From: "Pruis, Elaine" <epruis@verisign.com>
Date: Monday, September 15, 2025 at 9:24 PM
To: "sarmad.hussain@icann.org" <sarmad.hussain@icann.org>, "anneicanngnso@gmail.com" <anneicanngnso@gmail.com>, "karen@elstermcgrady.com" <karen@elstermcgrady.com>
Cc: "subpro-irt@icann.org" <subpro-irt@icann.org>
Subject: Re: [SubPro-IRT] Re: [Ext] Re: String Similarity and Reserved Names

From: Sarmad Hussain via SubPro-IRT <subpro-irt@icann.org>
Reply-To: Sarmad Hussain <sarmad.hussain@icann.org>
Date: Monday, September 15, 2025 at 5:38 PM
To: Anne ICANN <anneicanngnso@gmail.com>, Karen Day <karen@elstermcgrady.com>
Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [EXTERNAL] [SubPro-IRT] Re: [Ext] Re: String Similarity and Reserved Names

From: Anne ICANN via SubPro-IRT <subpro-irt@icann.org>
Reply-To: Anne ICANN <anneicanngnso@gmail.com>
Date: Monday, September 15, 2025 at 8:08 PM
To: Karen Day <karen@elstermcgrady.com>
Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [SubPro-IRT] Re: [Ext] Re: String Similarity and Reserved Names

Hi all, Just coming back from vacation and getting caught up. I'm sorry I wasn't available to discuss in real time last week, but I agree with Mike that there is Option 3 that could be put in play immediately.  In fact,  if you'll look back at the records, I and several others brought this exact option into our first discussion on this topic a couple of weeks ago with Sarmad, but somehow it did not make it into the 2 options presented for the follow-up call.  

 

My position remains that if .RODCROSS is legitimately delegated through the 2026 round, and then Red Cross applies for .REDCROSS in the 2028 round, then the Red Cross organization should be awarded its exact match TLD without regard for  any string similarity issues that would or would not not arise as a result of .RODCROSS having been delegated prior.  I cannot envision, nor did the NGO PDD per my reading of their discussions, that the co-existence of those few protected Red Cross, Olympic or IGO TLDs alongside "similar" TLDs is likely to cause security and/or stability problems in the global DNS.

 

Best,

Karen

 

 

 

 

Karen L. Day DNS Industry Advisor Elster & McGrady LLC   Phone: +1 (984) 335-4067 Email: karen@elstermcgrady.com www.elstermcgrady.com [elstermcgrady.com]

 

 

---

From: Mike Rodenbaugh via SubPro-IRT <subpro-irt@icann.org>
Sent: Friday, September 12, 2025 1:52 PM
To: Katrin Ohlmer | DOTZON GmbH <ohlmer@dotzon.com>
Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [SubPro-IRT] Re: [Ext] Re: String Similarity and Reserved Names

 

I think it can be an option for this Round also.

 

	Mike Rodenbaugh
		Rodenbaugh Law LLC
	email:	mike@rodenbaugh.com
	phone:	+1 (415) 738-8087

 

 

 

On Fri, Sep 12, 2025 at 1:50 PM Katrin Ohlmer | DOTZON GmbH <ohlmer@dotzon.com> wrote:

Hi All,

 

this was exactly my proposal yeserday in the call – to propose initiating a PDP after the next round and determine if/how applications from the reserved names list can be treated differently in terms of string similarity. Lars acklowledged that this is a potential option.

 

Best

Katrin

 

DOTZON GmbH – creating identities
Akazienstrasse 28
10823 Berlin
Deutschland - Germany
Mobile: +49 173 2019240
ohlmer@dotzon.consulting
www.dotzon.consulting [dotzon.consulting]

DOTZON GmbH
Registergericht: Amtsgericht Berlin-Charlottenburg, HRB 118598
Geschäftsführer: Katrin Ohlmer
Sitz der Gesellschaft: Akazienstrasse 28, 10823 Berlin

 

Von: Mike Rodenbaugh via SubPro-IRT <subpro-irt@icann.org>
Gesendet: Freitag, 12. September 2025 19:43
An: Lars Hoffmann <lars.hoffmann@icann.org>
Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Betreff: [SubPro-IRT] Re: [Ext] Re: String Similarity and Reserved Names

 

Lars and all,

 

I think there is an Option #3...  if now or in future the Red Cross or Olympics apply for their exact match protected TLD string, then it shall not be subject to String Similarity Review or SCO. In other words, if they want it then they get it. That can allow other legitimate uses meanwhile to happen, like perhaps .Olympia for the capital of our state of Washington.

