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Clive Feather's response to the Rules Consultation

The Name


New Rules

- Proposed Rules

- Summary of Changes

- Public Consultation

Infringing Third Party Rights

How to use WHOIS

  This is my personal response to the draft new rules published at http://www.nominet.org.uk/rules/new-rules.html.

For the record, this document is based in part on a document I wrote as a PAB member, but contains significant changes. In particular, though the PAB was "was asked to resolve any ambiguities in the current Rules. In particular, it was agreed that the sub-committee would review the technical mandatory syntax Rules" (see http://www.nominet.org.uk/rules/summary.html), this document has failed to adopt the sub-committee's recommendations, instead adopting flawed and inconsistent text.


  • There is no indication that names are delegated to registrants. In particular, it is not clear that somebody allocated a domain name has the right to create sub-domains within it, nor that they don't have to stick to Nominet's rules when doing so. On the contrary, the wording "and its sub-domains" in bold at the top of the document would imply the opposite.
  • 1.3 should say "... registered with Nominet within ...".
  • There should be a section 3.3 indicating that there are other SLDs which are not listed in either appendix, and explaining how to find out about them (a URL on the Nominet web site, as previously agreed at PAB). There should also be a section 3.4 pointing out that new SLDs are not created according to these rules, but under a separate process (again, with a URL).
  • "historical reasons" is not relevant to 4.7. The point is that rules change over time. The first sentence should be restored to that of the PAB draft:

    4.7 These rules may be subject to change or amendment in the future. No change in these rules ...

  • In 5.2.1 and 5.2.2, the use of "e.g." is wrong - it should be "i.e." - and the word "the" should be restored to the start for clarity. The comment about case should be restored to the end of 5.2.1.
  • There is no need to define "Character" nor to capitalize it in the rest of 5, since it retains its natural meaning.
  • 5.4 could be better worded:

    5.4 The third and fourth characters of a Third Level Domain may not both be hyphens; for the avoidance of doubt, either may be a hyphen if the other is not.

  • 5.6, 5.8, and 5.9 are currently only being applied in some SLDs, and the PAB intended them to apply only to co.uk, me.uk, org.uk, and net.uk (for historical reasons). As such, they don't belong here but rather in the rules for the specific SLDs. [Or, for neatness, in a referenced section in the way that the PAB draft managed.]

    On the policy point, my view is that they should not apply to net.uk either.

  • 5.6 should say "may not consist of two letters only", since "two letters long" is ambiguous ("ab-1" is two letters long). Furthermore, the last sentence should say "... Domains such as ..." and should use italics and full domain names in the same way as the rest of the sentence.
  • Is the figure 64 in 5.7 correct ? Is it likely that the automaton will not be fixed soon ? Even if it is redundant at present, the STD 13 limit of 63 characters in the third level should be stated separately.
  • In 5.8 and 5.9, it is not practical to track the creation of new TLDs and SLDs (while they're still in the proposal stage, someone will register them). For this reason, the PAB draft had an explicit table.
  • Why is 6.1 linking to my personal web site ? Can I put up my own versions of these rules which will then be binding on Nominet?
  • Why are there no links in 6.2, contrary to what 3.2 says?
  • In the me.uk rules, 4.2 and 4.3 are no longer relevant and should be deleted.
  • In the ltd.uk rules, section 3 contains a number of significant errors. This wording should be replaced by the PAB draft (subject to some minor corrections which have since be notified to Nominet).
  • In the net.uk rules, 2.1 would fit better between 2.4 and 2.5. The existing 2.4 doesn't make sense (it's recursive). It would be better to have a separate clause 3:

    3. Requirements on use of the Domain Name

    3.1 [present 2.4, changed to "... set out in this Clause 3, and ..."]

    3.2 [present 2.1]

    3.3 [present 2.5]

[I appreciate that the net.uk rules may be revised anyway.]

Clive D.W. Feather
Internet Expert
Demon Internet
Thus plc
Work: clive@demon.net
Home: clive@davros.org
WWW: http://www.davros.org
Tel: +44 20 8371 1138
Fax: +44 870 051 9937
Mobile: +44 7973 377646

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