- comments-geo-names-wt5-initial-05dec18@icann.org

[Comments-geo-names-wt5-initial-05dec18] Finnish Transport and Communications Agency's Comments on the Supplemental Initial Report of the New gTLD Subsequent Procedures Policy Development Process (Work Track 5 on Geographic Names at the Top Level)
by Sahlman Sanna Jan. 22, 2019

Jan. 22, 2019

To whom it may concern: On behalf of The Finnish Transport and Communications Agency (Traficom), please find attached Traficom's comment on the Supplemental Initial Report of the New gTLD Subsequent Procedures Policy Development Process under track 5. Yours sincerely, Sanna Sahlman Legal Counsel Fi-domain names The Finnish Transport and Communications Agency (Traficom) Visiting address: Dynamicum, Erik Palménin aukio 1, 00560 Helsinki Postal address: P.O. Box 313, 00561 HELSINKI Phone: +358 295 390 587

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[Comments-geo-names-wt5-initial-05dec18] CENTR BoD input for WT5 public consultation
by Peter Van Roste Jan. 22, 2019

Jan. 22, 2019

Please find the CENTR input attached. Best Regards, Peter Van Roste [cid:image001.png@01D23EC2.457D1AD0] Peter Van Roste General Manager CENTR - Belliardstraat 20, 1040 Brussels, Belgium tel +32 2 627 55 50 - direct +32 2 627 55 51 www.centr.org<http://www.centr.org> - Twitter<https://twitter.com/CENTRnews> - Facebook<https://www.facebook.com/centrnews> - LinkedIn<https://www.linkedin.com/company/centr> - Skype: pvanroste

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[Comments-geo-names-wt5-initial-05dec18] Input on “Supplemental Report on the new gTLD Subsequent Procedures Policy Devel-opment Process (Work Track 5 on Geographic Names at the Top Level)”
by Massimo Vittori Jan. 22, 2019

