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Approved Resolutions | Meeting of the New gTLD Program Committee

  1. Main Agenda

 

  1. Main Agenda:

    1. BGC Recommendation Regarding Reconsideration Request 13-9, Amazon EU S.á.r.l.

      Whereas, Amazon EU S.a.r.l.'s ("Amazon's") Reconsideration Request ("Request 13-9"), seeks reconsideration of the Expert Determination sustaining Commercial Connect LLC's objection to Amazon's TLD application for the Japanese characters that translate into "online shopping" as being confusingly similar to Commercial Connect's application for .SHOP.

      Whereas, the Board of Governance Committee ("BGC") considered the issues raised in Request 13-9.

      Whereas, the BGC recommended that Request 13-9 be denied because the Requester has not stated proper grounds for reconsideration and the New gTLD Program Committee agrees.

      Resolved (2014.11.07.NG01), the New gTLD Program Committee adopts the BGC Recommendation on Reconsideration Request 13-9, which can be found at http://www.icann.org/en/groups/board/governance/reconsideration/recommendation-amazon-10oct13-en.pdf [PDF, 132 KB].

      Rationale for Resolution 2014.11.07.NG01

      1. Brief Summary

        The Requester Amazon EU S.a.r.l. is an applicant for the TLD in Japanese characters that translate into "online shopping" ("Amazon's Applied-for String"). Commercial Connect LLC ("CC") applied for .SHOP ("CC's Applied-for String"). CC objected to Amazon's Applied-for String, asserting that it was confusingly similar to CC's Applied-for String ("CC's Objection"). The Panel ruled in favor of CC's Objection on the grounds that Amazon's Applied-for String is confusingly similar to CC's Applied-for String. The Requester claims that the Dispute Resolution Provider (ICDR) and the Panel failed to follow the established process for registering and/or accepting CC's Objection. The Requester further claims the Panel applied the wrong standard in evaluating CC's Objection. The Requester asks that ICANN disregard the Panel's Expert Determination, and either instruct a new Panel to review CC's objection with the standards set forth in the Applicant Guidebook or make the necessary accommodations to allow for a "non-discriminatory application of ICANN standards, policies and procedures." (Request, Section 9.)

        The BGC concluded that the Requester has not stated proper grounds for reconsideration because there is no indication that either the ICDR or the Panel violated any policy or process in accepting and sustaining CC's Objection. Given this, the BGC recommends that Request 13-9 be denied. The NGPC agrees.

      2. Facts

        1. Relevant Facts

          The Requester Amazon EU S.a.r.l. is an applicant for the TLD in Japanese characters that translate into "online shopping" ("Amazon's Applied-for String"). Commercial Connect LLC ("CC") applied for .SHOP ("CC's Applied-for String"). Top Level Domain Holdings Limited ("TLDH") applied for the TLD in Chinese characters that translate into "shopping" ("TLDH's Applied-for String").

          CC objected to both Amazon's Applied-for String and TLDH's Applied-for-String, asserting that both strings were confusingly similar to CC's Applied-for String.

          On 21 August 2013, the Expert Panel sustained CC's objection to Amazon's Applied-for String on the grounds that Amazon's Applied-for String is confusingly similar to CC's Applied-for String.

          A different Expert Panel dismissed CC's objection to TLDH's Applied-for-String on the grounds that the two applied-for strings are not confusingly similar and on 4 September 2013, the Requester filed Request 13-9.

        2. Requester's Claims

          The Requester claims that CC failed to provide Amazon with a copy of the objection as required by Article 7(b) of the New gTLD Dispute Resolution Procedure ("Procedure"), and that this failure is a deficiency that cannot be rectified. The Requester further claims that the Panel applied the wrong standard in evaluating CC's Objection. Specifically, the Requester claims that the Panel applied a standard that considered "the use of essentially the same word in two different languages [as] sufficient to cause string confusion among the average, reasonable Internet user," and claims that such a standard would eliminate the need to evaluate translations of words on a case-by-case basis.

