[twochar_comments] creditcard, credit, cool, contractors, construction, condos, computer, company, community, coffee, codes, clothing, clinic, cleaning, claims, city, church, cheap, center, catering, cash, careers, care, cards, capital, camp, camera, cab, business, builders, boutique, bike, bargains, associates, agency, accountants, academy, tirol, hamburg, google, globo, frl

Ziegie Willemse willemsez at gmail.com
Tue Mar 24 19:02:15 UTC 2015


*RESPONSE TO APPLICATIONS TO AUTHORIZE TWO-CHARACTER (LETTER-LETTER)
DOMAINS AT THE SECOND LEVEL BY GAC REPRESENTATIVE OF THE REPUBLIC OF
NAMIBIA: 25 MARCH 2015*



   1. We hereby respectfully submit an objection to release of  “na” with
   names in the subject line for its registration by the registry operators of
   the TLDs. We further request clarification from ICANN regarding the
   implementation of Specification 5 of the current Registry Agreement
   preventing all two-character ASCII labels from registration or allocation
   to a registry operator at the second level within the TLD. However, such
   two-character label strings may be released to the extent that the registry
   operator *reaches agreement with the relevant government and country
   code manager* of the string as specified in the ISO 3166-1 alpha-2
   standard (my emphasis added).
   2. NA is the country code for Namibia and the names in the subject
   line are new gTLDs generally within category 1 of GAC safeguards, as per
   the Beijing meeting of March 2013.
   3. Save for an agreement between the involved Registry Operators and the
   Namibian Government, through facilitation by the designated government
   representative accredited to the GAC, the “na” with names in the subject
   line must remain reserved until assigned to a person or entity proposed,
   supported or accepted by the Namibian Government and the ccTLD manager for
   “na”.
   4. The objection and request for clarification are necessitated based on
   the following considerations:
      1. A national policy on the matter is due to be revised to address
      changes and advances in the Namibian DNS arrangements, which may require
      such reservations.
      2. The Namibian Government enacted national legislation on the
      operation and management of the “na’ name and these are subject to
      revision, including ongoing consultations to develop a Namibian solution
      for the mandate to administer the “na” name.
      3. The Namibian Government and wider internet community have limited
      understanding and appreciation for the two-character ASCII labels
      authorization process and need urgent and effective capacity building in
      this critical area from ICANN.
      4. This would allow us to avoid third parties using the name “na” for
      the wrong reasons and in a way that could negatively affect the Namibian
      internet community and the Government of Namibia.
   5. Finally, the application form makes it utterly convenient and easy
   for applicants to select “All letter/ letter two-character ASCII labels”
   instead of compiling …“Appendix A by removing all labels that you do
   *NOT* wish to request.”, despite the fact than they may or may not have
   an interest in certain two-letter character names.  Thus, it should
   similarly be made more convenient for Governments to object in a more
   simpler, straightforward and collective way than to scrutinize each and
   every application and comment on each and every application. The process
   lends itself to acquiescence by omission to a sometimes undesirable
   outcome.
   6. We shall appreciate being informed of the decision taken in regards
   to our request and objection.



Kind regards,



Henri Jacob Kassen

Director for ICT Development

Ministry of ICT, Government of Namibia
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