. - the Net disconnected
the community - there is no New York on the Internet. And most regrettably,
many benefits the Internet's powerful capabilities can bring to the organization and
operation of our city remain outside the realm of possibility without a .nyc TLD.

The .nyc TLD provides the opportunity to put the Internet to work addressing local
issues and opportunities that are the blight and beauty of our lives. As well, it will
enable New York City to positioning itself as a new Trusted Center of Global

Success with these efforts depends on an education effort that persuades New
Yorkers that the TLD is a foundation resource for their future; that it is worth the
effort required by a learning curve, and that a moderate investment and the
ongoing care like that which one provides to one’s home, will result in better lives
for us all.

Connecting.nyc Inc. & the .nyc TLD

Connecting.nyc, Inc.’s founders trace their involvement with ICANN and city TLDs
from 1998. The organization evolved from Queens Community Board 3's Internet
Empowerment Resolution of April 2001 calling for .nyc’s acquisition and
development in the public interest. While that Resolution hoped for a rapid
acquisition, priorities in the city and at ICANN demanded otherwise.

In 2005, when it became apparent that a path toward the issuance of new TLDs
was being cleared, a member of Community Board 3 reinvigorated the effort to
bring .nyc home. With TLDs being virgin territory for cities, gaining support for the
concept from existing entities proved difficult. To facilitate the Resolution’s
implementation, in 2006 a small group of New Yorkers, determined to assure .nyc's
acquisition and development in the public interest, took steps leading to the
formation of the New York State not-for-profit Connecting.nyc Inc.

After years of advocacy by Connecting.nyc Inc. and others interested in creating a
place for cities on the Internet, the ICANN adopted its New TLD Policy in June 2008,
a policy that included cities as eligible applicants for TLDs. As a result, Berlin, Paris,

Barcelona, and other cities will apply to ICANN for their city TLDs in 2010 and begin
using the Internet's Domain Name System to organize their resources to more
effectively participate in our increasingly digital world.

From the beginning Connecting.nyc Inc.’s vision has been that the effective
development and use of the Internet required remedial and ongoing education.
That if chaos and disorder were to be avoided in developing the .nyc TLD, planning,
education, and care were to be the criteria that would guide the city’s newest

In reviewing our responses to the RFI, note that we view the technical operation of
the .nyc TLDs registry as the responsibility of contracted organization. Our role and
goal is to create an operational and oversight structure that will provide the best
technology for the residents and organizations of New York City and to establish a
mechanism that will facilitate .nyc’s integration into the existing operation of our
great city.

This RFI response is another chapter of our enduring commitment to educate
ICANN, other countries and initiatives, business, and the public as to the need and
benefits of city TLDs. We respectfully point to our website, blog, wiki for more
insight as to our longstanding efforts and vision.

We are delighted that New York City has chosen to evaluate the introduction of the
.nyc TLD as a tool for the City's development. Intelligent development will lead to
very substantial income streams and result in a heightened measure of control of
our City's presence and identity on the Net.

Over the years we've gathered a wealth of information about the operation of a city
TLD. Some of that information is reflected in the following. Our wiki and blog
contain the full body of our explorations.

In reading the following please note that we've presented options and opportunities
rather than firm recommendations. Our intent has been to withhold conclusions and
contractual entanglements pending the formal engagement of the city government.
We welcome the beginning of that engagement with this RFI.

                     Responses to Request for Information

      Suggested potential uses for the .nyc gTLD

Every day the globe shrinks as new social media connect us in previously unimagined
ways, at home, the office, and increasingly while mobile. Video, text, voice, maps,
documents, discussions, product and service information, invention, records, and plans are
being digitized where feasible. But much digital information remains isolated in silos and
walled gardens and is not shared over the Internet. The Internet's Domain Name System,
or DNS, facilitates making this digital information findable within this swelling ocean.

Invented in the early 1980's, the DNS provides the naming structure - the .com, .org, .gov,
.edu, .us, etc. – that is part of the many websites we daily traverse. If intelligently
managed, this naming structure provides insight into the nature of the information
provided within. When we access a .gov site we understand that a government is
responsible for the information provided. When on an .edu site we understand that it is
under the pre-authenticated flag of an accredited educational institution.

The quality of the DNS varies though. A .org has significantly strayed from its original not-
for-profit intent, as global registrants continue to secure those names for an array of
purposes due to an open, un-authenticated namespace.

Presently New York City's resources for residents, visitors, and businesses are scattered
over the web on .com, .org, .tv, and dozens of other TLDs. The .nyc TLD would serve to
house much of that content, creating the necessary structure, organization, and innovation
for the City – residents, businesses, government, not-for-profits, everyone - to grow and
operate in this new technological age.

Because of the Internet's size and the limited effectiveness of the DNS, search engines
have become the primary method for locating Internet resources - websites, documents,
pictures... This puts the algorithms that control their operation in command of how New
York City's resources are located by residents and visitors alike. New York not only doesn’t
have a place in the DNS, it is not in control of the signposts that lead to its disparate
locations on the Internet.

We have the opportunity to change that with the arrival of the .nyc TLD.
The .nyc TLD will provide a clean slate for developing New York City's space on the Internet.
It will enable New Yorkers to connect with one another and for the world to better locate our
vast resources. It will provide a platform upon which we can better control our future while
offering economic development and quality of life improvements.

A good domain name is typically short, descriptive, and memorable. The .nyc TLD will
provide names for new businesses, names that capture a community need and connect like
minded residents, names that facilitate civic discourse, and "portal" names that make the
city's resources visible to the world.

On a fundamental level, the DNS is about providing names that make locating an Internet
resource easier than remembering its technical address - nyc.gov rather than

Economic Development

      City Marketing / Tourism - The city can better market itself globally as a tourist
       destination and business market by setting aside and assuring the effective
       management of names such as hotels.nyc and tours.nyc. Effectively developed, the
       .nyc TLD will be a force to move the city from fourth place in the Anholt City Brands
       Index to first.

      Small Business and Organizations - Local businesses and organizations will have
       access to short, descriptive and memorable domain names facilitating their
       networking needs. Today acquiring a good domain name has become a significant
       budget item. (See prices paid for recent sales of good .com names.)

      Domain Name Revenue - Domain name registration fees will remain in the city.

      Matching Global Competition - New York City will be better able to serve as a
       corporate headquarters city with competitors like Singapore (.sg) and Hong Kong
       (.hk), which received TLDs as nation-states, and .Paris, .Berlin and Barcelona (.bcn)
       which have announced TLD acquisition efforts.

Quality of Life

      A More Livable City - Daily life in the city will improve with an organized and
       intuitive Internet organizing and presenting city resources. For example, if searching
       for a school, people will trust their intuition and begin at schools.nyc.

