[Ctn-crosscom] Updated StrawWoman Proposal on 3-character codes

Tue Apr 26 11:25:18 UTC 2016

Dear Alexander,

I have followed the discussion with interest. First let me say, you guys have done a terrific job with .berlin – many times it must have felt like the never ending story. It was a really good idea creating cityTLDs. The regime for them according to the AGB - which we must view as present policy as long as there hasn’t been decided otherwise – established this rule:

2.2.1.4.2

Geographic Names Requiring Government Support

The following types of applied-for strings are considered geographic names and must be accompanied by documentation of support or non-objection from the relevant governments or public authorities:

  1.  An application for any string that is a representation, in any language, of the capital city name of any country or territory listed in the ISO 3166-1 standard.

  2.  An application for a city name, where the applicant declares that it intends to use the gTLD for purposes associated with the city name.

I read your input in such way that you think that the same rules could be applied for 3-letter codes? You even seem to imply that the respective ccTLD operator should have a say.

I have a few questions regarding how you think that ISO 3166-3 letter codes should be applied in the future. I see that your plan is to establish them as 3-letter gTLDs. At the same time you write that they will be marketed as alternative to the corresponding ccTLD.
The will mean that a country will have one 2-letter code following local rules and local law and another 3-letter code following global law, read ICANN rules. Don’t you think that this might lead to confusion for the user?

If you take a look at my comments to the “Straw Man (Woman) Paper on 3-letter codes” you will see that I have serious doubts about the practicality of the “Starting point for Possible Framework”.  It would be useful if you could go through the document and comment directly there as well as your interesting thoughts in this mail exchange.

As you also see from the comments from Panos, I think it is unthinkable to avoid political interest from governments in this question. As he says, a government’s duty is to serve public interest first.

Kind regards,

Annebeth

Annebeth B. Lange
Special Adviser International Policy
UNINETT Norid AS
P.O.Box 6979 St. Olavs plass
NO-0130 Oslo

annebeth.lange at uninett.no<mailto:annebeth.lange at uninett.no>
Mobile: +47 959 11 559

From: <ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org>> on behalf of Alexander Schubert <alexander at schubert.berlin<mailto:alexander at schubert.berlin>>
Reply-To: "alexander at schubert.berlin<mailto:alexander at schubert.berlin>" <alexander at schubert.berlin<mailto:alexander at schubert.berlin>>
Date: Monday 25 April 2016 01:12
To: "ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>" <ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>>
Subject: Re: [Ctn-crosscom] Updated StrawWoman Proposal on 3-character codes

Dear Panos,

Thanks for your extensive and thoughtful response! You write:

Your case is interesting, but from your words is already implied that it's an ”edge case".
Well. “.berlin” in 2005 was perceived as “edge case” as well – now we have already 35 city gTLD’s and in the 2nd round some several hundred will follow. We actually had to lobby A LOT to convince the relevant ICANN circles that city-TLD’s aren’t the end of the world.

I just do not understand why we want to DENY Governments to create a certain TLD if they choose to. Why we would DENY a cTLD registry to market a TLD for WHATEVER purpose – would they chose to. To protect whom? That Government and this ccTLD operator? We protect them from themselves? We can create whatever rule we want – Governments and ccTLD operators should have the power to overrule them if THEY WANT.

Thanks,

Alexander.berlin

From: ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org> [mailto:ctn-crosscom-bounces at icann.org] On Behalf Of Panagiotis Papaspiliopoulos
Sent: Sunday, April 24, 2016 1:47 AM
To: ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>
Subject: Re: [Ctn-crosscom] Updated StrawWoman Proposal on 3-character codes

Dear Alexander,

Your case is interesting, but from your words is already implied that it's an "edge case". However, generally speaking, I believe that a PDP should guarantee that we have a stable and at the same time fertile environment that, at the same time, will prevent the creation of problems as much as possible. So, I think the safest solution is to have the ISO list protected and an Early Warning System activated.

Let me give you an example:

1. Greece has two ccTLDs: .gr (Latin, i.e. the ISO3166-1 alpha-2 code) and .ελ (IDN - live hopefully soon). Both of them are run by the same Registry in order to have policies implemented to avoid confusability issues, as well as trademark issues.

2. Someone is asking for .GRC (i.e. the ISO3166-1 alpha-3 code) for a new ccTLD. He has to have a letter of support from the Greek government. Let's think... who is this guy?

