Skip to main content
Resources

Two-Character Letter/Letter Label Comments and Mitigation Measures

As of 13 December 2016, this page is no longer active. Please visit here for more information.

For comments submitted before 6 October 2015, view the archive of comments received.

Download Excel
TLD  Two
Characters  		Comments from GovernmentLast
updated  		RO Mitigation PlanRO NameBRAND TLD
wtfpnView Comments
2015-12-02
2015-12-02View Mitigation

wtf Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xboxpnView Comments
2015-12-02
2015-12-02View Mitigation

xbox Mitigation

By Microsoft Corporation

Proposed Measure to Avoid Confusion—Brand TLD (Specification 13)

Provide a brief explanation of the TLD:

.XBOX TLD is a closed Brand new gTLD operated by Microsoft Corporation

Protections:

Microsoft Corporation for the .XBOX TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that Microsoft Corporation will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:

1. .XBOX is identical to a qualifying registered trademark;
2. .XBOX is not a Generic String, as this is defined in Specification 11;
3. .XBOX TLD has developed and will implement a closed registration policy for .XBOX that requires that all domain names in the .XBOX TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .XBOX TLD will clearly publish this registration policy;
5. .XBOX TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the .XBOX TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .XBOX TLD is a proprietary space in which all second-level domains in the TLD are being operated by Microsoft Corporation, its Affiliates and Trademark Licensees and not the government or the corresponding country code operator. By this Microsoft Corporation confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-05

Microsoft CorporationYes
xeroxpnView Comments
2015-12-02
2015-12-02View Mitigation

xerox Mitigation

By Xerox DNHC LLC

.XEROX gTLD Confusion Avoidance Plan
Xerox DNHC LLC, the Registry Operator for the .XEROX gTLD, has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that Xerox DNHC LLC will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .XEROX is identical to a qualifying registered trademark;
2. .XEROX is not a Generic String, as the term is defined in Specification 11 of the Registry
Agreement;
3. Xerox DNHC LLC has developed and will implement a closed registration policy for
.XEROX that requires that all domain names in the .XEROX gTLD be registered ONLY by
Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, Xerox DNHC LLC submitted this policy as part
of its application for Specification 13 and has clearly published this registration policy;
and
5. .XEROX will conduct internal reviews at least once per calendar year to ensure
continued compliance with Specification 13, as required by the Registry Agreement.
Compliance with Specification 13 prohibits the .XEROX gTLD from registering domain names to unaffiliated third parties and thus clearly designates to the public that the .XEROX gTLD is a proprietary space in which all second-level domains in the gTLD are being operated by Xerox DNHC LLC, its Affiliates and Trademark Licensees and not any government or corresponding country-code TLD operator.
With this submission, Xerox DNHC LLC confirms that all registrations of two-letter domain names shall comply with the requirements of Specification 13.


View Documents
2016-04-21

Xerox DNHC LLCYes
xinpnView Comments
2015-12-02
2015-12-02View Mitigation

xin Mitigation

By Elegant Leader Limited

A Proposal to Minimize the Potential Likelihood of Confusion in Connection with the Allocation of Specific Two Character Domain Names

The .XIN gTLD wishes to help establish a trusted and reliable namespace for the Chinese market.

Protections
Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct involving a two character domain name associated with the corresponding government and provide a written report in response
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Acceptable Use Policy for the .XIN TLD is the following text:

“Registry operator reserves the right at its sole discretion to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock, hold, or similar status, that it deems necessary: (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of registry operator, as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement and this Anti-Abuse Policy, or (5) to correct mistakes made by registry operator or any registrar in connection with a domain name registration. Registry operator also reserves the right to place upon registry lock, hold, or similar status a domain name during resolution of a dispute.



View Documents
2016-04-25

Elegant Leader LimitedNo
xn--3ds443gpnView Comments
2015-12-02
2015-12-02No
xn--3oq18vl8pn36apnView Comments
2015-12-02
2015-12-02View Mitigation

xn--3oq18vl8pn36a Mitigation

By Volkswagen (China) Investment Co., Ltd.

.大众汽车 is a closed Brand TLD for the sole and exclusive use of Volkswagen (China) Investment Co., Ltd.

Protections
Volkswagen (China) Investment Co., Ltd. (Registry Operator) for the .大众汽车 TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that the Registry Operator will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:

.大众汽车 is identical to a qualifying registered trademark;
.大众汽车 is not a Generic String, as this is defined in Specification 11;
Registry Operator has developed and will implement a closed registration policy for .大众汽车 that requires that all domain names in the .大众汽车 TLD be registered only by Volkswagen (China) Investment Co., Ltd., its Affiliates, and its Trademark Licensees.

As required under the Registry Agreement, the Registry Operator will publish this registration policy on its website.

Registry Operator will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the Registry Operator from registering domain names to unaffiliated third parties and thus clearly designate to the public that .大众汽车 TLD is a proprietary space in which all second-level domains in the TLD are being operated by the Registry Operator, its Affiliates and Trademark Licensees and not the governments or the corresponding country code operators.

By this submission Volkswagen (China) Investment Co., Ltd. confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-21

Volkswagen (China) Investment Co., Ltd.Yes
xn--55qx5dpnView Comments
2015-12-02
2015-12-02No
xn--czr694bpnView Comments
2015-12-02
2015-12-02View Mitigation

xn--czr694b Mitigation

By HU YI GLOBAL INFORMATION RESOURCES (HOLDING) COMPANY. HONGKONG LIMITED

Please see the attached file that details ". 商标" (dot Trademark) (xn--czr694b)
Registry's implementation plan to avoid confusion with corresponding country codes.


View Documents
2016-04-25

HU YI GLOBAL INFORMATION RESOURCES (HOLDING) COMPANY. HONGKONG LIMITEDNo
xn--czrs0tpnView Comments
2015-12-02
2015-12-02View Mitigation

xn--czrs0t Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xn--czru2dpnView Comments
2015-12-02
2015-12-02View Mitigation

xn--czru2d Mitigation

By Zodiac Registry

This “Proposed Measure to Avoid Confusion” is submitted to ICANN on behalf of the Registry Operator of the following TLDs:

Registry Operator TLD English translation
Zodiac Wang Limited .wang “web” or “net” or the Chinese surname "王"
Zodiac Aquarius Limited .商城 (xn--czru2d) .mall
Zodiac Taurus Limited .网店(xn--hxt814e) .web store
Zodiac Gemini Limited .八卦(xn--45q11c) .gossip

All four TLDs are Chinese IDNs, except .wang (a Chinese pinyin). All these TLDs have applied for and three of them have received approval from the Ministry of Industry and Information Technology (MIIT) of China to operate within the country.

As these TLDs are intended for the millions of the Chinese-speaking Internet users and the way in which pinyin (the official phonetic system for transcribing Chinese characters into Latin alphabet) works, we believe it is extremely unlikely that confusion with corresponding country codes will arise.

Nevertheless, we understand the concerns expressed by governments or ccTLD Managers and set out the protections below that are already in place or to be implemented by Registry Operator, to avoid confusion.

Protections

1. Registry Operator will commit to:

a. investigate any reports of misuse or abusive use, including misleading or deceptive conduct, including those from the relevant government or ccTLD Manager, and provide a written report in response; and

b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

2. The Registry Operator’s Anti-Abuse Policy contains the following text that prohibits abusive use and provides consequences for abusive use:

“Registry Operator expressly prohibits abusive use of a domain name for any illegal or fraudulent activities, including but not limited to, distributing malware, abusively operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent or deceptive practices, counterfeiting or otherwise engaging in activity contrary to applicable law”
…
“Registry Operator reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion:

a. to enforce any Registry Policies (http://en.zodiac.wang/policy.html, including this policy) and ICANN requirements, as amended from time to time;”

Further, the Registry-Registrar Agreements of all these TLDs require registrars to enter a registration agreement with each Registered Name Holder (“RNH Registration Agreement”) and such agreement must include the following term:

“Registered Name Holder must comply with all Registry Policies (http://en.zodiac.wang/policy.html), as if they were incorporated into, and form part of the RNH Registration Agreement. In the event of any inconsistency between any Registry Policy and the RNH Registration Agreement, then that Registry Policy will prevail to the extent of such inconsistency.”

This mandatory term in the RNH Registration Agreement means registrants in the above TLDs are bound by the Registry’s Anti-Abuse Policy. Thus, if a registrant’s use of a two-character domain name amounts to misuse or abusive use, the domain name may be cancelled, locked, placed on hold, transferred or deleted.


2016-04-22

Zodiac RegistryNo
xn--fiq228c5hspnView Comments
2015-12-02
2015-12-02No
xn--fjq720apnView Comments
2015-12-02
2015-12-02View Mitigation

xn--fjq720a Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xn--g2xx48cpnView Comments
2015-12-02
2015-12-02View Mitigation

xn--g2xx48c Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
xn--gk3at1e pnView Comments
2015-12-02
2015-12-02View Mitigation

xn--gk3at1e  Mitigation

By Amazon Registry Services, Inc.

