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FW: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes
by Lars Hoffmann Nov. 9, 2015

Nov. 9, 2015

Dear all, please find below responses form the .pl registry operator. Very best. Lars From: Roman Malinowski <Roman.Malinowski(a)nask.pl> Date: Thursday, 5 November 2015 05:30 To: Lars HOFFMANN <lars.hoffmann(a)icann.org> Subject: FW: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes Dear Lars, In refer to the set questions, please see my comments below in this note. I think, that You should know, that my experience with ICANN and domain industry is rather short one; just a couple of years. The presented comments have been formed mainly in refer to the messages presented on the attached slides, however I should add that my understanding of ISO 3166 is not only in context of domains. Best regards, Roman. Roman Malinowski Head of DNS Department | NASK | www.nask.pl mobile +48 692 158 947 | tel +48 22 380 85 06 ul. Wawozowa 18 | 02-796 Warsaw | Poland From:cctldcommunity-bounces@cctld-managers.org <mailto:cctldcommunity-bounces@cctld-managers.org> [mailto:cctldcommunity-bounces@cctld-managers.org <mailto:cctldcommunity-bounces@cctld-managers.org> ] On Behalf Of Bart Boswinkel Sent: Wednesday, November 04, 2015 10:31 AM To: ccnso-members(a)icann.org <mailto:ccnso-members@icann.org> ; cctldcommunity(a)cctld-managers.org <mailto:cctldcommunity@cctld-managers.org> Cc: Lars Hoffmann; ccnso-council(a)icann.org <mailto:ccnso-council@icann.org> Subject: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes Dear all, Please find included a request for input from the cross-community working group on the Use of Country and Territory Names as top-level domains (CWG-UCTN). Please respond to lars.hoffmann(a)icann.org <mailto:lars.hoffmann@icann.org> (also included in the cc). Closing date is 30 November 2015. The questionnaire is a follow-up from the presentation Annebeth Lange (.no) and Paul Szyndler (.au) gave at the ccNSO meeting in Dublin. Their presentation can be found here: https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentati on-ctn-20oct15-en.pdf <https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentat ion-ctn-20oct15-en.pdf> . Kind regards, Bart Boswinkel -------------------- Dear all, As you may be aware, the ccNSO and GNSO Councils have chartered a Cross Community Working Group on the Use of Country and Territory Names as top-level domains (CWG-UCTN). The objective of the CWG-UCTN is to review the current status of representations of country and territory names, as they exist under current ICANN policies, guidelines and procedures. In addition, the Group has been asked to provide advice regarding the feasibility of developing a consistent and uniform set of definitions that could be applicable across the respective SO's and AC's for country and territory names as top-level domains. Please note that the scope of the WG is strictly limited to: · Representations of names of Countries, Territories and their subdivisions listed on or eligible to be listed on the Alpha-2 code International Standard for country codes and codes for their subdivisions (ISO 3166-1), (Names of Country and Territory). Other geographical indicators, such as regions, are excluded; · The use of Country and Territory names as Top Level Domains. The use of Country and Territory names as second or other level is excluded. The CWG-UTCN has divided its work into three work stream: 2-letter codes, 3-letter codes, and full names of countries and territories; currently the Group is starting its discussion on 3-letter codes and it is on this issue specifically that your feedback is being sought at this time. Please note that the community will be given ample opportunity to comment and provide feedback on all other issues in due course. To help the CWG-UCTN in its discussion on three-character codes, you will find below a number of questions; it would be very helpful to the Group if you could provide feedback on some or all questions raised. Please do not hesitate to supply any additional comments you may have on three-letter codes, as long as they are within the scope of work of the CWG (see above). Please send your comments to Lars Hoffmann (lars.hoffmann(a)icann.org <mailto:lars.hoffmann@icann.org> ), who is part of the CWG¹s staff support team, by Monday 30 November 2015. If you cannot submit your input by that date, but you would like to contribute, please let us know when we can expect to receive your contribution so we can plan accordingly. Your input will be very much appreciated. With best regards, Heather Forrest, GNSO (Co-Chair) Carlos Gutiérrez, GNSO (Co-Chair) Annebeth Lange, ccNSO (Co-Chair) Paul Szyndler, ccNSO (Co-Chair) Questions by the CWG-UCTN on 3-character codes with regard to the use of country and territory names as top-level domains 1. In future, should all three-character top-level domains be reserved as ccTLDs only and be ineligible for use as gTLDs? What would be the advantage or disadvantage of such a policy? No, they should not, however all 3-character names listed in ISO tables are to be maintained in line with ISO rules and policy. This question is general one and somewhat misleading; my understanding of this project is that we are not in position to break down the ISO eligibility rules and create our own on Internet with regard the 3-character names. 