    2.1 Is the applicant someone that is a total stranger to the Greek government? Yes -> do we like him? If no, end of story / if yes -> so, we give him a letter of support. We can also be proud that we are in favour of the competition in the ccTLD market of Greece! We also take money for selling a "licence" to a new company that wants to operate in the Greek domain market! But it is also our duty to protect citizens and businesses from any kind of confusion. Do we really want to create customers just by registering their brand names and trademarks to another TLD? Too much mess, too much noise, not stable environment, too many complaints, too difficult to draw back...

    2.2 Is the applicant someone that is a total stranger to the Greek government? No -> so, it has taken government's support from the very beginning. That means that the government has taken into consideration all the above. It also adds a third ccTLD in the Greek domain market and creates even more competition! Is the government ready to take this risk? What is there to gain apart from an amount of money for selling a "licence" to another company operating in the Greek domain name market? However, this market is not at all similar to the mobile operators' market and, surely, the profit limit is in a different (much lower) level than the one in mobile operator's market, while the cons are too many, as described in 2.1 before...

3. Someone is asking for .GRC (i.e. the ISO3166-1 alpha-3 code) for a new gTLD. He doesn't need a letter of support because it's not a ccTLD, but... oops! this ISO code has been assigned to Greece! It's good that we have the Early Warning System to notify us! Even if we say that in the previous occasion (i.e. .GRC as a new ccTLD) the Greek government would take some money for selling a new "licence", in this case (Alexander's "edge case") there is no profit for the government at all, while, at the same time, it is government's duty to protect the interest of the local community and to do everything possible to avoid at least user confusion. And, above all, who is this guy that will use a 3-letter code that indicates Greece? Is a good guy or a bad guy? And what if now it's a good guy, but in the future will sell .GRC to a bad guy for any reason? No, not at all, this is a kind of risk that no government will ever take! Can you imagine .USA run by a north-korean company as a gTLD? I cannot!

4.1 Someone is asking for .GRE (or .ELL) for a new ccTLD -> he needs a letter of support form the Greek government. Go to No.2 :)

4.2 Someone is asking for .GRE (or .ELL) for a new gTLD -> he doesn't legally need a letter of support, BUT, unfortunately, this 3-letter code has been used globally in order to indicate Greek athletes and even the Greek National Team in almost every sport! Again, thanks God that we have the Early Warning System to notify us! If for any reason we are convinced that .ELL (for example) can be used without causing user confusion or any other problem, then we might come into some kind of agreement with the applicant. But we are clear from the begining: a government's duty is to serve public interest first!

5.1 Someone is asking for .HELLAS (transliteration of the name of the country from the Greek) for a new ccTLD -> he needs a letter of support form the Greek government. Go to No.2 :)

5.2 Someone is asking for .HELLAS for a new gTLD -> Can he easily take it, because it's a larger-than-3-character string? -> Again, thanks God that we have the Early Warning System to notify us! Depending the string, we may or may not come into some negotiations with the applicant, but, as mentioned before, a government's duty is to serve public interest first!

Finally, I would like to wish to all of our colleagues Happy Easter (the Greek-Orthodox Easter is on 1st May)! For this reason I'm taking some days off and I will be happy to discuss further with you during our conference call.

Best regards,

Panos

PS. Lars, can you please confirm the acceptance of the email? Thank you in advance!

---

Panagiotis Papaspiliopoulos

Accredited Representative of Greece to the GAC of ICANN

Senior Policy Advisor - Telecommunications Expert

Hellenic Ministry of Infrastructure, Transport & Networks

General Secretariat of Telecommunications & Post

General Directorate of Telecommunications & Post

tel: +30 210 650 8538

fax: +30 210 650 8533

email: p.papaspil[at]yme.gov.gr

On 23/04/2016 21:40, Carlos Raúl Gutiérrez G. wrote:

Dear Alexander

my comments inline and welcome to participate actively in the group!!!!

Carlos Raúl Gutiérrez

+506 8837 7176

Skype: carlos.raulg

Current UTC offset: -6.00 (Costa Rica)

On 23 Apr 2016, at 12:06, Alexander Schubert wrote:
Dear All, I have been following this group for quite some while but remained obviously silent. I have been engaged in geo-gTLD’s since November 2004; when Dirk and me started “.berlin”. I have also founded an applicant that went for a three letter new gTLD (the community applicant for .gay). I am planning to create a true community multi stakeholder applicant for a three letter gTLD based on an ISO 3166 III code in the 2nd round;

In that case I strongly encourage you to support a definitive

pdp-process on the use of country and territory names based on ISO that

may or may not support your idea but make it mandatory for any

subsequent round. So far this is only a CWG exercise, and the draft text

shows that for the time being it is not possible to preclude any of the

ideas submitted so far to the Team about using 3-letter codes or not,

because we are far from any consensus (other that developing a true

policy process from my personal perspective).
and write here in that capacity. Reading your thoughts I can say that that string: * WILL be marketed as alternative to the corresponding ccTLD! And there is absolutely ZERO reason to deny

