Re: [CPWG] [GTLD-WG] [registration-issues-wg] URGENT - WT5 proposal for 3-letter country codes

Aug. 17, 2018

      Dear Carlton,

I am going to play devil’s advocate now;

RFC 1591 is very clear here:

    “These are the generic TLDs (EDU, COM, NET, ORG, GOV, MIL, and INT), and the two letter country codes from ISO-3166”

“two letter country codes from ISO-3166” equal the ISO 3166-1 Alpha-2 code elements. This excludes Alpha-3 code elements. If you want this changed: just go ahead and create consensus among the Internet Community that RFC 1591 should be scrapped; and replaced with one that includes Alpha-3. Good luck. Until there is a revision; 1591 stands. Yes, Jon also wrote, that it will be unlikely that more TLDs would be created – well: the unlikely happened. So what? He factored it in – just thought it would be unlikely.

Actually to be fair I do not see any 3-letter country codes in the wild very often. Very rare actually. But IF I see one, then it’s usually very clear that it is meant to identify a COUNTRY. E.g. at sports events. Or as country identifier at car stickers. Even there more often than not I do not see THREE LETTER codes. Germany for example uses “D”. Belarus uses “BY”. My tiny 2 Million country Latvia uses “LV”. Belgium “B”. France “F”. But in the few times when they use 3-letter codes it’s often not even the Alpha-3 code. Cameroon uses “CAM” (a new gTLD btw) and NOT “CMR”. Canada uses “CDN” instead of “CAN”. So there is absolutely no clear pattern; or smth the general public might got used to. But still: Yes, when I would see a car with “BOL” as country designator sticker, I might be able to guess “Bolivia”. But I already have a basic information: It’s a COUNTRY sticker, so I know it should be a COUNTRY; and how many countries start with “Bolxxxxxx”? So it is not really knowledge – it is more an educated GUESS! In Olympics Switzerland is SUI and not CHE! I can assure you that almost nobody in Germany (Switzerland’s neighbor!) would connect “CHE” with Switzerland. I didn’t know – and I really, really pay attention to that stuff. Their car plate is “CH” btw.  Where has anybody seen “CHE” anyway? 

Let’s face reality; in all of the above cases we KNEW already that the 3-letter code is a country identifier. But gTLDs are presenting themselves BY DEFINITION always only as full domain names; and there is just no HINT that the TLD is a country identifier. You will never ever see a “.deu” standalone. It would be always something like www.hotels.deu <http://www.hotels.deu> ! And if you would show the domain hotels.deu to a random 100 Germans – I bet that at minimum 95 would NOT create a connotation between “.deu” and “Germany”. Or show someone the domain www.hotels.che <http://www.hotels.che> ! They wouldn’t know that “.che” must be a country code – it could be smth akin to .xyz, .icu (“I See You” – a new .xyz variation on the market). Do you really think that ANYBODY who saw a domain hotels.che would affiliate it with hotels in Switzerland (or a hotel booking platform based in Switzeland)? 

We are looking at all of this from an ivory tower perspective – and sometimes forget to factor in reality (and I am not pointing fingers here to others only – I include myself!)

If we are requiring Government support from the assigned country then we are fine, aren’t we? If the GAC member and the ccTLD operator would be ultra-concerned to assign such string to a third party – or as a gTLD in the first place: just make sure to inform the relevant Government authority and request to “reserve” the string until a global solution is found. But don’t deny Governments that are willing to allow such registration in the gTLD policy framework to go ahead. We are not babysitters here – Governments are not stupid. But a CLEAR WARNING language right in the “letter of non-objection form”:

“ICANN advises all Government authorities to NOT support country name or ISO 3166 Alpha-3 code based gTLD applications at this time. ICANN will likely create special application policy for these names in the future and Governments are STRONGLY advised to not granting support until these policies are in place. If a Government still wishes to support such application already now then ICANN requires a consultation between the signing Government authority and the countries GAC member and the respective ccTLD manager; with a short excerpt of the meeting minutes attached to the application. This to make sure that the Government has heard all affiliated parties before deciding to grant support.”

Thoughts?

Thanks,

Alexander.berlin

-----Original Message-----
From: GTLD-WG [mailto:gtld-wg-bounces@atlarge-lists.icann.org] On Behalf Of Carlton Samuels
Sent: Donnerstag, 16. August 2018 19:29
To: Justine Chew <justine.chew@gmail.com>
Cc: cpwg@icann.org
Subject: Re: [GTLD-WG] [CPWG] [registration-issues-wg] URGENT - WT5 proposal for 3-letter country codes

Very interesting indeed.

SO ISO 3166-1 defined three (3) sets of country codes; 2-letter, 3-letter, and 3-digit.

ISO 3166-1 is the authoritative baseline for country coded TLDs. So now, the proposition is that we accept that this baseline is restricted purely to the use of the 2-letter codes. Question is, why so?

