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

[Holly Raiche]

Hi Dev

I realise this is a bit late, but I tend to agree there may be a concern with two-chracter domain names.  Is there also the possibility of added confusion by users since two letter TLDs have, until now, referred to a country code (whether managed by an instrumentality of that government or not)

So maybe something brief in response?

Holly


On 10 Jul 2014, at 5:08 pm, Olivier MJ Crepin-Leblond <ocl at gih.com> wrote:

> 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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> 
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