Who would deny?
such use, if: o The respective ccTLD operator is the RSP for the new string and

the previous ccNSO working group could have come to that conclusion, but

to the best of my knowledge they didn´t.
o Hence agrees into creating its own “competition”

The Swiss authorities did it to some degree by not allowing .ch to run

.swiss, but that was their own innovation without the need of any new

policy and .swiss is longer than 3 letters……..sometimes the DNS is

also about innovation.
o The relevant Government authorities agree in such usage as well

which relevant Gov Auth.??
I think the litmus test is: What if a nation WANTS another TLD?

another TLD or another ccTLD?
What if UK said they want .eng Domains (no, I am not building a .eng) – and they WANT them in direct competition with .uk?

not sure if eng is a 3 letter code under ISO………
Who are we to deny them their wish?

So far, only the applicants guidebook of the last round
Why not simply assigning the same principles as for geo-TLD’s: If the relevant Government authorities agree – then obviously they want it. Why would we DENY them that string? Same with the ccTLD competition: If the ccTLD operator is in agreement (e.g. because they are the RSP for the new string or for whatever other reason) why not allowing them to market it as “competition”?

nice idea for the ccNSO
Would a double opt-in by Government AND the ccTLD operator ease the concerns?

possible, if the local jurisdiction make such a deal possible. But

again, outside the realm of ICANN
Does the GAC even REALIZE that the “perceived protection” amounts to restriction in the end?

GAC has its own WG on Geographic names. You could ask them
Sincerely yours,

Recommended reading on the previous work by the ccNSO

http://ccnso.icann.org/workinggroups/unct-framework-charter-27mar14-en.pdf

http://ccnso.icann.org/workinggroups/ccwg-ctn-progress-23sep14-en.pdf

Recommended reading on the objectives of this ccNSO-GNSO CWgroup

https://community.icann.org/pages/viewpage.action?pageId=48346463
Alexander.berlin

Cheers

Carlos Raul Gutierrez
From: ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org> [mailto:ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org>] On Behalf Of Lars Hoffmann Sent: Saturday, April 23, 2016 5:32 PM To: ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org> Subject: [Ctn-crosscom] FW: Updated StrawWoman Proposal on 3-character codes Der all, Here is Colin’s document for those who did not receive it. Best. Lars From: Colin O'Brien <colin at PartridgePartnersPC.com<mailto:colin at PartridgePartnersPC.com> <mailto:colin at PartridgePartnersPC.com<mailto:colin at PartridgePartnersPC.com>> > Date: Thursday 21 April 2016 at 14:19 To: Lars HOFFMANN <lars.hoffmann at icann.org<mailto:lars.hoffmann at icann.org> <mailto:lars.hoffmann at icann.org<mailto:lars.hoffmann at icann.org>> >, "ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org> <mailto:ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>> " <ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org> <mailto:ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>> > Subject: RE: Updated StrawWoman Proposal on 3-character codes Hello Lars, Please find attached my comments and edits. Cordially, Colin From: ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org> <mailto:ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org>> [mailto:ctn-crosscom-bounces at icann.org<mailto:ctn-crosscom-bounces at icann.org>] On Behalf Of Lars Hoffmann Sent: Thursday, April 14, 2016 1:35 PM To: ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org> <mailto:ctn-crosscom at icann.org<mailto:ctn-crosscom at icann.org>> Subject: [Ctn-crosscom] Updated StrawWoman Proposal on 3-character codes Dear all, Please find attached the updated version of the StrawWoman on 30-chacter codes. The document contains redlined comments from Annebeth, Panos, Ørnulf, and Jaap. If you have any comments please use the attached documents and add them via track-changes and submit back to the list or forward just to me. I will collate all comments and redistribute a master document prior to our next call. Speaking of … due to scheduling issues, the co-Chairs have decided to move the next call to Monday 2 May 2016, time TBD. Best wishes, Lars ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ _______________________________________________ Ctn-crosscom mailing list Ctn-crosscom at icann.org<mailto:Ctn-crosscom at icann.org> https://mm.icann.org/mailman/listinfo/ctn-crosscom

_______________________________________________

Ctn-crosscom mailing list

Ctn-crosscom at icann.org<mailto:Ctn-crosscom at icann.org>

https://mm.icann.org/mailman/listinfo/ctn-crosscom
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/ctn-crosscom/attachments/20160426/5cc99bd5/attachment-0001.html>