      3. Issues

        The issues for reconsideration are: (1) whether the ICDR and the Panel's acceptance of CC's Objection demonstrate a policy or process violation; and (2) whether the Panel applied the wrong standard in evaluating CC's Objection.

      4. The Relevant Standards for Evaluating Reconsideration Requests

        ICANN's Bylaws call for the BGC to evaluate and make recommendations to the Board with respect to Reconsideration Requests. See Article IV, Section 2 of the Bylaws. The NGPC, bestowed with the powers of the Board in this instance, has reviewed and thoroughly considered the BGC Recommendation on Request 13-9 and finds the analysis sound.

      5. Analysis and Rationale

        1. The ICDR and the Panel's Acceptance of Commercial Connect's Objection Does Not Demonstrate A Process Violation.

          The BGC concluded, and NGPC agrees, that the ICDR's acceptance of CC's Objection does not demonstrate a policy or process violation, and the Requester has not demonstrated otherwise. The Requester claims that CC failed to provide the Requester with a copy of the objection as required by Article 7(b) of the Procedure, and that this failure is a deficiency that cannot be rectified. The Requester further claims that, pursuant to Article 9(d) of the Procedure, which provides for dismissal of objections that do not comply with Articles 5-8 of the Procedure and where deficiencies have not been cured in the specified timeframe, the ICDR should have dismissed CC's Objection and closed the proceedings. Pursuant to the Procedure, the ICDR was required to perform an administrative review of CC's Objection, and to inform the objector, applicant, and ICANN of the results of its administrative review. (Procedure, Art. 9(a).) The BGC concluded that the available record shows that the ICDR complied with its obligations in this regard. The ICDR's 4 April 2013 email, requesting CC to cure the stated deficiency, was consistent with the process established in the Procedure for the administrative review of objections.

          The BGC further noted that the available record demonstrates that the Requester did receive notice that an objection had been filed against it and that the Requester was required to respond to avoid default. The Requester acknowledged receipt of a copy of the objection, and that the ICDR invited the Requester to raise the alleged procedural defects in its response to CC's Objection. The BGC found that the Panel, having received and considered the Requester's claims of procedural deficiencies, rejected the Requester's claims indicating there was no actual prejudice to the Requester. Accordingly, the BGC concluded that the ICDR's acceptance of CC's Objection did not violate any policy or process.

        2. The Requester's Claim That The Panel Applied The Wrong Standard Is Unsupported And Is Not A Basis For Reconsideration.

          The BGC concluded, and the NGPC agrees, that the Requester's claim that the Panel applied the wrong standard does not support reconsideration. The BGC noted that the relevant standard for evaluating a string confusion objection is set out in Section 3.5.1 of the Applicant Guidebook and that the Panel referenced and correctly stated the applicable standard more than once in its evaluation of CC's Objection. Based on the parties' contentions, it appears that the Panel concentrated on the meanings of the two strings and identified three related issues that needed to be examined. The BGC determined that the Panel's focus on the meanings of the strings is consistent with the standard for evaluating string confusion objections. A likelihood of confusion can be established with any type of similarity, including similarity of meaning. (Guidebook, Section 2.2.1.1.3.) The BGC further concluded that any claim by the Requester that the Panel must limit itself to a standard of aural or visual similarity is not supported by available documentation, and does not support a finding that the Panel violated any established policy or procedure.

          The BGC also noted that, contrary to the Requester's contention, the Panel did not automatically conclude that there was a likelihood of confusion between CC's Applied-for String and Amazon's Applied-for String. Rather, it appears that the Panel conducted a detailed and comprehensive analysis of the issues before reaching its determination.

          With respect to the Requester's reliance on another ICDR Panel's determination finding that Top Level Domain Holdings Limited's ("TLDH") application for the TLD in Chinese characters that translate into "shopping" ("TLDH's Applied-for String") is not confusingly similar to CC's application for .SHOP as evidence that the Panel applied the wrong standard, the BGC found that the fact that these two ICDR Panels evaluated potentially similar objections yet came to different conclusions does not mean that one Panel applied the wrong standard. On a procedural level, each Panel generally rests its determination on the materials presented to it by the parties to that particular objection, and the objector bears the burden of proof. Two Panels confronting nearly identical issues could rightfully reach different determinations, based on the strength of the materials presented. While CC was the objector in both proceedings, the objections were rebutted by different applicants. Thus, the Panels reached different determinations at least in part because the materials submitted by each applicant (Amazon and TLDH) in defense of its proposed strings were different.

