[Comments-gtld-subsequent-procedures-initial-03jul18] LACTLD Comment on Initial Report on the New gTLD Subsequent Procedures PDP (Overarching Issues & WT 1-4)

[Miguel Ignacio Estrada]

To Whom It May Concern,

The Latin American and the Caribbean ccTLD Organization (LACTLD), is a
nonprofit association created on August 20th, 1998 in Buenos Aires,
Argentina, during the International Forum on the White Paper (IFWP).
LACTLD’s vision is to to be the regional organization that represents the
interests and promotes the development of the ccTLDs in Latin America and
the Caribbean. Following, is LACTLD’s input with respect to the Initial
Report of the New gTLD Subsequent Procedures Policy Development Process
Working Group, which is chartered to evaluate what changes or additions
need to be made to existing new gTLD policy recommendations and includes
materials from the full Working Group and four sub-teams within the Working
Group, Work Tracks 1-4.

In reference to the Initial Report following questions: “2.7.1.e.2: If
there are no technical obstacles to the use of 2-character strings at the
top level consisting of one letter and one digit (or digits more
generally), should the reservation of those strings be removed? Why or why
not? Do you believe that any additional analysis is needed to ensure that
these types of strings will not pose harm or risk to security and
stability? Please explain.”

LACTLD states that:

1.  In order to assess if there are no technical obstacles to the use of
2-character stings at the top level consisting of one letter and one digit,
this

question should be addressed by DNS technical experts (such as ICANN’s
Security and Stability Advisory Committee (SSAC)).

2. In reference to the question: If there are no technical obstacles to the
use of two-character strings consisting of one letter and one digit, should
they be permitted to be registered in future gTLD string application
rounds?, LACTLD believes that two-character strings consisting of one
letter and one digit should NOT be permitted to be registered in future
gTLD applications for the following reasons:

a. Two-character top-level domains are firmly associated with country-code
Top Level domains; ccTLDs are created by IANA/PTI from two character codes
laid down in ISO 3166-1

– ccTLDs have an entirely different policy background to gTLDs. It is
entirely foreseeable that the ISO Maintenance Agency could, in the future,
decide to issue two character country codes including digits, as the ITU
already has done: see Appendix 2 to ITU Radio Regulations (e.g., ‘4X’ for
Israel, ‘2’ for the UK).


b. Homographic issues:

Homographic issues were not addressed by the GNSO.

Homographic issues pose a direct threat to the security and stability of
the Internet’s system of unique identifiers, including ccTLDs that might be
caught up in them; some examples are:

.ci -> .c1

.cl -> .c1

.co -> .c0

.do -> .d0

.nl -> .n1

.is -> .1s

.ls -> .1s

With sans-serif typefaces, there is considerable risk for consumer
confusion and consequent security risks, including phishing attacks.

ICANN’s core mission is “…to coordinate the stable operation of the
Internet's unique identifier systems.”. The introduction of
homonym-conflicted two-character top-level domains would be in direct
conflict with that core mission.

The GNSO’s proposal would introduce instability to the DNS via visual
confusion of strings.

3. In reference to the questions :

Is additional analysis needed to ensure that the introduction of
two-character strings consisting of one letter and one digit will not cause
harm or risk to the security and stability of the DNS?

LACTLD states that as per Question 1, this must be addressed by DNS
Technical Experts, such as the Security and Stability Advisory Committee
(SSAC).

In conclusion, LACTLD believes that the technical questions asked by the
GNSO Working Group need to be addressed and answered by relevant technical
bodies, two-character strings, consisting of one letter and one digit, or
two digits, should unequivocally not ever be permitted in future gTLD
application rounds because of the conflict with ccTLD allocation policy and
ISO two-character codes (which are external to ICANN), as well as the
homographic issues discussed above.

-- 
*Miguel Ignacio Estrada*
General Manager
LACTLD
+598 2 604 22 22
www.lactld.org
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