[CPWG] [registration-issues-wg] URGENT - WT5 proposal for 3-letter country codes

Wed Aug 15 02:16:12 UTC 2018

These are my thoughts on the issue of ISO 3166-1 3-letter codes:

I too believe that
WT5 is fully competent to deal with the issue of whether, when and how
strings identical to the existing ISO 3166 3-letter codes could be applied
for and delegated, though at the rate WT5 is going, the position may very
well end in a recommendation that it be chartered for deliberation by (yet)
a(nother) GNSO PDP WG.

Notwithstanding,

*3-letter strings on ISO 3166-1 standard*
I don't believe it is desirable for any un-delegated 3-letter strings
currently on the ISO 3166-1 standard to remain unavailable for application
in the next round.  However, I am not convinced that an outright claim can
be made that "there is no "tradition" of
ISO 3166-1 3-letter codes being used for top level domain names connected
with the related countries and territories".   Jorge Cancio suggested that
Switzerland does (in some way) and also some of these codes overlap with
others, eg those used by the IOC in the Olympic Games.

In any case, I take the view that by virtue of ICANN being represented on
the ISO 3166-1 Maintenance Agency, there should be at the very least, some
moral obligation by ICANN to recognise and treat (in the first instance)
all such 3-letter strings which exactly match the ISO 3166-1 3-letter codes
as a representation of the corresponding assigned country.

I have also noted that exceptions need to be considered -- as in the case
of the Union of Comoros, for which ".com" is no longer available -- for
which an alternative 3-letter string should be made available for
application by applicants who either represent the Union of Comoros or
which received letters of support/non-objection from the Union's government
should they wish to apply for a 3-letter string for a purpose associated
with the Union. This exception would also need to be made available for any
country that is put onto an updated ISO 3166-1 standard, where the assigned
3-letter code is no longer available.

As for 3-letter codes which also have generic meanings or said to be
subject to lost opportunities, I think 3-letter code country designations
should be prioritised -- think of them as "superlative" special nouns. So
as an eg .IOT, would be a "superlative" special noun of the British Indian
Ocean Territory, superlative to the special noun of The Internet of Things.
In other words, country names trumps everything else, and accordingly, the
concept of intended use does not apply.

As to who should be allowed to apply, in sharing concerns for terms which
have not been defined by Carlos per se, I too am concerned about who is
meant by "public interest/public benefit entities"; that could be any
entity, as Greg suggests, which claims to act in public interest/public
benefit. In this respect, on using the relatively successful cases of city
name gTLD applications as inspiration, I don't see the harm in opening up
application to anyone/any entity whereupon the "
relevant government or public authority or ccTLD manager" can also apply
and if there is contention, then curative mechanisms already in place kick
in to assist in resolution of such contention.  In the same breath, if an
entity which is not the "relevant government or public authority or ccTLD
manager" applies, then that application should be subject to the
requirement for a letter or support or non-objection from the relevant
government or public authority.  This could in my opinion best facilitate
the application for 3-letter strings which match ISO 3166-1 3-letter codes
under a preventive and curative 'safeguards' framework.

Also there is nothing to say that the relevant government or public
authority and an applicant cannot arrive to some understanding in respect
of the application, including terms and conditions of the gTLD (downstream
even) should the application be successful. The kind of partnership
framework which Maureen reminded us of is an appealing resolution
mechanism. Of course, this would depend on the attitudes of the parties
concerned, but don't other things suffer the same fate?  Also, the
suggestion of time limits for response by a government or public
authority is a good one IMO.

Perhaps, to facilitate (if one must insists upon it) a 'prioritisation' of
applications by a "relevant government or public authority or ccTLD
manager", I wonder if a  Sunrise Period would be a feasible option.
Possibly a difficult consideration, since application windows are typically
tight as it is, not to mention the need for effective pre-launch
marketing.

Lastly, I too don't wish to wade into the discussion of 'expanding the
territory of ccTLDs' -- it is clear in my mind that all 3-letter strings
(whether they match ISO 3166-1 3-letter codes or not) would be treated as
gTLDs and not ccTLDs. The realm of ccTLDs remains in the 2-letter sphere.

*3-letter strings NOT on ISO 3166-1 standard*
I also don't believe it is desirable for any un-delegated 3-letter strings
NOT currently on the ISO 3166-1 standard to remain unavailable for
application in the next round.  They should not be reserved and should be
made available for application, with a pre-defined resolution mechanism to
deal with exceptions arising out of changes to the ISO 3166-1 standard over
time.

