The following are comments submitted by the Singapore Network Information Centre (SGNIC) Pte Ltd in consultation with the various Internet Access Service Providers which are also represented in SGNIC's Board of Directors.

1. Protection of the root DNS

One of the shared principles highlighted in the Paper is ensuring the stability of the Internet. We believe that protecting the root DNS would go a long way in doing this.

2. Continuity of delegated country-code top-level domain registry

Almost all existing national registries for country-code top-level domains have invested a lot of effort and resources in setting up the registry and putting in place registration policies and in some cases legal framework to handle domain name disputes. For most of them this is sanctioned by the respective national governments.

The Green Paper gives some assurance in letting these registries continue to administer such TLDs but does not say enough about the new corporation recognising them. Some support from the new corporation may be necessary for these registries to continue doing their job.

3. Formation of new gTLDs

The Internet will be in a state of flux for some time with the formation of the new corporation to replace IANA. As such, it may be more workable for the new gTLDs to be introduced (if at all) only when the dust has settled. A good time frame would be a year from the formation of the new corporation.

4. Structure of the new corporation

The Paper has stated that a broad representation will be present on the board of directors for the new corporation. We noted that the representatives from the various regional registries would be considered. We would certainly hope that the international representation is reflected across the Board, i.e. with respect to all the seats and not be limited to the regional registries alone. What matters most is that the board members must have the support of the Internet community and are not influenced by national governments.

Finally, we would also like to voice our support for the new corporation to be a not-for-profit one.

5. Dispute resolution

Currently our policy is to allow for the disputing parties to settle the matter either in a court of law or by arbitration and we agree to abide by the decision. Our agreement with the registrants also allows for us to provide the contact information to the claimant. Additionally it requires the registrant to represent that the domain name does not violate or infringe the rights of a third party. With all these we do not see the need for the registry to be involved in the dispute resolution process, as it is likely to eat away our resources.

At the same time we are amenable to the setting up of a "clearing-house" mechanism to clear famous marks across the gTLDs. A clearing house could reduce the dependence of the registrants and third parties on the registries in disputes resolution. In this regard INTA may be able to assist to draw up a workable model with the consensus of its members.