Two-Character Letter/Letter Label Comments and Mitigation Measures
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For comments submitted before 6 October 2015, view the archive of comments received.
| TLD | Two Characters | Comments from Government | Last updated | RO Mitigation Plan | RO Name | BRAND TLD |
|---|---|---|---|---|---|---|
| zip | ir | View Comments 2016-08-17 | 2016-08-17 | No | ||
| zip | re | View Comments 2016-09-12 | 2016-09-12 | No | ||
| zip | vn | View Comments 2016-08-17 | 2016-08-17 | No | ||
| zip | mx | View Comments 2016-08-17 | 2016-08-17 | No | ||
| zip | ir | View Comments 2016-08-17 | 2016-08-17 | No | ||
| zip | pk | View Comments 2016-08-23 | 2016-08-23 | No | ||
| zip | it | View Comments 2016-09-06 | 2016-09-06 | No | ||
| zip | tw | View Comments 2016-09-22 | 2016-09-22 | No | ||
| zip | sg | View Comments 2016-10-06 | 2016-10-06 | No | ||
| zip | bn | View Comments 2016-10-14 | 2016-10-14 | No | ||
| zone | in | View Comments 2015-12-01 | 2015-12-01 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ln | View Comments 2015-12-01 | 2015-12-01 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | sg | View Comments 2015-11-11 | 2015-12-03 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | fk | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | pt | View Comments 2015-11-30 | 2015-11-30 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | gs | View Comments 2015-12-02 | 2015-12-02 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | pn | View Comments 2015-12-02 | 2015-12-02 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | vn | View Comments 2015-12-02 | 2015-12-02 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | bm | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | io | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ky | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ms | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | sh | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | tc | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | gi | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ac | View Comments 2015-12-02 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | il | View Comments 2015-12-03 | 2015-12-03 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | kr | View Comments 2015-12-04 | 2015-12-04 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ng | View Comments 2015-12-04 | 2015-12-05 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | ru | View Comments 2015-12-07 | 2016-08-15 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | su | View Comments 2015-12-07 | 2016-08-15 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | gb | View Comments 2015-12-08 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | uk | View Comments 2015-12-08 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zone | it | View Comments 2015-12-08 | 2015-12-08 | View Mitigation View Documents 2016-04-25 | Donuts Inc. | No |
| zuerich | tw | View Comments 2015-10-14 | 2015-12-02 | No | ||
| zuerich | in | View Comments 2015-12-01 | 2015-12-01 | No | ||
| zuerich | ln | View Comments 2015-12-01 | 2015-12-01 | No | ||
| zuerich | sg | View Comments 2015-11-11 | 2015-12-03 | No | ||
| zuerich | fk | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | pt | View Comments 2015-11-30 | 2015-11-30 | No | ||
| zuerich | gs | View Comments 2015-12-02 | 2015-12-02 | No | ||
| zuerich | pn | View Comments 2015-12-02 | 2015-12-02 | No | ||
| zuerich | vn | View Comments 2015-12-02 | 2015-12-02 | No | ||
| zuerich | bm | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | io | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | ky | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | ms | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | sh | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | tc | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | gi | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | ac | View Comments 2015-12-02 | 2015-12-08 | No | ||
| zuerich | hk | View Comments 2015-12-03 | 2015-12-03 | No | ||
| zuerich | il | View Comments 2015-12-03 | 2015-12-03 | No | ||
| zuerich | kr | View Comments 2015-12-04 | 2015-12-04 | No | ||
| zuerich | ng | View Comments 2015-12-04 | 2015-12-05 | No | ||
| zuerich | ru | View Comments 2015-12-07 | 2016-08-15 | No | ||
| zuerich | su | View Comments 2015-12-07 | 2016-08-15 | No | ||
| zuerich | gb | View Comments 2015-12-08 | 2015-12-08 | No | ||
| zuerich | uk | View Comments 2015-12-08 | 2015-12-08 | No | ||
| zuerich | it | View Comments 2015-12-08 | 2015-12-08 | No |
ir Comments
By Alireza Saleh, Director .ir ccTLD, ccTLD registry of .ir
.ir ccTLD, would like to express its concern about the likelihood of confusion between "ir" and the corresponding ccTLD. .ir ccTLD, hereby, asks the related authorities to inform us of any request including "ir" in order to concluding an explicit agreement with the related Registry Operator.
