A revision, 31/3, of the .pr.au Policy draft is available
at http://www.adna.asn.au/Documents/pr.au.html

The following is a summary of feedback received on draft
policy for a .pr.au domain.

>What does the "pr" stand for?

The reason for proposing a new SLD is that Users have
requested domain names that they can use for marketing
products and services.  Under the current rules in place
for existing SLDs, this demand cannot really be met in
.com.au, .net.au, etc.  If anyone belives that any other combination
is an improvement on .pr, please say so.

>My major issue is that the burden appears to be on the registrar to
>check things, rather than the registrant to assert that they are true.
>It makes it hard to automate this stuff, which adds up to expense for
>the customer and barriers to entry for registrars.  It will
>also lead to disputes between customers and registrars.

Our intention is that the process be automatable (is that a word? :)).
So either we can set it up so that it is easily automated by the
registrar, or it will have to done so that the User warrants that the
details are correct in their domain name licence application,
and the Registrar therefore does no manual checking.

The intention is to support multiple registrars operating in the SLD.
To achieve that efficiently really requires using automated validity
checking and/or Registrars relying on the Users warranting
that the details supplied are correct.

It is theoretically possible to retain subjective criteria and still
design a process that enables multiple registrars, but it increases
administrative overhead and system complexity - and therefore
costs, which will be borne by the User in the end.

>> Domain names in .pr.au are available to any legal entities who are
>> Australian entities or are Australian individuals who are resident in
>> Australia.
>Why?  I'm not (necessarily) arguing with you, I just think it needs to
>be justified to the community.  It certainly creates headache if the
>registrar is obliged to check that someone lives at a
>particular address for example.

Your point about justification is valid.  The requirement is
part of an overall strategy to try and make the .au part of
the DNS system
a 'high quality' part, and that includes some basic measures
to try and stop all the shonky traders - of whom the web has
more than its fair share - from setting up their fly-by-night
scams in .au.  Thats why the requirement for a physical
address - I know its a wierd requirement for a borderless
medium like the internet, but its in the current requirement
for the same reason that a business must have a physical
address.  So the cops know where to go to find you.  No,
we don't expect the Registrar to check that stuff.

The issue was raised at the NOIE forum in Melbourne on 30/3 that was
called to enable input to the Aust. Govt's response to the US Green
Paper.  The ACCC's presentation at that forum highlighted that one of
their major concerns was the issue of Consumer protection on the
internet - and one of the key issues for that is: "Where do we
send the cops".

Its also related to the issue of 'jurisdiction' - a related
issue which also received much discussion at the NOIE forum.

The internet is a borderless medium - when there is a dispute,
where does it take place?  The ADNA objective is that jurisdiction
over .au should be in Australia, but that isn't necessarily automatic.

If, say, a US company was using a .pr.au name and there was a dispute,
the User's preference might well be to have that dispute heard in the
US of A.  The US Court system has a tendency to claim jurisdiction
over anywhere in the world if a US company is involved, but going
to court in the US is only marginally less attractive than getting
sick in the US.

If Registrars in Oz were to get drawn into legal entanglements in
the US, the result would be increasing cost of registration as those
Registrars paid for expensive legal insurance.

I believe it is worth some effort to ensure that jurisdiction over
.au remains in Australia.  Currently that is reflected in two places:

1. The requirement that entities obtaining licences in .au have some
Australian committment.
2. A new 'mandatory condition' - see Section 6 of the revised
document - where the User agrees that jurisdiction for .pr.au
is in Australia.

>> If the domain name is for an organisation rather than for a product
>> or service, ADNA recommends that the organisation obtain a
>> domain name in other second level domains as follows:
>>            .gov.au for government organisations
>>            .edu.au for educational organisations
>>            .asn.au for not-for-profit associations
>>            .com.au, .net.au, .org.au for other organisations
>Is this useful or necessary?

Agreed - I'll take it out.  But something of the sort should
be available on the web, the current stuff on the AUNIC
pages is out of date and not sufficient.  When I get time.....

>> A domain name must be at least two characters long, (eg. ab.pr.au),
>> and must contain only letters (a-z, A-Z), numbers (0-9), or hyphens
>> (-), and must start with a letter.
>It is legal for domains to start with a number.  eg)
>7perth.com.au, or even 711.com
>The various RFCs describe the limitations imposed by the DNS.
>Any variations need to be justified to the community.
>Note that each rule is justified with reference to an RFC.
An excellent improvement.  Citing the relevant RFC's makes
good sense.  I have made that change and tried to use the
same format as the proposed CORE information.

(Note that I need to check the examples/comments against the
actual RFC's as one of the looks at little odd - probably
a transcription error by me).

>> Domain names that exactly match a trademark registered in
>> Australia, will only be issued to an entity that owns that
>> trademark.
>The wording puts the burden on the registrar to test.  Why?
>There are existing laws in place to handle this.
>Alternatively, consider the approach taken in the CORE-MOU

The issue of Trademarks is a complex one.  It would be nice
to ease the problem for Trademark owners - if that can be
done without causing other problems in the DNS administration
process.  eg. it would have to be automatable.  For the
moment, I've taken this section out.

>> Offensive words are not acceptable in principle as domain names.
>#%$!  Who get's to decide?  In which language?  It's a matter of taste
>ne c'est pas?
I agree with you.  It's one of those 'nice ideas' that's very
difficult to implement in any practical way - unless someone
(OFLC?) can produce an authoritative list of offensive terms
we can use as a source.  And as that is not really possible
(because 'offensive' depends muchly on the situation), I have
deleted this section.  If someone tries to use a business
/ sell a product with a name that offends someone, then
the public can raise the issue with the User through
existing channels.

>> 3.The ADNA Registrar Code of Practice governs conduct
>> between Users and Registrars.
>There's the law of the land to consider as well.  I know
>what you mean, but it has to be crafted quite carefully.
Yes, its a tricky area.  I have altered the section to
say that the law of the land also may apply.  We're
considering a couple of other options re dispute
resolution and codes of conduct also.  It would be nice
not to have to re-invent the wheel here.

>>Registrars must give Users at least 30 days notice
>Define "notice"?

I've changed the draft to clarify method of delivery, timing,
and content.
>You make several references to the AUNIC registry.
>I'm not sure that we should be using the AUNIC registry.
>For instance, CONF.AU, ASN.AU and NET.AU do not use it.
I have removed those references.

As always, feedback is welcome,

Regards, Mark