      6. Decision

        The NGPC had the opportunity to consider all of the materials submitted by or on behalf of the Requestor (see https://www.icann.org/resources/pages/13-9-2014-02-13-en) or that otherwise relate to Request 13-9. Following consideration of all relevant information provided, the NGPC reviewed and has adopted the BGC's Recommendation on Request 13-9, which shall be deemed a part of this Rationale and the full text of which can be found at https://www.icann.org/en/groups/board/governance/reconsideration/13-9/recommendation-amazon-10oct13-en.pdf [PDF, 132 KB].

        Although there are no grounds for reconsideration presented in this matter, following additional discussion of the matter, the BGC recommended that staff provide a report to the NGPC setting out options for dealing with the situation raised within this Request, namely the differing outcomes of the String Confusion Objection Dispute Resolution process in disputes similar to that of Amazon's Applied-for String and TLDH's Applied-for String. As a result, the NGPC postponed its consideration of Request 13-9 pending the NGPC's completion of its consideration of how to address concerns of perceived inconsistent SCO Expert Determinations. At its 5 February 2014 meeting, the NGPC directed the President and CEO to initiate a public comment period on framework principles of a proposed SCO Review Mechanism, which was the subject of public comment (see https://www.icann.org/en/system/files/files/report-comments-sco-framework-principles-24apr14-en.pdf [PDF, 166 KB]).

        After careful consideration of the report that the BGC asked staff to draft regarding Reconsideration Request 13-9 and 13-10, the public comments received regarding a proposed SCO Review Mechanism, other comments provided to the NGPC for consideration, as well as the processes set out in the Guidebook, at its 12 – 14 October 2014 meeting, the NGPC concluded its consideration of the perceived inconsistent or otherwise unreasonable SCO Expert Determinations. At that time, the NGPC identified two specific SCO Expert Determinations, one of which is the SCO at issue in Request 13-9, as not in the best interest of the New gTLD Program and the Internet community. The NGPC directed that these Expert Determinations be sent back to the ICDR for a three-member panel evaluation to render a final Expert Determination. As part of its rationale, the NGPC acknowledged that on balance, adopting the SCO Review Mechanism would not be appropriate for the current round of the New gTLD Program, but recommended that the development of rules and processes for future rounds of the New gTLD Program (to be developed through the multi-stakeholder process) should explore whether there is a need for a formal review process with respect to Expert Determinations. The NGPC noted that it would now resume its consideration of the BGC Recommendation's on Request 13-9.

        In terms of timing of the BGC's Recommendation, the Bylaws provide that the BGC shall make a final determination or recommendation to the Board [or NGPC as appropriate] with respect to a Reconsideration Request within thirty days following receipt of the request, unless impractical. See Article IV, Section 2.16 of the Bylaws. To satisfy the thirty-day deadline, the BGC would have to have acted by 4 October 2013. Due to the number of Reconsideration Requests submitted, the first practical opportunity for the BGC to take action on this Request was on 10 October 2013. Additionally, Article IV, Section 2.17 provides that the Board (or NGPC in this case) shall issue its decision on the recommendation of the BGC within 60 days of receipt of the Reconsideration Request or as soon thereafter as feasible. Due to the NGPC's consideration of how to handle perceived inconsistent SCO Expert Determinations, including the proposed SCO Review Mechanism and the public comment on the proposal, it was impractical for the NGPC to consider the Request sooner than now.

        Adopting the BGC's recommendation has no direct financial impact on ICANN and will not negatively impact the systemic security, stability and resiliency of the domain name system.

        This decision is an Organizational Administrative Function that does not require public comment.