re Comments
By Ross Dale, Senior Designer, Afnic
There should be no conflict with the use of .re, specifically the domain requested as mo.re, or any other two character domain in the reunion islands. With only a small population there should be minimum conflict whilst maximising profit opportunity.
vn Comments
By Le Thi Ngoc Mo, Deputy Director General of Vietnam Telecommunications Authority (VNTA), Ministry of Information and Communication (MIC)
Dear ICANN,
In response to ICANN’s proposal of measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes, we do not agree with the Exclusive Availability Pre-Registration Period as a measure to avoid confusion. The proposed measure is not clear that whether names would be made available to governments at a fee or no charge. In case governments have to pay fees for the protection of their names, it is not resonable and it is impossible to developing countries.
We would like to ask ICANN to keep the reservation of the two character label strings specified in the ISO 3166-1 alpha-2 standard. Those strings are released only if the Registry Operator reaches a formal agreement with the related government or country-code manager. Moreover, we believe that every mitigation plan proposed to avoid confusion with the corresponding country code should be subjected to the approval by ICANN only after being approved by the respective government/ccTLD manager.
Best Regards,
Le Thi Ngoc Mo (Ms)
Deputy Director General,
Viet Nam Telecommunications Authority (VNTA)
Ministry of Information Communications (MIC), Viet Nam.
mx Comments
By Miguel Ángel Muñoz Petrichole, Deputy Director of International Affairs Telecommunications, Secretariat of Communications and Transport
Comments of the Mexican Administrations to the document “Proposed Measures for Letter/Letter Two-Character ASCII Labels to Avoid Confusion with Corresponding Country Codes.”
Mexico considers that the proposed measures are not enough to avoid confusion with corresponding country codes. In contrast, we believe that the release of country codes in the Second Level Domain (SLD) could destabilize the domain name system.
Regarding the proposed measures, Mexico considers the following:
• To maintain the exclusivity of a country code for a 30-day period in favor of the related government does not necessarily contributes to consumer choice or competitiveness. Besides, it could produce additional costs to governments or country code managers who wish to obtain a country code under a new gTLD.
• Likewise, it will require additional efforts and resources to review each new policy that every new gTLD operator publishes.
Mexico considers that the protection of the country codes in the ISO-3166 list should not be released. Having the offer to register a country code as a SLD would foster combinations of domain name registrations in the third level of new gTLDs. This does not contribute to the objective of this round for new gTLDs, in which it sought to increase the available options only at the root level, taking into account that other options of registration already were available and covered by other top level domains (TLDs).
It is worth noting that the initial conception of the DNS, sought to foster the registration of new domain names with a specific orientation of diverse nature: some community-territorial, some other with technical or network orientation, military, commercial, among others*, and the new gTLDs were equally conceived in this sense.
Based on the principle of parsimony, which implicates that entities should not multiple needlessly and should use the available resources; given the existence of ccTLD, which purpose is the identification of a country or community, there would be no need to have it in the SLD under new gTLDs.
*See Postel, J. (1994). RFC1591, available on: https://www.ietf.org/rfc/rfc1591.txt , among other reference documents.
ir Comments
By H.S.Shahhoseini, Advisor of Information Technology Organization of Iran, International Office
Please find following comment which is official statement of Iran ICT Deputy Minister and Head of Information Technology Organization of Iran. Also similar letter has been sent to GAC Secretariat by email.
Dear GAC Secretariat
Re: Requests for Release of Two-Letter Second-Level Domains in gTLDs
As Islamic Republic of IRAN GAC Representative, I would like to express our concerns about the likelihood of confusion between "ir" and the corresponding ccTLD. We, hereby, ask the related authorities to inform us of any request including "ir" and other possibly two character labels which are similar to "ir" in order to concluding an explicit agreement with us for releasing Two-Letter Second-Level Domains in gTLDs.
So again we categorically reject any such release unless our explicit agreement is obtained.