        Improved Community - Community memory and communication will be improved
         enabling residents to more easily locate and network with one another to identify
         issues and organize for their resolution.

        Internet Access and Development - Connecting.nyc Inc.'s mission is to provide
         training and education about the .nyc TLD and the Internet. Funds raised through
         name sales and other revenue opportunities will be used to promote and provide Net
         services for all New Yorkers.


When the Commissioners Plan of 1811 created Manhattan’s street grid, it organized and
provided ready access to the city’s real estate resources to great economic gain. We see the
.nyc TLD as the Plan of 1811's digital parallel, as an organizing platform facilitating access
to the city’s Internet resources. The key enabling features provided by the .nyc TLD include:

     Good Domain Names – Names that are short, descriptive, and memorable.

     Identity - Every .nyc domain name says "Made" or "From" New York City.

     Intuitive Search

     The .nyc Portals

     Advantaged Search Engine Positioning

     Trusted TLD

     “Trademark” Benefits

A description of these features follows.

        Intuitive Search

Today, intuition enables one to enter a Fortune 500 name - say IBM.com - into the address
bar and expect a direct connection. But beyond a few giants, 99% of the time people are
better off doing a Google search.

But as residents become aware of .nyc's intuitive design (and those of other city-TLDs), that
will change. As educational efforts place .nyc into the consciousness of city residents they
will begin trusting their instincts and try entering the name of a local restaurant or clothing
store with a .nyc suffix and hope, and later expect, a direct connection.

With careful design, education, and time people will learn they can enter 75th-street.nyc
and find very local news, or queensfoundations.nyc to locate a listing of foundations serving
Queens. Today, you'll receive 1,670,000 Google hits for Queens foundations and
www.75thstreet.com will land you in a Kansas City brewery.


A step beyond Intuitive Search is using local sites for global TLDs. For example, coke.nyc or
nike.nyc will provide local job info, product distribution points, sponsored events, etc. The
public will learn that these intuitive glocal (globally-local) sites provide the results they

If an intuitive search landed on an unassigned domain name, .nyc could take you to a
combination index and "WhoIs" page. There one might refine a search or take the
opportunity to purchase an available domain name. This contrasts with today's .com world
where a wrong guess frequently lands one in a domain of charlatans.

There’s no panacea with .nyc, but we will be dealing within a universe of 8,400,000 people
living within 400 square miles, not 8,000,000,000 spread over the globe. Connecting.nyc
Inc.'s recommended awareness and education efforts will guide the public to a more
intuitive city.

        The .nyc Portals

A key feature of the .nyc TLD will be its portal and helper pages.

        Portal Pages - With names like schools.nyc, hotels.nyc, and parks.nyc, these pages
         will be set aside as search aides. Portal Page Guidelines will establish that alpha and
         geographical searches be facilitated on directory pages. Editorial and advertising
         content might also be found on portal pages, with advertising revenue shared
         between the page maintainer and .nyc, depending of policies that establish the .nyc
         TLD. The number of portal pages and the qualifications and responsibilities of their
         developers - yellow page operator, an industry group, or small businesses - has not
         yet been made. A Portal Page Management discussion on our wiki addresses the
         how, how many, and who of directory pages. And a Portal Page focuses on the
         elements that will ease navigating the .nyc TLD.

        Helper Pages - Access to portal pages will be facilitated by various helper pages
         such as index.nyc, directory.nyc, portals.nyc, and help.nyc.

With these features one might enter bakeries.nyc (or bakery.nyc) and receive a portal page,
providing alpha and geographic searches - via a clickable map. If unsure about a search
term, one could enter a helper page and peruse an alpha listing of portal pages. In our
multi-cultural city, these helper pages should include several languages with pétrisseuse,
pétrisseur, panaderia, enfrente mixed in with English synonyms like pastry.

        Advantaged Search Engine Positioning

Let’s imagine you try an intuitive entry or two for your local bakery and then look through
index.nyc and still can’t find your favorite cruller. So you enter “bakeries New York City” in
Google’s search field. What might you expect? Experts from Google and Yahoo have said
that search requests which include ".nyc" will rank domains which have ".nyc" as their TLD
much higher. Thus a search "east side bakery in Manhattan" will show
www.eastsidebakery.nyc higher in Google’s listing than www.eastsidebakerynewyork.com
or www.eastsidebakeryny.com.

Other advantages arise from this as good domain names, i.e., those that are short,
descriptive, and memorable, will translate into "findable" on search engines.

Following this search engine logic, businesses will learn that if their domains are located
within the .nyc domain will avoid competitors in the larger .com TLD.

     Trusted TLD

Identifiable and Trustable is another substantial advantage that .nyc will offer. While not
approaching the trust and security an FDIC label provides banks, a well managed TLD can
provide a measure of comfort in these days of spam and scam. For example, think of the
comfort one feels within a more managed TLD like .gov or .edu.

In contrast to open TLDs like .com, .net, and .org, the .nyc TLD should establish criteria for
those seeking a .nyc domain and provide ongoing oversight. To qualify for a .nyc TLD, the
policies for acquiring a .nyc name should require some form of presence or nexus in the city
(discussed below).

Oversight should include processes that convince the public that websites operating under
the .nyc umbrella are accountable. At the same time provision should be made to enable
residents and businesses to launch rapidly, to facilitate proposing new ideas, and to provide
breathing room that enables the First Amendment to live within the .nyc TLD, with new
names subject to post review and rapid take down processes for names that violate
community standards.

     Local “Trademark”

Another search benefit of .nyc will arise with increased availability of local TLDs, or what
might be called the local trademark issue. Trademarks were traditionally local in scope. And
there are thousands of local businesses (bakeries, copy shops, delis, hair cutters etc.) that
use generic business identifiers like Star, Blue, York, Cook, Magic, Link, Finest, Sun etc.
Having a .nyc TLD will enable more local identity for companies using the same name used
in other cities. While Chicago's Fresh Bakery may use freshbakery.com and Toronto has
freshbakery.biz, with the .nyc TLD, New York can have a freshbakery.nyc. With a city TLD
we can return a bit to the traditions and quality of the past, as judged by local residents.

Another view the uses of .nyc is via the allocation of domain names.

Names Reserved as per ICANN Contract
Our review indicates that comporting with ICANN recommendations on reserved names for
technical and public policy reasons is advisable. The ICANN will likely require that the
following second level names be reserved: 0, 1, 2, 3,4, 5, 6, 7, 8, 9, a, AFRINIC, APNIC,
ARIN, ASO, b, c, ccNSO, d, e, Example, f, g, GNSO, gtld-servers, h, i, IAB, IANA, iana-
servers, ICANN, IESG, IETF, Internic, IRTF, ISTF, j, k, l, LACNIC, LATNIC, m, n, NIC*, o, p,
q, r, rfc-editor, RIPE, root-servers, s, t, test, u, v, w, Whois*, www*, x, y, z.. The * names
are reserved for use by registry operators only.