If I were a ccTLD administrator and since this is so much like the land grab of that time, I would have been forced to paraphrase and grouse as allegedly the Bourbon King of France did at the Treaty of Tordesillas " am I not a Christian and a Prince?"  [Disclosure: At one time I was the one with the binding authority at .jm].

My previous attempt to pass on my own view with a tongue-firmly-in-cheek reference to 'jam' seems to have missed the mark. So now, let me be crystal clear. I am for a blanket reservation of all strings pertaining ISO 3166-1 with those already delegated grandfathered. Why, anything else will only encourage speculation like my proposal to go to the Prime Minister of Jamaica and ask his support for delegating the 3-letter code for Jamaica - 'jam' - to me. It is a opportunity that is pregnant with gaming possibilities. But that might be too firm and a bridge to far for all to accept.

So, I can live with my friend Carlos Guiterrez's proposed language; not totally satisfying but close enough to principle for an embrace.

-Carlton

==============================

*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* =============================

On Tue, Aug 14, 2018 at 9:16 PM Justine Chew < <mailto:justine.chew@gmail.com> justine.chew@gmail.com> wrote:
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These are my thoughts on the issue of ISO 3166-1 3-letter codes:
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I too believe that
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WT5 is fully competent to deal with the issue of whether, when and how
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strings identical to the existing ISO 3166 3-letter codes could be
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applied for and delegated, though at the rate WT5 is going, the
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position may very well end in a recommendation that it be chartered
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for deliberation by (yet)
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a(nother) GNSO PDP WG.
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Notwithstanding,
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*3-letter strings on ISO 3166-1 standard* I don't believe it is
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desirable for any un-delegated 3-letter strings currently on the ISO
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3166-1 standard to remain unavailable for application in the next
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round.  However, I am not convinced that an outright claim can be made
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that "there is no "tradition" of ISO 3166-1 3-letter codes being used
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for top level domain names connected
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with the related countries and territories".   Jorge Cancio suggested that
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Switzerland does (in some way) and also some of these codes overlap
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with others, eg those used by the IOC in the Olympic Games.
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In any case, I take the view that by virtue of ICANN being represented
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on the ISO 3166-1 Maintenance Agency, there should be at the very
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least, some moral obligation by ICANN to recognise and treat (in the
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first instance) all such 3-letter strings which exactly match the ISO
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3166-1 3-letter codes as a representation of the corresponding assigned country.
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I have also noted that exceptions need to be considered -- as in the
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case of the Union of Comoros, for which ".com" is no longer available
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-- for which an alternative 3-letter string should be made available
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for application by applicants who either represent the Union of
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Comoros or which received letters of support/non-objection from the
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Union's government should they wish to apply for a 3-letter string for
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a purpose associated with the Union. This exception would also need to
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be made available for any country that is put onto an updated ISO
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3166-1 standard, where the assigned 3-letter code is no longer available.
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As for 3-letter codes which also have generic meanings or said to be
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subject to lost opportunities, I think 3-letter code country
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designations should be prioritised -- think of them as "superlative"
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special nouns. So as an eg .IOT, would be a "superlative" special noun
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of the British Indian Ocean Territory, superlative to the special noun of The Internet of Things.
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In other words, country names trumps everything else, and accordingly,
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the concept of intended use does not apply.
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As to who should be allowed to apply, in sharing concerns for terms
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which have not been defined by Carlos per se, I too am concerned about
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who is meant by "public interest/public benefit entities"; that could
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be any entity, as Greg suggests, which claims to act in public
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interest/public benefit. In this respect, on using the relatively
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successful cases of city name gTLD applications as inspiration, I
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don't see the harm in opening up application to anyone/any entity whereupon the "
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relevant government or public authority or ccTLD manager" can also
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apply and if there is contention, then curative mechanisms already in
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place kick in to assist in resolution of such contention.  In the same
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breath, if an entity which is not the "relevant government or public
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authority or ccTLD manager" applies, then that application should be
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subject to the requirement for a letter or support or non-objection
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from the relevant government or public authority.  This could in my
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opinion best facilitate the application for 3-letter strings which
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match ISO 3166-1 3-letter codes under a preventive and curative 'safeguards' framework.
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Also there is nothing to say that the relevant government or public
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authority and an applicant cannot arrive to some understanding in
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respect of the application, including terms and conditions of the gTLD
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(downstream
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even) should the application be successful. The kind of partnership
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framework which Maureen reminded us of is an appealing resolution
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mechanism. Of course, this would depend on the attitudes of the
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parties concerned, but don't other things suffer the same fate?  Also,
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the suggestion of time limits for response by a government or public
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authority is a good one IMO.
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Perhaps, to facilitate (if one must insists upon it) a
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'prioritisation' of applications by a "relevant government or public
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authority or ccTLD manager", I wonder if a  Sunrise Period would be a feasible option.
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Possibly a difficult consideration, since application windows are
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typically tight as it is, not to mention the need for effective
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pre-launch marketing.