Amazon Registry Services, Inc. (“ARSI”), the Registry Operator for the .xn--gk3at1e TLD, proposes release of the following 2-character letter-letter combinations: ai, bh, bm, ci, cn, eg, gb, gi, il, in, io, it, kr, ky, me, ms, pt, ru, sg, sh, su, tc, tw, uk, and vn. ARSI further proposes the following measures to avoid confusion with the corresponding country codes.

ARSI will commit to:
1. Investigate in a timely manner a report by the government of the country, state, or territory for which a 2-character letter-letter combination listed above (ai, bh, bm, ci, cn, eg, gb, gi, il, in, io, it, kr, ky, me, ms, pt, ru, sg, sh, su, tc, tw, uk, or vn) corresponds to its country code:
a. the use in the .xn--gk3at1e TLD of a domain name consisting of a 2-character letter-letter combination listed above; and
b. corresponds to that government’s country code; and
c. implies or represents that it is, or has the approval of, such government; and
2. Where, in ARSI’s sole opinion, such use has occurred, ARSI, in its sole discretion:
a. will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address such use, or
b. may cause the domain name’s records to be removed from the DNS; and
3. Provide a written response within a commercially reasonable time period.

ARSI’s Acceptable Use Policy for the .xn--gk3at1e TLD will require registrants of a domain name in the .xn--gk3at1e TLD to ensure that their use of a 2-character letter-letter combination does not imply or represent that it is, or has the approval of, any government. ARSI will reserve the right to cancel, lock, place on hold, transfer or delete the domain name in accordance with our commitment above.


2016-04-25

Amazon Registry Services, Inc.No
xn--io0a7ipnView Comments
2015-12-02
2015-12-02No
xn--kcrx77d1x4apnView Comments
2015-12-02
2015-12-02View Mitigation

xn--kcrx77d1x4a Mitigation

By Koninklijke Philips N.V.

Registry Operator will not register two letter SLDs that are equal to ccTLDs under its gTLD, unless:
- the corresponding country has given general consent to register these SLDs, or
- that Registry Operator has obtained authorization of the competent authority of that corresponding country to register the two letter SLD under its TLD..

Registry Operator will not register two letter SLDs under its TLD that are equal to ccTLDs when the corresponding country has objected to these registrations.


2016-03-08

Koninklijke Philips N.V.Yes
xn--ngbe9e0apnView Comments
2015-12-02
2015-12-02No
xn--ses554gpnView Comments
2015-12-02
2015-12-02No
xn--unup4ypnView Comments
2015-12-02
2015-12-02View Mitigation

xn--unup4y Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xn--vermgensberater-ctbpnView Comments
2015-12-02
2015-12-02No
xn--vermgensberatung-pwbpnView Comments
2015-12-02
2015-12-02No
xn--vhquvpnView Comments
2015-12-02
2015-12-02View Mitigation

xn--vhquv Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xn--vuq861bpnView Comments
2015-12-02
2015-12-02No
xn--w4r85el8fhu5dnrapnView Comments
2015-12-02
2015-12-02No
xn--w4rs40lpnView Comments
2015-12-02
2015-12-02Yes
xperiapnView Comments
2015-12-02
2015-12-02View Mitigation

xperia Mitigation

By Sony Mobile Communications AB

Provide a brief explanation of the TLD:
Sony Mobile Communications AB has applied for .XPERIA to run a closed .brand environment.

Protections
Sony Mobile Communications AB for the .XPERIA TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that the Sony Mobile Communications AB will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .XPERIA is identical to a qualifying registered trademark;
2. .XPERIA is not a Generic String, as this is defined in Specification 11;
3. .XPERIA TLD has developed and will implement a closed registration policy for .XPERIA that requires that all domain names in the .XPERIA TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .XPERIA TLD will clearly publish this registration policy;
5. .XPERIA TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the .XPERIA TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .XPERIA TLD is a proprietary space in which all second-level domains in the TLD are being operated by Sony Mobile Communications AB, its Affiliates and Trademark Licensees and not the government or the corresponding country code operator.
By this letter Sony Mobile Communications AB confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-25

Sony Mobile Communications ABYes
xxxpnView Comments
2015-12-02
2015-12-02View Mitigation

xxx Mitigation

By ICM Registry

Protections

Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:

1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any governments, and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

Furthermore, we have the following Anti-Abuse Policy:

Registry has the right, pursuant to its Registry-Registrant Agreement, to immediately deny, cancel, terminate, suspend, lock, hold, or transfer any domain name and/or registration to ensure registrant’s compliance with the following Anti-Abuse Policy.

1. Accurate Registration Information
Registrant represents and warrants to have provided current, complete, and accurate information in connection with its registration and agrees to correct and update this information to ensure that it remains current, complete, and accurate throughout the term of any resulting registration in a TLD. Registrant’s obligation to provide current, accurate, and complete information is a material element of the Registry-Registrant Agreement, and the registry reserves the right to immediately deny, cancel, terminate, suspend, lock, or transfer any registration if it determines, in its sole discretion, that the information is materially inaccurate.

2. Child Protection Labeling
Registrant understands that Registry Operator may label the sites in the TLD and any site to which such sites are automatically redirected irrespective of the top-level domain for child protection purposes; registrant consents to such labeling.

3. Prohibition on Child Abuse Images and Conduct or Content Designed to Suggest the Presence of Child Abuse Images
The term “child abuse images” is defined as any photograph, film, video, picture, or computer or computer-generated image or picture, whether made or produced by electronic, mechanical, or other means, depicting child sexual abuse as stated in the United Nations Convention on the Rights of the Child. Registrant’s sites in the TLD shall not display any child abuse images. Registrant’s sites in the TLD shall not engage in practices that are designed to suggest the presence of child abuse images, including, without limitation, the use of meta-tags for that purpose. Registry Operator will refer any sites in a TLD that are reported to the Registry Operator to be in violation of this policy to child safety hotlines like the National Center for Missing and Exploited Children (NCMEC), the Internet Watch Foundation (IWF), or the International Association of Internet Hotlines (INHOPE).

4. Prohibition on Abusive Registrations
No registrant may register an abusive second-level domain name in the TLD including, without limitation, domain names that infringe the intellectual property rights of a third party, including common law trademark rights; domain names that are obvious variants of well-known trademarks not belonging to the registrant; or domain names that suggest the presence of child abuse images.

5. Prohibition on Malicious Conduct
No registrant shall use or permit use of a domain name in the TLD for or in connection with email spoofing, phishing, spam, or other forms of malicious behavior.

6. Ongoing Best Practices Policies
Registry Operator will revise this Anti-Abuse Policy or the Registry-Registrant Agreement to include commercially reasonable best practices policies developed by the International Foundation for Online Responsibility (IFFOR) that are designed to promote responsible business practices related to (i) combating online child abuse images, (ii) facilitating user choice and parental control regarding access to online adult entertainment, (iii) protecting free expression rights, and/or (iv) protecting the privacy, security, and consumer rights of consenting adult consumers of online adult entertainment goods and services; registrant consents to adhere to such policies.

The Registrant of a domain name, as recorded in the Registry Service, will be responsible for:
a. the use of their domain name;
b. ensuring that the use of the domain name, where that domain name is a two letter Label that corresponds to a country code described in the ISO 3166-1 alpha-2 standard, avoids confusion with the corresponding country code;”

Should a Registrant fail to comply with the Anti-Abuse Policy, the domain name may be cancelled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLD, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-19

ICM Registry No
xyzpnView Comments
2015-12-02
2015-12-02No
yachtspnView Comments
2015-12-02
2015-12-02View Mitigation

yachts Mitigation

By DERAutos LLC, DERBoats LLC, DERHomes LLC, DERMotorcycles LLC, DERYachts LLC (collective Dominion Registries)

See attached document


View Documents
2016-04-26

DERAutos LLC, DERBoats LLC, DERHomes LLC, DERMotorcycles LLC, DERYachts LLC (collective Dominion Registries)No
yodobashipnView Comments
2015-12-02
2015-12-02View Mitigation

yodobashi Mitigation

By YODOBASHI CAMERA CO.,LTD.

2 Letter Codes Mitigation Plan for YODOBASHI TLDs
(.yodobashi .goldpoint)

To address the confusion concerns cited by governments regarding the use of the second-level domains in the YODOBASHI TLDs,
YODOBASHI CAMERA CO.,LTD. will implement a closed registration policy for YODOBASHI TLDs that mitigates the potential confusion. To these ends, YODOBASHI CAMERA CO., LTD. commits to the following:

・Developing and implementing a closed registration policy for YODOBASHI TLDs that requires that all domains name in the TLDs be registered and used by YODOBASHI CAMERA CO.,LTD., its affiliates, or its trademark licensees;

・Clearly publishing this registration policy on Registry Operator`s homepage for the YODOBASHI TLDs at “nic.yodobashi”, and “nic.goldpoint”.