Names Reserved to Facilitate the Operation of the .nyc TLD
       index.nyc
       portal.nyc
       help.nyc
       connecting.nyc

Names Reserved for Intellectual Property Holder
"Sunrise" periods provide existing trademark and other intellectual property (IP) holders
with the opportunity to reserve names in the .nyc space.

       Trademark Sunrise Period - National and international trademark holders might seek
        names such as: www.siemens.nyc, www.hyatt.nyc, www.porsche.nyc,
        www.lufthansa.nyc, www.ebay.nyc, www.google.nyc, www.newyorkpost.nyc,
        www.ibm.nyc, www.nytimes.nyc, www.coke.nyc. Traditionally a 1-2 month period is
        set aside for such trademark holders.

       Local Sunrise Period - We are considering having NYC based companies and
        organizations provided with the opportunity to reserve familiar names such as
        www.cuny.nyc, www.nypl.nyc, www.nyu.nyc, and www.queenscollege.nyc.

Names Reserved for Future Use
Year names provide a good example of name set-asides: 2010.nyc, 2011.nyc, 2012.nyc,

Names Held in Trust for Local New York City Government Use
The .nyc TLD will facilitate the interaction and operation of city governance and service

delivery with institutions, residents, community organizations, and businesses. Intuitive
URLs like council.nyc, mayor.nyc, and police.nyc will make a city’s resources readily
available and easier to locate. As well, city government can develop micro sites like
parkingregs.gov.nyc and cityholidays.gov.nyc.

      gov.nyc - as redirect, mirror, or home (if the USA is forced to abandon its use of
       .gov) for New York City's government website.

      police.nyc

      NYPD.nyc

      fire.nyc

      911.nyc

      council.nyc

      mayor.nyc

      copic.nyc

      311.nyc

      211.nyc

      The cb##.borough.nyc series for the city's 59 community boards.

On June 9, 2008, Connecting.nyc volunteers reached out to public employees through our
"Names for a Livable City" effort. We'll repeat this again this year.

Traditional Neighborhood Names
New York is a city of neighborhoods. Criteria have been proposed for the distribution of 305
Traditional Neighborhood Names identified by the City Planning commission.

Names Set Aside for Auction
Auctioning names provide a rich opportunity to raise funds and diminish name hoarding.
See The Economic Case for Auctions in New TLDs, an August 2008 paper published by

Geographic Names
Some geographic names are legal entities. Others are real estate names coined to sell
property in specific geographic areas. New York City has hundreds of these

"neighborhoods." Some have value.

       Boroughs: queens.nyc, manhattan.nyc, brooklyn.nyc (kings.county.ny.us),
        bronx.nyc, thebronx.nyc, staten-island.nyc
       Neighborhoods: jackson-heights.nyc, astoria.nyc, greenwich-village.nyc,
        uppereastside.nyc, upper-east-side.nyc, bensonhurst.nyc.
       Park Names: central-park.nyc, centralpark.nyc

Names to Facilitate International Travel
On November 14, 2007 Connecting.nyc participated on a “Broadening the Domain Name
Space: Adding TLDs for Cities and Regions” panel at the U.N. sponsored Internet
Governance Forum (IGF) in Rio De Janeiro. Panelist Sebastian Bacholet, appearing on behalf
of the .paris TLD, previewed the internationalization study initiated by developers of the
.nyc, .berlin, and .paris TLDs at the ICANN Los Angeles meeting. He provided three
instances where second level domain names might be developed in various languages -
www.taxi.nyc, www.hotels.paris, and www.hospital.berlin. By way of example, he explained
that when in need of health care, German or French speaking visitors to New York City
might enter www.krankenhaus.nyc or www.hôpital.nyc in their respective languages and
receive pages with the needed, in some instances vital, information. We are continuing a
dialog on this innovation.

Shared / Temporary Names
It is expected that names for use on a temporary basis, for example, www.SaveTheTree.nyc
might facilitate civic goals of many different projects.

Undesirable Names
This is an area of great sensitivity for many people. Four letter words are frequently the first
to draw children to search a dictionary. What policy is appropriate for these words? What
about their counterparts in foreign languages? A study of the FCC's community will might
provide a starting point on this.

     Business model to partner with the City for the operation of the .nyc gTLD

When seeking a business model for the .nyc TLD one should begin by looking at the
complexities of the broader question of Internet governance. The below is the simplified
ICANN organization chart.

While some of participants in the ICANN structure are outside the realm of a city TLD’s
operation – Country Code and Address Supporting Organizations – there should be a place
for the city's Internet community to engage within the .nyc governance structure. We find
merit in an oversight structure like the following which provides the public with formal and
direct access to .nyc’s oversight structure and Operating Entity.

   Policy Oversight Committee - From the passage of the Internet Empowerment
    Resolution by Queens Community Board 3 in 2001, advocates for .nyc recognized the
    importance of an accountability framework that includes New York City's official
    governance structure. To the ICANN, the impact city TLDs would have on city
    operations and global Internet governance was not acknowledged until October 2008
    with it adopted the requirement that city TLD applications gain the support of their

    To effectively participate in .nyc policy development we recommend creating a Policy
    Oversight Committee with representatives from the office of the mayor and city
    council. On that committee should be representatives from city entities having a
    strong involvement or contribution to .nyc’s operation: Law, Consumer Affairs, Small
    Business Services, DoITT, as well as NYC&Co. The Committee might have City
    Council committees representing these interests as members.

   Executive Committee - During the development phase an Executive Committee
    should be constituted to reach out to residents and organizations within government,
    the business sector, not-for-profit community, and public to ascertain problems and
    opportunities that might be addressed by the .nyc TLD’s thoughtful development.

    The Executive Committee would first review the recommendations of the various
    responses to the April 2009 Request for Information and additional public outreach
    through channels such as the wikis. The wiki operated by Connecting.nyc Inc. since
    2006 will be maintained to assist in that effort. Additional in-person meetings should
    be scheduled to facilitate public input.

    The output of the Executive Committee’s efforts should be a Cyber Land-Use
    Document that outlines the role of the TLD in the city's future and a business model
    for the TLD’s Operating Entity. In the above graphic we’ve indicated that to be
    Connecting.nyc Inc.

   Cyber Land-Use Policy Document - This document should detail the role and
    accountability framework for the Operating Entity. The Document should indicate
    outcomes the city hopes to achieve with its TLD and offer guidelines for their
    implementation by the Operating Entity. It should provide flexibility on recommended
    pricing schemes with a requirement that the TLD’s operation be self sustaining. It
    should detail the Domain Name Allocation Policy, the flow of funds, and the
    responsibilities of the Operating Entity in providing and facilitating broad access to
    the TLD’s name space.

