Public comment on use of names of countries and territories as TLDs

[Timo Võhmar]

Hi

I would like to emphasize some points that are not present in these papers
regarding the reasoning why especially 3 letter ISO country codes should be
released as ccTLDs.

*Basis for ISO3166 Alpha-3 as ccTLD:* TLDs are part of the foundation of
the Internet. Internet is part of the world, so I think that direct
conflict between these two counterparts should be avoided. In the real
world the 3 letter codes are used in everyday life to represent certain
country, these codes are used on documents, car number plates, sports
broadcasts and thus have very strong relation to a country. Lets take USA
as an example. So avoiding this conflict and confusion is basis on its own
to keep country names and country codes from being released as generics for
general use. This point is clearly supported by ICANNs decision to keep
these strings from being released during the first round of new gTLDs (New
gTLD Applicant Guidebook 2012 chapter 2.2.1.4.1 treatment of country or
territory names) by defining what is considered as a country representation.

*.com is not a precedent* that changes USA, RUS, FRA or EST from being
associated with certain countries and the three letter labels from being
used internationally to mark that specific country. .com is one of the
first TLDs in the Internet and for majority of people stands for commercial
or companies or even international. It is truly sad that Comoros cannot
protect their interests that might be associated with this 3 letter ISO
3166 Alpha-3 country code, but this does not change anything for the
countries that have strong relation, widely known and recognized
association with their country codes and are still able to protect their
interests and sovereign right to these unreleased strings.

*gTLD space was built on 3-character codes - not entirely true.* gTLD space
was initially build on closed list of 5 TLDs that happened to be all 3
letters long (RFC920 1984). The list has been extended through out the
years with strings of various lengths. The closed list principle has been
in place from the beginning and was broken on 2012 (22 gTLDs in the list at
the time) by introduction of new gTLD program. So I see no reason why
extending the 2 letter ccTLD principle should be seen or handled any
differently than in case of dropping the limit in gTLDs case.

*Confusing internet users with introduction of ccTLDs longer than 2
characters:* Average internet user does not know and care about ccTLD and
gTLD classification. What matters for internet users is what the TLD stands
for and represent in their mind - so yet again com for international, .shop
for shopping, .me for myself, .info for information, .tv for television,
.eu for Europe, .ca for Canada etc. Domain registrants also care for what
the TLD represents for their target group and how to register their domain
under the TLD they are interested in. So this here is only a matter of
policy making concerning a limited group of interested parties (registries,
countries and companies interested to acquire a delegation for some TLD to
use in their business interests). In case of gTLDs the policy is set by
ICANN and in case of ccTLDs by local governments. That is the key for
countries - do they have full and sovereign control over the use of codes
and labels that represent their countries.

*Disclaimer:* I represent ccTLD of Estonia and Estonian interests in this
matter. Estonia is interested in protecting and use of ISO 3166 alpha-3
code .est.

Best Regards,

Timo Võhmar
Estonian Internet Foundation
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