・Referring to this registration policy in registry Operator`s Registry-Registrar Agreement with all appointed preferred registrars for the YODOBASHI TLDs.

・Enforcing of this registration policy and ensuring continued compliance, including through annual recertification of YODOBASHI TLDs` qualification for Specification 13; and

・Using all domain names in the YODOBASHI TLDs in association with YODOBASHI`s brand products, and services.

This publicly available registration and usage policy would prevent Governments from registering domains in the YODOBASHI TLDs. It would therefore clearly designate to the public that YODOBASHI TLDs were proprietary spaces in which all second-level domains in the TLDs were being operated by YODOBASHI CAMERA CO., LTD. and not governments.


2016-04-25

YODOBASHI CAMERA CO.,LTD.Yes
yogapnView Comments
2015-12-02
2015-12-02View Mitigation

yoga Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
yokohamapnView Comments
2015-12-02
2015-12-02View Mitigation

yokohama Mitigation

By GMO Registry

About .YOKOHAMA

.YOKOHAMA is a GeoTLD for the city of Yokohama, Japan, operated by GMO Registry, Inc. The purpose of .YOKOHAMA is to promote .YOKOHAMA and provide an opportunity for citizens, businesses and community groups to link their identities to the city’s brand. By bringing together quality and informative content, .YOKOHAMA provides a platform to effectively deliver city information to Internet users both locally and globally. It is also an important goal for the Registry that .YOKOHAMA is operated as a trusted, safe, secure, relevant and enjoyable namespace

Protections
Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the governments of a related country-code and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Domain Name Registration Policy for the .YOKOHAMA TLD is the following text:

All Applicants, all Domain Name Registrants, and any party submitting a Domain Name registration request represents and warrants that:
− to its knowledge, the registration of the Domain Name mentioned in the Application
or Domain Name Registration Request will not infringe upon or otherwise violate the
rights of any third party;
− will not register a domain name for the purpose of distributing malware, abusively
operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent
or deceptive practices, counterfeiting or otherwise engaging in activity contrary to
applicable laws or regulations;

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be canceled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

GMO RegistryNo
zappospnView Comments
2015-12-02
2015-12-02View Mitigation

zappos Mitigation

By Amazon Registry Services, Inc.

Amazon Registry Services, Inc. (“ARSI”), the Registry Operator for the .Brand TLDs .AUDIBLE, .AWS, .FIRE, .IMDB, .KINDLE, .PRIME, .SILK, and .ZAPPOS (collectively, “the .Brand TLDs”) proposes release of the following 2-character letter-letter combinations: : ai, bh, bm, ci, cn, eg, il, in, io, it, kr, ky, me, ms, pt, ru, sg, sh, su, tc, or tw.

ARSI has executed Specification 13 to the Registry Agreement for each of the .Brand TLDs. Specification 13 contractually requires ARSI to apply measures which, in and of themselves, avoid confusion with the country codes corresponding to the 2-character letter-letter combinations listed above, namely:

1. Each of the .Brand TLDs is identical to a qualifying registered trademark;
2. Each of the .Brand TLDs is not a Generic String, as this is defined in Specification 11;
3. ARSI has developed and will implement a registration policy for each of the .Brand TLDs that requires all domain names in each such TLD be registered only by ARSI, its Affiliates, or Trademark Licensees of ARSI or its Affiliates;
4. ARSI will publish the registration policy for each of the .Brand TLDs upon delegation; and
5. ARSI has ensured, and will continue to ensure, its compliance with the registration policy through annual certification of qualification for Specification 13 for each of the .Brand TLDs.

Compliance with Specification 13 clearly designates to the public that the .Brand TLDs are proprietary spaces in which ARSI, its Affiliates, or Trademark Licensees of ARSI or its Affiliates use all second-level domain names. Accordingly, there will be no basis on which a letter-letter domain name registered in any of the .Brand TLDs could be confused with the country codes corresponding to the 2-character letter-letter combinations listed above.


2016-04-25

Amazon Registry Services, Inc.Yes
zarapnView Comments
2015-12-02
2015-12-02View Mitigation

zara Mitigation

By INDITEX, S.A.

.ZARA TLD is a closed Brand new gTLD operated by Inditex S.A.

Protections:

Inditex S.A. for the .ZARA TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that Inditex S.A. will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:

1. .ZARA is identical to a qualifying registered trademark;
2. .ZARA is not a Generic String, as this is defined in Specification 11;
3. .ZARA TLD has developed and will implement a closed registration policy for .ZARA that requires that all domain names in the .ZARA TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .ZARA TLD will clearly publish this registration policy;
5. .ZARA TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the .ZARA TLD from registering domain names to unaffiliated third parties and thus clearly designates to the public that .ZARA TLD is a proprietary space in which all second-level domains in the TLD are being operated by Inditex S.A., its Affiliates and Trademark Licensees and not the government or the corresponding country code operator. By this notice, Inditex S.A. confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-20

INDITEX, S.A.Yes
zonepnView Comments
2015-12-02
2015-12-02View Mitigation

zone Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
zuerichpnView Comments
2015-12-02
2015-12-02No
abogadohkView Comments
2015-12-03
2015-12-03View Mitigation

abogado Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
airforcehkView Comments
2015-12-03
2015-12-03View Mitigation

airforce Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
amsterdamhkView Comments
2015-12-03
2015-12-03View Mitigation

amsterdam Mitigation

By City of Amsterdam

For the top level domain .AMSTERDAM we would like to use two letter domains and we propose the following measures to avoid confusion.

A brief explanation of the TLD:
.amsterdam is a geographic TLD for the City of Amsterdam; the City of Amsterdam is the designated Registry Operator. The toplevel domain is open, anyone in the world can register domain names.

Proposed measures to avoid confusion
The proposed protections to avoid confusion with country codes at the second level outlined below specifically apply to: ci, cn, eg, hk, il, in, it, me, pt and sg.

Protections
The Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:
• Registry Operator will commit to investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and
• where, in Registry Operator's sole opinion, misuse has occurred, cause the domain name's records to be removed from the DNS.

Policy measures
Contained within our Acceptable Use Policy for .amsterdam is the following text:
".Abuse in the context of this Policy shall be defined as an action that causes actual and substantial harm, or is a material predicate of such harm, or is illegal, illegitimate, or otherwise contrary to this Policy, including, but not limited to, the following:
...
h. Violation of any applicable local, state, national or international law or regulation by use of a Domain Name;
i . The confusing use of a 2character domain name that corresponds to a country code as described in the ISO 3166 alpha 2 standard with the corresponding country code...”

Should a Registrant fail to comply with the Acceptable Use Policy, the registry has the right to lock, transfer or cancel any offending domain name. Thus all Registrants in the TLDs, have an obligation to avoid confusion with two letter country codes and the City of Amsterdam has clear penalties for any failure to do so.


View Documents
2016-05-09

City of AmsterdamNo
armyhkView Comments
2015-12-03
2015-12-03View Mitigation

army Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
attorneyhkView Comments
2015-12-03
2015-12-03View Mitigation

attorney Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
bankhkView Comments
2015-12-03
2015-12-03View Mitigation

bank Mitigation

By fTLD Registry Services, LLC

Please see the attached file that details fTLD Registry Services' implementation plan for .BANK and .INSURANCE to avoid confusion with corresponding country codes.


View Documents
2016-04-20

fTLD Registry Services, LLCNo
bayernhkView Comments
2015-12-03
2015-12-03View Mitigation

bayern Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
berlinhkView Comments
2015-12-03
2015-12-03View Mitigation

berlin Mitigation

By dotBERLIN GmbH & Co. KG

Proposed Measures to Avoid Confusion within the Community-based GeoTLD .BERLIN for ci, cn, eg, hk, il, in, it, me, pt, sg, tw

“.BERLIN is the top-level domain for the Community of Berliners in the Internet (the .BERLIN Community). The local domain names available with the .BERLIN top-level domain are concise and create an identity for citizens, companies and institutions. Those providing and looking for information, goods and services can thus intuitively come together. The .BERLIN domain names strengthen the feeling of community amongst Berliners, improve communication and make interaction easier, thus providing a stimulus for innovation and development. Both for Berliners and for non-Berliners, Berlin becomes more attractive as a place to visit, as a commercial location and as a place to live.”