2. In future, should all three-character top-level domains be eligible for use as gTLDs as long as they are not in conflict with the existing alpha-3 codes from the ISO 3166-1 list; i.e. the three-character version of the same ISO list that is the basis for current ccTLD allocation? What would be the advantage or disadvantage of such a policy? Yes, they should, however we have to have in mind that the 3 character names listed in ISO tables ( not only limited to ISO 3166-1) relate to the names of currencies, the names of languages, etc. The eligibility should be maintained in line with ISO established policy. In general there is no need to design a policy which may limit Internet development. 3. In future, should three-character strings be eligible for use as gTLDs if they are not in conflict with existing alpha-3 codes form the ISO 3166-1 list and they have received documentation of support or non-objection from the relevant government or public authority? What would be the advantage or disadvantage of such a policy? It would be reasonable to answer shortly by saying yes, they should. I think, that would wise to keep in mind that many governments in fact are not in position to predict the future of its states; please refer for instance to the example of former Yugoslavia or Africa where we can see many new countries ³born² in Africa, etc. What would be the value of the mentioned permission? For how long will it be valid? With that rule in mind, for sure, someone in the future would have to decide what is at higher value by weighting an commercial interest vs. the interest of a new nation for instance? Do we really consider, that our legitimate is sufficient? and could prevail the one by UN? As already mentioned, the ³ delegation ( free) for assignment by ISO² 3-character names shall be handled by ISO. In addition, we can see that, there are many 3 character names which most probably will be never used by ISO; and I do believe that ISO knows that and keeps the list. I think, that these 3-character names should be allowed in naming of the top level domains. 4. In future, should there be unrestricted use of three-character strings as gTLDs if they are not conflicting with any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? In order to be consistent with the rules and policies we have already got I would vote for the unrestricted use, however the definition of the meaning of ³ unrestricted² in this context has to be set first. Having in mind the understanding of intention presented above, I found this question as general one. 5. In future, should all IDN three-character strings be reserved exclusively as ccTLDs and be ineligible as IDN gTLDs? What would be the advantage or disadvantage of such a policy? I do not think so, however there is some idea behind. First of all we are not sure about the future regarding IDN; it is complex technology which can cause Internet less stable or even partially unstable. I think we need more research and better analysis; otherwise, I think that we do not have enough knowledge to build any theoretical project and set the rules. The question is: do we have to decide just now? What is a reason behind for making a decision even if it would be wrong in the future? ( as our today¹s knowledge is not sufficient enough..?). In general, the rules applied should be as presented above. 6. In future, should there be unrestricted use of IDN three-character strings if they are not in conflict with existing TLDs or any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? As above, it would be good to have the unrestricted use, however the definition of the meaning of ³unrestricted² in this context has to be set first. 7. Do you have any additional comments that may help the CWG-UCTN in its discussion on three-character strings as top-level domains? In general, we should do our best and avoid of creating the artificial barriers driven by unjustified reasons and curb Internet development, however I think that the planning process in projects should follow the set polices and ISO rules first; I do think, that we have not got a legitimate position to change the UN policy and maintain any new one. Doing differently, I think that simply sooner or later the projects will fail, and the team will be busy with huge load and unproductive work. The known rule first come first served in this context is note the one we should focus on first.