Regards,

Justine Chew
-----

On Wed, 15 Aug 2018 at 03:44, Sivasubramanian M <6.Internet at gmail.com>
wrote:

>
>
> On Sun, Aug 12, 2018 at 12:14 AM Maureen Hilyard <
> maureen.hilyard at gmail.com> wrote:
>
>> Hi everyone
>>
>> If you have been following the discussions in WT5 you will see that there
>> has been a lot of controversy over the GNSO consensus process on Country
>> and Territory Names and how best to come to a decision on each of the key
>> issues that are being discussed.
>>
>> With regards to an agreement over 3-letter country codes, Carlos Raul
>> Gutierrez has proposed the following suggestion to help this process move
>> forward, I believe we should consider his proposal as a reasonable
>> compromise considering all the discussion that has taken place and send our
>> support (or otherwise) to our ALAC co-Chair. The ALAC views could be
>> coordinated by the CPWG leads but will be required *by Tuesday??*.
>>
>> *This is urgent, as it appears that consensus calls will be received by
>> the co-Chairs during the week  and as they will have to prepare for the
>> next WT5 meeting on the 22nd, it would be good to include an ALAC opinion
>> as well. *
>>
>> “Dear Annebeth,
>>
>> As you have heard me (too) many times before, I admire the track record
>> of preceding, clearly focused public interest 3 letter geo-TLDs, like the
>> ones from Catalonia in Spain, Brittany's in France, and Serbia's 3 letter
>> TLDs
>>
>> Now that I re-stated my rationale for such a clear-cut public interest
>> case in an email to Rosalia (for geo use ONLY, accessible -i.e. cheap- and
>> non-profit), I hereby submit to the WT my final revised language
>> suggestion, which is ONLY applicable for 3-Letter codes. It would
>> substitute the following final paragraph in the relevant section which
>> deals with 3-Letter codes: “*The SubPro may want to consider
>> recommending whether any future application/revision/delegation process to
>> be established (either generic or restricted to the Geographic categories
>> only), should determine if, when, and how specific interested parties, such
>> as relevant public international, national or sub-national public
>> authorities, may apply for country and territory names*"
>>
>> My suggestion for a FORWARD looking option is:
>>
>> “*ICANN may only consider applications of ISO 3166-1 Alpha 3 Letter
>> Codes submitted by relevant governmental authorities, ccTLD managers and
>> public interest/public benefit entities*.”
>>
>
> +1.   And, as Alpha3 Letter Codes become a new stream of ccTLDs, ICANN
> could impress upon the relevant local government authorities and ccTLD
> managers to agree on a common minimum set of DNS rules, conventions and
> best practices in the operation of this new stream of ccTLDs, as distinct
> from the 2 characters country codes, some operated well, some not so well,
> some in tune with the way the DNS works, some pulled in a different
> direction. Governments are right in considering ccTLDs as their space, but
> in the past some ccTLDs in some countries were transferred to external
> entities within or out of their countries, some ccTLD went out of control
> irrespective of who operated them; It became difficult for ICANN perhaps
> even promote Security and Stability measures such as DNSSEC.  If alpha3
> codes are deemed as a new stream of ccTLDs, it then becomes an opportunity
> for ICANN to delegate them as a more integrated TLD class within the DNS,
> somewhere between the somewhat detached 2 character ccTLD and the fully
> coordinated gTLDs. An example result of such an approach would be an alpha3
> application criteria that might look for technical expertise or a contract
> with an accredited Registry Service Provider with relevant ccTLD
> experience; while there may be more elaborate criteria, the respective
> countries may have country specific policies for operation of the alpha3
> codes except where such national policies are NOT in sharp contrast with
> the general principles of the DNS.
>
> Sivasubramanian M
>
>
>> This paragraph is, in my view, a sensible part of a forward-looking
>> recommendation that could go ahead with broader WT consensus. And if it
>> does not, please make sure it is recorded as an objection against a
>> permanent restriction of the delegation of the ISO 3-Letter list.
>>
>> Thanks to all,
>>
>> Carlos Raúl Gutiérrez"
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>>
>
>
> --
> Sivasubramanian M
> Please send all replies to 6.Internet at gmail.com
>
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