Protections

To address the confusion concerns cited by the governments regarding the use of the second-level domains cited above in the .BERLIN, the Registry Operator dotBERLIN GmbH & Co. KG has implemented a restricted registration policy for .BERLIN that mitigates the potential confusion. To these ends, Registry Operator commits to the following (as mentioned in its application at https://gtldresult.icann.org/application-result/applicationstatus/applicationdetails:downloadapplication/1777?t:ac=1777):

dotBERLIN developed and implemented a restricted registration policy and enforces this restricted Registration Policy for .BERLIN including:

Eligibility Requirements: To meet the requirements of ICANN to a community-based designation of the application and to meet a sufficient reference to BERLIN, the group of registrants is limited. Exclusively eligible to register a domain name under the top-level domain .BERLIN is any natural person, legal person, organization or association of persons, if they can demonstrate that they have an economic, cultural, historical, social or any other connection to the German capital Berlin, verifiable by
-their residence or second home, office or place of business, a branch or permanent establishment in the City of BERLIN, or
-a contact listed in the Whois database with a domicile in the City of BERLIN, or
-other appropriate proof e.g. the certification by an employer to enroll at a school or college, or birth certificate.

With the registration of a .BERLIN domain name each registrant implicitly signs the registration policies and agrees with the fact that he acknowledges compliance with the registration guidelines. A review of whether the applicant meets the required eligibility, does not take place regularly on the date of registration, however, anyone can check compliance with the registration requirements by initiating an extrajudicial dispute resolution procedure (ʺ.BERLIN Eligibility Requirements Dispute Resolution Policyʺ) or an objection process.

Content and Use Requirements: To meet the requirements of ICANN to a community-based designation of the application, the registrant must satisfy the following criteria for the content and the use of .BERLIN domain names:
- The contents of the website under a domain name must be directly related to the eligibility requirements, and
- the domain must be in use within 12 months of registration.

Legal Safeguards, Enforcement and continued Compliance: To meet the requirements of ICANN to a community-based designation of the application, the registrant must use the .BERLIN domain in an economic, cultural, social or any other meaningful connection to the City of Berlin.

This designation of .BERLIN to the .BERLIN Community will be enforced by specific language in the Registry-Registrar-Agreement that holds gTLD registrars responsible to include the restrictions as outlined above in respective agreements with their gTLD registrants.

The .BERLIN Registry will, from time to time in its sole discretion or upon evidence or advice manually conduct continuing or recurring audits of domain names registered to ensure continued compliance with these requirements. Failure to comply will result in a notice providing 20-days to comply. Non-compliance following such a notice period may result in take-down of the relevant domain name, at the discretion of the Registry.

Those policies have been clearly publishing policy on Registry Operator’s homepage for .BERLIN.

This registration and usage policy would prevent governments from registering domains in the .BERLIN TLD. It would clearly designate to users that .BERLIN was a restricted space in which all second-level domains were registered by eligible Registrants.


2016-04-25

View Mitigation

berlin Mitigation

By dotBERLIN GmbH & Co. KG


Proposed Measures to Avoid Confusion within the Community-based GeoTLD .BERLIN for su, ru, uk, it, gb, ac, gi, tc, sh, ms, ky, io, bm, fk, ng, kr, il, sg, hk, pn, gs, tw, vn, ln, in, pt

“.BERLIN is the top-level domain for the Community of Berliners in the Internet (the .BERLIN Community). The local domain names available with the .BERLIN top-level domain are concise and create an identity for citizens, companies and institutions. Those providing and looking for information, goods and services can thus intuitively come together. The .BERLIN domain names strengthen the feeling of community amongst Berliners, improve communication and make interaction easier, thus providing a stimulus for innovation and development. Both for Berliners and for non-Berliners, Berlin becomes more attractive as a place to visit, as a commercial location and as a place to live.”

Protections

To address the confusion concerns cited by the governments regarding the use of the second-level domains cited above in the .BERLIN, the Registry Operator dotBERLIN GmbH & Co. KG has implemented a restricted registration policy for .BERLIN that mitigates the potential confusion. To these ends, Registry Operator commits to the following (as mentioned in its application at https://gtldresult.icann.org/application-result/applicationstatus/applicationdetails:downloadapplication/1777?t:ac=1777):

dotBERLIN developed and implemented a restricted registration policy and enforces this restricted Registration Policy for .BERLIN including:

Eligibility Requirements: To meet the requirements of ICANN to a community-based designation of the application and to meet a sufficient reference to BERLIN, the group of registrants is limited. Exclusively eligible to register a domain name under the top-level domain .BERLIN is any natural person, legal person, organization or association of persons, if they can demonstrate that they have an economic, cultural, historical, social or any other connection to the German capital Berlin, verifiable by
-their residence or second home, office or place of business, a branch or permanent establishment in the City of BERLIN, or
-a contact listed in the Whois database with a domicile in the City of BERLIN, or
-other appropriate proof e.g. the certification by an employer to enroll at a school or college, or birth certificate.

With the registration of a .BERLIN domain name each registrant implicitly signs the registration policies and agrees with the fact that he acknowledges compliance with the registration guidelines. A review of whether the applicant meets the required eligibility, does not take place regularly on the date of registration, however, anyone can check compliance with the registration requirements by initiating an extrajudicial dispute resolution procedure (ʺ.BERLIN Eligibility Requirements Dispute Resolution Policyʺ) or an objection process.

Content and Use Requirements: To meet the requirements of ICANN to a community-based designation of the application, the registrant must satisfy the following criteria for the content and the use of .BERLIN domain names:
- The contents of the website under a domain name must be directly related to the eligibility requirements, and
- the domain must be in use within 12 months of registration.

Legal Safeguards, Enforcement and continued Compliance: To meet the requirements of ICANN to a community-based designation of the application, the registrant must use the .BERLIN domain in an economic, cultural, social or any other meaningful connection to the City of Berlin.

This designation of .BERLIN to the .BERLIN Community will be enforced by specific language in the Registry-Registrar-Agreement that holds gTLD registrars responsible to include the restrictions as outlined above in respective agreements with their gTLD registrants.

The .BERLIN Registry will, from time to time in its sole discretion or upon evidence or advice manually conduct continuing or recurring audits of domain names registered to ensure continued compliance with these requirements. Failure to comply will result in a notice providing 20-days to comply. Non-compliance following such a notice period may result in take-down of the relevant domain name, at the discretion of the Registry.

Those policies have been clearly publishing policy on Registry Operator’s homepage for .BERLIN.

This registration and usage policy would prevent governments from registering domains in the .BERLIN TLD. It would clearly designate to users that .BERLIN was a restricted space in which all second-level domains were registered by eligible Registrants.


2016-04-25

dotBERLIN GmbH & Co. KGNo
bethkView Comments
2015-12-03
2015-12-03View Mitigation

bet Mitigation

By Afilias

Afilias has reviewed the comments submitted for the release of certain 2 character labels. We have taken these comments into consideration and will will continue to block the respective labels at the second level until further notice to avoid confusion.


2016-04-20

AfiliasNo
bingohkView Comments
2015-12-03
2015-12-03View Mitigation

bingo Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
budapesthkView Comments
2015-12-03
2015-12-03View Mitigation

budapest Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
capitalhkView Comments
2015-12-03
2015-12-03View Mitigation

capital Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
casinohkView Comments
2015-12-03
2015-12-03View Mitigation

casino Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
cityhkView Comments
2015-12-03
2015-12-03View Mitigation

city Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
countryhkView Comments
2015-12-03
2015-12-03View Mitigation

country Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
creditcardhkView Comments
2015-12-03
2015-12-03View Mitigation

creditcard Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
dentisthkView Comments
2015-12-03
2015-12-03View Mitigation

dentist Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
frlhkView Comments
2015-12-03
2015-12-03View Mitigation

frl Mitigation

By Ewout de Graaf

Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:

Registry Operator will commit to investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and where, in Registry Operator's sole opinion, misuse has occurred, cause the domain name's records to be removed from the DNS.

Furthermore, .frl acceptable use policy contains definitions and measures to avoid confusion between the use of an .frl domain name and country codes listed in the ISO-3166 list of 2-letter country codes. Please review attached document for more information.


View Documents
2016-04-25

Ewout de GraafNo
hamburghkView Comments
2015-12-03
2015-12-03View Mitigation

hamburg Mitigation

By Hamburg Top-Level-Domain GmbH

Proposed Measures to Avoid Confusion within the Community-based GeoTLD .HAMBURG for su, ru, uk, it, gb, ac, gi, tc, sh, ms, ky, io, bm, fk, ng, kr, il, sg, hk, pn, gs, tw, vn, ln, in, pt

“.HAMBURG is the top-level domain of the Community of Hamburg in the Internet. The local domain names available with the .HAMBURG top-level domain are concise and create an identity for citizens, companies and institutions. Those providing and looking for information, goods and services can thus intuitively come together. The .HAMBURG domain names strengthen the feeling of community amongst Hamburgers, improve communication and make interaction easier, thus providing a stimulus for innovation and development. Both for Hamburgers and for non-Hamburgers, Hamburg becomes more attractive as a place to visit, as a commercial location and as a place to live.”