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FW: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes
by Lars Hoffmann Nov. 9, 2015

Nov. 9, 2015

Dear all, please find below responses form the .hk registry operator. Very best. Lars From: Jonathan Shea <jonathan.shea(a)hkirc.hk> Date: Thursday, 5 November 2015 21:25 To: Lars HOFFMANN <lars.hoffmann(a)icann.org> Subject: RE: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes Hi Lars, Below please find our replies to the questions raised. 1. In future, should all three-character top-level domains be reserved as ccTLDs only and be ineligible for use as gTLDs? What would be the advantage or disadvantage of such a policy? <JS> Yes, all country and territory 3-character TLDs should be reserved as ccTLDs only and be ineligible for use as gTLDs. Otherwise, confusion and wrong perception will be caused to Internet users as to whether the 3-character TLD or the 2-character ccTLD is the true official representation of the country/territory. Also, the basic difference between ccTLD and gTLD is that a ccTLD represents country/territory and gTLDs are for generic terms with no geographic connotation. 2. In future, should all three-character top-level domains be eligible for use as gTLDs as long as they are not in conflict with the existing alpha-3 codes from the ISO 3166-1 list; i.e. the three-character version of the same ISO list that is the basis for current ccTLD allocation? What would be the advantage or disadvantage of such a policy? <JS> Apart from the 3-character codes on the ISO 3166-1 list, there may be codes or strings which are 3-character or longer which are commonly accepted/used for specific countries or territories but not on the ISO list. These should be ineligible for use as gTLDs too. Otherwise gross misunderstanding and confusion will be caused on which ones of these are the ones truly representing the country/territory. 3. In future, should three-character strings be eligible for use as gTLDs if they are not in conflict with existing alpha-3 codes form the ISO 3166-1 list and they have received documentation of support or non-objection from the relevant government or public authority? What would be the advantage or disadvantage of such a policy? <JS> This is ok. But all ccTLDs should be consulted rather than only those which are thought to be relevant. 4. In future, should there be unrestricted use of three-character strings as gTLDs if they are not conflicting with any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? <JS> This is not sufficient. See answers to Q1, 2, 3 above. 5. In future, should all IDN three-character strings be reserved exclusively as ccTLDs and be ineligible as IDN gTLDs? What would be the advantage or disadvantage of such a policy? <JS> All IDNs which are official names or commonly known names of countries or territories, irrespective of their length (number of IDN characters) should be reserved exclusively as ccTLDs. 6. In future, should there be unrestricted use of IDN three-character strings if they are not in conflict with existing TLDs or any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? <JS> This is not sufficient. See answer to Q6 above. 7. Do you have any additional comments that may help the CWG-UCTN in its discussion on three-character strings as top-level domains? <JS> Nil. Regards, Jonathan Shea HKIRC (.hk ccTLD) From: cctldcommunity-bounces(a)cctld-managers.org [mailto:cctldcommunity-bounces@cctld-managers.org] On Behalf Of Bart Boswinkel Sent: Wednesday, 4 November 2015 5:31 PM To: ccnso-members(a)icann.org; cctldcommunity(a)cctld-managers.org Cc: Lars Hoffmann; ccnso-council(a)icann.org Subject: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes Dear all, Please find included a request for input from the cross-community working group on the Use of Country and Territory Names as top-level domains (CWG-UCTN). Please respond to lars.hoffmann(a)icann.org (also included in the cc). Closing date is 30 November 2015. The questionnaire is a follow-up from the presentation Annebeth Lange (.no) and Paul Szyndler (.au) gave at the ccNSO meeting in Dublin. Their presentation can be found here: https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentati on-ctn-20oct15-en.pdf <https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentat ion-ctn-20oct15-en.pdf> . Kind regards, Bart Boswinkel -------------------- Dear all, As you may be aware, the ccNSO and GNSO Councils have chartered a Cross Community Working Group on the Use of Country and Territory Names as top-level domains (CWG-UCTN). The objective of the CWG-UCTN is to review the current status of representations of country and territory names, as they exist under current ICANN policies, guidelines and procedures. In addition, the Group has been asked to provide advice regarding the feasibility of developing a consistent and uniform set of definitions that could be applicable across the respective SO's and AC's for country and territory names as top-level domains. Please note that the scope of the WG is strictly limited to: · Representations of names of Countries, Territories and their subdivisions listed on or eligible to be listed on the Alpha-2 code International Standard for country codes and codes for their subdivisions (ISO 3166-1), (Names of Country and Territory). Other geographical indicators, such as regions, are excluded; · The use of Country and Territory names as Top Level Domains. The use of Country and Territory names as second or other level is excluded. The CWG-UTCN has divided its work into three work stream: 2-letter codes, 3-letter codes, and full names of countries and territories; currently the Group is starting its discussion on 3-letter codes and it is on this issue specifically that your feedback is being sought at this time. Please note that the community will be given ample opportunity to comment and provide feedback on all other issues in due course. To help the CWG-UCTN in its discussion on three-character codes, you will find below a number of questions; it would be very helpful to the Group if you could provide feedback on some or all questions raised. Please do not hesitate to supply any additional comments you may have on three-letter codes, as long as they are within the scope of work of the CWG (see above). Please send your comments to Lars Hoffmann (lars.hoffmann(a)icann.org <mailto:lars.hoffmann@icann.org> ), who is part of the CWG¹s staff support team, by Monday 30 November 2015. If you cannot submit your input by that date, but you would like to contribute, please let us know when we can expect to receive your contribution so we can plan accordingly. Your input will be very much appreciated. With best regards, Heather Forrest, GNSO (Co-Chair) Carlos Gutiérrez, GNSO (Co-Chair) Annebeth Lange, ccNSO (Co-Chair) Paul Szyndler, ccNSO (Co-Chair) Questions by the CWG-UCTN on 3-character codes with regard to the use of country and territory names as top-level domains 1. In future, should all three-character top-level domains be reserved as ccTLDs only and be ineligible for use as gTLDs? What would be the advantage or disadvantage of such a policy? 2. In future, should all three-character top-level domains be eligible for use as gTLDs as long as they are not in conflict with the existing alpha-3 codes from the ISO 3166-1 list; i.e. the three-character version of the same ISO list that is the basis for current ccTLD allocation? What would be the advantage or disadvantage of such a policy? 3. In future, should three-character strings be eligible for use as gTLDs if they are not in conflict with existing alpha-3 codes form the ISO 3166-1 list and they have received documentation of support or non-objection from the relevant government or public authority? What would be the advantage or disadvantage of such a policy? 4. In future, should there be unrestricted use of three-character strings as gTLDs if they are not conflicting with any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? 5. In future, should all IDN three-character strings be reserved exclusively as ccTLDs and be ineligible as IDN gTLDs? What would be the advantage or disadvantage of such a policy? 6. In future, should there be unrestricted use of IDN three-character strings if they are not in conflict with existing TLDs or any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? 7. Do you have any additional comments that may help the CWG-UCTN in its discussion on three-character strings as top-level domains?

