The W3C document proceeds from a wrong premise -- that domain names are trademarks and their inherent value must be protected. Trademark pressures on the DNS therefore justify the limited market for 2nd level TLDs and moves designed to protect that market. But the hidden costs of such a restrictive view of the DNS are high and so are the costs of granting exclusive rights to domain names (a technical imposition of the DNS). Instead of protecting the market for tradename-domain names, ICANN should introduce hundreds of new TLDs (as originally proposed by Jon Postel). Then the DNS namespace will mimic the features of language in which case, as Landes and Posner have shown, the costs of exclusive rights to words are minimized while the benefits of exclusivity (i.e., lower search costs) are maximized.