Protections

To address the confusion concerns cited by the governments regarding the use of the second-level domains cited above in the .HAMBURG, the Registry Operator Hamburg Top-Level-Domain GmbH has implemented a restricted registration policy for .HAMBURG that mitigates the potential confusion. To these ends, Registry Operator commits to the following (as mentioned in its application at https://gtldresult.icann.org/application-result/applicationstatus/applicationdetails:downloadapplication/1351?t:ac=1351):

Registry Operator developed and implemented a restricted registration policy and enforces this restricted Registration Policy for .HAMBURG including:

Eligibility Requirements: .HAMBURG is intended to serve the community of the Hamburgers in general, the group of eligible registrants is limited. Exclusively eligible to register a domain name under the top-level domain .HAMBURG is any natural person, legal person, organization or association of persons, if they can demonstrate that they have an economic, cultural, historical, social or any other connection to the metropolitan area of Hamburg, verifiable by

- their residence or second home, office or place of business, a branch or permanent establishment in the metropolitan area of Hamburg, or
- a contact listed in the Whois database with a domicile in the metropolitan area of Hamburg, or
- other appropriate proof e.g. the certification by an employer to enroll at a school or college, or birth certificate.

With the registration of a .HAMBURG domain name each registrant implicitly signs the registration policies and agrees with the fact that he acknowledges compliance with the registration guidelines. A review of whether the applicant meets the required eligibility, does not take place regularly on the date of registration, however, anyone can check compliance with the registration requirements by initiating an extrajudicial dispute resolution procedure.

Content and Use Requirements: The contents of websites under .HAMBURG must be accessible under a domain directly related to the registration criteria of .HAMBURG.

The Registry has in its discretion developed restrictions on the content and use of any domain name. Such restrictions apply to any domain name registration that occurs after such restrictions come into effect.

Each domain name must, within one year following the date of registration, and thereafter throughout the term of the domain name, be used as the domain name for a website displaying Hamburg Community related content relevant to the domain name, or in such other manner (such as email) that the Registry may approve after review. Domain names used as contemplated above may resolve directly to the relevant website or be forwarded or redirected to another domain name displaying content relevant to the domain name.

Legal Safeguards, Enforcement and continued Compliance: This designation of .HAMBURG to the .HAMBURG Community will be enforced by specific language in the Registry-Registrar-Agreement that holds gTLD registrars responsible to include the restrictions as outlined above in respective agreements with their gTLD registrants.

The Registry Operator will, from time to time in its sole discretion or upon evidence or advice, but at least once a year, conduct continuing or recurring audits of domain names registered to ensure continued compliance with these requirements. Failure to comply will result in a notice providing a timeframe to comply. Non-compliance following such a notice period may result in take-down of the relevant domain name, at the discretion of the Registry. The Registry is entitled to lock, cancel, initiate the gTLD-deletion cycle or transfer domain names that do not meet the registration criteria if certain circumstances appear.

Those policies have been clearly published on Registry Operator’s homepage for .HAMBURG.

This registration and usage policy would prevent governments from registering domains in the .HAMBURG TLD. It would clearly designate to users that .HAMBURG was a restricted space in which all second-level domains were registered by eligible Registrants.


2016-04-25

Hamburg Top-Level-Domain GmbHNo
kyotohkView Comments
2015-12-03
2015-12-03View Mitigation

kyoto Mitigation

By Kyoto Jyoho Gakuen

About .KYOTO

.KYOTO is a GeoTLD for the city of Kyoto, Japan, operated by Kyoto Jyoho Gakuen. GeoTLDs are domain extensions that represent cities, states or geographic regions. All GeoTLDs are supported by their respective governments.
The mission and purpose of .kyoto is to create a high performance top-level domain registry that fosters global communication, improves international commerce, and expands the online communities of Kyoto.

Protections
Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the governments of a related country-code and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Domain Name Registration Policy for the .KYOTO TLD is the following text:

All Applicants, all Domain Name Registrants, and any party submitting a Domain Name registration request represents and warrants that:
− to its knowledge, the registration of the Domain Name mentioned in the Application
or Domain Name Registration Request will not infringe upon or otherwise violate the
rights of any third party;
− will not register a domain name for the purpose of distributing malware, abusively
operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent
or deceptive practices, counterfeiting or otherwise engaging in activity contrary to
applicable laws or regulations;

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be canceled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

Kyoto Jyoho GakuenNo
lawyerhkView Comments
2015-12-03
2015-12-03View Mitigation

lawyer Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
londonhkView Comments
2015-12-03
2015-12-03No
melbournehkView Comments
2015-12-03
2015-12-03View Mitigation

melbourne Mitigation

By The Crown in right of the State of Victoria, represented by its Department of State Development, Business and Innovation

Proposed Measure to Avoid Confusion

A brief explanation of the TLD:

.melbourne is a geographic TLD for the city of Melbourne, Australia and the the State Government of Victoria is the designated ‘Registry Operator’. While .melbourne is an open TLD, registration of domain names is limited to Victorian residents and businesses, and other entities with an interest in the state of Victoria, Australia as described in the Registration Policy.

The proposed protections to avoid confusion with country codes at the second level outlined below specifically apply to: ai, bh, bm, ci, cn, eg, hk, il, in, io, it, kr, ky, me, ms, pt, ru, sg, sh, su, tc, and tw

Protections

Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

Furthermore, contained within our Acceptable Use Policy for the .melbourne TLD is the following text:
“…The Registrant of a domain name, as recorded in the Registry Service, will be responsible for:
a. the use of their domain name;
b. ensuring that the use of the domain name, where that domain name is a two letter Label that corresponds to a country code described in the ISO 3166-1 alpha-2 standard, avoids confusion with the corresponding country code;…”

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be cancelled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-03-31

 The Crown in right of the State of Victoria, represented by its Department of State Development, Business and InnovationNo
miamihkView Comments
2015-12-03
2015-12-03View Mitigation

miami Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
nagoyahkView Comments
2015-12-03
2015-12-03View Mitigation

nagoya Mitigation

By GMO Registry

About .NAGOYA

.nagoya is a GeoTLD for the city of Nagoya, Japan, operated by GMO Registry, Inc.
The purpose of .nagoya is to promote Nagoya and provide an opportunity for citizens,
businesses and community groups to link their identities to the city’s brand. By bringing together quality and informative content, .NAGOYA provides a platform to effectively deliver city information to Internet users both locally and globally. It is also an important goal for the Registry that .NAGOYA is operated as a trusted, safe, secure, relevant and enjoyable namespace.

Protections
Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the governments of a related country-code and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Domain Name Registration Policy for the .NAGOYA TLD is the following text:

All Applicants, all Domain Name Registrants, and any party submitting a Domain Name registration request represents and warrants that:
− to its knowledge, the registration of the Domain Name mentioned in the Application
or Domain Name Registration Request will not infringe upon or otherwise violate the
rights of any third party;
− will not register a domain name for the purpose of distributing malware, abusively
operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent
or deceptive practices, counterfeiting or otherwise engaging in activity contrary to
applicable laws or regulations;

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be canceled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

GMO RegistryNo
navyhkView Comments
2015-12-03
2015-12-03View Mitigation

navy Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
nrwhkView Comments
2015-12-03
2015-12-03View Mitigation

nrw Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
nychkView Comments
2015-12-03
2015-12-03View Mitigation

nyc Mitigation

By The City of New York by and through the New York City Department of Information Technology & Telecommunications

Proposed Measure to Avoid Confusion

A brief explanation of the TLD
The .nyc is a geographic TLD representing the city of New York. The designated “Registry Operator” is The City of New York, a municipal corporation under the laws of the State of New York, by and through the New York City Department of Information Technology & Telecommunications. The .nyc TLD is open for registration to individuals or entities having a substantive and lawful connection to the city of New York. This requirement for “nexus” with the city of New York is strictly enforced and is described in our Nexus Policy which can be found at the following link: http://www.ownit.nyc/policies/nyc_nexus_policy.php. Further in order to ensure that we have complete Registrant information the .nyc TLD does not allow the use of proxy, private or anonymous domain name registrations. The .nyc TLD employs an algorithm to detect the inadvertent or intentional registration of proxy, anonymous and/or private domain name registrations, and enforces a Registrar’s obligation to not offer such services.

The proposed protections to avoid confusion with country codes at the second level outlined below specifically apply to: ai, bm, ci, cn, eg, hk, il, in, io, it, ky, me, ms, pt, sg, sh, tc and tw.

Protections
Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

Furthermore, contained within our Acceptable Use Policy for the .nyc TLD is the following text:
“1. By registering a name in the .nyc top-level domain (.NYC), you represent and warrant that you will not use that registration for any illegal purposes, including without limitation, to:
…
4. Infringe the intellectual property rights of any other person or entity including, without limitation, counterfeiting, piracy or trademark or copyright infringement;
5. Impersonate any person or entity, or submit information on behalf of any other person or entity, without their express prior written consent;…”

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be cancelled, locked, placed on hold, transferred or deleted.