   Operating Entity – Presented in the graphic as Connecting.nyc Inc., the Operating
    Entity would undertake the following tasks:

         Marketing - From the outset it is vital that one understands that marketing the
          .nyc TLD is tantamount to selling our city. In the western world, where .nyc will
          be seen as parallel to NYC, any abusive action within the TLD will be seen as
          equivalent to a crime on our streets is to the tourism world. The Operating
          Entity must assure that those using .nyc names operate under our city’s legal
          framework. This dominion of city law will be confirmed by domain name holders
          in accepting our Nexus Policy.

          The basis for the marketing plan will begin locally and build out to the global.

            First developed will be the Name Space Preserves for city streets, monuments,
            transportation facilities, neighborhoods, and government services (see below
            for details). The parties developing these names should be engaged early in the
            TLD’s development and thereby ensuring that useful content will be available
            from the TLD’s first availability.

            Once these foundation resources are operational, with existing businesses and
            Intellectual Property owners brought on board, the TLD can be incorporated
            into the city’s global marketing efforts.

           Registry Operation - The operation of the Registry - the database that indicates
            valid .nyc names - is a technical task that can be successfully accomplished by
            several entities. Considering the importance of this aspect of the effort, we
            would contract with one of those several entities that have exhibited experience
            on a global basis and seek that entity demonstrating flexibility of operation and
            price to meet these criteria.

           Aftermarket - In real estate it is said that the aftermarket is the real market as
            a new home are sold but once but existing homes are sold over and over. It is
            important that the opportunities of the aftermarket not infringe on the integrity
            of the .nyc TLD. Aftermarket transfer policies must adhere to the .nyc Nexus

           Education - Key to the success of the .nyc TLD is awareness and acceptance by
            the general public of .nyc as a key New York City resource.

            The Operating Entity must oversee awareness campaigns showing the .nyc’s
            importance to the city's future. Public education efforts pointing to the
            importance of .nyc to every New Yorker and guiding each to become a Trustee
            for the .nyc TLD are essential. These campaigns should be coordinated with city
            government, city marketing entities, and the business and not-for-profit
            communities. The marketing theme for the education campaign might center
            on The New York City Enterprise, a starship-like entity on which every resident
            benefits and every resident has responsibilities.

            Additional information on this can be found on the Governance Page on our

     The potential sources of future revenue streams

The .nyc TLD can provide three revenue streams, direct, indirect, and from a Cyber Land-
Use Plan that includes Name Space Preserves.

     Direct - Direct sources include initial domain name sales, domain name renewals,
      and name auctions. Ownership transfer fees provide another opportunity to
      maintain the TLD’s integrity and raise revenue.

     Indirect - By far the most significant revenue impact on the city will be the
      indirect. To grasp the value of the indirect, think about the value we derive from our
      air, our water, roadways, subways, schools, and libraries. Without these there
      would be no New York City. And to the extent that we neglect them, our future is


    Here are a few examples of the indirect revenue streams we might expect from a
    well planned and administered .nyc TLD.

          Digital Grid - Think of the advantages we derived from the Commissioners
           Plan of 1811 and the organization and accessibility advantages it provided to
           Manhattan’s real estate resources. By creating a digital grid (through the
           Cyber Land Use Plan) that organizes and makes our city’s goods and services
           more visible and accessible to the world, the .nyc TLD will make be more
           readily found and acquired. The indirect revenue would flow from increased
           sales and improved business opportunities.

          Trusted Space - By making the .nyc TLD a Trusted Internet Space, the city
           can become an important global center for internet commerce. Today New
           York City does not exist on the Internet. If in vitalizing the .nyc TLD, we
           succeed in creating a secure TLD, that is, if we create the reality and,
           through marketing and education, the awareness that the .nyc TLD is as safe
           as our streets, people will shop here rather than elsewhere. And in the
           coming yeas, as tax policy catches up with digital reality of cell phone goods
           purchases, the sales tax revenue to the city will be significant. As well, the
           Grid and Trusted Space will have a direct impact on name sales, making
           names more desirable and valuable.

          More Livable City - As we integrate the .nyc TLD with our existing
           institutions, structures, and culture we will lay the foundation for a more
           connected and intelligent city, resulting in a more livable city. More livable
           means desirable, enabling development and related tax revenues. And by
           enabling our residents to organize themselves around the .nyc TLD those
           most important things in like community, friendships, and caring for one's
           neighbor will be facilitated making it better beyond revenue.

   Cyber Land-Use Plan / Name Space Preserves - A third area for revenue
    generation is through the development of a Cyber Land-Use Plan with Name Space

    Connecting.nyc Inc., evolved from the Internet Empowerment Resolution passed
    by a Community Board. With the Board’s role in the city’s land use planning
    process, the TLD’s advocates recognized early on that the traditional view of land-
    use "the scientific, aesthetic, and orderly disposition of land, resources, facilities
    and services with a view to securing the physical, economic and social efficiency,
    health and well-being of urban … communities"[1] had direct parallels to the
    development of the .nyc TLD.

    In seeking a model for effecting land use beliefs we were guided in imagining a
    Cyber Land-Use Plan by the innovative work of the CORE - The Internet Council of
    Registrars. Its Name Space Preserves concept provides a framework for the early
    introduction of “infrastructure” domain names into the .nyc TLD’s early
    development phase.

    Much like the recently released Street Design Manual published by the city’s
    Department of Transportation, a thoughtful Cyber Land-Use Plan will guide our
    presence on the Internet providing an orderly Internet presence and the potential
    to generate revenue for the city.

       The Name Space Preserves provides an innovative management paradigm for the
       allocation and oversight of community and government oriented domain names.
       Contrary to the traditional first-come, first-served domain name registration
       paradigm, it conveys exclusivity for large or important segments of the name
       space, involves activating a large number of domain names early in the TLD’s
       introduction period, and imposes policy obligations upon contracted preserve
       trustees. These policy obligations may cover compulsory content provision on the
       entire preserve name space, a requirement for attached services and guidelines or
       restrictions on advertising.

       Managed Preserves for the .nyc TLD might include Streets, Monuments, Buildings /
       Property, Neighborhoods, Professional Categories, Public Transportation Facilities,
       Community/Public Services, Government Services, Governance / Voters, Tourism,
       and Businesses.

       The Name Space Preserves will play a key role from the policy-oriented and service
       perspectives. The aggregate effect of the Name Space Preserve blocks will make
       new policy choices possible and innovative services practicable.