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FW: Partridge & Garcia's Comments on Use of Country & Territory Names as TLDs
by Lars Hoffmann Nov. 9, 2015

Nov. 9, 2015

Dear all, Please find attached a reply from Partridge and Garcia PC Best wishes, Lars From: Colin O'Brien <colin(a)partridgegarcia.com> Date: Friday, 6 November 2015 10:36 To: Lars HOFFMANN <lars.hoffmann(a)icann.org> Subject: Partridge & Garcia's Comments on Use of Country & Territory Names as TLDs Hello Lars, Please find our comments on the use of country & territory names as TLDs. Cordially, Colin Colin T.J. O¹Brien Partner Partridge & Garcia P.C. <http://partridgeiplaw.com/> 321 North Clark Street Suite 720 Chicago IL 60601 312-634-9503 ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________

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Next CWG-UCTN Meeting?
by Susan Payne Nov. 4, 2015

Nov. 4, 2015

Hi Lars, do we have any CWG-UCTN meetings scheduled? Someone mentioned that there is due to be a meeting on 10 November but I have not seen anything to the list to that effect - although I may have missed it. Thanks Susan Susan Payne Head of Legal Policy | Valideus Ltd E: susan.payne(a)valideus.com<mailto:susan.payne@valideus.com> D: +44 20 7421 8255 T: +44 20 7421 8299 M: +44 7971 661175 -----Original Appointment----- From: Lars Hoffmann [mailto:lars.hoffmann@icann.org] Sent: 18 October 2015 18:22 To: ctn-crosscom(a)icann.org Subject: [Ctn-crosscom] CWG-UCTN Meeting When: 19 October 2015 10:30-11:00 (UTC) Dublin, Edinburgh, Lisbon, London. Where: Wicklow MR3 Dear all, Below you find the proposed agenda for tomorrow's meeting. Best wishes, Lars CWG-UCTN Meeting, Monday 19 October 2015, 11:30-13:00, Wicklow MR3 1. Welcome and Tour de table 2. Review of Achievements and next steps * Presentation of request for input including extension of deadline * Outreach efforts 3. Initial discussion of comments on 3-letter codes submitted so far 4. Any other business 5. Next meeting << File: ATT00001.txt >>

