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<https://urldefense.com/v3/__https:/icann-community.atlassian.net/wiki/x/AQB3...>, 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<https://gnso.icann.org/sites/default/files/filefield_42639/igo-ingo-final-10...>). 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<https://itp.cdn.icann.org/en/files/consensus-policy-implementation/irt-princ...> 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.