Dear Kim Please find attached a response to your requests for clarification. Best regards, Alejandra ******************************************* Work like you don't need the money. Love like you've never been hurt. Dance like nobody's watching. Sing like nobody's listening. And live like it's Heaven on Earth. ******************************************* On Thu, Mar 13, 2025 at 6:33 PM Kim Davies <kim.davies@iana.org> wrote:

Dear Alejandra:

We appreciate your willingness to discuss the ccNSO Retirement Policy earlier this week, and wanted to put a new request for clarification in writing.

Section 3 of the ccNSO Retirement Policy states that the policy applies to all entries in the Root Zone database that are identified as ccTLD and subject to a Trigger. For 2-letter ASCII ccTLDs, there are two potential Triggering Events identified in the Retirement Policy. We understand the first trigger applies to 2 letter ascii ccTLDs that correspond to an ISO 3166-1 Alpha-2 Code Element. We further understand that a Triggering Event occurs when the corresponding Alpha-2 Code Element is deleted from the ISO 3166-1 Standard by the ISO 3166-1 Maintenance Agency (“ISO 3166/MA”). See Retirement Policy Section 3, p. 15.

To break this down a bit, the language suggests that a “Triggering Event” occurs when:

(i) an ascii entry identified as a ccTLD in the Root Zone database

(ii) that corresponds to any ISO 3166-1 Alpha 2 Code Element

(iii) is deleted from the ISO 3166-1 standard by the ISO 3166-1 Maintenance Agency.

Further, based on the ISO 3166-1 Maintenance Organization’s website, it appears that the Alpha-2 Code Elements include, among others, “officially assigned code elements,” “unassigned code elements,” “transitionally assigned code elements,” and “exceptionally reserved code elements.” Under this interpretation, a ccTLD corresponding to any ISO 3166-1 Alpha-2 code element would never be subject to retirement until it has been fully deleted from anywhere within the ISO 3166-1 Standard, which incorporates unassigned codes, Reserved Codes, Exceptionally Reserved Codes, etc. ( https://www.iso.org/glossary-for-iso-3166.html [iso.org] <https://urldefense.com/v3/__https:/www.iso.org/glossary-for-iso-3166.html__;...> )?

Can the ccNSO confirm that this is the correct interpretation of the ccNSO Retirement Policy? If we have misunderstood the intent of the Retirement Policy, would it be possible for the ccNSO to clarify the circumstances under which a Triggering Event specified in item 1 above would occur?

Kindest regards,

kim

Kim Davies

VP, IANA Services, ICANN

President, PTI