September 2018 - comments-gtld-subsequent-procedures-initial-03jul18@icann.org

[Comments-gtld-subsequent-procedures-initial-03jul18] MARQUES feedback on Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group
by Alessandra Romeo Sept. 26, 2018

Sept. 26, 2018

Dear Sirs On behalf of MARQUES, I submit to your kind attention MARQUES feedback on Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group, as attached. Should you wish to receive any clarifications or to contact our experts, please do not hesitate to let the undersigned know. Best regards, Alessandra Romeo, MARQUES External Relations Officer <mailto:aromeo@marques.org> aromeo(a)marques.org / +39 333 5809303 <http://www.marques.org/> www.marques.org CONFIDENTIALITY NOTE: This message and any attachment therewith may contain confidential and privileged material for the sole use of the intended recipient. The use, distribution, transmittal or re-transmittal by an unintended recipient of this message and/or the attachment therewith is prohibited without our express authorization in writing or by e-mail. Any unauthorized use, distribution, transmittal or re-transmittal of this message and/or the attachment therewith may be a violation of law and is strictly prohibited. If you are not the intended recipient, please delete this e-mail message and notify the sender immediately.

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[Comments-gtld-subsequent-procedures-initial-03jul18] LACTLD Comment on Initial Report on the New gTLD Subsequent Procedures PDP (Overarching Issues & WT 1-4)
by Miguel Ignacio Estrada Sept. 26, 2018

Sept. 26, 2018

To Whom It May Concern, The Latin American and the Caribbean ccTLD Organization (LACTLD), is a nonprofit association created on August 20th, 1998 in Buenos Aires, Argentina, during the International Forum on the White Paper (IFWP). LACTLD’s vision is to to be the regional organization that represents the interests and promotes the development of the ccTLDs in Latin America and the Caribbean. Following, is LACTLD’s input with respect to the Initial Report of the New gTLD Subsequent Procedures Policy Development Process Working Group, which is chartered to evaluate what changes or additions need to be made to existing new gTLD policy recommendations and includes materials from the full Working Group and four sub-teams within the Working Group, Work Tracks 1-4. In reference to the Initial Report following questions: “2.7.1.e.2: If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit (or digits more generally), should the reservation of those strings be removed? Why or why not? Do you believe that any additional analysis is needed to ensure that these types of strings will not pose harm or risk to security and stability? Please explain.” LACTLD states that: 1. In order to assess if there are no technical obstacles to the use of 2-character stings at the top level consisting of one letter and one digit, this question should be addressed by DNS technical experts (such as ICANN’s Security and Stability Advisory Committee (SSAC)). 2. In reference to the question: If there are no technical obstacles to the use of two-character strings consisting of one letter and one digit, should they be permitted to be registered in future gTLD string application rounds?, LACTLD believes that two-character strings consisting of one letter and one digit should NOT be permitted to be registered in future gTLD applications for the following reasons: a. Two-character top-level domains are firmly associated with country-code Top Level domains; ccTLDs are created by IANA/PTI from two character codes laid down in ISO 3166-1 – ccTLDs have an entirely different policy background to gTLDs. It is entirely foreseeable that the ISO Maintenance Agency could, in the future, decide to issue two character country codes including digits, as the ITU already has done: see Appendix 2 to ITU Radio Regulations (e.g., ‘4X’ for Israel, ‘2’ for the UK). b. Homographic issues: Homographic issues were not addressed by the GNSO. Homographic issues pose a direct threat to the security and stability of the Internet’s system of unique identifiers, including ccTLDs that might be caught up in them; some examples are: .ci -> .c1 .cl -> .c1 .co -> .c0 .do -> .d0 .nl -> .n1 .is -> .1s .ls -> .1s With sans-serif typefaces, there is considerable risk for consumer confusion and consequent security risks, including phishing attacks. ICANN’s core mission is “…to coordinate the stable operation of the Internet's unique identifier systems.”. The introduction of homonym-conflicted two-character top-level domains would be in direct conflict with that core mission. The GNSO’s proposal would introduce instability to the DNS via visual confusion of strings. 3. In reference to the questions : Is additional analysis needed to ensure that the introduction of two-character strings consisting of one letter and one digit will not cause harm or risk to the security and stability of the DNS? LACTLD states that as per Question 1, this must be addressed by DNS Technical Experts, such as the Security and Stability Advisory Committee (SSAC). In conclusion, LACTLD believes that the technical questions asked by the GNSO Working Group need to be addressed and answered by relevant technical bodies, two-character strings, consisting of one letter and one digit, or two digits, should unequivocally not ever be permitted in future gTLD application rounds because of the conflict with ccTLD allocation policy and ISO two-character codes (which are external to ICANN), as well as the homographic issues discussed above. -- *Miguel Ignacio Estrada* General Manager LACTLD +598 2 604 22 22 www.lactld.org

