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

Evan Leibovitch evan at telly.org
Thu Jul 10 19:49:50 UTC 2014


Personally, I don't think there should be any restriction on of two-letter
strings.

Each country has an ISO code for its own ccTLD. That should suffice. Unless
a gTLD registry wants themselves to segment their TLD by country there
should be no reason to reserve strings, especially when the strings are
also dictionary words ("my", "is", "to", "je", "si") or useful acronyms
("ie", "fm", "ps", "ip").

Since when is an ISO code a trademark (or to be treated like one)?

I disagree with compounding the problem by reserving every two letter
string to anticipate conflict with countries not yet existing.

And where does the lunacy stop? WIPO and other non-state intellectual
property orgs have reserved numerous ISO "country codes" for themselves
(ap, bx, ef, em, ep, ev, gc, ib, oa, wo)

As yet I'm not convinced of the need for an ALAC statement. But if there
was one I would recommend dropping ALL reservations against two-letter
strings in gTLDs.



On 10 July 2014 02:06, Dev Anand Teelucksingh <devtee at gmail.com> 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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-- 
Evan Leibovitch
Toronto Canada

Em: evan at telly dot org
Sk: evanleibovitch
Tw: el56



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