[ALAC] Re "Introduction of Two-Character Domain Names in the New gTLD Namespace" Public comment

[Olivier MJ Crepin-Leblond]

Thanks for this, Dev.
You'll note that the Statement is currently marked "No Statement" but if
there is interest and your comments gain traction, the ALAC could indeed
make a Statement.
Kindest regards,

Olivier

On 10/07/2014 08:06, Dev Anand Teelucksingh wrote:
> Regarding the public comment on "Introduction of Two-Character Domain Names
> in the New gTLD Namespace" at https://community.icann.org/x/VqzhAg
> which ends July 10 2014, I've posted the following at
> https://community.icann.org/x/VqzhAg
> for consideration:
>
> "Various registries for multiple gTLDs are applying for exceptions to
> Specification 5, Section 2 of the New gTLD Registry Agreement
> ("Specification 5") with some registries suggesting the release of 2
> character ASCII labels not on the current ISO 3166 standard would suffice.
>
> While this seems harmless, there is a possibility of new countries and
> territories being created, and then allocated a new two character ASCII
> label by ISO 3166/MA (see
> https://web.archive.org/web/20111101141651/http://www.iso.org/iso/country_codes/iso-3166-1_decoding_table.htm
> ).
>
> Any new country or territory created after 2014 would therefore not receive
> the same protection as those in the 2014 ISO 3166-2 list and would find
> that their new 2 character label is "given away", should they wish for
> their 2 character ASCII label to be protected, as per Specification 5.
>
> Now, should the principle established by Specification 5 protecting 2
> character ASCII labels even be in the New gTLD Registry Agreement? Many
> would say, especially given the prevalence of two character labels in
> existing TLDs like .com, .org and .net that this principle shouldn't be
> applied to new gTLDs.
> However, this (IMO) is a separate issue to the question being asked for in
> the public comment.
>
> If Specification 5 is meant to defend the principle that country codes in
> ISO 3166-2 should be protected in new gTLDs, then it should be enforced to
> ensure future countries and territories with new 2 character ASCII labels
> are protected in the same way as those territories and countries in today's
> ISO 3166-2 list.
>
> Therefore, the proposals by Donuts for 143 of its new gTLDS, .kred by
> KredTLD Pty Ltd, .best by BestTLD Pty Ltd and .ceo by CEOTLD Pty Ltd.
> should be turned down in keeping with the principle of Specification 5.
>
> The proposal by .wiki by Top Level Design LLC which specifies that the two
> character ASCII labels will only be used for languages identified by ISO
> 639-1 does appear to meet the threshold that the use will not be confused
> with the corresponding country codes, as per Specification 5 and could be
> approved.
>
> Similarly, the proposal by .globo by Globo Comunicação e Participações S.A
> which proposed the use of two character ASCII labels that are not letters
> or by two characters where only one of the character is a letter are labels
> that would not be used by ISO 3166-2 and could be approved."
>
> Thoughts?
>
> Kind Regards,
>
> Dev Anand Teelucksingh
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