Internet Society of China (ISC) actively supports ICANN’s next round of new gTLDs initiative and highly appreciates the efforts made by the ICANN’s stakeholders and community for the preparation of open application.

We have noticed that this round of applications will allow single characters to be used as top-level domains. Considering the unique and diverse cultural connotations of Chinese language, we are concerned that using single characters as top-level domains may lead to embarrassing situations where users may misunderstand or misinterpret. Therefore, we hope to take this opportunity of Public Comment process to submit the following inputs:

Chinese characters, as an important carrier of the inheritance of Chinese civilization, are not only a text symbol but also have rich cultural connotations. A single Chinese character is the basic element of the Chinese language, and on the basis of a single character, words can be formed, sentences can be made, and articles can be composed. Furthermore, it is worth noting that compared with words composed of two or more single characters, a single character often has more meanings.

Single Chinese characters have the following characteristics:

1. Polysemy: A single character contains multiple meanings. For example, the character “号(Hao)” can represent a national title, a commercial brand, or a signal; the character “仇(Chou)” can represent hatred and is also a surname; the character “新(Xin)” can represent something new and can also refer to Xinjiang Uygur Autonomous Region of China or Singapore under certain conditions or language context.

2. Renewed use of “old” characters: With the change of times, many single characters may have extended meanings. For example, the character “舔(Tian)” originally meant the action of moving by sticking the tongue on something, and in the current Internet era, it has been given the meaning of “flattery and obsequiousness”.

In addition, there is a significant difference between Chinese and English, that is, with the expansion of human exploration and the development of technology, new things and phenomena continuously emerge. Therefore, new English words are constantly increasing created and added, such as Bitcoin, Clone. While Chinese only needs to be integrated into the Chinese context without creating new characters when translating, such as the translations of the above two words are: 比特币(Bitcoin), 克隆(Clone), only need to combine the existing single characters could express the new things. This example also reflects the rich cultural connotation that a single character itself has.

In view of the above, if single characters are opened as top-level domains, it may increase the difficulty for up to billions of Chinese users to identify the meaning represented by a single character top-level domain, and may even provide convenience for criminals to use the loopholes of understanding confusion for phishing fraud. Therefore, it is suggested that ICANN further expand the hearing of opinions from all parties of the Chinese community and carefully assess the various risks that may follow.

Considering the unique and diverse cultural connotations of Chinese language, we are concerned that using single characters as top-level domains may lead to embarrassing situations where users may misunderstand or misinterpret.