       Name Space Preserves can play a role in funding the .nyc TLD’s development as
       coherent name spaces have significant advertising potential that grow with the
       TLD. For example, one might imagine contracting with a yellow page operator to
       oversee the development of several hundred valuable names. Or one might also
       imagine these names as providing the opportunity for several hundred small
       information businesses. The development of Name Space Preserves and the
       tradeoffs they highlight provides a key example of the policy decisions we feel fall
       face our Civic Enterprise.

       Potential preserve holders could participate in the initial funding of the TLD. They
       could also be allowed to participate with other stakeholders in the design of the
       TLD policies.

       Finally, Name Space Preserves can contribute to a successful launch, as a city-TLD
       can go live on Day 1 with a large number of meaningful domains carrying useful

       The Name Space Preserves can coexist with the first-come, first served paradigm
       outside the designated blocks. And they can help put the .nyc TLD "on the map"
       with meaningful content thanks to the early availability of coherent Name Space
       Preserves content. This promotes the TLD and encourages individual registrations
       as well.

       Name-Space Preserves (NSPs) are a foundation for city-TLDs. Beyond the benefits
       to New York City, CORE is promoting their adoption on a global scale. With generic
       interface standardization and accessibility, the utility of conforming cities globally
       will be enhanced.

       Long term, how well educated city residents and organizations are about the
       effective use of the .nyc TLD will have an impact on its revenue potential.

     The ability for the City to reserve certain domain names for its own use/protection

In a digital era, the city's success is tied into the effective use of the Internet and the .nyc

TLD. When one thinks of the Internet as the city's central nervous system, connecting
every person and organization in the city, one begins to feel the necessity of assuring its
effective development. And when one realizes that the .nyc TLD will be our city’s face to
the world and a significant part of the city brand, the need to carefully develop and protect
it is redoubled.

When "The ability for the City to reserve certain domain names" is considered, there are
several perspectives to consider. From the perspective of names helpful for city
government service delivery, Connecting.nyc Inc. has some experience to contribute. In
June 2008 we researched this question hading out fliers to city employees entering the
Municipal Building and requesting that they suggest .nyc names that might be set aside to
facilitate the administration of city government.

While the names suggested in conversations that day were of a general nature, we did
receive email suggesting that city Tax forms might be made more readily accessible, with
the hotel tax form HTXB.nyc suggested. To those few thousand people who use this form
annually the direct access would make for eased delivery of this city service. There are
probably several thousand names that might be set aside of similar nature. Whether the
city chooses to utilize the .nyc TLD immediately or not city service delivery names of this
sort should be identified and set aside.

From a different perspective, if the .nyc TLD achieves our highest expectations, with a
huge demand for a presence within our Trusted and Protected space, all unprotected good
names will be rapidly purchased by speculators. Should this occur .nyc will become just
another option to .com. An effective Nexus Policy, legal oversight policies, and community
support of the .nyc TLD as a prized and vital common resource are essential.

Additionally, typos that relate to city agencies or vital resources can be directed to
disambiguation pages to guard against abuses. And spelling mistakes for names such
police.nyc might be reserved for the protective services. And take down policies for
abusive name registrations can be stronger and faster to protect vital city resources.

Community standards should be adopted by the Operating Entity to set the tone,
identification, and access to adult materials.

Names of use for the future operation should be set aside: taxforms-2012.nyc, taxforms-
2013.nyc, etc.

The best measure to assure that city names are reserved and protected is to be proactive
in the TLD’s development.

     Options for domain registration, including pricing models, trademark protection
      measures, dispute resolution, terms and conditions of use

While we may bemoan the two decade delay in New York City's access to the DNS, there
is a commensurate two decades of experience from new TLD launches to draw upon.

Positive lessons were provided by the .cat introduction where a cultural community
demonstrated the capability of a TLD to address its publishing and networking needs.

Sunrise, First-Come First-Served, Nexus, and Landrush, are terms used to differentiate
the distribution techniques for new TLDs. Each is described in the following.

Although there are many critics of the ICANN’s decade long saga to open the DNS, there

have been several lessons learned from the proof-in-concept TLDs that have launched in
the interim. .Biz and .info launches demonstrated the fragility of TLD trademark protection
measures. .Eu and .asia reflected the vulnerabilities of the auction system. Even Country-
Code .me had an illogical auction platform where under bidders could ensure the bidding
process continued with any name by merely continuing to increase underbids.

City TLD nexus requirements must be put in place for domain registration. Proof of
residency or business contacts must be provided by registrants. Regrettably, registrars
have set up agents in the past to act on behalf of out-of-nexus registrants to create more
sales at the expense of the restricted TLDs. NYC and city TLDs should police registrars to
enforce that nexus requirements are not “gamed” by registrars, whose very existence is to
largely aid as a checks-and-balance system for registries in the DNS system and not to
undermine upon their operations.

We note that names must be reserved for Internet Operational Purposes. Our initial name
space allocation will be to comport with ICANN recommendations on reserved names for
technical and public policy reasons. ICANN has traditionally required that the following
second level names be reserved: 0, 1, 2, 3,4, 5, 6, 7, 8, 9, a, AFRINIC, APNIC, ARIN,
ASO, b, c, ccNSO, d, e, Example, f, g, GNSO, gtld-servers, h, i, IAB, IANA, iana-servers,
ICANN, IESG, IETF, Internic, IRTF, ISTF, j, k, l, LACNIC, LATNIC, m, n, NIC*, o, p, q, r,
rfc-editor, RIPE, root-servers, s, t, test, u, v, w, Whois*, www*, x, y, z, with asterisk
names reserved for registry use. ICANN has traditionally allowed single and double
character, non-country-code domains to be opened upon further application and fees.

In this light, names should be reserved to facilitate the operation of the .nyc TLD and to
facilitate navigation, such as: index.nyc, portals.nyc, help.nyc, and connecting.nyc.
Moreover, importantly, names should be set aside for New York City Government Units to
secure, protect and facilitate the interaction with and operation of city government.
Intuitive URLs in this genre may include: council.nyc, mayor.nyc, and police.nyc will make
a city’s resources both findable and accessible. Others should be: gov.nyc, NYPD.nyc,
fire.nyc, 911.nyc, 311.nyc, 211.nyc, copic.nyc, cb##.borough.gov.nyc series for the city's
59 community boards, etc.

Moreover, we recommend some names be reserved for future activation, e.g., 2010.nyc,
2011.nyc, 2012.nyc, etc. Additionally, we are monitoring and submitting suggestions to
the ongoing work of the Implementation Recommendation Team convened by ICANN to
help facilitate the TLD effort.

