[Comments-gtld-subsequent-procedures-initial-03jul18] ICANN New gTLD Subsequent Procedures PDP Working Group

[Dr Eberhard W Lisse]

On behalf of the Namibian Network Information Center (Pty) Ltd, the
ccTLD Manager for .NA, I wish to comment as follows:

1) Using 2 alphanumeric codes other than those associated with the
   widely used ISO 3166 code is a bad idea as it will lead to confusion.

   For example the string .5A has the dubious honor of being able to be
   confused both with .ZA and .SA,

   Or .N7 could easily be confused with .NZ, in particular to the
   proximity of the 7 and Z on the US keyboard.

   .NZ can already be confused with .NA due to the proximity of the Z
   and A on the QWERTY keyboard, which (German speaking) users of QWERTZ
   do not appreciate immediately, as can 0 and O and so can 1, l and I.

   Handwritten links or addresses generate even more possibilities.

2) In the future the ISO may even decide to use and assign alpha-2 codes
   containing numerals.

3) Such confusion is not new, there are IDN strings which can cause
   similar issues, never mind this being used already in phishing

4) There is no need for doing this, since there are an infinite number
   of possiboe Top Level Domain names with 4 or more characters.

5) (Changes in) ICANN policy affecting the ccTLDs must be developed by
   the ccNSO.

6) RFC 1591 is clear about 2 letter Top Level Domain names.

   We are not opposed to doing away with that RFC.

greetings, el

-- 
Dr Eberhard W Lisse
Managing Director
Namibian Network Information Center (Pty) Ltd.
PO Box 8421 Bachbrecht
Namibia