    2. BGC Recommendation Regarding Reconsideration Request 13-10, Commercial Connect, LLC

      Whereas, Commercial Connect, LLC's ("Commercial Connect's") Reconsideration Request ("Request 13-10"), seeks reconsideration of ICANN staff's acceptance of two allegedly inconsistent expert determinations from dispute resolution Panels appointed by the International Centre for Dispute Resolution.

      Whereas, Request 13-10 challenges the staff's acceptance of the Expert Determination dismissing Commercial Connect's objection to Top Level Domain Holdings Limited's gTLD application for the Chinese characters that translate into "shopping" in light of the 21 August 2013 Expert Determination sustaining Commercial Connect's objection to Amazon EU S.a.r.l.'s gTLD application for the Japanese characters that translate into "online shopping".

      Whereas, the Board of Governance Committee ("BGC") considered the issues raised in Request 13-10.

      Whereas, the BGC recommended that Request 13-10 be denied because Commercial Connect has not stated proper grounds for reconsideration and the New gTLD Program Committee ("NGPC") agrees.

      Resolved (2014.11.07.NG02), the NGPC adopts the BGC Recommendation on Reconsideration Request 13-10, which can be found at http://www.icann.org/en/groups/board/governance/reconsideration/recommendation-commercial-connect-10oct13-en.pdf [PDF, 113 KB].

      Rationale for Resolution 2014.11.07.NG02

      1. Brief Summary

        The Requester Commercial Connect LLC ("Requester" or CC") applied for the .SHOP string ("CC's Applied-for String"). Top Level Domain Holdings Limited ("TLDH") applied for the gTLD in Chinese characters that translate into "shopping" ("TLDH's Applied-for String"). Amazon EU S.a.r.l. applied for the gTLD in Japanese characters that translate into "online shopping" ("Amazon's Applied-for String"). CC objected to both TLDH's Applied-for String and Amazon's Applied-for String, asserting that both strings were confusingly similar to CC's Applied-for String. The ICDR ruled in favor of CC on its objection to Amazon's Applied-for String on the grounds that Amazon's Applied-for String is confusingly similar to CC's Applied-for String. A different ICDR Expert Panel dismissed CC's objection to TLDH's Applied-for String on the grounds that TLDH's Applied-for String was not confusingly similar to CC's Applied-for String. The Requester claims that both Expert Panels failed to follow the appropriate process in evaluating the merits of the objections by applying the Applicant Guidebook in an inconsistent manner. The Requester also claims that ICANN staff's failure to provide clear and well-defined guidance to the Panels and failure to ensure that the Panels complied with the guidelines constituted a material failure of process resulting in inconsistent decisions by the Panels.

        The BGC concluded the Requester has not stated proper grounds for reconsideration. There is no indication that either panel violated any policy or process and there is similarly no indication that ICANN acted inconsistent with any established policy or procedure. Given this, the BGC recommends that Request 13-10 be denied. The NGPC agrees.

      2. Facts

        1. Relevant Facts

          The Requester Commercial Connect LLC ("Requester" or "CC") applied for the .SHOP string ("CC's Applied-for String"). Top Level Domain Holdings Limited ("TLDH") applied for a gTLD in Chinese characters that translate into "shopping" ("TLDH's Applied-for String"). Amazon EU S.a.r.l. applied for the gTLD in Japanese characters that translate into "online shopping" ("Amazon's Applied-for String").

          The Requester objected to both TLDH's Applied-for String and Amazon's Applied-for String, asserting that both strings were confusingly similar to CC's Applied-for String; TLDH and Amazon each filed responses in separate proceedings.

          On 8 August 2013, ICDR's appointed panelist rendered an expert determination on CC's objection to TLDH's Applied-for String ("TLDH Expert Determination"). The Panel ("TLDH Panel") dismissed CC's objection on the grounds that the two applied-for strings are not confusingly similar to the average, reasonable Internet user under the standard set forth in the New gTLD Dispute Resolution Procedure ("Procedure") and the Applicant Guidebook ("Guidebook").

          Separately, for the Requester's objection to Amazon's Applied-for String, a different ICDR panel ("Amazon Panel") sustained CC's objection on the grounds that the two applied-for strings are confusingly similar ("Amazon Expert Determination").

