Regarding the public comment on "Introduction of Two-Character Domain Names in the New gTLD Namespace" at https://community.icann.org/x/VqzhAg which ends July 10 2014, I've posted the following at https://community.icann.org/x/VqzhAg for consideration: "Various registries for multiple gTLDs are applying for exceptions to Specification 5, Section 2 of the New gTLD Registry Agreement ("Specification 5") with some registries suggesting the release of 2 character ASCII labels not on the current ISO 3166 standard would suffice. While this seems harmless, there is a possibility of new countries and territories being created, and then allocated a new two character ASCII label by ISO 3166/MA (see https://web.archive.org/web/20111101141651/http://www.iso.org/iso/country_co... ). Any new country or territory created after 2014 would therefore not receive the same protection as those in the 2014 ISO 3166-2 list and would find that their new 2 character label is "given away", should they wish for their 2 character ASCII label to be protected, as per Specification 5. Now, should the principle established by Specification 5 protecting 2 character ASCII labels even be in the New gTLD Registry Agreement? Many would say, especially given the prevalence of two character labels in existing TLDs like .com, .org and .net that this principle shouldn't be applied to new gTLDs. However, this (IMO) is a separate issue to the question being asked for in the public comment. If Specification 5 is meant to defend the principle that country codes in ISO 3166-2 should be protected in new gTLDs, then it should be enforced to ensure future countries and territories with new 2 character ASCII labels are protected in the same way as those territories and countries in today's ISO 3166-2 list. Therefore, the proposals by Donuts for 143 of its new gTLDS, .kred by KredTLD Pty Ltd, .best by BestTLD Pty Ltd and .ceo by CEOTLD Pty Ltd. should be turned down in keeping with the principle of Specification 5. The proposal by .wiki by Top Level Design LLC which specifies that the two character ASCII labels will only be used for languages identified by ISO 639-1 does appear to meet the threshold that the use will not be confused with the corresponding country codes, as per Specification 5 and could be approved. Similarly, the proposal by .globo by Globo Comunicação e Participações S.A which proposed the use of two character ASCII labels that are not letters or by two characters where only one of the character is a letter are labels that would not be used by ISO 3166-2 and could be approved." Thoughts? Kind Regards, Dev Anand Teelucksingh