Jan. 22, 2019

To whom it might concern On behalf of oriGIn, the global alliance of Geographical Indications (GIs) representing 500 associations and over 3 million producers around the world, I would like to thank you for the opportunity to provide a feed-back on the abovementioned supplemental report and offer the following comments: 1. General comments The rules applicable to geonames as TLDs in the 2012 Applicant Guidebook (AGB) worked generally well and struck an appropriate balance between the different interests at stake. Therefore they should be maintained, subject to the comments below. The exclusion of country names and variations thereof is consistent with the fact that such names are not “generic” TLDs, and should be under the policy authority of the respective national communities, in analogy to ccTLDs. The “non-objection” framework established e.g. for capital city names, subnational and supranational regions, etc. worked well and should be maintained. In the case of non-capital city names the rule according to which the “non-objection” framework is not applicable when the alleged “intended use” is non-geographic should be suppressed at it ignores the unique character of the TLDs and creates wrong incentives to circumvent (i.e. “game”) the requirement to contact and obtain the non-objection from the relevant public authorities. Accordingly, we also disagree with any proposals that suggest to extend the “intended use” rule to any other categories of geonames. Issues have been identified for geonames as TLDs not covered by the 2012 AGB – the lack of a “non-objection” framework for such names has generated conflicts between the different interested parties. This should be avoided in future expansions of the TLD space. Extending the “non-objection” framework to such cases would be advisable. The “non-objection” framework as such can be further improved by establishing reasonable deadlines for issuing the “non-objection”, by providing a default implied “non-objection” if the public authority does not react within the given deadline, by establishing a geonames advoisory panel, whom applicants may consult before even filing their string, and by establishing a mediation process for cases where an objection by a public authority is not accepted by the interested applicant. 2. Specific comments · Questions e1-e4: see general comments above · Question e5: ICANN is bound by its Articles of Incorporation and Bylaws to respect relevant principles of international law and applicable local law. ICANN also has to consider the public policy advice from the GAC. Furthermore, the evidence included in the report shows clearly that many national legislations provide for protections of geonames and that they are applied and enforced regarding domain names. Hence, both international law, national law and relevant public policy input from GAC and Governments should be considered. · Question e6: no factual explanation is contained in the report that would support the need to reduce the number of languages. If any limitation is made it should still afford protection to all official and relevant national, regional and community languages. · Question e7: see general comments above. · Question e8: see answer to question e6. · Question e9: see general comments, i.e.: “In the case of non-capital city names the rule according to which the “non-objection” framework is not applicable when the alleged “intended use” is non-geographic should be suppressed at it creates wrong incentives to circumvent the application of the requirement to contact and obtain the non-objection from the relevant public authorities.” · Question e10: see answer to question e9. · Question e11: see general comments, i.e.: “Issues have been identified for geonames as TLDs not covered by the 2012 AGB – the lack of a “non-objection” framework for such names has generated conflicts between the different interested parties. This should be avoided in future expansions of the TLD space. Extending the “non-objection” framework to such cases would be advisable.” · Proposal 1: support. · Proposal 2: support. · Proposal 3: support. · Proposal 4: support. · Proposal 5: support. The deadline needs to be reasonable. · Proposal 6: not supported. · Proposal 7: not supported. · Proposal 8: support. · Proposal 9: no position. · Proposal 10: no position. · Proposal 11: not supported. · Proposal 12: not supported. · Proposal 13: not supported. · Proposal 14: unclear what the intent is. No position. · Proposal 15: the burden should not be on the country alone – the determination can be made prima facie by the geographic names panel. · Proposal 16: support. · Proposal 17: not supported. · Proposal 18: not supported. · Proposal 19 and variants: not supported. · Proposal 20: not supported. · Proposal 21: support. · Proposal 22: no position. · Proposal 23: not supported. · Proposal 24: support. Consistent with its Bylaws ICANN should defer to applicable local laws and policies, including on the definition of what is considered as a city. The Geonames Panel could assist in this. · Proposal 25: not supported. · Proposal 26: support. · Proposal 27: not supported. · Proposal 28: not supported. · Proposal 29: not supported. · Proposal 30: not supported. · Proposal 31: not supported. · Proposal 32: not supported · Proposal 33: not supported. · Proposal 34: support. · Proposal 35: support. · Proposal 36: support. · Proposal 37: support. · Proposal 38: support. I remain at your disposal for any further clarification. Kind regards, Mr Massimo Vittori Managing Director - oriGIn 1, rue de Varembé 1202, Geneva, Switzerland T: +41 (0) 22 755 07 32 massimo(a)origin-gi.com<mailto:massimo@origin-gi.com> www.origin-gi.com<http://www.origin-gi.com/> Find us on [cid:image001.png@01CEAEFE.E98162A0] Twitter<https://twitter.com/oriGInNetwork> [cid:image002.png@01CEAEFE.E98162A0] LinkedIn<https://www.linkedin.com/company/origin-the-organization-for-an-internation…> [téléchargementyoutube] YouTube<https://www.youtube.com/user/oriGInNetwork1> [origin-logo twitter small_2] Unique & United<https://youtu.be/IEugZL03fbY> CONFIDENTIALITY NOTICE: The contents of this e-mail message and any attachments are confidential and are intended solely for addressee. The information may also be legally privileged. This transmission is sent in trust, for the sole purpose of delivery to the intended recipient. If you have received this transmission in error, any use, reproduction or dissemination of this transmission is strictly prohibited. If you are not the intended recipient, please immediately notify the sender by reply e-mail or phone and delete this message and its attachments, if any.

