[Note: Including the SubPro IRT in this reply for transparency, as this information could be helpful to others] Dear Ashley, Thank you for your questions. We appreciate the opportunity to clarify how the new definitions of "Reserved Names" and "Blocked Names" interact with string similarity rules under the updated Applicant Guidebook. Reserved Names and Blocked Names Redefined: As you’ve noted, the terminology has been adjusted from the 2012 Guidebook. Specifically: * In the 2012 Applicant Guidebook, what was termed the “Strings Ineligible for Delegation” is now referred to as the Reserved Names List. * The list previously called the “Top-Level Reserved Names List” is now referred to as the Blocked Names List. In the most recent version of the Blocked and Reserved Names AGB draft<https://community.icann.org/download/attachments/315490346/EXT_2024-09-05_Updated_Topic%2021_Blocked%20and%20Reserved%20Names.pdf?version=1&modificationDate=1725546284000&api=v2> which you find on the IRT Community Wiki<https://community.icann.org/display/SPIR>, you can see the clarifying language we’ve added. It states: “Note: In the 2012 Applicant Guidebook, the list called “Strings Ineligible for Delegation” is now referred to as the Reserved Names List, and the list previously called the “Top-Level Reserved Names List” is now known as the Blocked Names List.” In response to the questions in your email, the string similarity rules apply to all Reserved Names and Blocked Names listed in the table in the current AGB document. This means that: * Any applied-for gTLD string, or any of its variant strings, will not proceed if it is found to be similar to any name in the Reserved Names List or Blocked Names List. * However, there is an exception as noted in the draft String Similarity Review AGB language<https://community.icann.org/display/SPIR/1.+Working+Documents?preview=/315490346/359432209/EXT_Topic%2024_String%20Similarity%20Evaluations_2024-07-17.pdf>: “If the applied-for gTLD string is a variant of a Reserved Name and the applicant is the Reserved Name entity itself, then the application can proceed with the evaluation as a variant gTLD of that Reserved Name.” As noted on the table, the only strings that are Reserved Names in the Next Round are Limited International IGO INGOs. * As a reminder, the variant of reserved name can only be applied for if the actual reserved name string is also applied for. Language in the draft IDN AGB language<https://community.icann.org/display/SPIR/1.+Working+Documents?preview=/315490346/363069665/EXT_Topic%2025_IDNs_Proposed%20AGB%20language_2024-07-24.pdf> states: “An application for an allocatable variant gTLD cannot precede an application for its primary IDN gTLD.” I hope this clarifies how the terms "Reserved Name" and "Blocked Name" are now used in the AGB and confirms the scope of string similarity evaluation for all names included in these lists. Please don’t hesitate to reach out if you have further questions or if there’s anything more we can assist with. Thank you! Best, Michael Original email: From: Ashley Roberts <ashley.roberts@comlaude.com<mailto:ashley.roberts@comlaude.com>> Date: Wednesday, 30 October 2024 at 11:23 To: Lars Hoffmann <lars.hoffmann@icann.org<mailto:lars.hoffmann@icann.org>> Subject: [Ext] Reserved Names List Dear Lars, We are already speaking to clients that are exploring applying for a TLD in the next round so we are beginning to carry out due diligence on the strings they are interested in. In going through the new string similarity rules it wasn’t clear to me what comprised the Reserved Names list referenced in point 6 on page 3 [itp.cdn.icann.org]<https://urldefense.com/v3/__https:/itp.cdn.icann.org/en/files/policy-development/agb-string-similarity-topic24-10-09-2024-en.pdf__;!!PtGJab4!4gFLQnHfBUnOwhflagc7rmn6rz-2YpzDrtVejXsKNPfrpthJuCMcMlW6yrPaOvpxKvDbY7x_GdQBayIM_ncKQMRM4UtLCqsGZL3T$> of the rules so I wonder if you can please clarify? In the 2012 round the only Reserved Names which were subject to string similarity (as opposed to exact match blocking) were those on the ICANN reserved list, which consisted of 34 strings (see page 60 [newgtlds.icann.org]<https://urldefense.com/v3/__https:/newgtlds.icann.org/sites/default/files/guidebook-full-04jun12-en.pdf__;!!PtGJab4!4gFLQnHfBUnOwhflagc7rmn6rz-2YpzDrtVejXsKNPfrpthJuCMcMlW6yrPaOvpxKvDbY7x_GdQBayIM_ncKQMRM4UtLChQc5bQP$>). Other categories of term were blocked from application but were not subject to string similarity. This included country names, IOC and RC names, and 3 letter country codes. So something like FRANCE was blocked from registration but anything confusingly similar to that was fine. Under the new AGB language it seems as though what were termed “reserved names” and “blocked names” in 2012 have been re-categorised. According to the table in this AGB section [itp.cdn.icann.org]<https://urldefense.com/v3/__https:/itp.cdn.icann.org/en/files/generic-names-supporting-organization-council-gnso-council/reserved-blocked-names-topic-21-01-02-2024-en.pdf__;!!PtGJab4!4gFLQnHfBUnOwhflagc7rmn6rz-2YpzDrtVejXsKNPfrpthJuCMcMlW6yrPaOvpxKvDbY7x_GdQBayIM_ncKQMRM4UtLCsPe1x_W$>, the only terms which are Reserved Names are the IOC/RC/IGO names; everything else is considered a Blocked Name. Based on this categorisation, that would mean the only “reserved names” that are subject to string similarity are the IOC/RC/IGO names. However, that doesn’t seem right. Alternatively, if I assume all Reserved Names and Blocked Names in the table are subject to string similarity that would include country names and 3 letter country codes in that review, which also doesn’t seem right. This is making me wonder if there is an inconsistency with the use of the terms “reserved name” and “blocked name” across these different sections of the AGB. Can I ask you to kindly clarify: * Whether all categories in this table [itp.cdn.icann.org]<https://urldefense.com/v3/__https:/itp.cdn.icann.org/en/files/generic-names-supporting-organization-council-gnso-council/reserved-blocked-names-topic-21-01-02-2024-en.pdf__;!!PtGJab4!4gFLQnHfBUnOwhflagc7rmn6rz-2YpzDrtVejXsKNPfrpthJuCMcMlW6yrPaOvpxKvDbY7x_GdQBayIM_ncKQMRM4UtLCsPe1x_W$> are subject to string similarity rules, or * Whether only some of the categories in the table are subject to string similarity rules (and if so, which categories) Apologies that I didn’t pick this up during the recent public comment period. 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