We recommend a Local Sunrise for NYC based companies and organizations to provide
them with the opportunity to reserve familiar names such as www.cuny.nyc,
www.nypl.nyc, www.nyu.nyc, and www.queenscollege.nyc. Civic organizations and
neighborhoods would also be assigned during this period. Small businesses are also given
the opportunity to acquire names. Then, during Trademark Sunrise, national and
international trademark holders will have the right to seek names such as:
www.siemens.nyc, www.hyatt.nyc, www.porsche.nyc, www.newyorkpost.nyc,
www.ibm.nyc, www.nytimes.nyc, www.coke.nyc, etc. Traditionally a 1-2 month period is
set aside for such trademark holders. We see the recommendations of the Perfect Sunrise
document prepared by the ICANN's Intellectual Property Constituency providing guidance
during this period.

Connecting.nyc, Inc. is presently being courted by many of the top back-end providers of
top registries to operate its domain platform. Several are apparently proffering .nyc RFI
responses herein. Such interest by the back-end technical provider will be absolute best-
in-breed and at a very realistic price-point due to the demonstrated desirability for such
providers to work with our first-moving, innovative non-profit model. In this way, domain

pricing will be best matched to provide optimal revenue streams to the Operating Entity’s
educational programs and the city of New York.

The inherent nature of the non-profit model is to best serve the City of New York as a
pass-through system to aid it financially and otherwise, especially in these trying financial

Clearly Trademark Protection measures are a very big issue regarding the opening of the
DNS. Business and individual IP-holders must have the ability to protect their brands
without compromising the innovation of allowing cities to better define their namespace on
the web. Again, the proof-in-concept TLDs have shown that different mechanisms were
better in practice than others. Some aspects are clear. A Sunrise period for IP-holders to
provide proof of IP-rights for registration before Landrush makes sense. Those systems
that have accepted such submissions in good faith, without review, have run into some
problems, like .mobi. Regrettably, many Sunrise requests were provided with Chinese
trademark registrations that were issued in just days time and names were granted on
good-faith bases. A simple human or sophisticated automated review would have
discovered many bulk similarities, including default dates. IP-holders’ rights aside, the
registry and mobile domain community then suffered at large due to the lack of
significantly trafficked and regard IP-holder adoption and name development on those
names. Such failures are never overcome by registry marketing and mainstream adoption
falls one more step shorter than the prevailing .com TLD.

Terms of Condition of Use is also a very important issue. Having nexus rules that go
unrewarded can prove disastrous. The mobi TLD has yet to clearly enforce that its
premium name holders develop names according to its complex best-practice guidelines.
It has not pulled the names from at-large registrants that fail to develop sites that are
minimally mobile-friendly. As such, the mobile TLD has somewhat failed to establish a
brand trustmark for mobile namespace. The .nyc names must be policed for New York City
nexus with quick takedown mechanisms and sophisticated WHOIS systems with non-
competing databases or privacy protection aliases. This leads to better adoption and
search engine optimization placement on the web. Authenticity of community-based new
gTLDs is key for adoption and mainstream usage.

The prior City responses have been correct to assert concern for the minimal awareness of
the issues potentially facing municipalities and other sub-national governments in the new
gTLD process and how such interests are not actively represented by any ICANN panel or
governing body. Issues such as GNP continue to need better shape and refinement by
ICANN and the city stakeholder community.

Dispute Resolution issues are very important in consideration of .nyc. It is well-taken that
the City of New York should ensure substantial time and resources are not risked in
disputing aspects of application and local government registry operation in a global arena.
Importantly, the validity of non-objection/support letters should be corroborated by
separate, disparate means to protect the city from unnecessary litigation. Moreover, the
United Nations Code for Trade and Transport Locations, LOCODES, should be adopted as
an alternative criteria for geographic terms as suggested, and in this light US cityTLDs
would be considered more categorically appealing and adopted if uniform three-character.
Moreover, the different costs for the various objection categories have not yet been
tackled. These remaining questions, and many others, continue to be one of the many
reasons why Connecting.nyc has traveled to, and will continue to lobby ICANN, policy-
makers and global stakeholders to best serve the City of New York within the new gTLD

      A platform for auction of popular domain names

Several platforms for auctioning domain names are available. Others are being developed
in anticipation of demand resulting from the ICANN’s New TLD program.

After reviewing the types of contention that resulted from the recent TLD introductions for
.eu and .asia, we recommend that a key design philosophy be that the platform be
created to resolve contention as gracefully as possible. This is in contrast to traditional
auctions that are designed to raise the maximum revenue. Here’s an example.

We enter the Sunrise period and two entries are made for the same name. A graceful
system will enable participants to communicate with one another, possibly enabling two
people from the same organization to learn that they’ve double bid, with an auction
gracefully avoided.

Or one might imagine another instance where two entries are made for a name that is less
than vital to one or both of the parties, and with a minimum of disruption, the parties
could amicably resolve the contention. For example, two bidders for “best-astoria-
bikes.nyc” might conference and agree to select best-bikes.nyc and Astoria-bikes.nyc
rather than engage in an unnecessary and costly auction.

But there will be irresolvable situations and the selected auction system should be
designed to resolve contention at the lowest cost to the parties. One certainly doesn’t
want to drive up the cost of a name and leave the winning party so financially drained as
to be unable to adequately develop the name.

We recommend that the goal of creating a great city be kept in mind as the goal, and that
resolving contentions gracefully, with as little bitterness as possible, be the first goal of
the auction system. Resolving contention gracefully should be the goal, not maximizing
auction commissions.

A graceful auction system might take a few extra weeks to implement, but we've waited
10 years for .nyc, we should be able to wait an additional month or two to make sure we
do it correctly.

      A platform to accept on-line payments

To understand the history affecting “accepting on-line payments,” some industry
background is required.

In the mid to late 1990’s if you wanted a .com, .net, or .org name, you had to deal with
Network Solutions Inc. Being an early contractor facilitating the Internet’s development,
the Net’s evolution had given it a monopoly on those TLDs.

A basis for the ICANN’s creation and one of its earliest actions was the separation of
Network Solutions Inc., into two firms using a Registry-Registrar Model. Under the ICANN’s
Registry–Registrar Model, Network Solutions Inc. was split into a name producer (or
registry), Verisign Inc., and a name distributor (or registrar), Network Solutions Inc.

The settlement also created a category of businesses, Registrars, that would compete with
Network Solutions as name distributors. These Registrars would all have equal access to
sell .com names. As well, they would have equal access to other products of future name
producers, for example .nyc.

So the ICANN created industry model has Registrars selling names from the various
Registries to name holders (Registrants) - those individuals and organizations that create
and present websites for access to Internet users. (See below Domain Name Industry
Overview graphic.)

That Registry-Registrar Model exists today and will presumably be the model under which
.nyc will operate. Thus the answer to the “platform for on-line payments” is that the
Registrars (resellers such as GoDaddy and Network solutions), will provide the interface
and payment verification systems that name purchasers will see. The contact information
gathered from by Registrars will be shared with the registry operator, e.g., .nyc, using
standard industry interfaces.

