Summary of Policy Review Panel Submissions

  Submissions to the Registrant Policy Issues Paper consultation have now been published on the auDA website.  The Paper presented a series of questions, and invited members to express their views on the current policies. The table below is a summary of the responses. Full submissions can be found by clicking on each person’s name. The “Key Overall Comment” section is obviously my subjective viewpoint. So please don’t be offended if you don’t agree. I simply didn’t have the space to put a lot more in. We look forward to hearing your comments.

Name	Answered Questions	Attitude to Domain Monetisation	Key Overall Comment
Aaron Rasmussen	No	N/a	There is zero benefit to the public in doing this. There surely couldn’t be any demand for it, let alone enough demand that would outstrip the people upset about it.
ACCAN	Yes	Strongly opposed	ACCAN opposed this move at the time of the 2015 auDA consultation on the basis that it would increase consumer confusion and detract from the existing investment in marketing and branding made by many Australian organisations (registrants) for the domain name over which their organisation operates its business. ACCAN has not shifted from this central view.
Alan Gladman	Yes	Should be allowed	I don’t think we need the new extension we have enough already the UK has some 65 million people Australia has about 24 million and they have just adopted the .uk which has been a disaster this can only be seen as a grab for cash by the registrar’s
Alex Blake	Yes	Should be allowed	I can say this no other way, but your lack of consultation with SME’s (Small Business) undermines the validity of any recommendations you the PRP may ultimately make. The same goes for not appointing a “Peak Body Representative” to the PRP. That is simply ludicrous. That’s like wanting to create a new suburb on the outskirts of Melbourne and failing to consult the Council.
Andrew Waterhouse	Yes	N/A	Succinctly, I and my company are strenuously opposed to allowing direct .au registration as posited in the document and support retention of the status quo. Our opposition to said changes is based significantly on concerns about the intelligibility of the domain naming taxonomy, and about the security, stability and trustworthiness of the internet in a period of greatly heightened abuses, technical complexities and consumer anxieties.
Baby Paws Australia Pty Ltd	No	N/A	The public and businesses appear to be unaware of this action. There has been very little publicity explaining the “need” for this change, or how it would affect owners of current .com.au domains. Given that there is apparently a Government review into auDA’s operations underway, surely there should be a halt to introducing something as radical as this.
Ben Hall	No	N/A	For the past two years, no website, domain or bricks and mortar business with an online presence can sell, transfer, invest or value their enterprise without being unable to answer the critical variable of whether their investment in any 2LD .com.au business will automatically include the TLD .AU, or worse, if their right to .au will be given away to a competitor to imitate or compete with their investment, or the business will be forced into litigation, mediation, or held to ransom via an auction process.
Ben Motteram	No	N/A	I wish to register my opposition to the proposed introduction of a .au domain name. It won’t deliver me any benefit whatsoever and in fact will just end up confusing my customers. The only people who will benefit from the change are domain name sellers and lawyers. Please scrap this proposal immediately.
Brian Worth	No	N/A	Those who paid for and acquired domain names they considered valuable generic names should either be protected, or if rights are to be removed, then compensated at present day values. To do otherwise is subject to Protest.
CAANZ	No	N/A
Carsales.com Ltd	No	N/A	It is imperative that any process to introduce the .au TLD supports these businesses by reserving the .au TLD for existing 2LD registrants, with .com.au 2LD registrants afforded preference over other 2LD holders.
Cherie Quin	Yes	Should be allowed	I would like to say that I oppose direct registrations and I am a small business person. It should not happen.
Christopher Norris	Yes	Should be allowed	Our strong suggestion on this topic is to that the implementation of direct registration should be reversed until such time as the public is made adequately aware of this change. If this is to go forward, the .com.au owner should receive first rights to the .au counterpart for 5 years for free.
Colin McKechnie	No	N/A	If foreign language characters are to be allowed a lot of problems will occur when these characters are required in documents prepared using the standard qwerty keyboard.
Craig Kirchner	No	N/A	As a small business with much to do in marketing our business and not enough people to do it, the last thing we need is to be fixing things that are working fine. We have NO issues with our current domains. Moreover, we have marketing collateral developed over many years, all pointing to our .com.au domains. We DO NOT want to confuse our customers.
David Warmuz	Yes	Should be allowed	Domain monetisation needs to continue to be permitted in .com.au. If the .com in .com.au stands for commerce then why would we want to limit a perfectly legitimate commercial activity like advertising. It is hard to imagine a namespace without monetisation.
Davies Collison Cave	Yes	Conditionally opposed	Domain monetisation should only be permitted in certain limited circumstances. DCC also confirms its previous submission that rights holders and existing registrants be allowed to apply for a .au domain name during a sunrise period prior to general release.