 

I was hung up on the process yesterday, and note that Anne or Susan (whoever is the liaison) needs to make an assessment whether there is IRT consensus to bring Staff's two proposed options to Council. There was no effort to gauge that consensus yesterday, but I did speak up that I thought it was a bad idea. Martin today has agreed. Anyway maybe that is premature if my proposed third option is potentially viable, at least for further Staff consideration and IRT discussion.

 

	Mike Rodenbaugh
		Rodenbaugh Law LLC
	email:	mike@rodenbaugh.com
	phone:	+1 (415) 738-8087

 

 

 

On Fri, Sep 12, 2025 at 12:38 PM Lars Hoffmann via SubPro-IRT <subpro-irt@icann.org> wrote:

Thank you, Martin.

 

We put forward the two options because we believe these are the only two ways forward that we identified. We also stated in the paper that we proposed to move forward with Option 2. The IRT did not agree with our proposal. Therefore, there is a disagreement between IRT and staff on the intent of Board-approved recommendations. Moving this to the Council to obtain guidance on the intent of the recommendation seems to be the appropriate next step. I fail to see how this could possibly undo any policy efforts.

 

Best. Lars

 

 

 

From: Martin Sutton <martin@tldz.com>
Date: Friday, 12 September 2025 at 18:07
To: "Jeff@jjnsolutions.com" <jeff@jjnsolutions.com>, Lars Hoffmann <lars.hoffmann@icann.org>
Cc: Juan Manuel Rojas <jumaropi@yahoo.com>, Susan Payne <susan.payne@comlaude.com>, Anne ICANN <anneicanngnso@gmail.com>, Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [Ext] Re: [SubPro-IRT] String Similarity and Reserved Names

 

Hi Lars,

 

Firstly my apologies for not being available for recent calls, I am trying to keep up via the recordings.  

 

Having listened to yesterday’s call, I am surprised by the approach actions in regard to the string similarity assessment for reserved names. Focusing entirely on the process, the IRT was presented with two options by ICANN Org, with many supporting Option 1, backed up with sound reasoning. Despite this, ICANN Org is pushing this aside in favour of Option 2. 

 

Why put options forward for the IRT to consider in the first place, if they are simply overruled by ICANN Org?  This is not good practice.

 

I hope we can avoid such steps in the future, as we can already see in the follow-up emails how lengthy policy efforts can potentially come undone.

 

Best regards,

 

Martin

 

Martin Sutton
Co-Founder, TLDz
martin@tldz.com
+44 (0)7774 556680
Tldz.com [tldz.com]

 

Illumiati Limited. 77 Camden Street Lower, Dublin, D02 XE80

The contents of this email message and any attachments are intended solely for the addressee(s) and may contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the intended recipient of this message or their agent, or if this message has been addressed to you in error, please immediately alert the sender by reply email and then delete this message and any attachments. If you are not the intended recipient, you are hereby notified that any use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.

 

On 12 Sep 2025, at 16:37, Jeff Neuman via SubPro-IRT <subpro-irt@icann.org> wrote:

 

Juan,

 

This was exactly the work that was done in the original IGO/INGO PDP in the 2012-2014 time frame and there was consensus on NOT recognizing INGOs for any special treatment.  In order for any further work to be done (which I would personally oppose as I was involved in that PDP), the appropriate place to raise this is with the GNSO Council and not with the IRT.