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on Initial Report on the New gTLD Subsequent Procedures Policy Development Process submitted by participants of APIGA 2018
by Hesham M. AlHammad Sept. 26, 2018

Sept. 26, 2018

Dear ICANN, We would like to submit our comments on the "Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)<https://gnso.icann.org/sites/default/files/file/field-file-attach/subsequen…>". We call your attention to our full support for APTLD72 Statement on Country and Territory designators as Top-level Domains, dated 18 September 2017. See: https://aptld.org/documents/Others/201711/APTLD%2072%20Communique%20and%20S… Hence, we definitely stand up for the continuation of the status-quo regarding country and territory designators as top-level domains, i.e.: - All 2-letter ASCII codes, whether or not in the ISO 3166 alpha-2 list, are reserved for ccTLDs, - All 3-letter ASCII codes in the ISO 3166 alpha-3 list are reserved and cannot be applied for, and - Any string in the ICANN's Reserved Country and Territory Names lists<https://www.icann.org/resources/country-territory-names/#reserved> would not be delegated as a gTLD. Also we strongly don't accept the initial report's proposal that seeks permission for 2 character domain names as gTLDs, so long as one of the characters is a numeric digit<https://gnso.icann.org/sites/default/files/file/field-file-attach/subsequen…> for the following reasons: - All 2-letter ASCII codes, whether or not in the ISO 3166 alpha-2 list, have historically been reserved for ccTLDs. - It is possible that the ISO 3166 Maintenance Agency may, at some point in the future, begin to assign 2-character alpha-numeric strings as Country and Territory code points. - Introduction of 2-character strings containing a digit may well cause visual confusion for the internet-user, thus leading to security issues within the DNS. - Creating 2-letter ASCII TLDs (regardless of inclusion of numeric characters or not) would crack a solidly established notion among Internet users that "all ASCII ccTLD identifiers are two letters long, and all two-letter top-level domains are ccTLDs (https://en.wikipedia.org/wiki/Country_code_top-level_domain ). Sincerely Yours, Hesham M. AlHammad Director of SaudiNIC

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[Comments-gtld-subsequent-procedures-initial-03jul18] ICANN New gTLD Subsequent Procedures PDP Working Group
by Dr Eberhard W Lisse Sept. 26, 2018

Sept. 26, 2018

On behalf of the Namibian Network Information Center (Pty) Ltd, the ccTLD Manager for .NA, I wish to comment as follows: 1) Using 2 alphanumeric codes other than those associated with the widely used ISO 3166 code is a bad idea as it will lead to confusion. For example the string .5A has the dubious honor of being able to be confused both with .ZA and .SA, Or .N7 could easily be confused with .NZ, in particular to the proximity of the 7 and Z on the US keyboard. .NZ can already be confused with .NA due to the proximity of the Z and A on the QWERTY keyboard, which (German speaking) users of QWERTZ do not appreciate immediately, as can 0 and O and so can 1, l and I. Handwritten links or addresses generate even more possibilities. 2) In the future the ISO may even decide to use and assign alpha-2 codes containing numerals. 3) Such confusion is not new, there are IDN strings which can cause similar issues, never mind this being used already in phishing 4) There is no need for doing this, since there are an infinite number of possiboe Top Level Domain names with 4 or more characters. 5) (Changes in) ICANN policy affecting the ccTLDs must be developed by the ccNSO. 6) RFC 1591 is clear about 2 letter Top Level Domain names. We are not opposed to doing away with that RFC. greetings, el -- Dr Eberhard W Lisse Managing Director Namibian Network Information Center (Pty) Ltd. PO Box 8421 Bachbrecht Namibia