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Lastly, I too don't wish to wade into the discussion of 'expanding the
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territory of ccTLDs' -- it is clear in my mind that all 3-letter
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strings (whether they match ISO 3166-1 3-letter codes or not) would be
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treated as gTLDs and not ccTLDs. The realm of ccTLDs remains in the 2-letter sphere.
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*3-letter strings NOT on ISO 3166-1 standard* I also don't believe it
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is desirable for any un-delegated 3-letter strings NOT currently on
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the ISO 3166-1 standard to remain unavailable for application in the
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next round.  They should not be reserved and should be made available
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for application, with a pre-defined resolution mechanism to deal with
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exceptions arising out of changes to the ISO 3166-1 standard over
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time.
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Regards,
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Justine Chew
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-----
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On Wed, 15 Aug 2018 at 03:44, Sivasubramanian M < <mailto:6.Internet@gmail.com> 6.Internet@gmail.com>
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wrote:
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On Sun, Aug 12, 2018 at 12:14 AM Maureen Hilyard <
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<mailto:maureen.hilyard@gmail.com> maureen.hilyard@gmail.com> wrote:
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Hi everyone
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If you have been following the discussions in WT5 you will see that
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there has been a lot of controversy over the GNSO consensus process
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on Country and Territory Names and how best to come to a decision on
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each of the key issues that are being discussed.
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With regards to an agreement over 3-letter country codes, Carlos
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Raul Gutierrez has proposed the following suggestion to help this
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process move forward, I believe we should consider his proposal as a
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reasonable compromise considering all the discussion that has taken
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place and send our support (or otherwise) to our ALAC co-Chair. The
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ALAC views could be coordinated by the CPWG leads but will be required *by Tuesday??*.
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*This is urgent, as it appears that consensus calls will be received
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by the co-Chairs during the week  and as they will have to prepare
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for the next WT5 meeting on the 22nd, it would be good to include an
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ALAC opinion as well. *
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“Dear Annebeth,
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As you have heard me (too) many times before, I admire the track
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record of preceding, clearly focused public interest 3 letter
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geo-TLDs, like the ones from Catalonia in Spain, Brittany's in
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France, and Serbia's 3 letter TLDs
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Now that I re-stated my rationale for such a clear-cut public
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interest case in an email to Rosalia (for geo use ONLY, accessible
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-i.e. cheap- and non-profit), I hereby submit to the WT my final
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revised language suggestion, which is ONLY applicable for 3-Letter
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codes. It would substitute the following final paragraph in the
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relevant section which deals with 3-Letter codes: “*The SubPro may
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want to consider recommending whether any future
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application/revision/delegation process to be established (either
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generic or restricted to the Geographic categories only), should
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determine if, when, and how specific interested parties, such as
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relevant public international, national or sub-national public authorities, may apply for country and territory names*"
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My suggestion for a FORWARD looking option is:
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“*ICANN may only consider applications of ISO 3166-1 Alpha 3 Letter
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Codes submitted by relevant governmental authorities, ccTLD managers
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and public interest/public benefit entities*.”
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+1.   And, as Alpha3 Letter Codes become a new stream of ccTLDs, ICANN
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could impress upon the relevant local government authorities and
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ccTLD managers to agree on a common minimum set of DNS rules,
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conventions and best practices in the operation of this new stream of
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ccTLDs, as distinct from the 2 characters country codes, some
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operated well, some not so well, some in tune with the way the DNS
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works, some pulled in a different direction. Governments are right in
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considering ccTLDs as their space, but in the past some ccTLDs in
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some countries were transferred to external entities within or out of
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their countries, some ccTLD went out of control irrespective of who
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operated them; It became difficult for ICANN perhaps even promote
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Security and Stability measures such as DNSSEC.  If alpha3 codes are
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deemed as a new stream of ccTLDs, it then becomes an opportunity for
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ICANN to delegate them as a more integrated TLD class within the DNS,
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somewhere between the somewhat detached 2 character ccTLD and the
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fully coordinated gTLDs. An example result of such an approach would
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be an alpha3 application criteria that might look for technical
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expertise or a contract with an accredited Registry Service Provider
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with relevant ccTLD experience; while there may be more elaborate
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criteria, the respective countries may have country specific policies
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for operation of the alpha3 codes except where such national policies are NOT in sharp contrast with the general principles of the DNS.
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Sivasubramanian M
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This paragraph is, in my view, a sensible part of a forward-looking
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recommendation that could go ahead with broader WT consensus. And if
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it does not, please make sure it is recorded as an objection against
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a permanent restriction of the delegation of the ISO 3-Letter list.
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Thanks to all,
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Carlos Raúl Gutiérrez"
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--
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Please send all replies to  <mailto:6.Internet@gmail.com> 6.Internet@gmail.com
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Re: [CPWG] [GTLD-WG] [registration-issues-wg] URGENT - WT5 proposal for 3-letter country codes

Alexander Schubert