EXCEPTION NOTE: During the ongoing development phase for the New TLD Guidebook,
Connecting.nyc Inc. submitted comments to the ICANN indicating that domain names for
some city resources – streets, monuments, street furniture, etc., what some call the
Internet of Things – should not be charged the normal registration fees.

Should a more city-aware pricing and registration policy of this sort be accepted by ICANN,
we will seek an exception to the standard Registry-Registrar Model during contract
negotiations with ICANN, seeking a registration process that would eliminate the costs to
the city of naming these important civic resources using third party registrars.

Security within this system should include transparency of all financial information.

 Simplified Industry Overview Model - This graphic is of a prototypical relationship. ICANN contracts negotiated
 over time resulted in different fees being paid by the parties in the Cash Flow chain. As well, there are different
                 levels of distributors than those presented in this simplified registration process.

         A plan to organize a sales network

As mentioned in our response to the “platform to accept on-line payments” inquiry, the
distributor of domain names is the Registrar channel. To facilitate the development of a
broad and effective sales network we advise selecting a registry provider that has
demonstrated an ability and competence to establish relationships with existing registrars
on a global basis. More resellers of .nyc names should result in more visibility of .nyc
names, easier access to names, and in lower price to name holders (Registrants).

Extended Reseller Channels - Beyond the traditional sales distribution network provided
in the Registry-Registrar Model, we recommend the creation of additional sales channels
both locally and globally. While the above Simplified Industry Model graphic shows a single
level of Registrars, in reality there are different “sub-registrars” that work as specialized
resellers. For example, law firms specializing in Intellectual Property provide one type of
such reseller.

Drawing upon Connecting.nyc Inc.’s community and educational roots, we envision other
opportunities for developing domain name reseller channels. For example, locally, as part
of its educational efforts, the .nyc Operating Entity should work with educational, business,
and government organizations to establish education /reseller relationships.

For example, the Operating Entity should create relationships with city agencies such as
the Department of Consumer Affairs. The Operating Entity should work to place education
resources on the Consumer Affairs website, these might include tips for selecting good
domain names, selecting proper listings in .nyc business category database, search engine
positioning guidance, and general guidance for current and future licensed businesses on
ways to develop their businesses using domain names.

Chambers of Commerce and educational organizations might similarly be recruited into an
extended reseller channel.

Globally, the Operating Entity should work with marketing organizations such as NYC&Co.
to facilitate the sale of appropriate .nyc tourism names through their global offices and

The Operating Entity should create relationships with reseller’s experts in expiring names
within the scope of a high quality TLD. Policy rules for expiring names will need to be
specified in the Nexus Policy.

         A technical solution and plan of coordination with the City administrators

There are many levels where the Operating Entity and city will benefit from the
coordination of their efforts.

        Enhanced Reseller Channels - Creating the above “Enhanced Reseller Channels” is one
         example. This will involve the development of a standard interface for connecting the
         city departments, chambers of commerce, and educational institutions with the
         Operating Entities registry provider.

        Common Complaint and Inquiry Interface - With the .nyc TLD vital to the city’s

         identity and its viability as a tourism and online shopping venue, there needs to be
         “Complaint Interface” tied into different levels of city government, e.g., the
         Department of Consumer Affairs. While complaints adjudication will be within the
         realm of the Operating Entities responsibilities, there must be transparency into the
         Operating Entities complaint and dispute resolution systems that provides needed
         awareness to the city administration. Using the Interface, administrators could
         coordinate enforcement efforts.

        Trend Analysis – The Operating Entity should endeavor to present a timely picture of
         trends in name selection that might facilitate city administrative and governance
         processes. For example, beginning in March 2009 New York City struggled with the
         H1N1 virus. As the epidemic grew, name selection could be analyzed by health and
         education administrators with suitable domain name(s) selected.

One of the tasks Connecting.nyc will provide is working with various city agencies to
facilitate their generating and sharing in the revenue.

         A plan to ensure a secure and reliable domain space

At first glance the response to this might seem to be one that is technical in nature. And
indeed the fundamental operation is highly technical. And in that regard, thanks to the
decade long efforts of the ICANN and its component organizations, the technical workings
of the TLD space is more reliable than ever.

The .nyc TLD’s Operating Entity should feel comfortable engaging any one of the handful of
registry operators that have served the global market. Each can provide solutions to
abusive registrations and other technical affronts to the TLDs secure and reliable operation.
Each can provide the security of DNSSEC and certificates of reliability.

But today’s world is one where fraud and various types of malware are perceived as
rampant. And these are problems that are not easily resolved via a technical fix. So the
long term theme to assure the operation of .nyc in a secure and reliable manner might be
“Ora na azu nwa” or as translated from the Nigerian proverb by Hillary Clinton, “It takes a

It is only through the recognition by New Yorkers that we are seen globally as a single
identity that we will begin to act in concert to protect our name. This requires
comprehensive and ongoing city-wide education efforts. The Operating Entity should be
expected to engender amongst New Yorkers an awareness that we are all in the same boat
and will rise and fall together; that we all have a stake in assuring that .nyc is perceived as
secure, reliable, and trusted.

The education must bring our entire society into the .nyc TLD fold. The school system,
government departments, business organizations, community and civic groups,
neighborhoods, and every New Yorker must be educated to spot the poisoning of our digital
well and be provided with an awareness of the channels to expeditiously report violations.

It is only when we have all bought into the TLD’s importance to our lives that the .nyc TLD
will become both “secure and reliable.”

         Suggestions for innovation and responsible growth

Responsible growth comes from viewing the .nyc TLD as infrastructure and the primary
benefits arising through indirect benefits that arise from the TLD’s operation as
infrastructure, there are several actions that might facilitate innovation and responsible

        Pricing on a sliding scale should be considered, with earlier purchases being at higher

        Cyber Land-Use – The adoption of the Land Use concept for the TLD with the inclusion
         of Name Space Preserves is a path for responsible growth.

        Working with city agencies, chambers of commerce, and educational institutions as
         sales channel partners is another innovation.

         A plan for zero risk of transition

While the steps and processes needed to assure “zero risk” have in most respects been
achieved by the ICANN through its Registrar Data Escrow Program and the Inter-Registrar
Transfer Policy, there is an additional step the .nyc Operating Entity should take to further
reduce risk, replication and transfer.

Registry replication and transfer involves the periodic copying and transfer of such copy to
other registries. Risk can be further reduced by assuring that at least one such replication
transfer registries is operating under a different software architecture, thereby reducing
cross-registry malware spread.

Replication and transfer actions should be confirmed and verified to the .nyc TLD’s
Oversight Entity.