Sincerely yours,
Nasrollah Jahangard
I.R. Iran GAC Representative
Deputy Minister of ICT and
Head of Information Technology Organization of Iran
pk Comments
By Syed Iftikhar H Shah, Director IT, Ministry of IT, Government of Pakistan
With reference to subject matter our Pakistan’s instance is that we also have the same issue as some government has already raised to the concerned quarters. In this regard, the major issue is that such subject proposal will create confusion in the domain name system for the internet community particularly for out internet community due to lack of awareness and capacity building of our users for such domain name schemes of. So, it is suggested that ICANN, GAC and the relevant bodies, local communities of the world may further deliberate on the subject matter and then proceed accordingly In this regard, awareness program may also be launched by the ICANN globally and in developing countries as a special case.
In view of the above, it is recommended that GAC may take the subject matter with ICANN. In current situation we would ask ICANN not to proceed with releasing Pakistanis country code and names at 2nd level for all new gTLDs.
lt Comments
By Rita Forsi, Italian GAC Representative, Ministry of Economic Development
By Rita Forsi, Italia GAC Representative, Ministry of Economic Development
With reference to the process for Considering Comments for Two-Character Letter/Letter Labels launched by ICANN on October 6, 2015, Italy restates its position expressed on March 25, 2015 (http://mm.icann.org/pipermail/twochar_comments/2015/000063.html) and on May 14, 2015 (email attached).
Italy does not object tout-court to the delegation of our ccSLD, but wants to exercise the right to evaluate the delegation of “it” as a SLD on a case-by-case basis.
The evaluation process takes into account not only the confusion risks, but also the national and international legal framework (e.g. IPR) and opportunity considerations (e.g. it.sucks).
We would like to recall that both the Singapore and Dublin GAC Communiqué advise the Board that comments submitted by the relevant Governments be fully considered regardless of the grounds for objection.
For the abovementioned reasons, we reiterate our position expressed in March 25 2015 for the release of the two‐character “it” label at the second level under new gTLDs.
In general, “it” label string may be released to the extent that the registry operator reaches a formal agreement with the Italian government (included our ccTLD registry “.it”) as per Specification 5 of the Registry Agreement.
This policy is to be applied to all new gTLDs, including, but not limited to, those falling within Category 1 and Category 2 of the Beijing Communiquè. who have requested for the release of “it” labels at the second level.
The authorization requests should be sent to the Italian GAC representatives.
Furthermore, we would like to underline that these “lines-to-take” are agreed with the “.it” Registry.
Rita Forsi
tw Comments
By Lin, Mao-Shong, Deputy Director, Ministry of Transportation and Communications
I’m writing hereby to submit Taiwan government’s comments on the release of the “tw” label under the New gTLDs.
We object to the release of “tw” as SLD under all the above-mentioned New gTLDs for their registration by the corresponding Registry operators. We reserve the right to change position in this regard in the future.
The rationale of our objections are below:
Since “tw” label is the country code for Taiwan, the use of “tw” as SLD under these diverse New gTLDs would create confusion or concerns at multiple levels on our part, which include, but not limited to, ”dwarfing national dignity”, “violation of public order or good social custom”, “affecting the rights of domestic enterprises”, and “being prone to produce perplexity to our disadvantage”.
sg Comments
By Queh Ser Pheng, Deputy Director, Internet Resource Management, Policy & Competition Development Group, Infocomm Development Autority of Singapore
We hereby respectfully submit our comment regarding the release of letter/letter two-character labels as second level domains.
At this stage, we are unable to agree to the release of the two-character "sg" label at the second-level under gTLDs because of the concern that such use would create confusion with the ccTLD "sg" representing Singapore. Until further notice, this policy is to be applied to all gTLDs who have requested or will be requesting for the release of letter-letter two-character labels at the second level.
To elaborate further, we are open to considering the release of "sg" to registry operators who have robust framework in place to address concerns of government. We recognise there are legitimate and valid reasons for such use. However, we are of the view that it is prudent for ICANN to first put in place a holistic and robust framework before approvals can be given. More thoughts need to be given to the evaluation process and in particular the remedies available should a registry operator use the approved names in an undesirable manner. Besides possible confusion with the corresponding country code and/or country/territory name, we are also concerned with:
(a) The possible reputational harm if ".sg." is associated with illegal or objectionable content and/or manner-of-use; and
(b) The direct harm if ".sg." content or manner-of-use targets Singapore as a nation or Singapore entities (e.g., websites could masquerade as Singapore Government agencies).
