Neighborhood Name License, part 3 – Secondary Level Names

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Third Level Domains

Jackson Hts., NYC, February 20, 2016 – This is our third post about concerns we have with the city’s draft Licensing Agreement for neighborhood domain names. In our first we bemoaned a “Without Cause” clause that allows the city to revoke a dotNeighborhood license without notice and without cause. We opined that this policy would preclude any serious investment in developing neighborhood domain names. In our second we spoke of the chilling effects of various content prohibitions and vague language in the License agreement.

Today’s post focuses on a requirement in the draft Licensing Agreement (see Exhibit B, Section 8) that dotNeighborhood operators receive prior written approval before issuing “secondary-level” domain names. Our goal here is to explain how this prior-approval policy reduces the potential of the dotNeighborhoods. But first a bit of background secondary-level domain names.


Like many words and phrases in the draft License Agreement “secondary-level domain” is not defined. And since it can easily be confused with second level domain names, we need to take a close look at the terms.

Second level vs. Secondary-levels – By reserving the 385 neighborhood domain names and requiring detailed applications and license agreements from applicants, city hall established tight control over these 385 second level domain names. Our graphic above shows the 2nd level (Harlem) and 3rd level (Pizza) domains. But there can be far more levels than that. While seldom used there can be a 4th, 5th, 6th, 7th, all the way up to 127th level of domain names. In total these comprise what the city is calling “secondary-level” domain names. (An explanation on the domain name system (DNS) and the rules governing the use of these 127 levels can be found in Wikipedia.)

What the city apparently intends to do by requiring that the operator of a dotNeighborhood domain name receive written consent prior to issuing a “secondary-level domain” is to extend its control over the entire breadth of the neighborhood domains, not just the 385 2nd level neighborhood domain names, but all potential names within the 127 secondary-levels.

The Chrysalis

One of the promising opportunities neighborhood domain names offer arises through the development of these secondary-level domain names. Seldom used on the commercial Internet, we see the secondary-levels as a Chrysalis within the domain name system, with a Monarch awaiting emergence.

The secondary-level names add an intuitive layer to the naming system. They build upon what’s already in our heads. The graphic above shows the word “Pizza” being used in a 3rd level in the “” It doesn’t take an Einstein to imagine where “” or “” will lead.

Thoughtfully allocated and introduced, these names offer advantages to dotNeighborhood operators, name purchasers, users, and the neighborhood as a whole.

  • For dotNeighborhood operators, they offer the potential of revenue. Will entrepreneurs pay $100 a year for the right to develop,, or Will a local retailer like Harlem’s Tonys Pizza pay $20 a year for the “dirt cheap” marketing channel “” represents? We think so.
  • Internet users benefit from what is in essence a digital transplant of New Yorkers mental map that the secondary-level names represent. And with community buy-in (wiki-like with moderated comments, reviews, and ratings) these secondary names will create a trusted resource for residents and visitors alike, and a way to traverse a sea of questionable Yelper services that plague today’s search results.

But innovation will be sapped if the city’s Licensing Agreement requires dotNeighborhood operators to get written permission for every secondary name sold. The licensing agreement’s main sections provide suitable structure to assure that operators run them in a responsible manner. There’s no need for this additional over-the-shoulder regulation. The Section 8 permission requirements for secondary-level names should be deleted.


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  1. Kathleen Hulser  February 28, 2016

    Thanks for clarifying how the confusing “secondary-level” operates


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