Don Rankin	Yes	Should be allowed
edu Domain Administration Committee	Yes	N/A	The eDAC submission argues for retaining the current 2LDs and the eligibility and allocation rules which currently relate to them. The submission also supports the current use of state and territory designations and extension of their use where appropriate. eDAC also strongly supports the reservation of names in the public interest and for other reasons, and in particular education and training names.
eDigital	No	N/A	We are entrepreneurs with no salaries and your porposed .au will bring only concerns and wasted money to our business!! Please do not offer .au as it has not actually worked in other countries and the only people who benefit are domain name sellers.
Education Services Australia	Yes	N/A	The .au domain namespace should reflect the same general principles as the rest of the domain, which are: • no proprietary rights in a domain name • no hierarchy of rights • allocation of domains on a first come, first served basis.
Federation of Ethnic Communities’ Councils of Australia	No	N/A	FECCA recommends that auDA distribute a community education campaign clearly outlining the implications of direct registration and which outlines processes and procedures that may be required for individuals and entities to secure new domain names in addition to existing 2LDs. As above, FECCA recommends campaigns that are easy to access, offered in multiple languages and distributed through a variety of channels.
Internet Australia	Yes	Opposed	It is of paramount importance that the Australian .AU TLD continues to be governed, managed, maintained and monitored with the overarching goal of enhancing the trust, safety and confidence of Internet users accessing the content of the registrants’ names, ahead of convenience or revenue for registrants and registrars.
Jeanette Gayler	No	N/A	We do not support the proposed introduction of the .au namespace. Having read the Policy proposal, I can see no justification for the introduction of the new namespace. It is my understanding that there is no shortage of domain names under the current system.
Jeff Marr	Yes	Should be allowed	I am clearly not in favour of the introduction of direct registrations via the .au domain name extension for all the reasons provided. I also feel that the broader community (who have not really been made aware of these proposed changes in any substantial numbers), have also not been fairly represented in the entire process, with the Policy Panel selected to make the final decision not having a peak business body representative present on the panel from the very beginning as was the intention and plan when originally forming the Panel.
Jeremy LaBrooy	No	N/A	As a person who could benefit from this introduction of a new series of domain names can I implore you to scrape this plan. I operate a small digital web agency and I manage my clients DNS and domains on a reseller hosting platform. I could reach out to my clients and say you need to buy these extra domains to protect your online IP, buy why should they (or I for that matter) have to? What protection will you offer a business that goes through the proper business name registration channels?
Jim Stewart	No	N/A	In summary auda is proposing a change, that will devalue existing com.au assets and if implemented properly by site owners, will see a 50% drop in traffic/revenue and a further drop in click through rates for a unknown period. There are zero benefits. None. Nada. Zilch. Direct AU registrations are disastrous idea for the AU namespace and should be abandoned as soon as possible. It would be negligent of auda to do otherwise now they are informed. I will be making this submission publicly available and encouraging clients who register a Direct AU and have losses to bring a claim against auda for compensation.
John Naismith	No	N/A	As a business owner with several .com.au domain names, this proposal if approved will devalue .com.au domain names, thus damaging my business and others. The only businesses that will gain from this proposal are the sellers of domain names. Australian small businesses have enough challenges in front of them without introducing another unnecessary challenge. Please do not allow this proposal to go ahead.
Julie Pianto	No	N/A	I believe this push to have “.AU” domains is just a way for registrars to increase revenue and apart from usage statistics from around the world (which is misleading – because owners of 2LD and 3LD would have felt forced to register), I have not seen an answer to the question “why do we need .au?”. Who is pushing this and why?
Justin Bohlmann	No	N/A	It’s an absolute waste of time and money. Why would a registered business who already owns the .com.au need to then own the .au other than to stop someone trying to impersonate their brand and take market share from their business?? That’s a problem that wouldn’t exist if the .au wasn’t available.
Karen Morrison	No	N/A	I have no choice but to now publicly come out and say, I no longer have any faith that Direct .AU Registrations are going to be a good idea. In fact, I feel that implementing Direct .AU Registrations are now going to do nothing but damage the reputation, value and trust of our Australian domain name ccTLD. auDA need to reverse their decision, about bringing Direct .AU Registrations into existence. It’s clear this just isn’t going to work.
Keith Bower	No	N/A	We propose that the domain name allocations to be always awarded to the longest serving registrant instead of the raffle. Since this ‘first in best dressed system’ is already operated for TLD registration, giving priority rights to the longest serving registrant would be ‘fairest’ in this situation. To align with most of the other TLDs on the market and to be consistent, we also suggest that the registration term for .au should be 1 – 10 years. This would align .au with other TLDs and be the least confusing option for customers.
Kon Summer	No	N/A	Will owners of existing .com.au, .net.au, have first rights to register? If yes what is the point of opening up .au most will just register their name not creating additional alternatives, just creating extra costs?