ICANN's current policy focuses only on the "initial release" process. There needs to be considerations given to "post-release" issues. As such, the ICANN framework should include:
(a) A recourse for the government/country code manager to issue a notice to object to the content and/or manner-of-use that is misleading, questionable, objectionable or contrary to the country’s reputation and laws. There should be an effective and robust process acceptable by the government/country code manager for the registry operator to address the concern; and
(b) Provisions to require the registry operator to re-seek approval from government/country code manager should there be material changes in ownership or organisational control (for example merger with or acquisitions by another entity).
In addition, ICANN must be committed to take actions against the registry operator should they fail to comply with the framework (e.g. implement a process for country/territory to raise objections to ICANN and for ICANN to take appropriate remedial actions such as remove/delete/revoke affected names).
bn Comments
By Haji Hairul Mohd Daud Bin Haji Abd Karim, Senior Assistant Chief Executive, Regulatory & Resource Management Group, Authority for Info-communications Technology Industry for Brunei Darussalam, Regulatory & Resource Management Group
As Brunei Darussalam GAC Representative, we hereby respectfully submit our comment with regards to the release of “bn” labels as second level domains.
Currently, we do not agree to the release of "bn" label at the second-level under New gTLDs.
We are concerned that the use of “bn” would create confusion in representing Brunei Darussalam. This applies to all Registry Operators who have requested or will be requesting for the release of “bn” labels at the second level domains.
Additionally, the use of “bn” at second level domain of any new gTLDs may inflict damaging or reputational harm to Brunei Darussalam if associated with illegal or objectionable content and the manner of its use. We wish to protect “bn” from such abuse.
To conclude, we wish to be notified of all Registry Operators request to use “bn” labels at the second level domains of all new gTLDs.
in Comments
By Rahul Gosain, Director, Department of Electronics and Information Technology, Ministry of communication and Information Technology
India is not favouring the release of Two-Character ASCII labels "in", "1n" and deceptively similar as the ccTLD ".in" at the second level. ICANN is requested that India's objection on release of Two-character ASCII labels "in" and "1n" at the second level should apply to all current and future requests from new gTLD's
in Comments
By Rahul Gosain, Director, Department of Electronics and Information Technology, Ministry of communication and Information Technology
India is not favouring the release of Two-Character ASCII labels "ln" and "1n" and deceptively similar as the ccTLD ".in" at the second level. ICANN is requested that India's objection on release of Two-character ASCII labels "ln" and "1n" at the second level should apply to all current and future requests from new gTLD's
sg Comments
By Queh Ser Pheng, Deputy Director, Internet Resource Management, Policy & Competition Development Group, Infocomm Development Authority of Singapore
We hereby respectfully submit our comment regarding the release of letter/letter two-character labels as second level domains.
At this stage, we are unable to agree to the release of the two-character "sg" label at the second-level under gTLDs because of the concern that such use would create confusion with the ccTLD "sg" representing Singapore. Until further notice, this policy is to be applied to all gTLDs who have requested or will be requesting for the release of letter-letter two-character labels at the second level.
To elaborate further, we are open to considering the release of "sg" to registry operators who have robust framework in place to address concerns of government. We recognise there are legitimate and valid reasons for such use. However, we are of the view that it is prudent for ICANN to first put in place a holistic and robust framework before approvals can be given. More thoughts need to be given to the evaluation process and in particular the remedies available should a registry operator use the approved names in an undesirable manner. Besides possible confusion with the corresponding country code and/or country/territory name, we are also concerned with:
(a) The possible reputational harm if ".sg.
(b) The direct harm if ".sg.
ICANN's current policy focuses only on the "initial release" process. There needs to be considerations given to "post-release" issues. As such, the ICANN framework should include:
(a) A recourse for the government/country code manager to issue a notice to object to the content and/or manner-of-use that is misleading, questionable, objectionable or contrary to the country’s reputation and laws. There should be an effective and robust process acceptable by the government/country code manager for the registry operator to address the concern; and
(b) Provisions to require the registry operator to re-seek approval from government/country code manager should there be material changes in ownership or organisational control (for example merger with or acquisitions by another entity).
In addition, ICANN must be committed to take actions against the registry operator should they fail to comply with the framework (e.g. implement a process for country/territory to raise objections to ICANN and for ICANN to take appropriate remedial actions such as remove/delete/revoke affected names).
