pt Comments

By Ana Cristina Ferreira Amoroso das Neves, Director, Department Information Society, Fundação para a Ciência e a Tecnologia, Ministry of Science, Technology and Higher Education

I request previous comments to objections to the release of the ".pt" as the SLD signalling 1) consumer protection concerns and confusion; 2) some gTLD correspond to a regulated market in EU countries, so their release might generate possible abuses and confusion at the end-users level and therefore must be subject to authorization by the Portuguese Government; 3) others should remain reserved so that can only be assigned to a person, entity or corporation proposed or accepted by the Portuguese Government, which demands consultations with the Portuguese Government. These comments are due to the ICANN's new process launched on the 6th October 2015 on the use of the 2-letter CC and CN at the SLD, taken into account nonetheless GAC's advice from Dublin Communiqué (October 2015). Confusability exists in all instances since the PT code is widely recognized both on and off the Internet as an identifier for Portugal. In this regard, we are concerned that consumers assume that persons or undertakings operating under "pt.string" not only offer their services in Portugal or products or services related to Portugal but that they comply with applicable regulations. As this may not be warranted by registration policies and contracts, we would request Portuguese Government is consulted before any registration, regardless of the grounds for objection. Portugal reserves the right to change position in this regard in the future.
The Portuguese Government will continue to closely follow the evolution of the market and of the technical and political framework to collect data and evidence to better understand the consequences of such release.