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

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on new gTLD round
by Administrador de Dominios NIC.py Sept. 26, 2018

Sept. 26, 2018

Buenos días, [.PY] considera que las preguntas técnicas solicitadas por el Grupo de trabajo de la GNSO deben ser abordadas y respondidas por el SSAC, cadenas de dos caracteres, que constan de una letra y un dígito, o dos dígitos, inequívocamente no deberían permitirse en futuras rondas de aplicaciones de gTLD debido al conflicto con la política de asignación de ccTLD y los códigos ISO de dos caracteres (que son externos a la ICANN), así como los problemas homográficos discutidos anteriormente. Atentamente ------------------------ Administrador Técnico de Servidores DNS Centro Nacional de Computación Universidad Nacional de Asunción Campus - San Lorenzo Tel-Fax: +595 21 585550, 585619 ------------------------ -- *“El presente correo electrónico puede contener información confidencial y/o reservada de la UNA o de terceros, Sea usted el destinatario o no del presente correo (o responsable de la entrega del mensaje a la persona indicada), no podrá utilizar, copiar, reproducir o distribuir el mensaje de manera total o parcial, sin autorización previa. Los criterios, opiniones, conclusiones y otras informaciones expresadas en el presente correo electrónico son de exclusiva responsabilidad de la persona remitente o usuario, y no implica ningún tipo de responsabilidad para la UNA. La UNA no se hace responsable de cualquier pérdida o daño causado por el uso del correo electrónico o archivos adjuntos. No obstante se recomienda el análisis pertinente del mismo, que incluya los procedimientos inherentes a la verificación de software malicioso antes de su uso. Si ha recibido este mensaje por error, notifique a la UNA por correo electrónico y elimínelo inmediatamente.”*

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments from cctld.PR
by Oscar Moreno de Ayala-Diaz Sept. 26, 2018

Sept. 26, 2018

ccTLD.pr wholeheartedly supports and echos LACTLD's responses to the GNSO questions as per the communique attached to this message. ccTLD.pr considers that the technical questions requested by the GNSO Working Group should be addressed and answered by the SSAC, two-character strings, which consist of a letter and a digit, or two digits, unequivocally should not be allowed in future rounds of gTLD applications due to the conflict with the ccTLD assignment policy along with potentially new two-character ISO codes in the future, which are external to ICANN. Respectfully, Oscar Moreno de Ayala Díaz ccTLD .PR Manager -- Oscar Moreno de Ayala Díaz President oscar(a)nic.pr Phone: 787-753-5869 787-455-9847 Skype: moreno.nic.pr <https://www.facebook.com/> <https://twitter.com/>

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments for the Initial Report on the New gTLD Subsequent Procedures Policy Development Process
by Clara Angela Collado Vilorio Sept. 26, 2018

Sept. 26, 2018

.do believes that the technical questions asked by the GNSO Working Group need to be addressed and answered by the SSAC, 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. Hasta luego, Ing. Clara Collado Administradora de Dominios NIC DO - ccTLD .do Pontificia Universidad Catolica Madre y Maestra Av. Abraham Lincoln esq. Romulo Betancourt, La Julia Apartado postal 2748, Santo Domingo, R. D. Tel. 809 535-0111 ext. 2050, Fax 809 534-7060 http://www.nic.do<http://www.nic.do/>

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] ccNSO Council Statement subsequent procedures WT 1-4
by Bart Boswinkel Sept. 26, 2018

Sept. 26, 2018

Dear all, On behalf of the ccNSO Council please find included the ccNSO Council’s Statement on the Initial Report on the New gTLDs Subsequent Procedures Work Track 1-4, Kind regards, Bart Boswinkel ccNSO support staff

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Comment on the gNSO proposal regarding two character top level domains
by Elisabeth Ekstrand Sept. 26, 2018

Sept. 26, 2018

The Swedish Internet Foundation submit the following comments to Annex C . Question 1: “If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit, should the reservation of these strings be removed? Why or why not?” Even if there are no technical obstacles to the use of 2-character strings at the top level, there are reasons why the reservation should be kept. The most important reason for keeping the reservation for gTLDs at the top level consisting of 1 letter/1digit – or the other way around – is the danger of confusion. It is for example easy to read a zero as an o and the number 1 as an l. Such as .RO vs. R0, .SL vs S1 etc. Opening up for this will also be in conflict with the difference between 2-character ccTLDs and 3-letters and more as gTLDs. The difference between those two groups should be maintained. Question 2: “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?” As stated above, we are of the opinion that it should not be opened for these types of strings. However, if the community still decides to remove the reservation and go forward with this idea, there should be conducted a careful analysis to ensure security and stability. The Swedish Internet Foundation also support the comments submitted by CENTR, https://centr.org/library/library/policy-document/centr-comment-on-the-gnso… Best regards, Elisabeth Ekstrand Head of Legal and Administration The Swedish Internet Foundation (iis.se) Phone: +46 733 611015 The Internet Foundation in Sweden, IIS, is an independent public-service organization that acts to ensure positive development of the internet. We are based in Sweden and are responsible for the internet’s Swedish top-level domain, .se, and the operation of the .nu top-level domain.

1 0

[Comments-gtld-subsequent-procedures-initial-03jul18] Comments on new gTLD round
by Margarita Valdés Sept. 26, 2018

Sept. 26, 2018

Dear sirs, Please include the following comment: */NIC Chile, .CL registry, believes that 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./* Regards, -- Margarita Valdés Cortés, MBM - UAI Legal and Business Manager NIC Chile - Faculty of Physical and Mathematical Sciences University of Chile www.nic.cl Tel: +56229407734

1 0

[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.

1 0

[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

1 0

[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

1 0

[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

1 0