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
The administration of the Falkland Islands (UK overseas territory) have no objection to the use of two character domains which coincide with their ccTLD at the second level, and do not wish to be notified of such requests by registries.
pt Comments
By Ana Cristina Ferreira Amoroso das Neves, Director, Department Information Society, Fundação para a Ciência e a Tecnologia, Ministry of Science, Technology and Higher Education
I request previous comments to objections to the release of the ".pt" as the SLD signalling 1) consumer protection concerns and confusion; 2) some gTLD correspond to a regulated market in EU countries, so their release might generate possible abuses and confusion at the end-users level and therefore must be subject to authorization by the Portuguese Government; 3) others should remain reserved so that can only be assigned to a person, entity or corporation proposed or accepted by the Portuguese Government, which demands consultations with the Portuguese Government. These comments are due to the ICANN's new process launched on the 6th October 2015 on the use of the 2-letter CC and CN at the SLD, taken into account nonetheless GAC's advice from Dublin Communiqué (October 2015). Confusability exists in all instances since the PT code is widely recognized both on and off the Internet as an identifier for Portugal. In this regard, we are concerned that consumers assume that persons or undertakings operating under "pt.string" not only offer their services in Portugal or products or services related to Portugal but that they comply with applicable regulations. As this may not be warranted by registration policies and contracts, we would request Portuguese Government is consulted before any registration, regardless of the grounds for objection. Portugal reserves the right to change position in this regard in the future.
The Portuguese Government will continue to closely follow the evolution of the market and of the technical and political framework to collect data and evidence to better understand the consequences of such release.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
The administration in South Georgia and the South Sandwich Islands (UK overseas territory) have no objection to the use of two character domains which coincide with their ccTLD at the second level, and do not wish to be notified of such requests by registries.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
The administration in the Pitcairn Islands (UK overseas territory) have no objection to the use of two character domains which coincide with their ccTLD at the second level, and do not wish to be notified of such requests by registries.
vn Comments
By Le Thi Ngoc Mo, Deputy Director General of Vietnam Telecommunications Authority (VNTA), Ministry of Information and Communication (MIC)
Dear ICANN,
“vn” is the country code for Viet Nam. The release of the two-character ".vn" label at the second-level under new gTLDs would create confusion with the ccTLD ".vn". On behalf of Viet Nam government, I would like to submit an objection to the release of the “.vn” at the second level under all new gTLDs.
Viet Nam is seting up the accurate criteria for releasing this two character at the second level domain names under new gTLDs . This is sensitive issue for government so it is taking some time for government to consider.
To reiterate, our objections are applied to all new gTLDs who have requested or will be requesting for the release of “.vn” at the second level until we set up the accurate criteria for releasing and send notice to ICANN.
Thank you and best regards,
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Bermuda (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of British Indian Ocean Territory wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Cayman Islands (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Montserrat (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Saint Helena (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of the Turks and Caicos Islands (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Gibraltar (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion and any unintended consequences, the administration of Ascension Island (UK overseas territory) wish to be notified of all registry requests to use the two characters of their country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
il Comments
By Dr. Amir Adler, Chief Scientist, Ministry of Communications, Ministry of Communications
Request that “il” will be assigned under these TLDs only to a person, entity or
corporation proposed or accepted by the Israeli Government, due to the following concerns:
(1) Unproper or offensive utilization in conjuction with ".il".
(2) Missleading association with the State of Israel.
(3) Interference, or violation of the rights of domestic businesses and organizations.
kr Comments
By Seonyoung Jeong, Assistant Director, Internet Policy Division, Internet Convergence Policy Bureau Ministry of Science, ICT and Future Planning
KR is the country code for the republic of Korea. On behalf of the .kr registry and Korean government, we would like to submit a temporary objection to the release of the '.kr' at the second level under all new gTLDs UNTIL we, Korea government, set up the accurate criteria for releasing. This is sensitive issue for government so it is taking some time for government to consider.
