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Message from RegistryPro Advisory Board to Tina Dam

Via Email

Ms. Tina Dam
Chief gTLD Registry Liaison
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina Del Ray, California 90292

RE: Request to Amend .Pro Registry Agreement

Dear Ms. Dam:

We are submitting the following statement on behalf of the RegistryPro Advisory Board.

We understand that RegistryPro has requested a modification of its Registry Agreement with the Internet Corporation for Assigned Names and Numbers (ICANN) to provide for the offering of a second-level .Pro domain name alternative to the third-level .Pro domain name which ICANN has already approved (Second-Level Domain Proposal). The primary purpose of the second-level .Pro domain name is to offer the consumer greater choice with respect to available naming conventions.

We believe this choice will enhance the appeal of .Pro to our distribution channel. The proposed second-level .Pro domain will continue to uphold Pro's existing eligibility requirements and registration restrictions and will simply offer wider latitude to end-users.

We have reviewed the Second-Level Domain Proposal and believe it will provide a positive alternative to the .Pro third-level domain name and eliminate unnecessary obstacles to consumer choice and adoption.

Please feel free to contact either of us at the numbers below if you have any questions or would like to discuss this matter further.


John F. Hudson, CPA
Hudson Consulting Group, LLC
78 Main Street
Hastings on Hudson, NY 10706
Direct - (914) 478-8405
[Formerly, Vice President and Chief Knowledge Officer,
American Institute of Certified Public Accountants]

Ron Usher
Staff Lawyer / C.E.O.
Juricert Services Inc.
The Law Society of British Columbia
845 Cambie Street
Vancouver, B.C., Canada V6B 4Z9
Direct - (604) 605-5310

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"""" is not an IDN."