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[Comments-gtld-subsequent-procedures-initial-03jul18] New gTLD - s.i comment
by Barbara Povše Sept. 26, 2018

Sept. 26, 2018

Dear Ms/Sir, please find .si comment on the GNSO proposal regarding 2-char TLDs attached. Best regards, Barbara Povse Head of Registry.si

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[Comments-gtld-subsequent-procedures-initial-03jul18] Afnic Comment // Initial Report on the New gTLD Subsequent Procedures PDP (Work Tracks 1-4)
by Marianne Georgelin Sept. 26, 2018

Sept. 26, 2018

Dear ICANN, Please find enclosed Afnic's comment on the Intial Report on the New gTLD Subsequent Procedures PDP (Work Tracks 1-4). Best regards, Marianne GEORGELIN Responsable Juridique Head of Legal & Policy marianne.georgelin(a)afnic.fr Mob +33 (0) 6 30 15 19 09 Tel +33 (0) 1 39 30 83 09 Skype / m.georgelin

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[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on Initial Report on the New gTLD Subsequent Procedures Policy Development Process submitted by participants of APIGA 2018
by Shek Sen Hiu Sept. 26, 2018

Sept. 26, 2018

Dear Sir/Madam, Please find the comments below: https://docs.google.com/document/d/1IGJjo-qlpriRe1TJBfMQtv91PZ1HaM6QlLMcGG2… Thank you very much for your attention. Best regards, Sherry Shek NetMission

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[Comments-gtld-subsequent-procedures-initial-03jul18] ICANN New gTLD Subsequent Procedures PDP Working Group
by Sean Copeland Sept. 26, 2018

Sept. 26, 2018

NIC.VI 4608 Tutu Park Mall, Suite 202 St. Thomas, VI 00802-1816 US Virgin Islands re: ICANN New gTLD Subsequent Procedures PDP Working Group NIC.VI is pleased to comment on the New gTLD Subsequent Procedures Initial Report. In particular section 2.7.1.e.2. We want to thank the author of the widely available “White Paper on the GNSO proposal regarding two-character top-level domains” which brought this issue to our attention. We are one of the existing ccTLD’s which would be immediately impacted by character confusion caused by the potential addition of a two-letter alphanumeric tld. A brief history shows Jon Postel saw determining what constituted a country and how it was assigned is best left to ISO. We do not believe it is in the best interest of ICANN to abandon this principle. The white paper correctly points out we can not presume what codes ISO may assign in the future, and it's highly presumptuous to think ICANN should be able to dictate how a pre-existing third party ought to operate. The result can only lead to balkanization. With respect, Sean Copeland NIC.VI

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[Comments-gtld-subsequent-procedures-initial-03jul18] String similarity and homonym can cause confusions to the users' community
by พจนันท์ รัตนไชยพันธ์ Sept. 26, 2018

Sept. 26, 2018

Dear Sirs, 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) as follows: 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. Best regards, Photchanan Ratanajaipan Executive Director The Thai Network Information Center Foundation Tel. (+66) 2244 8261 THNIC Foundation 159 Pichai Rd., Thanon Nakhon Chai Si, Dusit, Bangkok 10300 THAILAND

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[Comments-gtld-subsequent-procedures-initial-03jul18] comments-gtld from ming group
by victory Sept. 26, 2018

Sept. 26, 2018

Dear Sir or madam , My comments are as follows , First, we understand that there are a few TLDs have been put in the forbidden list resulted from the early study on name collision. Before the new round of New gTLD program begins, we hope that ICANN can look for one or more third-party organizations to re-evaluate these strings and consult with the community for the availability of the strings as TLDs. We also think that the former applicants for these forbidden TLDs will have priority to apply. Second, we strongly recommend differentiating the application fees between ASCII and IDN TLDs, and lower the cost of IDN application. We also believe that ICANN should adjust the application procedures to make the local brand owners more easily to apply for the IDN TLDs of their brands. Best wishes, Victor Zhang from ming.Ltd Group ,Hangzhou, China

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