Dear Council Members, Brian Beckham of WIPO reached out to me a few days ago asking if I could transmit the below information to Council. As I am not the GAC’s Liaison I kindly asked for the message to be transmitted via the GAC Liaisons - Manal and Rida - and with the clarification that the below is a GAC-approved statement; both of which were accomplished. With this in mind, please receive the information Brian and the GAC asked me to transmit. From: BECKHAM Brian <brian.beckham@wipo.int> Date: Wednesday, October 1, 2025 at 9:55 PM To: Manal Ismail <manal@tra.gov.eg>, "Tahir, Rida (ISED/ISDE)" <rida.tahir@ised-isde.gc.ca>, "sebastien@registry.godaddy" <sebastien@registry.godaddy>, Mary Wong <mary.wong@icann.org> Subject: [Ext] Discussion on Protection for Red Cross & IGO Names [CORRESPONDENCE: Tripti Sinha to Tomslin Samme-Nlar and Nacho Amadoz] Hi Manal, Rida, Mary and Seb, Following a call with GAC Leadership yesterday in which there was clear support for option 2 outlined in the Board’s letter to the Council (i.e., including reserved strings in string similarity reviews as a matter of implementation of existing policy), I am writing to provide some background information I pulled together to help me better understand the present discussion in the SubPro IRT and now before Council (I have already shared a version of the below with the GAC). I hope this might be helpful to others and could be shared with the IRT and/or Council in advance of the upcoming discussion on 9-Oct-2025. I would first note that in keeping with the ICANN Bylaws requirement to "ensure that those entities most affected can assist in the policy development process", in the present discussion that would mean providing IGOs and the GAC a chance to weigh in (I have been trying to find a Red Cross contact since Stephane's retirement) on the ICANN policy which acknowledges the rights of IGOs and by extension the global public that rely on their humanitarian missions. Excerpts from the relevant policies here include: ICANN Generic Names Supporting Organisation Final Report Introduction of New Generic Top-Level Domains 8 August 2007 * Strings must not be confusingly similar to an existing top-level domain or a Reserved Name. Final Report on the Protection of IGO and INGO Identifiers in All gTLDs Policy Development Process * Top-Level protections of Exact Match, Full Name Scope 1 identifiers of the [IGOs] are placed in the Applicant Guidebook section 2.2.1.2.3, Strings "Ineligible for Delegation" * For [IGO] Identifiers, if placed in the Applicant Guidebook as ineligible for delegation at the Top-Level, an exception procedure should be created for cases where a protected organization wishes to apply for their protected string at the Top-Level GAC Principles on New gTLDs * The process for introducing new gTLDs must make proper allowance for prior third party rights, in particular trademark rights as well as rights in the names and acronyms of inter-governmental organizations (IGOs). * In the interests of consumer confidence and security, new gTLDs should not be confusingly similar to existing TLDs. To avoid confusion with country-code Top Level Domains no two letter gTLDs should be introduced. String Similarity Assessment of Reserved Names, Version 2: Prepared for Discussion with the SubPro Implementation Review Team, 10 September 2025 * String similarity evaluation is conducted to make sure that two confusingly similar strings are not both delegated into the Root Zone, with “[t]he objective … to prevent user confusion and loss of confidence in the DNS resulting from delegation of many similar strings”, as noted in 2012 AGB, section 2.2.1.1. * In the 2012 new gTLD round, the AGB required checking for string similarity with existing TLDs, Reserved Names (e.g., ICANN, IANA, called Top-Level Reserved Names List), one- or two-char ASCII, and applied-for strings. […] * The Strings Ineligible for Delegation from the 2012 round are referred to as Reserved Names in the 2026 new gTLD round AGB (public comment version). In keeping with ICANN’s Mission (ref. security and stability), a policy decision was taken to include strings that would trigger a risk of user confusion (e.g., the "rodcross" or “redcross” examples) in the string similarly review. Put another way: if there is a policy decision to reserve certain strings in the public interest to avoid potential user confusion, then failing to include those in the string similarity review process undermines that policy. In the 2012 round, reserved names (e.g., ICANN, IANA) were part of string similarity review; this seems to have stemmed from implementation of recommendations in the 2007 GNSO report on new gTLDs. Under the current ABG, Red Cross and IGO names are now reserved and ICANN and IANA are now “blocked”. Looking at the many examples in the ICANN String Similarity Guidelines, it is clear that the string similarity review assessment is concerned with typos and hidden IDN (homoglyph) uses that would trick or confuse users; this does not prevent plurals or coexisting or even similar terms. The Guidelines state: “the objective of the String Similarity Review is to prevent user confusion and loss of confidence in the DNS resulting from delegation of visually similar strings.” The Guidelines then go on to say: “The focus of this review, as well as for the pre-screening, is on confusable similarity, as experienced by a competent native user who is reasonably attentive.” As a practical matter, looking at the 2012 round, there were e.g., applications for “bom” and “cam” (ref. “com”), for “email” and “mail”, for “merck” and “emerck” and “merckmsd”, for “car” and “care”, for “abc” and “bbc”, and for a number of plurals; in other words, if none of these variations were stopped by the string similarity review (they may have faced a string confusion objection, but that is a wholly separate process); this experience from the last round seems to affirm that option 2 will not upset applicant expectations for a predictable application process. I also note Anne’s proposed motion which states: “An applicant whose string is determined to be confusingly similar to a protected identifier in the String Similarity evaluation could challenge that determination, where applicable, in the usual manner.” Even putting aside all of the above policies, with such a safety valve, it is not clear on what basis there would be any objection to the practical implementation of string similarity reviews to include reserved terms. I would also point out that Option 1 would unfairly shift the burden of policing applications to IGOs and the Red Cross. This does not seem to be in line with the public interest nor the above policies. In sum, it seems clear that option 2 should be seem as implementation of the applicable policies. Kind regards, and please do not hesitate to reach out. Brian Kindly, Sebastien Ducos GoDaddy Registry | Senior Client Services Manager [cid:image001.png@01D81E10.09821660] +49 172 690 8418 Germany sebastien@registry.godaddy<mailto:sebastien@registry.godaddy>