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Feedback on Use of Three-Letter Names at the Top Level
by Winterfeldt, Brian J. Oct. 19, 2015

Oct. 19, 2015

Dear colleagues: We previously provided written feedback to the Working Group as shown in the attached email; however, in reviewing the summary document circulated in today’s face to face meeting, we did not see our feedback reflected. Therefore, we wanted to re-circulate our feedback, with a few additional updates, for the benefit of the Working Group. Below please find our updated input with respect to the options presented regarding the use of three-letter names (including three-letter country codes) at the top level. Option Feedback All three-character strings reserved for use as ccTLD only, ineligible for use as gTLD. This would prevent any future applications for three-character combinations as gTLDs. We oppose this option. Three-character strings eligible for use us gTLDs if not in conflict with ISO 3166 list. This would prevent any applications for three-character combinations as gTLDs that match any alpha-3 codes, reflecting the current status quo. Alpha-3 codes have never been used as active TLDs by any country or territory, even though they have been assigned. There is no legal basis for government ownership, control, or priority over these names. We oppose this option. Three-character strings eligible for use as gTLD if not in conflict with ISO 3166 list unless accompanied by documentation of support or non-objection from the relevant government or public authorities. This would prevent any applications for three-character combinations as gTLDs that match any alpha-3 codes, without the relevant government’s consent. There is no legal basis for requiring such consent, and no legal basis for government ownership, control, or priority over these names. Alpha-3 codes have never been used as active TLDs by any country or territory, even though they have been assigned. We oppose this option. Unrestricted use of three-character strings if not in conflict with any applicable string similarity rules. This would permit any gTLD applications so long as the string were not confusingly similar to another previously-delegated or applied-for string. This is the most logical, historically aligned, and legally-sound option, as it is consistent with internationally-recognized principles of free speech as well as intellectual property and consumer protection doctrines, including those contained in the 1883 Paris Convention for the Protection of Industrial Property and modern treaties on intellectual property rights including TRIPS, and the Universal Declaration of Human Rights and International Covenant on Civil and Political Rights. In addition, national sovereignty has no bearing on the use of country and territory names beyond the ability of a sovereign state to determine its own internationally-recognized name(s). See, e.g., Former Yugoslav Republic of Macedonia v. Greece, I.C.J. Reports 2011, p. 644. Thus, international law, while not necessarily needing to serve as the basis for ICANN policy-making, should be considered, and in this case, multiple sources of international law support open use of three-letter names as gTLDs except in cases of confusing similarity, while international legal support for continued reservation of these names is lacking. Furthermore, this position aligns with the historical separation as between two-letter names, which have been used by countries and territories to represent their respective TLD resources, and three letter names, which have only ever been used to represent generic TLDs. Despite the fact that the ISO has undertaken to assign three-letter names to each country and territory, these names have never been used as TLDs. End users of the Internet know three-letter generic names like .COM, .NET, .ORG, and now .XYZ, with no likelihood of confusion vis-à-vis country or territory names (even through, for example COM is the ISO 3-letter name for COMOROS, and NET could be, but is not, the ISO 3-letter name for NETHERLANDS). Thus, historical practice further supports the use of three-letter names as gTLDs. Future three-character strings reserved for use as IDN ccTLD only, ineligible for use as gTLD. This would prevent any future applications for three-character IDNs as gTLDs. We oppose this option. Unrestricted use of three-character IDN strings if not in conflict with an existing TLD or any applicable string similarity rules. This would permit any IDN gTLD applications so long as the string were not confusingly similar to another previously-delegated or applied-for string. This is the most logical, historically aligned, and legally-sound option. For the same reasons stated above, we support this option. We hope this input is valuable to the Working Group. We look forward to continuing to engage in this work going forward. Best regards, Brian and Griffin Brian J. Winterfeldt Co-Head of Global Brand Management and Internet Practice Mayer Brown LLP bwinterfeldt(a)mayerbrown.com<mailto:bwinterfeldt@mayerbrown.com> 1999 K Street, NW Washington, DC 20006-1101 202.263.3284 direct dial 202.830.0330 fax 1221 Avenue of the Americas New York, New York 10020-1001 212.506.2345 direct dial Griffin M. Barnett Staff Attorney Mayer Brown LLP 1999 K Street, NW Washington, DC 20006 gbarnett(a)mayerbrown.com<mailto:bwinterfeldt@mayerbrown.com> 202.263.3289 phone 202.830.0333 fax __________________________________________________________________________ This email and any files transmitted with it are intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.

