[Comments-gtld-subsequent-procedures-initial-03jul18] Comment on the gNSO proposal regarding two character top level domains

Elisabeth Ekstrand elisabeth.ekstrand at iis.se
Wed Sep 26 14:46:54 UTC 2018


The Swedish Internet Foundation submit the following comments to Annex C .
Question 1: “If there are no technical obstacles to the use of 2-character strings at the top level consisting of one letter and one digit, should the reservation of these strings be removed? Why or why not?”
Even if there are no technical obstacles to the use of 2-character strings at the top level, there are reasons why the reservation should be kept.
The most important reason for keeping the reservation for gTLDs at the top level consisting of 1 letter/1digit – or the other way around – is the danger of confusion. It is for example easy to read a zero as an o and the number 1 as an l. Such as .RO vs. R0, .SL vs S1 etc.
Opening up for this will also be in conflict with the difference between 2-character ccTLDs and 3-letters and more as gTLDs. The difference between those two groups should be maintained.
Question 2: “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?”
As stated above, we are of the opinion that it should not be opened for these types of strings. However, if the community still decides to remove the reservation and go forward with this idea, there should be conducted a careful analysis to ensure security and stability.
The Swedish Internet Foundation also support the comments submitted by CENTR, https://centr.org/library/library/policy-document/centr-comment-on-the-gnso-proposal-regarding-two-character-top-level-domains.html
Best regards,

Elisabeth Ekstrand
Head of Legal and Administration
The Swedish Internet Foundation (iis.se)
Phone: +46 733 611015

The Internet Foundation in Sweden, IIS, is an independent public-service organization that acts to ensure positive development of the internet. We are based in Sweden and are responsible for the internet’s Swedish top-level domain, .se, and the operation of the .nu top-level domain.


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