Hi Elisa and Sarmad, Thanks for summarising the issue and offering two potential solutions. However, I disagree with ICANN's conclusion that we should adopt option 2, as that would be creating new policy. Option 2 proposes to: * In the case of contention between an IGO/RC/IOC applicant and a non-IGO/RC/IOC applicant, give priority to the IGO/RC/IOC applicant. This would create an entirely new method of priority for resolving contention. * Include the Reserved Names list strings in the standard string similarity review performed by the ICANN evaluators. This is a reversal of the policy from the 2012 round, when Strings Ineligible for Delegation (as Reserved Names were known at the time) were explicitly excluded from the string similarity review. The paper asserts that "...based on remaining recommendations in SubPro and IDN EPDP Phase 1, ICANN proposes to move forward with option 2...". However, I don't believe there are any policy recommendations in either SubPro or the IDN EPDP Phase 1 which allow for either of the above rules. The original policy from the 2012 round AGB states in section 2.2.1.2.3 that: "the following [strings ineligible for delegation] names are prohibited from delegation as gTLDs in the initial application round. Future application rounds may differ according to consideration of further policy advice. These names are not being placed on the Top-Level Reserved Names List, and thus are not part of the string similarity review conducted for names on that list." The SubPro final report affirmed the continuation of the 2012 rules on this topic in Affirmation 24.2: "...the Working Group affirms the standard used in the String Similarity Review from the 2012 round to determine whether an applied-for string is "similar" to any existing TLD, any other applied-for strings, Reserved Names, and in the case of 2-character IDNs, any single character or any 2-character ASCII string." Note it does not list "strings ineligible for delegation" (i.e. the IGO/RC/IOC names) as a type of string subject to string similarity review. Similarly, section 4.4.1 of the IDN EPDP phase 1 report is clear on the types of name which are subject to string similarity review and "strings ineligible for delegation" are not among them: "If an applied-for primary gTLD string or any of its variant label(s) is confusingly similar to an existing gTLD, an existing ccTLD, a New gTLD Program Reserved Name*, a two-character ASCII string, or any of the variant label(s) of the aforementioned categories of strings, the entire variant label set of the applied-for primary gTLD string will be ineligible to proceed in the application process." Thus, implementing the two above rules proposed by option 2 would be creating new policy, which is not the job of the IRT. Whereas option 2 would create new policy, the path outlined in option 1 is consistent with existing policy. Therefore, option 1 is the only viable option outlined in your paper. Please note that both the SubPro and EPDP final reports use the old definition of "Reserved Names", which is a little confusing. In those reports, the relevant term to describe the IOC/RC/IOC names is "strings ineligible for delegation". For clarity and completeness you may want to make this clear in the annex of your paper. * Definitions of New gTLD Program Reserved Names and Strings Ineligible for Delegation, used by the IDN EPDP per their Final Report: * New gTLD Program Reserved Name: A string that is reserved to maintain the exclusive rights to the names of ICANN, its bodies, or essential related functions of ICANN and IANA. For a full list of New gTLD Program Reserved Names, see Section 2.2.1.2.1 of the 2012 Applicant Guidebook. In addition, the SubPro PDP recommended adding "PTI" to the New gTLD Program Reserved Names list. * String Ineligible for Delegation: A string that is ineligible for delegation in order to provide special protections at the top-level and second-level for the names and acronyms of intergovernmental organizations (IGOs) and international non-governmental organizations (INGOs) which receive protections under treaties and statutes across multiple jurisdictions. Those organizations specifically include the Red Cross/Red Crescent Movement (RCRC) and the International Olympic Committee (IOC). I hope that makes sense. Please shout if anything in my explanation is unclear. Kind regards, Ashley Ashley Roberts Head of New TLD Consultancy Com Laude T +44 (0) 20 7421 8250 Ext 264 [cid:image001.png@01DC20EA.26D71C20] <https://comlaude.com/> Follow us on LinkedIn<https://t-uk.xink.io/Tracking/Index/pRkAAGVfAADD_RQA0> and YouTube<https://t-uk.xink.io/Tracking/Index/bhkAAGVfAADD_RQA0> From: Elisa Busetto via SubPro-IRT <subpro-irt@icann.org> Sent: 05 September 2025 12:10 To: subpro-irt@icann.org Subject: [SubPro-IRT] String Similarity Assessment of Reserved Names Hello IRT, We have just published a paper concerning the String Similarity Assessment of Reserved Names on the wiki page of meeting #158a: https://icann-community.atlassian.net/wiki/x/AQB3Gw Sarmad will go through it during the call, but it would be appreciated if you could already review it and provide any input you may have on list. Many thanks, Elisa ________________________________ The contents of this email and any attachments are confidential to the intended recipient. 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