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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.

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TLD  Two
Characters  		Comments from GovernmentLast
updated  		RO Mitigation PlanRO NameBRAND TLD
glebnView Comments
2016-10-14
2016-10-14No
gugebnView Comments
2016-10-14
2016-10-14No
hangoutbnView Comments
2016-10-14
2016-10-14No
mapbnView Comments
2016-10-14
2016-10-14No
memebnView Comments
2016-10-14
2016-10-14No
movbnView Comments
2016-10-14
2016-10-14No
naturabnView Comments
2016-10-14
2016-10-14Yes
nbabnView Comments
2016-10-14
2016-10-14Yes
newbnView Comments
2016-10-14
2016-10-14No
pfizerbnView Comments
2016-10-14
2016-10-14Yes
phdbnView Comments
2016-10-14
2016-10-14No
prodbnView Comments
2016-10-14
2016-10-14No
profbnView Comments
2016-10-14
2016-10-14No
pwcbnView Comments
2016-10-14
2016-10-14Yes
rogersbnView Comments
2016-10-14
2016-10-14Yes
rsvpbnView Comments
2016-10-14
2016-10-14No
searchbnView Comments
2016-10-14
2016-10-14No
sfrbnView Comments
2016-10-14
2016-10-14Yes
showtimebnView Comments
2016-10-14
2016-10-14Yes
watchesbnView Comments
2016-10-14
2016-10-14No
xfinitybnView Comments
2016-10-14
2016-10-14Yes
xn--flw351ebnView Comments
2016-10-14
2016-10-14Yes
xn--kpu716fbnView Comments
2016-10-14
2016-10-14No
xn--pbt977cbnView Comments
2016-10-14
2016-10-14No
xn--qcka1pmcbnView Comments
2016-10-14
2016-10-14Yes
zipbnView Comments
2016-10-14
2016-10-14No
auspostirView Comments
2016-10-28
2016-10-28Yes
comcastirView Comments
2016-10-28
2016-10-28Yes
dupontirView Comments
2016-10-28
2016-10-28Yes
fidoirView Comments
2016-10-28
2016-10-28Yes
gdnirView Comments
2016-10-28
2016-10-28No
naturairView Comments
2016-10-28
2016-10-28Yes
nbairView Comments
2016-10-28
2016-10-28Yes
pfizerirView Comments
2016-10-28
2016-10-28Yes
pwcirView Comments
2016-10-28
2016-10-28Yes
rogersirView Comments
2016-10-28
2016-10-28Yes
smartirView Comments
2016-10-28
2016-10-28Yes
vanguardirView Comments
2016-10-28
2016-10-28Yes
xfinityirView Comments
2016-10-28
2016-10-28Yes
xn--5tzm5girView Comments
2016-10-28
2016-10-28No
ausposttwView Comments
2016-11-24
2016-11-24Yes
comcasttwView Comments
2016-11-24
2016-11-24Yes
fidotwView Comments
2016-11-24
2016-11-24Yes
gdntwView Comments
2016-11-24
2016-11-24No
naturatwView Comments
2016-11-24
2016-11-24Yes
nbatwView Comments
2016-11-24
2016-11-24Yes
pwctwView Comments
2016-11-24
2016-11-24Yes
rogerstwView Comments
2016-11-24
2016-11-24Yes
smarttwView Comments
2016-11-24
2016-11-24Yes
vanguardtwView Comments
2016-11-24
2016-11-24Yes
xfinitytwView Comments
2016-11-24
2016-11-24Yes
xn--5tzm5gtwView Comments
2016-11-24
2016-11-24No
auspostbnView Comments
2016-12-01
2016-12-01Yes
eusbnView Comments
2016-12-01
2016-12-01No
gdnbnView Comments
2016-12-01
2016-12-01No
seekbnView Comments
2016-12-01
2016-12-01Yes
smartbnView Comments
2016-12-01
2016-12-01Yes
stockholmbnView Comments
2016-12-01
2016-12-01No
vanguardbnView Comments
2016-12-01
2016-12-01Yes
xn--5tzm5gbnView Comments
2016-12-01
2016-12-01No

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.

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. Similar letter had 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

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”.

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

“At this stage, we are unable to agree to the release of the two-character label "bn" at the second-level under gTLDs.

Since the two-character label "bn" is assigned to Brunei Darussalam as per ISO standard 3166-1, and this two-character label is widely recognized both on and off the Internet as an identifier for Brunei Darussalam. The release of this two-character country code, at the second level under gTLDs will be misleading and confusing for Internet users. This applies equally to all two character country codes and not just to “bn”.

The use of “bn” at second level of any new gTLDs may also result in damaging or reputational harm to Brunei Darussalam and we want to protect the use of two-character country code “bn” from any association with illegal or undesirable content and also the manner of its use.

Furthermore, we are concerned that this will lead to a situation requiring governments and ccTLD managers to register the country code themselves to manage these risks described above. This course of risk mitigation will be resource-intensive and create unnecessary burdens on governments.”

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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."