Dear all, please find below responses form the .pl registry operator. Very best. Lars From: Roman Malinowski <Roman.Malinowski@nask.pl> Date: Thursday, 5 November 2015 05:30 To: Lars HOFFMANN <lars.hoffmann@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@icann.org <mailto:ccnso-members@icann.org> ; cctldcommunity@cctld-managers.org <mailto:cctldcommunity@cctld-managers.org> Cc: Lars Hoffmann; ccnso-council@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@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@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.