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Feedback on Use of Three-Letter Names at the Top Level
by Winterfeldt, Brian J. Oct. 19, 2015

Oct. 19, 2015

Dear colleagues: We previously provided written feedback to the Working Group as shown in the attached email; however, in reviewing the summary document circulated in today’s face to face meeting, we did not see our feedback reflected. Therefore, we wanted to re-circulate our feedback, with a few additional updates, for the benefit of the Working Group. Below please find our updated input with respect to the options presented regarding the use of three-letter names (including three-letter country codes) at the top level. Option Feedback All three-character strings reserved for use as ccTLD only, ineligible for use as gTLD. This would prevent any future applications for three-character combinations as gTLDs. We oppose this option. Three-character strings eligible for use us gTLDs if not in conflict with ISO 3166 list. This would prevent any applications for three-character combinations as gTLDs that match any alpha-3 codes, reflecting the current status quo. Alpha-3 codes have never been used as active TLDs by any country or territory, even though they have been assigned. There is no legal basis for government ownership, control, or priority over these names. We oppose this option. Three-character strings eligible for use as gTLD if not in conflict with ISO 3166 list unless accompanied by documentation of support or non-objection from the relevant government or public authorities. This would prevent any applications for three-character combinations as gTLDs that match any alpha-3 codes, without the relevant government’s consent. There is no legal basis for requiring such consent, and no legal basis for government ownership, control, or priority over these names. Alpha-3 codes have never been used as active TLDs by any country or territory, even though they have been assigned. We oppose this option. Unrestricted use of three-character strings if not in conflict with any applicable string similarity rules. This would permit any gTLD applications so long as the string were not confusingly similar to another previously-delegated or applied-for string. This is the most logical, historically aligned, and legally-sound option, as it is consistent with internationally-recognized principles of free speech as well as intellectual property and consumer protection doctrines, including those contained in the 1883 Paris Convention for the Protection of Industrial Property and modern treaties on intellectual property rights including TRIPS, and the Universal Declaration of Human Rights and International Covenant on Civil and Political Rights. In addition, national sovereignty has no bearing on the use of country and territory names beyond the ability of a sovereign state to determine its own internationally-recognized name(s). See, e.g., Former Yugoslav Republic of Macedonia v. Greece, I.C.J. Reports 2011, p. 644. Thus, international law, while not necessarily needing to serve as the basis for ICANN policy-making, should be considered, and in this case, multiple sources of international law support open use of three-letter names as gTLDs except in cases of confusing similarity, while international legal support for continued reservation of these names is lacking. Furthermore, this position aligns with the historical separation as between two-letter names, which have been used by countries and territories to represent their respective TLD resources, and three letter names, which have only ever been used to represent generic TLDs. Despite the fact that the ISO has undertaken to assign three-letter names to each country and territory, these names have never been used as TLDs. End users of the Internet know three-letter generic names like .COM, .NET, .ORG, and now .XYZ, with no likelihood of confusion vis-à-vis country or territory names (even through, for example COM is the ISO 3-letter name for COMOROS, and NET could be, but is not, the ISO 3-letter name for NETHERLANDS). Thus, historical practice further supports the use of three-letter names as gTLDs. Future three-character strings reserved for use as IDN ccTLD only, ineligible for use as gTLD. This would prevent any future applications for three-character IDNs as gTLDs. We oppose this option. Unrestricted use of three-character IDN strings if not in conflict with an existing TLD or any applicable string similarity rules. This would permit any IDN gTLD applications so long as the string were not confusingly similar to another previously-delegated or applied-for string. This is the most logical, historically aligned, and legally-sound option. For the same reasons stated above, we support this option. We hope this input is valuable to the Working Group. We look forward to continuing to engage in this work going forward. Best regards, Brian and Griffin Brian J. Winterfeldt Co-Head of Global Brand Management and Internet Practice Mayer Brown LLP bwinterfeldt(a)mayerbrown.com<mailto:bwinterfeldt@mayerbrown.com> 1999 K Street, NW Washington, DC 20006-1101 202.263.3284 direct dial 202.830.0330 fax 1221 Avenue of the Americas New York, New York 10020-1001 212.506.2345 direct dial Griffin M. Barnett Staff Attorney Mayer Brown LLP 1999 K Street, NW Washington, DC 20006 gbarnett(a)mayerbrown.com<mailto:bwinterfeldt@mayerbrown.com> 202.263.3289 phone 202.830.0333 fax __________________________________________________________________________ This email and any files transmitted with it are intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.