Thus all Registrants in the TLD have an obligation not to infringe any intellectual property rights nor to impersonate any person or entity, including the governments that are represented by these two letter country codes, and there are clear penalties in place for doing so.


2016-04-25

The City of New York by and through the New York City Department of Information Technology & TelecommunicationsNo
osakahkView Comments
2015-12-03
2015-12-03No
pharmacyhkView Comments
2015-12-03
2015-12-03View Mitigation

pharmacy Mitigation

By National Association of Boards of Pharmacy

Background

The National Association of Boards of Pharmacy® (NABP®), the impartial professional organization that supports state boards of pharmacy in protecting public health, is the exclusive Registry Operator for the .pharmacy Top-Level Domain (TLD). The .pharmacy TLD was established to provide a secure, verified, and trustworthy TLD where consumers around the globe can be sure the medications they buy online are safe. To that end, a global coalition of stakeholders, including NABP and the International Pharmaceutical Federation, developed policies and maintains standards to govern the .pharmacy TLD, ensuring those websites with a .pharmacy domain are safe and legal.

Implementation Plan to Avoid Confusion

To respond to the confusion concerns cited by several governments regarding the use of the second-level domains (SLDs) in the .pharmacy TLD, NABP notes that it currently implements a restricted registration policy for .pharmacy that recognizes the ongoing and critical need for patients’ medications to be managed by a licensed pharmacist and for their medications to be appropriately sourced in accordance with applicable standards of care. A copy of the policy can be found at http://safe.pharmacy/standards-policies. The very fact that .pharmacy verifies that each entity acquiring a .pharmacy SLD meets all applicable regulatory standards, including those addressing pharmacy licensure and valid prescription requirements, prior to allowing that entity to register a .pharmacy domain name avoids any potential confusion between the .pharmacy registration and a country code.

In order to ensure that there will be no confusion between any two character registrations and a country code sharing the same two letters, NABP will administer its verified registry operation in a manner that avoids potential confusion by:
• Continuing to implement a restricted registration policy for .pharmacy that verifies that each entity acquiring a .pharmacy SLD is an eligible member of the pharmacy community and meets all applicable regulatory standards to conduct pharmacy-related business.
• Continuing to implement a restricted registration policy that ensures website content is relevant to pharmacy services and drug information, which provides the opportunity for NABP to proactively identify any potential confusing use of the domain name with a corresponding country code.
• Maintaining, and continuing to create, ongoing “working relationship[s] with the relevant regulatory, or industry self-regulatory, bodies, including developing a strategy to mitigate as much as possible the risks of fraudulent, and other illegal, activities.” See Beijing GAC Communique. NABP will not issue a .pharmacy domain name in a given country until it has created a relationship with the appropriate health care regulators for a jurisdiction.
• Clearly publishing this registration policy on .pharmacy’s registry homepage.
• Including this registration policy in NABP’s Registry-Registrar Agreement with all accredited registrars for the .pharmacy TLD.
• Enforcing this registration policy and ensuring continued compliance. The process for obtaining a .pharmacy domain name is described here: http://www.safe.pharmacy/apply. More detailed instructions and information are available here: http://www.safe.pharmacy/apply/application-instructions.

NABP’s use of .pharmacy two-character domains would not, in and of itself and absent a verification process, cause any confusion with the corresponding two-letter country codes; nonetheless, NABP further contends that it avoids any potential confusion through its strenuous verification requirements and registration policies, which ensure only licensed and verified pharmacy-related entities are permitted to register and use .pharmacy domains.

Request to ICANN in Accordance With Specification 5 of the Registry Agreement

Based on public comments received, no government objecting to the release of its country code offered a specific explanation for the potential confusion arising from the use of a two-character SLD within a verified registry operation (as defined herein); therefore, based on the aforementioned proposal to avoid confusion as a verified registry operation and in accordance with Specification 5 of its Registry Agreement, NABP respectfully requests that Internet Corporation for Assigned Names and Numbers release the remainder of all second-level two-character country code domain names.


View Documents
2016-04-25

National Association of Boards of PharmacyNo
saarlandhkView Comments
2015-12-03
2015-12-03No
sarlhkView Comments
2015-12-03
2015-12-03View Mitigation

sarl Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
spreadbettinghkView Comments
2015-12-03
2015-12-03View Mitigation

spreadbetting Mitigation

By dotBroker Registry, dotCFD Registry, dotForex Registry, dotMarkets Registry, dotSpreadbetting Registry, dotTrading Registry [collectively, the "Boston Ivy Registry"]

Please find attached a document which outlines the Registry's plans to avoid confusion in respect of the below TLDs:

.Markets
.Trading
.Forex
.Broker
.Spreadbetting
.CFD


View Documents
2016-04-21

dotBroker Registry, dotCFD Registry, dotForex Registry, dotMarkets Registry, dotSpreadbetting Registry, dotTrading Registry [collectively, the "Boston Ivy Registry"]No
surgeryhkView Comments
2015-12-03
2015-12-03View Mitigation

surgery Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
sydneyhkView Comments
2015-12-03
2015-12-03View Mitigation

sydney Mitigation

By State of NSW, Department of Premier and Cabinet

Proposed Measure to Avoid Confusion

A brief explanation of the TLD:
.sydney is a geographic TLD for the city of Sydney, Australia and the State Government of New South Wales is the designated ‘Registry Operator’. While .sydney is an open TLD, registration of domain names is limited to New South Wales residents and businesses, and other entities with an interest in the state of New South Wales, Australia as described in the Registration Policy.

The proposed protections to avoid confusion with country codes at the second level outlined below specifically apply to: ai, bh, bm, ci, cn, eg, hk, il, in, io, it, kr, ky, me, ms, pt, ru, sg, sh, su, tc, and tw

Protections
Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:

1. Registry Operator will commit to:

a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and

b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

Furthermore, contained within our Acceptable Use Policy for the .sydney TLD is the following text:

“…The Registrant of a domain name, as recorded in the Registry Service, will be responsible for:
a. the use of their domain name;
b. ensuring that the use of the domain name, where that domain name is a two letter Label that corresponds to a country code described in the ISO 3166-1 alpha-2 standard, avoids confusion with the corresponding country code;…”

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be cancelled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-21

State of NSW, Department of Premier and CabinetNo
taipeihkView Comments
2015-12-03
2015-12-03No
tirolhkView Comments
2015-12-03
2015-12-03View Mitigation

tirol Mitigation

By punkt Tirol GmbH







.tirol Mitigation Measures to avoid confusion with specific Country codes


Please find attached the measures to avoid confusion for 2-letter SLDs that correspond with country codes of the .tirol TLD.


View Documents
2016-04-12

View Mitigation

tirol Mitigation

By punkt Tirol GmbH

Please find our measures to avoid confusion for 2-letter SLDs corresponding with country codes in the attached PDF document. The document refers to the domains: ac.tirol; bm.tirol; gb.tirol; gi.tirol; hk.tirol; il.tirol; in.tirol; io.tirol; it.tirol; kr.tirol; ky.tirol; ms.tirol; ng.tirol; pt.tirol; ru.tirol; sg.tirol; sh.tirol; su.tirol; tc.tirol; tw.tirol; uk.tirol; vn.Tirol
Best regards, .tirol Team


View Documents
2016-04-19

punkt Tirol GmbHNo
tokyohkView Comments
2015-12-03
2015-12-03View Mitigation

tokyo Mitigation

By GMO Registry

Mitigation Plan for .tokyo

About .tokyo

.tokyo is a GeoTLD for the city of Tokyo, Japan, operated by GMO Registry, Inc. (the “Registry Operator”) with the support of the Tokyo Metropolitan Government.
The purpose of .tokyo is to promote .tokyo and provide an opportunity for citizens, businesses and community groups to link their identities to the city’s brand. By bringing together quality and informative content, .tokyo provides a platform to effectively deliver city information to Internet users both locally and globally. It is also an important goal for the Registry that .tokyo is operated as a trusted, safe, secure, relevant and enjoyable namespace.