 

Sincerely,

 

Jeffrey J. Neuman

Founder & CEO

JJN Solutions, LLC

+1.202.549.5079

Jeff@jjnsolutions.com

---

From: Juan Manuel Rojas via SubPro-IRT <subpro-irt@icann.org>
Sent: Friday, September 12, 2025 11:09 AM
To: Susan Payne <susan.payne@comlaude.com>; Anne ICANN <anneicanngnso@gmail.com>; Lars Hoffmann <lars.hoffmann@icann.org>
Cc: Next Round Policy Implementation via SubPro-IRT <subpro-irt@icann.org>
Subject: [SubPro-IRT] Re: String Similarity and Reserved Names

 

Dear Lars and all, 

I would like to raise some concerns on this topic, as I try to said in the chat of the meeting. This concern is made in my own personal capacity:

The IGO/INGO PDP recommendations provide appropriate protections for a small set of globally recognized organizations — the Red Cross/Red Crescent Movement, the IOC, and IGOs — including:

• Ineligible-for-delegation status for their exact-match names (Section 2.2.1.2.3 of the Applicant Guidebook), and
• Exception procedures for those organizations to apply for their own string at the top level.

While these protections are welcome, they leave out a range of globally recognized INGOs that hold unique positions in civil society and whose names are highly vulnerable to misuse at the top level.

Proposal

1. Create a clear process and criteria to identify INGOs of global significance that merit similar top-level protection.

• Possible criteria:

• Presence in 100+ countries or global scope of operations
• Consultative status with the UN ECOSOC or other intergovernmental bodies
• Evidence of long-standing global brand recognition

2. Include their exact-match strings in Section 2.2.1.2.3 (“Strings Ineligible for Delegation”) to prevent misuse.
3. Offer an exception procedure so that these INGOs, or their authorized affiliates, may apply for and operate their protected TLDs if they wish.

Illustrative Examples

• World Organization of the Scout Movement (WOSM) – Represents over 170 national organizations and millions of youth globally.
• Médecins Sans Frontières / Doctors Without Borders (MSF) – A leading humanitarian organization responding to global crises.
• Amnesty International – Global human rights movement with chapters in more than 70 countries.
• Greenpeace International – International environmental NGO with a highly recognized global identity.

Without protection, strings like .scout, .msf, .amnesty, or .greenpeace could be registered by unrelated parties, causing confusion, reputational harm, and possible exploitation of public trust.

 

JUAN MANUEL ROJAS, M.Sc.

Director - MINKA DIGITAL Colombia

NPOC Chair - NCSG/GNSO

M.Sc. Information Technology

 

Registered Linux User No.533108.

http://www.jmanurojas.com [jmanurojas.com]

 

-----BEGIN GEEK CODE BLOCK-----

Version: 3.1
GIT d- s: a+ C+++ UL P+ L+++ !E !W+++ !N !o K+++ w-- !O M- V PS+ PE-- Y+ PGP+ t+ 5 X++ R tv+ b+ DI D G e+++(+++)>+++ h+ r++ y+
------END GEEK CODE BLOCK------

 

 

                                               

 

 

El viernes, 12 de septiembre de 2025, 09:49:15 a.m. GMT-5, Lars Hoffmann via SubPro-IRT <subpro-irt@icann.org> escribió:

 

 

Dear Anne, dear Susan,

 

I hope this email finds you well. I am reaching out to you in your capacities as Council liaisons to the SubPro IRT. During last night’s IRT discussion, it became clear that ICANN’s proposed implementation regarding string similarity evaluation for reserved names differs from the IRT’s view. Therefore, we are kindly asking you, as Council liaisons, to work with the Council to help us ensure the next round implementation aligns with the wording and intent of all applicable Board-approved recommendations, including those that protect the Red Cross Red Crescent Movement identifiers, the International Olympic Committee Identifiers, and the identifiers of the International Governmental Organizations (see recommendations 3.1.1,  3.1.2, 3.2.1, 3.2.2, 3.3.1, and 3.3.2 of the Final Report on the Protection of IGO and INGO Identifiers in All gTLDs Policy Development Process [gnso.icann.org]).

 

During yesterday’s call, a consensus majority of participating IRT members supported the paper’s Option 1 (attached). I asked the IRT whether anyone on the call agreed with the staff proposal (Option 2). Three IRT members (one orally and two in the chat) said they were supportive of Option 2, some stayed silent and most explicitly supported Option 1.

