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