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CWG-UCTN Meeting
by Lars Hoffmann Oct. 18, 2015

Oct. 18, 2015

Dear all, Below you find the proposed agenda for tomorrow's meeting. Best wishes, Lars CWG-UCTN Meeting, Monday 19 October 2015, 11:30-13:00, Wicklow MR3 1. Welcome and Tour de table 2. Review of Achievements and next steps * Presentation of request for input including extension of deadline * Outreach efforts 3. Initial discussion of comments on 3-letter codes submitted so far 4. Any other business 5. Next meeting

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CWG-UCTN Meeting
by Lars Hoffmann Oct. 18, 2015

Oct. 18, 2015

Dear all, Below you find the proposed agenda for tomorrow's meeting. Best wishes, Lars CWG-UCTN Meeting, Monday 19 October 2015, 11:30-13:00, Wicklow MR3 1. Welcome and Tour de table 2. Review of Achievements and next steps * Presentation of request for input including extension of deadline * Outreach efforts 3. Initial discussion of comments on 3-letter codes submitted so far 4. Any other business 5. Next meeting

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FW: WG: Use of Country and Territory Names as top-level domains - please provide feedback
by Lars Hoffmann Oct. 16, 2015

Oct. 16, 2015

Dear all, Please find below an email from Karine Perset sent on behalf of Thomas Schneider, GAC Chair, regarding the CWG-UCTN¹s request for input that was sent to the GAC last month. Best wishes, Lars From: Karine Perset <karine.perset(a)icann.org> Date: Tuesday, 6 October 2015 00:35 To: Glen de Saint Géry <Glen(a)icann.org>, Lars HOFFMANN <lars.hoffmann(a)icann.org> Cc: "Thomas.Schneider(a)bakom.admin.ch" <Thomas.Schneider(a)bakom.admin.ch>, Olof Nordling <olof.nordling(a)icann.org>, Tom Dale <tom(a)acig.com.au>, Julia Charvolen <julia.charvolen(a)icann.org> Subject: Re: WG: Use of Country and Territory Names as top-level domains - please provide feedback On behalf of Thomas Schneider, GAC Chair Dear Co-Chairs of the CWG-UCTN, Thank you for your email of 9 September seeking feedback from the GAC and other SO/ACs on the use of three-character codes as top-level domains in future rounds of new gTLDs. The subject of the use of three-character country and territory codes at the top-level is of significant interest to the GAC, but the GAC will not be able to provide input to the CWG-UCTN by the requested date of Friday 9 October. The GAC has scheduled a discussion of this topic at its meeting at ICANN54 in Dublin and expects to be able to provide a response to your letter shortly thereafter. With best regards, Karine Von: Glen de Saint Géry [mailto:Glen@icann.org] Gesendet: Mittwoch, 9. September 2015 15:08 An: Schneider Thomas BAKOM <Thomas.Schneider(a)bakom.admin.ch> Cc: Olof Nordling <olof.nordling(a)icann.org>; Tom Dale <tom(a)acig.com.au>; Julia Charvolen <julia.charvolen(a)icann.org>; Lars Hoffmann <lars.hoffmann(a)icann.org> Betreff: Use of Country and Territory Names as top-level domains - please provide feedback Dear SO/AC Chair, As you may be aware, the ccNSO and GNSO Councils have chartered a Cross Community Working Group on the Use of Country and Territory Names as top-level domains (CWG-UCTN). The objective of the CWG-UCTN is to review the current status of representations of country and territory names, as they exist under current ICANN policies, guidelines and procedures. In addition, the Group has been asked to provide advice regarding the feasibility of developing a consistent and uniform set of definitions that could be applicable across the respective SO's and AC's for country and territory names as top-level domains. Please note that the scope of the WG is strictly limited to: · Representations of names of Countries, Territories and their subdivisions listed on or eligible to be listed on the Alpha-2 code International Standard for country codes and codes for their subdivisions (ISO 3166-1), (Names of Country and Territory). Other geographical indicators, such as regions, are excluded; · The use of Country and Territory names as Top Level Domains. The use of