Protections
Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the governments of a related country-code and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Domain Name Registration Policy for the .TOKYO TLD is the following text:

All Applicants, all Domain Name Registrants, and any party submitting a Domain Name registration request represents and warrants that:
− to its knowledge, the registration of the Domain Name mentioned in the Application
or Domain Name Registration Request will not infringe upon or otherwise violate the
rights of any third party;
− will not register a domain name for the purpose of distributing malware, abusively
operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent
or deceptive practices, counterfeiting or otherwise engaging in activity contrary to
applicable laws or regulations;

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be canceled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

GMO RegistryNo
townhkView Comments
2015-12-03
2015-12-03View Mitigation

town Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
universityhkView Comments
2015-12-03
2015-12-03View Mitigation

university Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
vegashkView Comments
2015-12-03
2015-12-03No
wienhkView Comments
2015-12-03
2015-12-03View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes - this is the document for .CI

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes - this is the document for .EG

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes - this is the document for .HK

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes - this is the document for .IL

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes - this is the document for .IN

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .IT

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .ME

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .TW

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .CN

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .PT

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond to country codes - this is the document for .SG

best regards
Ronald


View Documents
2016-04-12

View Mitigation

wien Mitigation

By punkt.wien GmbH

Hello

please find attached our measures to avoid confusion for 2-letter SLDs that correspond with country codes (applicable to all 2-letter cc-SLDs)

best regards
Ronald


View Documents
2016-04-15

punkt.wien GmbHNo
worldhkView Comments
2015-12-03
2015-12-03View Mitigation

world Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
xn--vermgensberater-ctbhkView Comments
2015-12-03
2015-12-03No
yokohamahkView Comments
2015-12-03
2015-12-03View Mitigation

yokohama Mitigation

By GMO Registry

About .YOKOHAMA

.YOKOHAMA is a GeoTLD for the city of Yokohama, Japan, operated by GMO Registry, Inc. The purpose of .YOKOHAMA is to promote .YOKOHAMA and provide an opportunity for citizens, businesses and community groups to link their identities to the city’s brand. By bringing together quality and informative content, .YOKOHAMA provides a platform to effectively deliver city information to Internet users both locally and globally. It is also an important goal for the Registry that .YOKOHAMA is operated as a trusted, safe, secure, relevant and enjoyable namespace

Protections
Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to offer the following:
1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from the governments of a related country-code and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.
Furthermore, contained within our Domain Name Registration Policy for the .YOKOHAMA TLD is the following text:

All Applicants, all Domain Name Registrants, and any party submitting a Domain Name registration request represents and warrants that:
− to its knowledge, the registration of the Domain Name mentioned in the Application
or Domain Name Registration Request will not infringe upon or otherwise violate the
rights of any third party;
− will not register a domain name for the purpose of distributing malware, abusively
operating botnets, phishing, piracy, trademark or copyright infringement, fraudulent
or deceptive practices, counterfeiting or otherwise engaging in activity contrary to
applicable laws or regulations;

Should a Registrant fail to comply with the Acceptable Use Policy, the domain name may be canceled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

GMO RegistryNo
zuerichhkView Comments
2015-12-03
2015-12-03No
aarpsgView Comments
2015-11-11
2015-12-03View Mitigation

aarp Mitigation

By AARP

.AARP gTLD Confusion Avoidance Plan

AARP, the Registry Operator for the .AARP gTLD, has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that AARP will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:

1. .AARP is identical to a qualifying registered trademark;
2. .AARP is not a Generic String, as the term is defined in Specification 11 of the Registry Agreement;
3. AARP has developed and will implement a closed registration policy for .AARP that requires that all domain names in the .AARP gTLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, AARP submitted this policy as part of its application for Specification 13 and has clearly published this registration policy; and
5. .AARP will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13, as required by the Registry Agreement.

Compliance with Specification 13 prohibits the .AARP gTLD from registering domain names to unaffiliated third parties and thus clearly designates to the public that the .AARP gTLD is a proprietary space in which all second-level domains in the gTLD are being operated by AARP, its Affiliates and Trademark Licensees and not any government or corresponding country-code TLD operator.

With this submission, AARP confirms that all registrations of two-letter domain names shall comply with the requirements of Specification 13.


View Documents
2016-04-25

AARPYes
abbsgView Comments
2015-11-11
2015-12-03View Mitigation

abb Mitigation

By ABB Ltd

Provide a brief explanation of the TLD:
ABB Ltd has applied for .ABB to run a closed .brand environment.

Protections
ABB Ltd for the .ABB TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that the ABB Ltd will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .ABB is identical to a qualifying registered trademark;
2. .ABB is not a Generic String, as this is defined in Specification 11;
3. .ABB TLD has developed and will implement a closed registration policy for .ABB that requires that all domain names in the .ABB TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .ABB TLD will clearly publish this registration policy;
5. .ABB TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the .ABB TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .ABB TLD is a proprietary space in which all second-level domains in the TLD are being operated by ABB Ltd, its Affiliates and Trademark Licensees and not the government or the corresponding country code operator.
By this letter ABB Ltd confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-25

ABB LtdYes
abbottsgView Comments
2015-11-11
2015-12-03View Mitigation

abbott Mitigation

By Abbott Laboratories, Inc.

Abbott Laboratories, Inc., the Registry Operator for the .ABBOTT gTLD, has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that Abbott Laboratories, Inc. will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:

1. .ABBOTT is identical to a qualifying registered trademark;
2. .ABBOTT is not a Generic String, as the term is defined in Specification 11 of the Registry Agreement;
3. Abbott Laboratories, Inc. has developed and will implement a closed registration policy for .ABBOTT that requires that all domain names in the .ABBOTT gTLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, Abbott Laboratories, Inc. submitted this policy as part of its application for Specification 13 and has clearly published this registration policy; and
5. .ABBOTT will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13, as required by the Registry Agreement.

Compliance with Specification 13 prohibits the .ABBOTT gTLD from registering domain names to unaffiliated third parties and thus clearly designates to the public that the .ABBOTT gTLD is a proprietary space in which all second-level domains in the gTLD are being operated by Abbott Laboratories, Inc., its Affiliates and Trademark Licensees and not any government or corresponding country-code TLD operator.

With this submission, Abbott Laboratories, Inc. confirms that all registrations of two-letter domain names shall comply with the requirements of Specification 13.


2016-04-22

Abbott Laboratories, Inc.Yes
abogadosgView Comments
2015-11-11
2015-12-03View Mitigation

abogado Mitigation

By Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbH

Registry Operator understands the concern that confusion may arise, and in order to mitigate such concern is willing to commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant government and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, registry operator will seek to work indirectly with the sponsoring registrar and/or directly with the registrant to address the misuse.
c. In the event that misuse continues to occur, the Registry Operator may, in its sole discretion, undertake direct action up to and including suspension or deletion of the domain name.


2016-04-22

Minds + Machines Group Limited, Bayern Connect GmbH, Minds + Machines GmbHNo
academysgView Comments
2015-11-11
2015-12-03View Mitigation

academy Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
accenturesgView Comments
2015-11-11
2015-12-03View Mitigation

accenture Mitigation

By Accenture plc

Proposed Measure to Avoid Confusion—Brand TLD (Specification 13)
Provide a brief explanation of the TLD: Accenture plc has applied for .ACCENTURE to run a closed .brand environment.

Protections

Accenture plc for the .ACCENTURE TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that Accenture plc will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .ACCENTURE is identical to a qualifying registered trademark;
2. .ACCENTURE is not a Generic String, as this is defined in Specification 11;
3. .ACCENTURE TLD has developed and will implement a closed registration policy for .ACCENTURE that requires that all domain names in the .ACCENTURE TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .ACCENTURE TLD will clearly publish this registration policy;
5. .ACCENTURE TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.
Compliance with Specification 13 prohibits the .ACCENTURE TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .ACCENTURE TLD is a proprietary space in which all second-level domains in the TLD are being operated by Accenture plc - its Affiliates and Trademark Licensees and not the Government or the corresponding country code operator.
By this letter, Accenture plc confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-20

Accenture plcYes
accountantsgView Comments
2015-11-11
2015-12-03View Mitigation

accountant Mitigation

By Famous Four Media Limited

By Famous Four media Limited.

Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:

1. Registry Operator will commit to:

a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any relevant governments, and provide a written report in response; and

b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

2. Registry Operator will enforce the terms of its Acceptable Use and Take down Policy against Registrants.

3. Should a Registrant fail to comply with the Acceptable Use and Take down Policy, the domain names may be cancelled, locked, placed on hold, transferred or deleted. Thus, all Registrants in the TLDs, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-25

Famous Four Media LimitedNo
accountantssgView Comments
2015-11-11
2015-12-03View Mitigation

accountants Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
actorsgView Comments
2015-11-11
2015-12-03View Mitigation

actor Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
adultsgView Comments
2015-11-11
2015-12-03View Mitigation

adult Mitigation

By ICM Registry

Protections

Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:

1. Registry Operator will commit to:
a. investigate any reports of misuse, including misleading or deceptive conduct, including those from any governments, and provide a written report in response; and
b. where, in Registry Operator’s sole opinion, misuse has occurred, cause the domain name’s records to be removed from the DNS.

Furthermore, we have the following Anti-Abuse Policy:

Registry has the right, pursuant to its Registry-Registrant Agreement, to immediately deny, cancel, terminate, suspend, lock, hold, or transfer any domain name and/or registration to ensure registrant’s compliance with the following Anti-Abuse Policy.