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[Comments-geo-names-wt5-initial-05dec18] .hamburg comments to WT5
by Dirk Krischenowski Hamburg Top-Level-Domain GmbH Jan. 22, 2019

Jan. 22, 2019

Dear ICANN, Hamburg Top-Level-Domain GmbH is the Registry Operator for the .hamburg gTLD which is a geographic top-level domain acknowledged and contracted by ICANN. We feel accountable for the handling of geographic names from Germany in the next application round at ICANN. Names of cities & regions are public and community ressources in Germany and are legally protected by § 12 BGB (German Civil Code). ICANN is respecting local or national laws within the European Union so far. We appreciate to comment to the WT5 documents. Best regards, Dirk Krischenowski CEO Hamburg Top-Level-Domain GmbH

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[Comments-geo-names-wt5-initial-05dec18] .berlin comments to WT5
by Dirk Krischenowski | dotBERLIN GmbH & Co. KG Jan. 22, 2019

Jan. 22, 2019

Dear ICANN, dotBERLIN GmbH & Co. KG is the Registry Operator for the .berlin gTLD which is a geographic top-level domain acknowledged and contracted by ICANN. We feel accountable for the handling of geographic names from Germany in the next application round at ICANN. Names of cities & regions are public and community ressources in Germany and are legally protected by § 12 BGB (German Civil Code). ICANN is respecting local or national laws within the European Union so far. We appreciate to comment to the WT5 documents. Best regards, Dirk Krischenowski CEO dotBERLIN GmbH & Co. KG

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[Comments-geo-names-wt5-initial-05dec18] CITC Input on Work Track 5 on Geographic Names at the Top Level
by CITC International Affairs Jan. 22, 2019

Jan. 22, 2019

Dears, Please find attached the Communications and Information Technology Commission (CITC) of the Kingdom of Saudi Arabia input to the on the new gTLD Subsequent Procedures Policy Development Process (Work Track 5 on Geographic Names at the Top Level) Best regards, International Affairs Communications and Information Technology Commission Tel.: + 9 66 11 4619777 Fax: + 9 66 11 461 8340 Email: intaff(a)citc.gov.sa<mailto:intaff@citc.gov.sa>

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[Comments-geo-names-wt5-initial-05dec18] CW Comments on WT5 Initial Report
by cw＠christopherwilkinson.eu Jan. 21, 2019

Jan. 21, 2019

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[Comments-geo-names-wt5-initial-05dec18] German GAC comments on Work Track 5 on Geographic Names at the Top Level - Supplemental Initial Report of the New gTLD Subsequent Procedures Policy Development Process
by bernd.neujahr＠bmwi.bund.de Jan. 21, 2019

Jan. 21, 2019

Dear colleagues, please find attached the German GAC comments. Kind regards, Bernd Neujahr German GAC ________________________ Division VIA5 Federal Ministry for Economic Affairs and Energy Scharnhorststraße 34-37, 10115 Berlin, Germany Phone: +49-(30)-18-615-6016 E-Mail: bernd.neujahr(a)bmwi.bund.de Internet: http://www.bmwi.de The protection of your data is important to us. You can find out more about how your personal data are handled by the Federal Ministry for Economic Affairs and Energy in the data protection statement at www.bmwi.de/privacy-policy.

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[Comments-geo-names-wt5-initial-05dec18] Comments on behalf of Georgia
by Mzia Gogilashvili Jan. 21, 2019

Jan. 21, 2019

Dear colleagues, Please find attached comments on “Supplemental Report on the new gTLD Subsequent Procedures Policy Development Process (Work Track 5 on Geographic Names at the Top Level)”. Best regards, Mzia Gogilashvili On behalf of Georgia

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[Comments-geo-names-wt5-initial-05dec18] Iceland - Input
by William Freyr Huntingdon-Williams Jan. 21, 2019

Jan. 21, 2019

(See attached file: Scan_William Freyr Huntingdon_09_16_21-01-2019.pdf) To Whom It May Concern, Please find within the attached document Iceland´s input towards ICANN´s " Work Track 5 on Geographic Names at the Top Level". Yours sincerely, William Freyr Huntingdon-Williams, Legal Advisor Sérfræðingur Directorate for External Trade and Economic Affairs Viðskiptaskrifstofa Ministry for Foreign Affairs Utanríkisráðuneytið T. +354 545 9900 M. +354 860 8025 E-mail: wfhw(a)mfa.is www.mfa.is

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