Firstly, many thanks to all who were involved in the excellent Discussion paper. Comments have been sought in a number of specific areas, so here goes:

1. Industry Self Regulation: General Principles
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Suggestion for addition: aim to regulate the .au name space as a National Resource on behalf of ALL Australians, be they members of the Internet community or not.

By this I would like to emphasise that even if the Public Trust legal structure described further in the document is not adopted, that conceptually the .au name space and its regulatory regime is enshrined as a National Resource, conceptually owned by and managed on behalf of all Australians. This principle may assist in guiding discussion away from agendas promoted by vested interests.

2. Industry Self Regulation: Public Trust Provision
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>From both a credibility and competitive perspective I think it is desireable to separate the Registry/Registrar functions as described. 

This will enable any body wishing to do so to compete directly on a level playing field with Internet Names Australia/MIT in registering .com.au names, something I am sure the majority would welcome.

3. Membership Classes and Voting Rights
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The structure described seems overly complex. I cannot envisage justification for a board of more than say 6 members and even that is on the heavy side.

Allowing specific associations to elect a director(s) *reduces* representation as these bodies have their own agenda - not necessarily limited to Domain Name issues. 

I would suggest a at the other end of the spectrum a class structire as follows:

Class 1 - full voting rights
Any body willing to pay a membership fee of say $1000. This will ensure that the players representing the supply side have a voice that is undiluted by parties who consider themselves to be stakeholders, but are not commercially relevant (and remember that by and large, domain names *are* a commercial, not academic or public issue - they are bought and used for predominantly commercial purposes).

This would also assist with initial funding requirements.

Class 2 - Diluted or no voting rights
Any other individual or body, not including by default all domain name owners.

My contention is that the commecial interests of stakeholders will ensure that domain owners are fairly represented. What we don't currently have is sufficient competition for this to occur, but experience in the UK indicates that a level playing field ensures enough Registrars/agents for the markets' will to prevail.

4. Board
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The powers proposed seem appropriate

5. Councils (or Advisory Panels)
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The following Councils will be required but may not need to be permanently convened.

Policy Council
Pricing Council
Competition and Fair Trading Council
 - permanently convened and will hear allegations of unfair or misleading practices by members.


6. The Way Forward
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As one of the few operating, commercial registries, NetRegistry would like to be part of the Working Group. Do we need someone to nominate us or can we self nominate?

7. Lastly - pricing
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A $5 fee is unworkable. It would cost double this just to administer receipt. Essentially, revenues for registrations/renewals must cover the expenses of the technical, admin and legal sides of the body. 

The UK NOMINET model has a discounted pricing to members in return for them being a single billing point of contact for many domains and a full price to members of the public who apply directly (and for whom the body therefore has a full administrative burden).

I think that it is desirable to set pricing to restrict the number of members of the public who apply directly (as opposed to via their ISP). Domain names are confusing and having membersof the public applying directly to the central body will require considerable additional expense and therefore raise the per name cost to the central body.

Regards

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Larry Bloch                   
Chief Executive Officer       
NetRegistry Pty Limited       
email:  larry§netregistry.au.com
Office: +61-(0)2-9699 6099
Fax:    +61-(0)2-9699 6088


http://www.netregistry.au.com
Domain House, PO Box 2088, Sydney, NSW 1043
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