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

[Dev Anand Teelucksingh]

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