          On 5 September 2013, the Requester filed Request 13-10.

        2. Requester's Claims

          The Requester claims that both the TLDH and the Amazon Panels failed to follow the appropriate process in evaluating the merits of the objections by applying the Guidebook in an inconsistent manner. The Requester claims that ICANN staff's failure to provide clear and well-defined guidance to the Panels and failure to ensure that the Panels complied with the guidelines constituted a material failure of process resulting in inconsistent decisions.

      3. Issues

        The issues for reconsideration are: (1) whether the purported inconsistencies between expert determinations demonstrate a policy or process violation; and (2) whether ICANN's alleged failure to provide guidance to the Panels supports Reconsideration.

      4. The Relevant Standards for Evaluating Reconsideration Requests

        ICANN's Bylaws call for the BGC to evaluate and make recommendations to the Board with respect to Reconsideration Requests. See Article IV, Section 2 of the Bylaws. The New gTLD Program Committee ("NGPC"), bestowed with the powers of the Board in this instance, has reviewed and thoroughly considered the BGC Recommendation on Request 13-10 and finds the analysis sound.

      5. Analysis and Rationale

        1. The Purported Inconsistencies Between Expert Determinations Do Not Demonstrate A Process Violation.

          The BGC concluded, and the NGPC agrees, that the fact that two different expert panels came to different conclusions does not mean that the panels inconsistently applied the standard for evaluating string confusion objections, nor does it establish a policy or process violation. CC relies on Section 2.2.1.1.3 of the Guidebook, which states that a string confusion objection may be based on any type of similarity, including visual, aural or similarity of meaning. CC contends that the TLDH Panel determined that "the guidelines do not permit confusion to be based on meaning alone" when evaluating an application for Internationalized Domain Names with foreign characters, while the Amazon Panel determined the "use of essentially the same word in two different languages is sufficient to cause string confusion." (Request, Pg. 5.) The BGC noted that each expert panel generally rests its determination on the materials presented to it by the parties to that particular objection, and the objector bears the burden of proof. Two panels confronting nearly identical issues could rightfully reach different determinations, based on the strength of the materials presented. While CC was the objector in each of these determinations, each objection was rebutted by a different applicant. Thus, the panels reached different decisions at least in part because the materials submitted by each applicant (TLDH and Amazon) in defense of its proposed string were different, and not because one panel violated any established policy or process in reaching its determination.

          The BGC further noted that the TLDH Panel dismissed CC's objection not because it concluded that translations of essentially the same word are insufficient to cause string confusion – as CC contends – but because TLDH presented convincing evidence that there was little likelihood of confusion between CC's Applied-for String and TLDH's Applied-for String.

          Accordingly, the BGC determined, and the NGPC agrees, that CC has not been able to establish an actual policy or process that either panel failed to follow. The Request instead challenges the substantive determinations of the panels rather than the processes by which the panels reached their determinations. While CC may disagree with the TLDH Panel's findings, Reconsideration is not available as a mechanism to re-evaluate the substantive determination of the TLDH Panel.

        2. ICANN's Alleged Failure To Provide Guidance To The Panels Does Not Support Reconsideration.

          The BGC concluded, and the NGPC agrees, that CC does not identify any established policy or process that required ICANN to take action above the action it has already taken in implementing the New gTLD Program. CC's disagreement as to whether the standards should have resulted in the TLDH Panel dismissing CC's objection does not mean that ICANN violated any policy or process in accepting the decision (nor does it support a conclusion that either panel's decision was wrong). The Guidebook sets out the standards used to evaluate and resolve objections. The TLDH Expert Determination and the Amazon Expert Determination reflect that the panels followed the evaluation standards.

          The BGC also found that ICANN's acceptance of the determinations as advice to ICANN is also in accordance with the established process. (Guidebook, Section 3.4.6.) CC's attempt to claim here that the procedures set forth in the Guidebook for evaluating string confusion objections, which followed years of inclusive policy development and implementation planning, are somehow deficient because of allegedly inconsistent expert determinations is therefore not supported and should be rejected.