Louise Sandberg	No	N/A	Based on my own views and those of a considerable number of private business owners I have discussed the matter with, I feel strongly that preference should be given to existing .com.au domain owners for the registration and allocation of .au names.
Luke Scott	No	N/A	We have a situation where businesses are not allowed to have the same name to stop confusion via ASIC. By not offering these dot au extensions to the business with that registered business name then only problems can only arise. This change smells of a cash grab on your front as it will be another set of extensions that businesses will have to buy in order to protect their business interests.
Magnus Celander	No	N/A	If this is not a money grab aimed at raising money for Domain Registrars and auDA, then why not simply give the .au extension to the .com.au owner for free along with the option to use it? Many small business will find themselves in a lottery under the current proposal, especially if they own a good domain name. It should not have been introduced, the major stakeholders are being ignored and the push behind this seems to be from the registrars.
Matt Knighton	No	N/A	The new proposed .au is a very much worthless idea. At present we do not have a shortage of domain names or issues around domains in Australia. Its actually one of the best systems internationally to ensure the right domain stays with the right company.
Melbourne IT	Yes	Opposed	Monetisation should be removed from the allocation criteria in the existing 2LD spaces. Furthermore we believe there should be a prohibition on re-sale in the second level space for a period of no less than 5 years. Re-sale as a business asset in a whole of business sale should be allowed, the re-sale of only a domain license should not.
Michelle Mannering	No	N/A	The changes you are proposing will hinder many new companies coming through the system and will bring the startup community to a hault. I urge you to strongly consider your review. I don’t believe anything such as this is necessary.
NAME WITHHELD	No	N/A	I submit that auDA needs to offer .au registrant consumers the opon to choose Whois Privacy and that this is made policy as soon as is possible. auDA has not kept up to date with the reasons why this is needed and how it has worked successfully now in the majority of world extensions as a FREE option by Registrar.
News Corp Australia	No	N/A	The decision to implement .au direct registration should be reviewed; and if auDA determines that it will proceed with the implementation of .au direct registration, News submits that auDA should adopt an order of priority allocation model with first priority given to .com.au registrants.
Nick Young	No	N/A	As a .com.au holder, I am strongly against this blatant cash grab by AUDA, and incredibly disappointed to see a regulatory body so obviously corrupted.
Nikki Scholes	Yes	Should be allowed	If the panel proceeds with the current implementation model for direct registrations there should be a system in place which manages or provides support for the agreement phase. During this phase registrants could be subject to coercion from competing registrants, being forced to forgo their opportunity to hold the .au domain name
Paul Shaw	Yes	Should be allowed	I continue to oppose auDA’s decision to introduce the .AU extension. This will create consumer confusion and it will have a negative effect on the brand equity that Australian business has built up under the current system.
Peter Cawley-Boevey	No	N/A	This is an appalling idea. It will simply be confusing for the general public, open to abuse by fake news generators and other internet scammers. The only people that stand to benefit are people like me who sell domain names and i don’t want it.
REA Group Ltd.	Yes	Opposed	REA submits that the decision to implement .au direct registration should be reviewed. If auDA determines that it will proceed with implementation of .au direct registration, REA submits that auDA should adopt an order of priority allocation model with first priority given to .com.au registrants.
Robert Kaay	Yes	Should be allowed	I would first prefer that Direct .AU Registrations be taken off the table. I am reversing my previous opinion because I feel mislead on how the PRP are planning on implementation. I have publicly written about this on NameBid.com.au(.) If more people than not support abandoning Direct .AU Registrations in this latest submission process, auDA should reverse the decision to implement Direct .AU Registrations altogether.
Samuel Herzberg	Yes	Should be allowed	There should not be any eligibility requirements in place.
Scott Long	Yes	Should be allowed	Introducing tighter restriction on allocating domain names would reduce the number of registered and registrable domains in the DNS, this will dramatically affect auDA’s bottom line, increase end user costs, and registries will go broke. Relaxing or abolishing this “close and substantial rule” allows for a healthier market place, everyone with an interest in obtaining the best brand for their business will simply make an offer on existing domain names, if rejected, get a loan or get creative.
Telstra Corporation Ltd.	Yes	Opposed	While Telstra supports some of the reforms proposed by the panel in the issues paper, we do not agree with measures which would unfairly dilute domain holders’ rights, the goodwill they have built in their domains, or undermine user confidence in the .au namespace.
Vinesh Chora	Yes	Should be allowed	(Direct registrations) will cause confusion in the market place including trademark and legal issues. The implementation proposals are unfair including cut off dates and a “ lottery” system which is an unacceptable way to conduct business. It forces registrants to defensively register domains adding costs to small business for no real benefit. We still haven’t been shown any proof that there is a demand for direct au registrations.

Luke O’Meara – 23 March 2018

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