To reiterate, our objections are applied to all new gTLDs who have requested or will be requesting for the release of .kr at the second level until we set up the accurate criteria for releasing. Thank you.
ng Comments
By Nkiru Ebenmelu, GAC Rep, Nigerian Communications Commission
Nigeria does not support the release of Two-Character ASCII Labels ".ng" or the use of "NIGERIA", in the context of any/all of the gTLD(s) at the second level. This should apply to all current and future requests. It is against Nigerian law and strictly prohibited to use the word "Nigeria" or code representing Nigeria without proper authorization by the Government. This assists the Country forestall the abuse and misuse of reserved names associated with the Government; the release would be a breach of our laws. We also wish to inform you that Nigeria reserves the right of authorization for use of “NGR” and “NGA”. As these are also reserved for use by Nigeria. (ISO 3166). We will appreciate it if we are informed of the decision(s) taken.
ru Comments
By Yulia Elanskaya, Deputy Director of International Cooperation Department, Ministry of Telecom and Mass Communications of the Russian Federation
Russia objects the release of Two-Character combination “.ru” at the second level under any kind/all gTLD.
We are concerned that the deceptive similarity of these two-letter combinations with country codes ccTLDs creates the risk of confusion and misleading of Internet users.
This requirement should apply to all current and future requests.
su Comments
By Yulia Elanskaya, Deputy Director of International Cooperation Department, Ministry of Telecom and Mass Communications of the Russian Federation
Russia objects the release of Two-Character combination “.su” at the second level under any kind/all gTLD.
We are concerned that the deceptive similarity of these two-letter combinations with country codes ccTLDs creates the risk of confusion and misleading of Internet users.
This requirement should apply to all current and future requests.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
The UK government notes that gb is a reserved ccTLD string. In order to avoid the potential for confusion, any unintended consequences and consistency within the DNS, the UK requests that this two character code must not be delegated for use as a second-level domain.
uk Comments
By Nick Shorey, Senior Policy Officer, Department for Culture, Media & Sport
In order to avoid the potential for confusion, and any unintended consequences, the UK government wish to be notified of all registry requests to use the two characters of its country code at the second level - and any existing requests should be put on hold accordingly until they have considered these requests.
it Comments
By Rita Forsi, Italia GAC Representative, Ministry of Economic Development
With reference to the process for Considering Comments for Two-Character Letter/Letter Labels launched by ICANN on October 6, 2015, Italy restates its position expressed on March 25, 2015 (http://mm.icann.org/pipermail/twochar_comments/2015/000063.html) and on May 14, 2015 (email attached).
Italy does not object tout-court to the delegation of our ccSLD, but wants to exercise the right to evaluate the delegation of “it” as a SLD on a case-by-case basis.
The evaluation process takes into account not only the confusion risks, but also the national and international legal framework (e.g. IPR) and opportunity considerations (e.g. it.sucks).
We would like to recall that both the Singapore and Dublin GAC Communiqué advise the Board that comments submitted by the relevant Governments be fully considered regardless of the grounds for objection.
For the abovementioned reasons, we reiterate our position expressed in March 25 2015 for the release of the two‐character “it” label at the second level under new gTLDs.
In general, “it” label string may be released to the extent that the registry operator reaches a formal agreement with the Italian government (included our ccTLD registry “.it”) as per Specification 5 of the Registry Agreement.
This policy is to be applied to all new gTLDs, including, but not limited to, those falling within Category 1 and Category 2 of the Beijing Communiquè. who have requested for the release of “it” labels at the second level.
The authorization requests should be sent to the Italian GAC representatives.
Furthermore, we would like to underline that these “lines-to-take” are agreed with the “.it” Registry.
Rita Forsi
tw Comments
By Lin, Mao-Shong, Deputy Director, Ministry of Transportation and Communications
I’m writing hereby to submit Taiwan government’s comments on the release of the “tw” label under the New gTLDs.
We object to the release of “tw” as SLD under all the above-mentioned New gTLDs for their registration by the corresponding Registry operators. We reserve the right to change position in this regard in the future.