 

We understand that the SubPro PDP was silent on this issue. And, as these strings were not part of string similarity evaluation in 2012, it is reasonable to assume (and ICANN agrees if it were not for the issues below) that this should not change for the next round. Similarly, the IDN EPDP Phase 1 did not recommend that reserved strings (then referred to as strings ineligible for delegation) are part of string similarity evaluation. So far, no disagreement.

 

However, the 2013 IGO INGO PDP classified the identifiers for the Red Crescent Movements, the International Olympic Committee, as well as the identifiers of the International Governmental Organizations as ‘protected strings’ (see full text of recommendations below and in the attached paper’s annex).

 

It is ICANN’s view that the protection intended by these recommendations would not be met if .rodcross is delegated in the next round and, thus, the Red Cross were not able to obtain its protected .redcross string in future rounds because .redcross is found confusingly similar with the now-delegated .rodcross. To ICANN, the only way to avoid such a scenario, and meet the intent of the IGO INGO recommendations during the next round, is to evaluate string similarity of the applied-for strings not just against other applied-for strings, delegated strings, two-character country codes, and blocked names, but also against the list of reserved names, which is reflected in Option 2 (see attached paper).

 

The consensus view expressed by attending IRT members differed from this, stating that the protection granted in the IGO INGO recommendations only extends to the actual strings not to those that are found confusingly similar to them. Thus, the consensus view of the IRT is to support Option 1. As you know the IRT Principles and Guidelines [itp.cdn.icann.org] note in Section E that in such a case the issue should be referred back to the Council.

 

Therefore, we kindly ask you, at your earliest convenience, to confer with the GNSO Council on how the relevant recommendations should be interpreted. Considering that the implementation draws on recommendations from three different PDPs we believe it would be prudent for the Council to weigh in. I note that during last night’s call, I laid out these steps of reaching out to you as Council liaisons and no one on the call raised concerns about proceeding accordingly.

 

Please, do not hesitate to reach out with any questions or concerns you may have.

Very best. Lars

 

 

 

 

 

Please see the attached paper for an overview of the issues, including both Options and a collation of all relevant recommendations. Below here, I only pasted the relevant recommendations from the IGO INGO PDP.

 

 

Recommendation 3.1.1: 

 

• Top-Level protections of Exact Match, Full Name Scope 1 identifiers of the Red Cross Red Crescent Movement are placed in the Applicant Guidebook section 2.2.1.2.3, Strings “Ineligible for Delegation”.

 

Recommendation 3.1.2: 

 

• For Red Cross Red Crescent Movement 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.

Recommendation 3.2.1: 

 

• Top-Level protections of Exact Match, Full Name Scope 1 identifiers of the International Olympic Committee are placed in the Applicant Guidebook section 2.2.1.2.3, Strings “Ineligible for Delegation”.

 

Recommendation 3.2.2: 

 

• For International Olympic Committee 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.

 

Recommendation 3.3.1: 

 

• Top-Level protections of Exact Match, Full Name Scope 1 identifiers of the International Governmental Organizations are placed in the Applicant Guidebook section 2.2.1.2.3, Strings “Ineligible for Delegation”.

 

Recommendation 3.3.2: 

 

• For International Governmental Organizations 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.

 

_______________________________________________
SubPro-IRT mailing list -- subpro-irt@icann.org
To unsubscribe send an email to subpro-irt-leave@icann.org

_______________________________________________
By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.

_______________________________________________
SubPro-IRT mailing list -- subpro-irt@icann.org
To unsubscribe send an email to subpro-irt-leave@icann.org

_______________________________________________
By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.

 

_______________________________________________
SubPro-IRT mailing list -- subpro-irt@icann.org
To unsubscribe send an email to subpro-irt-leave@icann.org

_______________________________________________
By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.

This email originated from outside the firm. Please use caution.

_______________________________________________
SubPro-IRT mailing list -- subpro-irt@icann.org
To unsubscribe send an email to subpro-irt-leave@icann.org

_______________________________________________
By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.