I. Discussion of the Internet as a means for global electronic commerce
rarely takes place at the same time as the discussion of the Internet as
the best means for global electronic communication yet created. DNRC
recommends that these discussions be linked, and both commercial and
communications possibilities be mentioned in policy discussion.

II. DNRC is very pleased that, during the last year, the White House and
NTIA have entered the domestic discussion of Internet governance and become
leaders in that discussion. However, we remain concerned that the U.S.
Patent and Trademark Office continues to take the lead on the international
development of these policy issues. DNRC recommends that the White House and
NTIA organize a task force to develop a cohesive U.S. position on these
issues. This task force should be charged to consider the needs of the
commercial and noncommercial users of the Internet and should be comprised
of people representing both groups.

III. DNRC, in its comments to the Department of Commerce, recommended
and continues to recommend creation of a domestic Internet Council. The IC
would be organized pursuant to the Federal Advisory Committee Act and
include balanced representation from schools and libraries, small and large
businesses, public interest groups, small and large Internet service
providers, and consumer groups. We recognize that the issues of concern
today are only the first to emerge, and a two-year Internet Council will
provide a domestic structure for discussion, discourse and determination of
U.S. positions in the national and international debate. DNRC believes that
creating only international structures (largely in Geneva) will result
immediately in the loss of many voices from the discussion, including
schools, libraries, public interest groups and consumers.

IV. The Internet Council should have authority as quickly as possible
over the .US domain name. The U.S. is the only country without a usable
and dynamic country code. At the same time, the U.S. is the most dynamic
and diverse user of the Internet, with individuals, small businesses,
entrepreneurs and large businesses seeking to share and publish information.
The domain names run by NSI provide no outlet for personal speech, and
the .ORG for organizations is used often by companies who cannot obtain
their chosen domain name in . COM. Tremendous time pressure could be
removed from the international Internet governance debate by allowing the
reorganization and proper management of the .US top level domain.

V. Not all registrars should be bound by the same set of rules for
settling domain name disputes. While it might be appropriate for two
holders of WIPO-registered trademarks to have their dispute mediated under
WIPO rules, DNRC believes that free speech and common law intellectual
property rights will be severely curtailed should WIPO's proposed rules
become the standard for conflict resolution.

VI. Even in the first round of issuing new domain names, gTLDs must
include space for all speech. The DNRC recommends: .POL for Political
Speech (for international town halls and political communities); .LIB and
.SCH for Libraries and Schools; .PERS for Personal Speech (not just last
names, but personal speech of all varieties); and .SBA for small businesses
(and entrepreneurs. This group includes the new companies who are making
the greatest strides in offering goods and services over the Internet.)