The rationale of our objections are below:
Since “tw” label is the country code for Taiwan, the use of “tw” as SLD under these diverse New gTLDs would create confusion or concerns at multiple levels on our part, which include, but not limited to, ”dwarfing national dignity”, “violation of public order or good social custom”, “affecting the rights of domestic enterprises”, and “being prone to produce perplexity to our disadvantage”.
hk Comments
By Dominic Kwong, Alternate GAC Representative of Hong Kong Special Administrative Region, China, Office of the Government Chief Information Officer
In response to ICANN’s request for clarification of 6 October 2015 on how the release of two-character country codes as the second level domain (SLD) in new gTLDs would create confusion, we would like to reiterate our views on 24 March and 27 May 2015, which have stated the confusion and rationale related to the release of "hk" as SLD on the following two categories of new gTLDs, that they shall NOT be released for ALL requests:
(a) New gTLDs associated with Highly-regulated Sectors/Closed Entry Requirements in Multiple Jurisdictions and Inherently Governmental Functions as set out in ICANN NGPC Resolution No. 2014.02.05.NG01; and
(b) New gTLDs falling within the category of Geographic gTLDs referred to in ICANN’s New gTLD Program (i.e. the gTLD string is a geographic name as provided in the ICANN's gTLD Applicant Guidebook), and .capital, .city, .country, .town, and .world.
For easy reference, texts of our previous submitted views are reproduced below:
HKSARG’s VIEWS ON 24 MARCH 2015
‘I am writing to express the view of Hong Kong Special Administrative Region Government on the release of "hk" as the second level domain (SLD) in new gTLDs.
Our ccTLD, .hk, is commonly understood as the abbreviated name of Hong Kong. HK means Hong Kong to the Internet community globally and locally. The use of "hk" as SLD in new gTLDs would give the perception that the domain names in question belong to or are related to Hong Kong and the Hong Kong community.
(I) gTLDs for Regulated Sectors
As pointed out by GAC, gTLD strings that are linked to regulated or professional sectors should operate in a way that is consistent with applicable laws. These gTLD strings or Category 1 gTLDs are likely to invoke a level of implied trust from consumers, and carry higher levels of risk associated with consumer harm. GAC advised ICANN to apply safeguards (GAC Safeguard Advice 1 - 5) to these strings. In addition, for a limited subset of the Category 1 gTLDs that are associated with market sectors which have clear and/or regulated entry requirements (i.e. highly-regulated sectors), additional safeguards (GAC Safeguard Advice 6 - 8) should apply.
In this context, for the use of "hk" as SLD in new gTLDs associated with (1) Highly-regulated Sectors/Closed Entry Requirements in Multiple Jurisdictions and (2) Inherently Governmental Functions as set out in the ICANN NGPC Resolution No. 2014.02.05.NG01, The Government of Hong Kong Special Administrative Region (HKSAR Government) requests that :
(a) Registry operator should consult HKSAR Government on any request for domain name registration;
(b) The registry operator should implement measures in line with GAC safeguards 6-8 on verification and validation of credentials of registrants;
(c) Registry operator should consult HKSAR Government on any complaint expressing doubt with regard to authenticity of licences or credentials.
(II) Geographic gTLDs
For geographic gTLDs which are names of cities, countries or regions, or have strong geographic connotation, putting "hk" at the second level may cause confusion or perception of subordination. Among the current requests posted from 23 February 2015 to 19 March 2015, these gTLDs include: .amsterdam, .bayern, .berlin, .budapest, .capital, .city, .country, .frl, .hamburg, .kyoto, .london, .miami, .nagoya, .nrw, .nyc, .osaka, .taipei, .tirol, .tokyo, .town, .wien, .world, .yokohama, and .zuerich.
In this context, HKSAR Government requests that Registry operator should consult HKSAR Government on any request for domain name registration on such gTLDs.’
HKSARG’s VIEWS ON 27 MAY 2015
‘For the current requests of R000375 to R000466 and ALL FUTURE requests, “hk” shall NOT be included in ICANN's Authorization for Release of Two-character Letter/Letter ASCII Labels at the Second Level and shall NOT be released as SLD for -
(a) New gTLDs associated with Highly-regulated Sectors/Closed Entry Requirements in Multiple Jurisdictions and Inherently Governmental Functions as set out in ICANN NGPC Resolution No. 2014.02.05.NG01; and
(b) New gTLDs falling within the category of GEOGRAPHIC gTLDs referred to in ICANN’s New gTLD Program (i.e. the gTLD string is a geographic name as provided in the ICANN's gTLD Applicant Guidebook), and NAMELY .melbourne, .saarland, and .sydney in the current requests.'
Best Regards,
Dominic Kwong
Alternate GAC Representative of Hong Kong Special Administrative Region, China