         A Nexus Policy to preserve the gTLD for use by the community of New York City
          related users

An effective Nexus Policy is a vital to maintaining the integrity of the .nyc TLD. The Nexus
Policy model that most closely matches New York City’s needs is that used for the .us TLD.
See http://www.neustar.us/policies/docs/ustld_nexus_requirements.pdf.

The .us Nexus Policy’s goal is to maintain dominion over entities using .us domain names.
A similar goal is needed if New York City is to maintain the quality, trust, and identity
desired for the .nyc TLD.

Doing a simple substitution of “New York City” for the “United States” in the .us Nexus
Policy, with edits for geographical incongruities such as controlled territories, creates a
workable city nexus policy when coupled with a certification statement such as the
following as part of the registration process (again modified from .us):

         Prospective Registrants will certify that they have a “bona fide presence in the New
         York City” on the basis of real and substantial lawful connections with, or lawful
         activities in New York City. This requirement is intended to ensure that only those
         individuals or organizations that have a substantive lawful connection to New York

       City are permitted to register for .nyc TLD domain names

One limitation exists with the .us nexus: The .us policy requires that servers be located in
the United States. Requiring that .nyc name servers be located in the city might prove
stifling for reasons of price, innovation, maintenance, and particularly, security needs.
Perhaps an acknowledgement of intent and certification by registrants as to their servers
“virtual legal presence,” regardless of actual server location, might meet the city’s
dominion needs.

A Nexus Policy requiring that .nyc domain name holders have a bone fide city presence
would help eliminate bad faith registrations and, combined with random audits and
complaint based challenges, establish the needed integrity of the .nyc TLD.

       Additional policies essential for organizing the locality-based gTLD space, and for
        developing the expanded gTLD space, including among others

A city TLD’s role is to assist with the routine operation of the geographic entity it serves,
fulfilling traditional needs while providing the option to address new challenges and
opportunities in innovative ways.

Early into the development of the .nyc TLD it was recognized that neighborhood names
could be allocated and developed to facilitate communication in those important historic
entities, for example, astoria.nyc, Brooklyn-Heights.nyc, soho.nyc...

Connecting.nyc Inc. evaluated the Name Space Preserve system developed by CORE, the
Council of European Registrars, to assist with imagining ways groups of names might be
allocated. We found CORE’s Name Space Preserve’s concept readily adaptable to the needs
of New York City and the operation of the .nyc TLD.

A Name-Space Preserves (NSP for short) is a coherent set of domain names in a
community-oriented TLD that are assigned to a trustee. The trustee must provide services
to the assigned Preserve names as specified in a preserve agreement. As well, it may
provide additional services not specifically barred. Different pricing structure for each
category, including “no charge” for an Internet of Things Preserve might be advantageous.

In the instance of a Neighborhood Preserve, a not-for-profit Trust might provide for
allocation and oversight of the Preserve.

       Delegated Manager (“DM”) Tool

With Connecting.nyc Inc.'s origin in the world of Community Boards, the management of
portions of the .nyc TLD within a Cyber Land-Use Plan seemed natural. We found a cohort
in this belief in CORE - the Council of European Registrars and its Name Space Preserve.

While the management of nationwide TLD such as .us might require a Delegated Manager
tool like that developed by Neustar for .us, see http://dm.neustar.us/dm_inames.html, a
contract supported by random audits and objections might provide the most efficacy for an
allocation of Name Preserves in a limited geographic area such as New York City.

Connecting.nyc Inc. continues its work on the Cyber Land-Use Plan and anticipates its
completion during summer 2009.

      a Ban on Proxy domain name registration

Proxy registrations merely hide details from the general public but show the information in
the proxy server. Many large companies use proxy servers for their mail systems.
Therefore, proxy server and the legitimate need to be anonymous is not always a sign of
malicious behavior.

Registrars must maintain complete and up to date information for all registrants.

The operation of the .nyc TLD as a trusted TLD will require the availability of domain holder
(registrant) information to relevant entities. For example, in the instance of product and
service complaints, domain owners within a Small Business Preserve must maintain up to
date information about their operation within the .nyc registry. They may however opt-out
of general publication through a check box during registration.

      a WHOIS Accuracy Program

The "WHOIS" command is used to access registration information about domain name
registrants, the database used by DNS. The ICANN takes care to assure that registry and
registrar audit tools are effective and has established detailed procedures and penalties for
violations of their accuracy requirements. These seem suitable to the need.

      the prevention of abusive domain name registration and DNS practices.

We find the practices developed by WIPO to meet the needs of the city.

      Transfer polices

Domain name transfer policies are tied into the Nexus Policy. Inter-registrar transfer policy
is guided by the ICANN with registrar choice guaranteed and the software effecting
transfers be standards based. Time requirements for effecting transfers are governed by
ICANN and are currently under review, with the anticipation that time allowed for the
transfer periods will be shortened.

Within a Name Space Preserve transfer policies might vary, with special approvals
required for some transfers, for example, the transfer of a city department names, the
broad stroke policies endorsed by the ICANN seem suitable for .nyc.

On a general basis however, transfers should be done expeditiously with post validation

      Policies for the prevention of Phishing, Malware, Bot-nets, etc.

There are several ways to prevent these various malware occurrences: technical,

organization based, and education.

On a technical front the registry operator needs experience addressing these issues on a
global basis. For example, those with experience addressing conflicker through redirect
intervention to community servers will have important experience in these areas. Rapid
takedown experience is also desirable.

The Information Systems industry has spawned an entire community creating anti-virus
software: http://www.us-cert.gov/nav/report_phishing.html tracks phishing and Symantec
publishes anti-virus fixes numerous times each day. The Operating Entity can also facilitate
the use of technologies such as SSL (Secure Socket Layer) using 128-bit encryption or EV-
SSL (Extended Validation SSL) to assure trusted connections between parties.

But some of these attacks are “human engineering” based, that is, the perpetrators trick
people into providing passwords or other security information. Public education campaigns
by the Operating Entity using the TLD’s publishing capabilities, and at the neighborhood
level, through education efforts aimed at civic groups, community boards, schools, senior
centers, and other entities should be part of an ongoing campaign to inform the public
about various scams.

         A contingency response plan(s) (in addition to a policy to prevent) technical
          problems, Phishing, Malware, Bot-nets, distributed denial-of-service attacks, etc.

The participation in joint registry efforts, something learned in fighting the conflicker worm,
is an essential part of the effort to respond to various malware occurrences.

         Proposals for additional uses and functionality

With the Net changing so rapidly opportunities of this sort arise and are addressed
routinely. A few opportunities one might address today include:

        A grand collaborative enterprise – “wikipedia is us”

        Issue Communities - See http://www.openplans.org/projects/campaign-for.nyc/issue-

        Preparation on use of the Semantic Web.

        Collaborating on setting a global standard for how city TLDs should be developed.



To top