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