Dear At-Large Community Please see below the public comment made by the Thai Network Information Center (THNIC) Foundation on String Confusability based on homophone variants. The statement is being circulated at their request to the larger At-Large Community, as it is considered as an issue that may impact end-users and language/script communities: The Thai Network Information Center (THNIC) Foundation would like to submit the following comment on the Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4) : Work Track 3’s Recommendation 2: “Strings must not be confusingly similar to an existing top-level domain.” refers to only the visual or spelling similarity. We would like to emphasize the importance of homonym which can cause confusions to the users' community, and must be avoided particularly at the TLD level. An example case can be found from the first round of the new gTLD where there was an application for .thai new gTLD which phonetically clashes with existing .ไทย (Thai IDN ccTLD). However, thanks to the ICANN board ruling, the application was "Not Approved” in November 2013. From this expensive exercise, we would like to request that homonym be explicitly included in the similarity to existing top-level domain consideration of the new gTLD Applicant Guidebook to prevent future confusions and costly disputes. With kind regards, satish