Country and Territory names as second or other level is excluded. The CWG-UTCN has divided its work into three work stream: 2-letter codes, 3-letter codes, and full names of countries and territories; currently the Group is starting its discussion on 3-letter codes and it is on this issue specifically that your feedback is being sought at this time. Please note that the community will be given ample opportunity to comment and provide feedback on all other issues in due course. To help the CWG-UCTN in its discussion on three-character codes, you will find below a number of questions; it would be very helpful to the Group if you could provide feedback on some or all questions raised. Please do not hesitate to supply any additional comments you may have on three-letter codes, as long as they are within the scope of work of the CWG (see above). Please send your comments to Lars Hoffmann (lars.hoffmann(a)icann.org) who is part of the CWG¹s staff support team, by Friday 9 October 2015. If you cannot submit your input by that date, but you would like to contribute, please let us know when we can expect to receive your contribution so we can plan accordingly. Your input will be very much appreciated. With best regards, Heather Forrest, GNSO (Co-Chair) Carlos Gutiérrez, GNSO (Co-Chair) Annebeth Lange, ccNSO (Co-Chair) Paul Szyndler, ccNSO (Co-Chair) Questions by the CWG-UCTN on 3-character codes with regard to the use of country and territory names as top-level domains 1. In future, should all three-character top-level domains be reserved as ccTLDs only and be ineligible for use as gTLDs? What would be the advantage or disadvantage of such a policy? 2. In future, should all three-character top-level domains be eligible for use as gTLDs as long as they are not in conflict with the existing alpha-3 codes from the ISO 3166-1 list; i.e. the three-character version of the same ISO list that is the basis for current ccTLD allocation? What would be the advantage or disadvantage of such a policy? 3. In future, should three-character strings be eligible for use as gTLDs if they are not in conflict with existing alpha-3 codes form the ISO 3166-1 list and they have received documentation of support or non-objection from the relevant government or public authority? What would be the advantage or disadvantage of such a policy? 4. In future, should there be unrestricted use of three-character strings as gTLDs if they are not conflicting with any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? 5. In future, should all IDN three-character strings be reserved exclusively as ccTLDs and be ineligible as IDN gTLDs? What would be the advantage or disadvantage of such a policy? 6. In future, should there be unrestricted use of IDN three-character strings if they are not in conflict with existing TLDs or any applicable string similarity rules? What would be the advantage or disadvantage of such a policy? 7. Do you have any additional comments that may help the CWG-UCTN in its discussion on three-character strings as top-level domains?

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FW: RySG comments on Use of Country & Territory Names as TLDs
by Lars Hoffmann Oct. 15, 2015

Oct. 15, 2015

Dear all, Please find attached the comments submitted by the Registry Stakeholder Group. Best wishes, Lars From: Paul Diaz <pdiaz(a)pir.org> Date: Wednesday, 14 October 2015 21:14 To: Lars HOFFMANN <lars.hoffmann(a)icann.org> Cc: ICANN Registry Constituency <regycon(a)googlegroups.com> Subject: RySG comments on Use of Country & Territory Names as TLDs Hi Lars, Please find attached comments from the Registries Stakeholder Group (RySG) on the ³Use of Country and Territory Names as Top-Level Domains.² In the interest of time, the RySG did not conduct a formal vote on these comments. They were circulated and debated on our mailing list, however, and no member expressed opposition to the submission of these comments. We are available to respond to any questions. Respectfully, Paul Diaz RySG Chair (elect)

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