Two-Character Letter/Letter Label Comments and Mitigation Measures
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For comments submitted before 6 October 2015, view the archive of comments received.
|Comments from Government||Last|
|RO Mitigation Plan||RO Name||BRAND TLD|
By Queh Ser Pheng, Deputy Director, Internet Resource Management, Policy & Competition Development Group, Infocomm Development Autority of Singapore
We hereby respectfully submit our comment regarding the release of letter/letter two-character labels as second level domains.
At this stage, we are unable to agree to the release of the two-character "sg" label at the second-level under gTLDs because of the concern that such use would create confusion with the ccTLD "sg" representing Singapore. Until further notice, this policy is to be applied to all gTLDs who have requested or will be requesting for the release of letter-letter two-character labels at the second level.
To elaborate further, we are open to considering the release of "sg" to registry operators who have robust framework in place to address concerns of government. We recognise there are legitimate and valid reasons for such use. However, we are of the view that it is prudent for ICANN to first put in place a holistic and robust framework before approvals can be given. More thoughts need to be given to the evaluation process and in particular the remedies available should a registry operator use the approved names in an undesirable manner. Besides possible confusion with the corresponding country code and/or country/territory name, we are also concerned with:
(a) The possible reputational harm if ".sg." is associated with illegal or objectionable content and/or manner-of-use; and
(b) The direct harm if ".sg." content or manner-of-use targets Singapore as a nation or Singapore entities (e.g., websites could masquerade as Singapore Government agencies).
ICANN's current policy focuses only on the "initial release" process. There needs to be considerations given to "post-release" issues. As such, the ICANN framework should include:
(a) A recourse for the government/country code manager to issue a notice to object to the content and/or manner-of-use that is misleading, questionable, objectionable or contrary to the country’s reputation and laws. There should be an effective and robust process acceptable by the government/country code manager for the registry operator to address the concern; and
(b) Provisions to require the registry operator to re-seek approval from government/country code manager should there be material changes in ownership or organisational control (for example merger with or acquisitions by another entity).
In addition, ICANN must be committed to take actions against the registry operator should they fail to comply with the framework (e.g. implement a process for country/territory to raise objections to ICANN and for ICANN to take appropriate remedial actions such as remove/delete/revoke affected names).
By Lin, Mao-Shong, Deputy Director, Ministry of Transportation and Communications
I’m writing hereby to submit Taiwan government’s comments on the release of the “tw” label under the New gTLDs.
We object to the release of “tw” as SLD under all the above-mentioned New gTLDs for their registration by the corresponding Registry operators. We reserve the right to change position in this regard in the future.
The rationale of our objections are below:
Since “tw” label is the country code for Taiwan, the use of “tw” as SLD under these diverse New gTLDs would create confusion or concerns at multiple levels on our part, which include, but not limited to, ”dwarfing national dignity”, “violation of public order or good social custom”, “affecting the rights of domestic enterprises”, and “being prone to produce perplexity to our disadvantage”.
By Ross Dale, Senior Designer, Afnic
There should be no conflict with the use of .re, specifically the domain requested as mo.re, or any other two character domain in the reunion islands. With only a small population there should be minimum conflict whilst maximising profit opportunity.
By Rita Forsi, Italian GAC Representative, Ministry of Economic Development
By Rita Forsi, Italia GAC Representative, Ministry of Economic Development
With reference to the process for Considering Comments for Two-Character Letter/Letter Labels launched by ICANN on October 6, 2015, Italy restates its position expressed on March 25, 2015 (http://mm.icann.org/pipermail/twochar_comments/2015/000063.html) and on May 14, 2015 (email attached).
Italy does not object tout-court to the delegation of our ccSLD, but wants to exercise the right to evaluate the delegation of “it” as a SLD on a case-by-case basis.
The evaluation process takes into account not only the confusion risks, but also the national and international legal framework (e.g. IPR) and opportunity considerations (e.g. it.sucks).
We would like to recall that both the Singapore and Dublin GAC Communiqué advise the Board that comments submitted by the relevant Governments be fully considered regardless of the grounds for objection.
For the abovementioned reasons, we reiterate our position expressed in March 25 2015 for the release of the two‐character “it” label at the second level under new gTLDs.
In general, “it” label string may be released to the extent that the registry operator reaches a formal agreement with the Italian government (included our ccTLD registry “.it”) as per Specification 5 of the Registry Agreement.
This policy is to be applied to all new gTLDs, including, but not limited to, those falling within Category 1 and Category 2 of the Beijing Communiquè. who have requested for the release of “it” labels at the second level.
The authorization requests should be sent to the Italian GAC representatives.
Furthermore, we would like to underline that these “lines-to-take” are agreed with the “.it” Registry.