      6. Decision

        The NGPC had the opportunity to consider all of the materials submitted by or on behalf of the Requestor (see https://www.icann.org/resources/pages/13-10-2014-02-13-en) or that otherwise relate to Request 13-10. Following consideration of all relevant information provided, the NGPC reviewed and has adopted the BGC's Recommendation on Request 13-10, which shall be deemed a part of this Rationale and the full text of which can be found at https://www.icann.org/en/groups/board/governance/reconsideration/13-10/recommendation-commercial-connect-10oct13-en.pdf [PDF, 113 KB].

        Although there are no grounds for reconsideration presented in this matter, following additional discussion of the matter, the BGC recommended that staff provide a report to the NGPC setting out options for dealing with the situation raised within this Request, namely the differing outcomes of the String Confusion Objection Dispute Resolution process in disputes similar to that of Amazon's Applied-for String and TLDH's Applied-for String. As a result, the NGPC postponed its consideration of Request 13-10 pending the NGPC's completion of its consideration of how to address concerns of perceived inconsistent SCO Expert Determinations. At its 5 February 2014 meeting, the NGPC directed the President and CEO to initiate a public comment period on framework principles of a proposed SCO Review Mechanism, which was the subject of public comment (see https://www.icann.org/en/system/files/files/report-comments-sco-framework-principles-24apr14-en.pdf [PDF, 166 KB]).

        After careful consideration of the report that the BGC asked staff to draft regarding Reconsideration Request 13-9 and 13-10, the public comments received regarding a proposed SCO Review Mechanism, other comments provided to the NGPC for consideration, as well as the processes set out in the Guidebook, at its 12 – 14 October 2014 meeting, the NGPC concluded its consideration of the perceived inconsistent or otherwise unreasonable SCO Expert Determinations. At that time, the NGPC identified two specific SCO Expert Determinations as not in the best interest of the New gTLD Program and the Internet community. The NGPC directed that these Expert Determinations be sent back to the ICDR for a three-member panel evaluation to render a final Expert Determination. Of significance to this Reconsideration Request, the NGPC specifically directed review of the Expert Determination concerning Amazon's Applied-for String (at issue in Request 13-9), and in so doing, the NGPC recommended that the three-member panel also review as background the Expert Determination concerning TLDH's Applied-for String. As part of its rationale, the NGPC acknowledged that on balance, adopting the SCO Review Mechanism would not be appropriate for the current round of the New gTLD Program, but recommended that the development of rules and processes for future rounds of the New gTLD Program (to be developed through the multi-stakeholder process) should explore whether there is a need for a formal review process with respect to Expert Determinations. The NGPC noted that it would now resume its consideration of the BGC Recommendation on Reconsideration Request 13-10.

        In terms of timing of the BGC's Recommendation, Section 2.16 of Article IV of the Bylaws provides that the BGC shall make a final determination or recommendation to the Board [or the NGPC as appropriate] with respect to a Reconsideration Request within thirty days following receipt of the request, unless impractical. See Article IV, Section 2.16 of the Bylaws. To satisfy the thirty-day deadline, the BGC would have to have acted by 4 October 2013. Due to the number of Reconsideration Requests submitted between September through October 2013, the first practical opportunity for the BGC to take action on this Request was on 11 October 2013. Additionally, Article IV, Section 2.17 provides that the Board (or the NGPC in this case) shall issue its decision on the recommendation of the BGC within 60 days of receipt of the Reconsideration Request or as soon thereafter as feasible. Due to the NGPC's consideration of how to handle perceived inconsistent SCO Expert Determinations, including the proposed SCO Review Mechanism and the public comment on the proposal, it was impractical for the NGPC to consider the Request sooner than now.

        Adopting the BGC's recommendation has no direct financial impact on ICANN and will not negatively impact the systemic security, stability and resiliency of the domain name system.

        This decision is an Organizational Administrative Function that does not require public comment.

    3. GAC Advice – Los Angeles Communiqué

      No resolution taken.

    4. ALAC Statement on Public Interest Commitments

      No resolution taken.

Published on 11 November 2014

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as""icann.org"" is not an IDN."