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 -----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<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. _______________________________________________ SubPro-IRT mailing list -- subpro-irt@icann.org<mailto:subpro-irt@icann.org> To unsubscribe send an email to subpro-irt-leave@icann.org<mailto: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). 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