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).