1. Accurate Registration Information
Registrant represents and warrants to have provided current, complete, and accurate information in connection with its registration and agrees to correct and update this information to ensure that it remains current, complete, and accurate throughout the term of any resulting registration in a TLD. Registrant’s obligation to provide current, accurate, and complete information is a material element of the Registry-Registrant Agreement, and the registry reserves the right to immediately deny, cancel, terminate, suspend, lock, or transfer any registration if it determines, in its sole discretion, that the information is materially inaccurate.

2. Child Protection Labeling
Registrant understands that Registry Operator may label the sites in the TLD and any site to which such sites are automatically redirected irrespective of the top-level domain for child protection purposes; registrant consents to such labeling.

3. Prohibition on Child Abuse Images and Conduct or Content Designed to Suggest the Presence of Child Abuse Images
The term “child abuse images” is defined as any photograph, film, video, picture, or computer or computer-generated image or picture, whether made or produced by electronic, mechanical, or other means, depicting child sexual abuse as stated in the United Nations Convention on the Rights of the Child. Registrant’s sites in the TLD shall not display any child abuse images. Registrant’s sites in the TLD shall not engage in practices that are designed to suggest the presence of child abuse images, including, without limitation, the use of meta-tags for that purpose. Registry Operator will refer any sites in a TLD that are reported to the Registry Operator to be in violation of this policy to child safety hotlines like the National Center for Missing and Exploited Children (NCMEC), the Internet Watch Foundation (IWF), or the International Association of Internet Hotlines (INHOPE).

4. Prohibition on Abusive Registrations
No registrant may register an abusive second-level domain name in the TLD including, without limitation, domain names that infringe the intellectual property rights of a third party, including common law trademark rights; domain names that are obvious variants of well-known trademarks not belonging to the registrant; or domain names that suggest the presence of child abuse images.

5. Prohibition on Malicious Conduct
No registrant shall use or permit use of a domain name in the TLD for or in connection with email spoofing, phishing, spam, or other forms of malicious behavior.

6. Ongoing Best Practices Policies
Registry Operator will revise this Anti-Abuse Policy or the Registry-Registrant Agreement to include commercially reasonable best practices policies developed by the International Foundation for Online Responsibility (IFFOR) that are designed to promote responsible business practices related to (i) combating online child abuse images, (ii) facilitating user choice and parental control regarding access to online adult entertainment, (iii) protecting free expression rights, and/or (iv) protecting the privacy, security, and consumer rights of consenting adult consumers of online adult entertainment goods and services; registrant consents to adhere to such policies.

The Registrant of a domain name, as recorded in the Registry Service, will be responsible for:
a. the use of their domain name;
b. ensuring that the use of the domain name, where that domain name is a two letter Label that corresponds to a country code described in the ISO 3166-1 alpha-2 standard, avoids confusion with the corresponding country code;”

Should a Registrant fail to comply with the Anti-Abuse Policy, the domain name may be cancelled, locked, placed on hold, transferred or deleted. Thus all Registrants in the TLD, including ourselves, have an obligation to avoid confusion with two letter country codes and we have clear penalties for any failure to do so.


2016-04-19

ICM Registry No
aegsgView Comments
2015-11-11
2015-12-03View Mitigation

aeg Mitigation

By Aktiebolaget Electrolux

Provide a brief explanation of the TLD:
Aktiebolaget Electrolux has applied for .[TLD] to run a closed .brand environment.

Protections
Aktiebolaget Electrolux for the .[TLD] TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that the Aktiebolaget Electrolux will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .[TLD] is identical to a qualifying registered trademark;
2. .[TLD] is not a Generic String, as this is defined in Specification 11;
3. .[TLD] TLD has developed and will implement a closed registration policy for .[TLD] that requires that all domain names in the .[TLD] TLD be registered ONLY by Registry Operator, its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .[TLD] TLD will clearly publish this registration policy;
5. .[TLD] TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.

Compliance with Specification 13 prohibits the .[TLD] TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .[TLD] TLD is a proprietary space in which all second-level domains in the TLD are being operated by Aktiebolaget Electrolux, its Affiliates and Trademark Licensees and not the government or the corresponding country code operator.
By this letter Aktiebolaget Electrolux confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-25

Aktiebolaget ElectroluxYes
agencysgView Comments
2015-11-11
2015-12-03View Mitigation

agency Mitigation

By Donuts Inc.

Attached.


View Documents
2016-04-25

Donuts Inc.No
aigsgView Comments
2015-11-11
2015-12-03View Mitigation

aig Mitigation

By American International Group, Inc.

Provide a brief explanation of the TLD: American International Group, Inc. has applied for .AIG to run a closed .brand environment.
Protections
American International Group, Inc. for the .AIG TLD has executed Specification 13 to the Registry Agreement. Specification 13 already contractually requires that the American International Group, Inc. will apply measures which, by their very nature, avoid confusion with the corresponding country code, namely the following:
1. .AIG is identical to a qualifying registered trademark;
2. .AIG is not a Generic String, as this is defined in Specification 11;
3. .AIG TLD has developed and will implement a closed registration policy for .AIG that requires that all domain names in the .AIG TLD be registered ONLY by American International Group, Inc., its Affiliates, and its Trademark Licensees;
4. As required under the Registry Agreement, the .AIG TLD will clearly publish this registration policy;
5. .AIG TLD will conduct internal reviews at least once per calendar year to ensure continued compliance with Specification 13.
Compliance with Specification 13 prohibits the .AIG TLD from registering domain names to unaffiliated third parties and thus clearly designate to the public that .AIG TLD is a proprietary space in which all second-level domains in the TLD are being operated by American International Group, Inc., its Affiliates and Trademark Licensees and not the [GOVERNMENT] or the corresponding country code operator.
By this [LETTER] American International Group, Inc. confirms that all registrations of two letter domain names shall comply with the requirements of Specification 13.


2016-04-20

American International Group, Inc.Yes
airforcesgView Comments
2015-11-11
2015-12-03View Mitigation

airforce Mitigation

By United TLD Holdco

Please see attached PDF on behalf of United TLD Holdco


View Documents
2016-04-25

United TLD Holdco No
allfinanzsgView Comments
2015-11-11
2015-12-03View Mitigation

allfinanz Mitigation

By Allfinanz Deutsche Vermögensberatung Aktiengesellschaft

Please find Allfinanz Deutsche Vermögensberatung Aktiengesellschaft's "Mitigation Measures to Avoid Confusion" (concerning 2-letter labels in general) for the “.ALLFINANZ” attached.


View Documents
2016-04-23

Allfinanz Deutsche Vermögensberatung AktiengesellschaftNo
allysgView Comments
2015-11-11
2015-12-03Yes
amsterdamsgView Comments
2015-11-11
2015-12-03View Mitigation

amsterdam Mitigation

By City of Amsterdam

For the top level domain .AMSTERDAM we would like to use two letter domains and we propose the following measures to avoid confusion.

A brief explanation of the TLD:
.amsterdam is a geographic TLD for the City of Amsterdam; the City of Amsterdam is the designated Registry Operator. The toplevel domain is open, anyone in the world can register domain names.

Proposed measures to avoid confusion
The proposed protections to avoid confusion with country codes at the second level outlined below specifically apply to: ci, cn, eg, hk, il, in, it, me, pt and sg.

Protections
The Registry Operator understands the concern that confusion may arise, and in order to avoid such confusion is willing to offer the following:
• Registry Operator will commit to investigate any reports of misuse, including misleading or deceptive conduct, including those from the government of a related country code, and provide a written report in response; and
• where, in Registry Operator's sole opinion, misuse has occurred, cause the domain name's records to be removed from the DNS.

Policy measures
Contained within our Acceptable Use Policy for .amsterdam is the following text:
".Abuse in the context of this Policy shall be defined as an action that causes actual and substantial harm, or is a material predicate of such harm, or is illegal, illegitimate, or otherwise contrary to this Policy, including, but not limited to, the following:
...
h. Violation of any applicable local, state, national or international law or regulation by use of a Domain Name;
i . The confusing use of a 2character domain name that corresponds to a country code as described in the ISO 3166 alpha 2 standard with the corresponding country code...”

Should a Registrant fail to comply with the Acceptable Use Policy, the registry has the right to lock, transfer or cancel any offending domain name. Thus all Registrants in the TLDs, have an obligation to avoid confusion with two letter country codes and the City of Amsterdam has clear penalties for any failure to do so.


View Documents
2016-05-09

City of AmsterdamNo
analyticssgView Comments
2015-11-11
2015-12-03View Mitigation

analytics Mitigation

By Karen L. Day

Please see the attached documents outlining our registry's plans to avoid confusion with certain 2 character labels as previously requested.


View Documents
2016-05-06

Karen L. DayNo

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.

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

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." 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).

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."