Dear all, Please fine below preliminary feedback from Ørnulf Storm. Best wishes, Lars From: "Storm, Ørnulf" <ornulf.storm@Nkom.no> Date: Friday, 9 October 2015 15:43 To: Lars HOFFMANN <lars.hoffmann@icann.org> Cc: "Lindeberg, Elise" <elise.lindeberg@Nkom.no>, Julia Charvolen <julia.charvolen@icann.org>, Karine Perset <karine.perset@icann.org> Subject: VS: [GAC] Use of 3-letter country codes as top-level domains - please provide feedback Hi, Please find our preliminary brief answers to the questions: 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? The question is not asked correctly. We don¹t think 3-letter country codes should be used at all (unless for some instances of IDN ccTLDs and gTLDs. See answers below on Q5). They should not be reserved for ccTLDs neither should they be used for gTLDs. The reason for this is the 3-letter country code represent the same country or territory as the 2-letter country code. Therefore, using these 3-letter codes at allcould create end user confusion. Using the 3-letter country codes for ccTLDs could be a confusion for the end user since the 3-letter country codes has so strong association to the country and could therefore by the end user be mixed up with the existing ccTLD. 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? No. Certain 3-letter codes have already been used for gTLDs and there are actually some instances of them being on the 3-letter country code list. To use more 3-letter codes for new gTLDs will increase the risk for end user confusion, so our suggestion is to not use any new three letter code at all for new neither ccTLDs nor gTLDs. 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? No, the 3-letter codes should not be used at all. Again, end user confusion. 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? No. As stated before. We do not think it is a good idea to use more 3-letter codes for any new top level domains. 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? No. Existing 3-letter gTLDs should be eligible for an exact match of an equivalent IDN 3-letter code. Also new IDN ccTLD should also be eligible for a IDN 3-letter code. 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? No. Same as previous answer. The should be very limited use of IDN 3-letter codesas suggest in the answer to Q5. 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 our view there are so many other available strings that could be used for a new top level domain and you should therefore not pick those that will most certainly cause end user confusion and also are likely to create conflicts between national law and ICANN policy Regards, Ørnulf Storm Head of Section Section for Electronic Communication and Internet Networks Department Norwegian Communications Authority Switchboard: + 47 22 82 46 00 Direct: + 47 22 82 46 22 Mobile: + 47 970 72696 www.nkom.no <http://www.nkom.no/> Von: Glen de Saint Géry [mailto:Glen@icann.org] Gesendet: Mittwoch, 9. September 2015 15:08 An: Schneider Thomas BAKOM <Thomas.Schneider@bakom.admin.ch> Cc: Olof Nordling <olof.nordling@icann.org>; Tom Dale <tom@acig.com.au>; Julia Charvolen <julia.charvolen@icann.org>; Lars Hoffmann <lars.hoffmann@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@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?